Knowledge is often divided into “need to know” and “nice to know” categories. “Need to know” knowledge can be looked upon as the critical must have information, while “nice to know” knowledge is often the information that is quite useful, but not necessarily vital or critical.

When it comes to environmental, health and safety issues, make sure you obtain and understand what you “need to know” first and foremost, and then complement that knowledge with the “nice to know” information.

You should take this approach to all of your environmental, health and safety issues at your facility – regardless of complexity. For one client we worked with in the Mid-West, the location and discharge point of several floor drains throughout their facility definitely became “need to know”.

Vapor intrusion is a “hot topic” across the country these days when it comes to environmental, health and safety. There are definitely times when indoor air quality is severely affected by this issue.

But, we’ve also found instances where it’s all too easy to just declare there is vapor intrusion causing an indoor air issue and then initiate costly mitigation… when there may be another cause if you dig deeper.

A while back, I highlighted just such a case involving a warehouse that contained plastic hotel supplies. Now, I’d like to share another similar situation where a company was being pressured into taking drastic action over a vapor intrusion issue that turned out to be non-existent.

It’s a great example of where you can’t take test results at face value, and it’s important to do a little more investigation before embarking on an expensive remediation effort.

I was recently undergoing some continuing education training at Rutgers University, when a comment the instructor made in passing caught my attention.

He’s an old pro, a veteran of a public utility. He said that contamination and releases are “lazy.” The rest of the group kind of looked at him strangely. But I caught on right away.

You might think this is good news… that lazy releases mean you don’t have anything to worry about. However, it’s the opposite.

Here’s what he meant:

When a contaminant is released by accident, it looks for the path of least resistance. It does the least amount of “work” possible to do the greatest amount of damage to your facility. Say there’s a chemical spill – that liquid is headed straight to the nearest floor drain… and you better know where that drain discharges.

This is an issue that should keep you up night, because you probably have some lazy contamination just waiting to happen; especially if there are hazardous materials stored, handled, offloaded and/or loaded in your facility that have the potential to be spilled.

Of course, no facility is really immune; almost all have the potential for lazy contamination, as you’ll see in a moment.

The good news is these issues are generally easy to solve. To reduce, or eliminate, the potential for lazy contamination, all you have to do is identify and eliminate the paths of least resistance. And, if you take action now and put preventive measures in place, you’ll be able to avoid a potentially expensive cleanup situation.

When you have a strong environmental, health and safety program at your facility, wonderful things happen.

• You add value to your organization by increasing efficiency and productivity.
• Your customers appreciate the improvement in product quality.
• You reduce costs on healthcare and downtime thanks to reduced workplace accidents.
• You boost your company’s image and employee morale.

Of course, this all reflects well on you as the facility or plant manager.

So why do so many facilities lack strong EH&S programs, even at facilities that have the required regulatory knowledge and resources, and understand the importance of having such a program in place?

Two contributing factors are lack of buy-in from management and lack of participation from employees. These two groups just don’t get it—and for very different reasons, as we cover in this article in detail.

When you’re trying to implement an effective environmental, health and safety program at your facility, there are two major audiences you must reach:

1. Management

2. Employees

As the facility or plant manager, you’re caught right in the middle—and as you try to put your EH&S plan into action, you have to consider that you need to communicate in very different ways to these two populations for them to understand and act on your program.

Among all the regulations that facility managers must follow, those dealing with hazardous waste are some of the most important… and the easiest to fall afoul of.

The main hazardous waste regulation that is often overlooked is the Resource Conservation and Recovery Act (RCRA), a.k.a. the “cradle-to-grave” law. In simple terms, hazardous waste must be accounted for throughout its entire life cycle (generation, accumulation, transportation, treatment, disposal and post-disposal).