The I.C.E. Protocol: An Easy Approach for Reducing Your Environmental Exposures and Liabilities

Posted by Mark Roman on April 3, 2019

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The I.C.E. (Identify, Control and Eliminate) Protocol is an easy to follow approach for reducing your environmental exposures. With so much going on at your facility at any one time, these simple steps go a long way toward eliminating existing and potential liabilities.

This keeps your employees safe, helps stop costly cleanups from spills and other incidents, and ensures you’re in the good graces of regulators.

The first step is to…

Identify your environmental, health and safety issues.

To do this you must develop a strong knowledge base about your facility. You must understand everything your facility does and how you do it. Your team (long-service employees and managers, especially) is a great resource here, as are existing permits, your current documentation of processes, and your colleagues at a sister facility.

You should also consider getting a second pair of eyes on your facility, such as an environmental consultant. As an “outsider” they can often spot things you miss because of familiarity blindness. In a nutshell, you’re so used to seeing your facility as is, you can’t identify what are seemingly obvious liabilities – which is probably why they haven’t been dealt with before.

Through close observation, you can Identify where issues are likely to occur, which gives you a list for further inspection and management.

For example, if you have a chemical storage area, that’s more than likely the place where a spill could occur. So, take a closer look for pathways to the environment in areas where you store chemicals and other liquids.

When Identifying potential EH&S issues, don’t forget to look to the past. Examine historic records for information on past processes used, as well as where underground storage tanks or other equipment used to be (and perhaps still are without your knowledge).

By Identifying issues early, you can take care of them before they turn into time-consuming and expensive liabilities.

But keep in mind that the most easily resolved issues are quite often the ones that lead to the costliest remedial measures if not Identified and taken care of.

Now it’s time to…

Control your environmental, health and safety issues.

After you’ve done your assessment of potential exposures, it’s time to take action. If you have a chemical storage area, this could mean adding additional containment as needed to prevent spills from impacting the environment. If you have a crack in the floor or a containment wall, that’s an easy fix. In some cases, you might have to do a complete redesign of the containment system.

This should help prevent future issues, or at least manage them better.

Whether you fix the issue or conduct a total redesign, you must document what you did in each step as your memory isn’t as good as you think it is.

Finally, you must…

Eliminate your issues completely.

It’s the same in any workplace. There’s a way things have always been done. There is a lot of inertia there. And even when you Identify and Control an environmental, health and safety issue, the tendency is to “creep” back to the old way of doing things.

To stop it, you must engage everyone in your organization with effective communication. Make sure everyone is aware of the issues you’ve identified… and understands that they can’t do it the old way any more.

You must also create a proactive culture that…

  • Rewards people for Identifying other issues and bringing them to you. Nobody should think of themselves as a whistleblower.
  • Encourages your team to engage in preventative maintenance of the issues you’ve Identified and are trying to Control.

Do this, and eventually your EH&S issues should be Eliminated altogether.

Case Studies

In one facility we worked in, they had installed a containment system in the mix room where they make pigments and inks for coating materials. So, if anything spilled, the system would capture it and a sensor would sound the alarm to advise the team in the area. They were very proud of this.

When we visited the mix room, the first thing that caught our eye was the manhole cover in the room. The facility folks had never really noticed it and certainly didn’t know where it led – familiarity blindness. We Identified it as a potential pathway to the environment.

We opened the manhole cover and found that it was part of the on-site stormwater system. We Controlled the issue by sealing the manhole cover. Now, as part of regular preventative maintenance they inspect the manhole and periodically reseal it if needed. That Eliminated the issue.

In another situation we came across, we were visiting a client’s facility and inspecting the chemical storage room. We found that material had stained the floor in the past. Once we Identified that issue, we asked, “Where does spilled material go?” Well, we found a pathway to the environment in the chemical storage room.

Turns out the released material flowed under an exterior door, then into a storm drain that discharged to an on-site stream. And that required a costly cleanup to address the impact to the stream.

Our next step was Control. We implemented safe storage practices in the room. Nothing should be stored near the exterior door. Material should be stored on containment pallets to contain spills. And, using $100 worth of materials from Home Depot, we built a berm across the threshold for the exterior door to eliminate the pathway to the storm drain (and painted it yellow so nobody trips).

To further Eliminate the problem, the facility manager has a program in place to check for leaky containers and ensure the berm is sound.

One of the more serious exposures we found was in a tanker offloading area at another facility.

During a delivery event, the tanker truck backs up into a driveway to the offloading area. The offloading area contains a small outbuilding that holds the hoses that connect the tanker truck to the main building, which has aboveground storage tanks inside. Adjacent to the offloading area is an overhead door that leads into the main portion of the building. This overhead door is accessed via a sloped driveway. The sloped driveway leads away from the overhead door to a manhole, which connects to a stormwater system that discharges to a nearby natural pond.

A recipe for disaster.

In one incident, the tanker driver hooked up and started offloading… then went to have a smoke elsewhere. The facility employee had left after signing in the shipment. The tanker truck continued to pump material into the aboveground tanks located inside the building while no one was present to supervise the offloading event. During the material transfer, the overflow valve to the tank inside the building was stuck in the open position. As a result, the tank was overfilling and spilling onto the floor.

The released material found the path of least resistance and flowed out of the tank room, through the overhead door, onto the sloped driveway, into the manhole and finally ended up in the pond. Even when the tanker employee came back 20 minutes later, he didn’t notice anything for quite awhile because the truck was blocking his view of the release area.

All told, it was a six-figure cleanup to address the resultant impact to the pond and its wildlife.

The whole situation could have been prevented if there had been a strict material offloading policy that required continuous oversight. In addition, a containment berm installed across the overhead door threshold would have eliminated the pathway to the environment for the released material from impacting the pond.

Five hundred dollars worth of material to create the berm could have prevented a six-figure spill.

Next Steps

In many facilities we visit, familiarity blindness stops facility managers and other personnel from Identifying serious environmental, health and safety issues. They see the place every day and fail to see the problems that an outsider can spot right away.

We call these Invisible Environmental Gorillas. And to help you in Step 1 of the I.C.E. Protocol, I’ve put together a list to help you Identify any liabilities you’ve potentially overlooked.

It’s a free download here: The Top 10 Environmental Gorillas Checklist. 

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