President Harry Truman famously said, “The buck stops here.” As a facility manager, that’s your motto.
When something happens at your site, even if it’s not your fault or something you can’t control, the responsibility ultimately rests with you.Often, these issues – even very serious ones – are hiding in plain sight. It might be a simple matter of “it’s always been done this way” that you don’t realize puts you out of compliance or could potentially cause an environmental impact. Often, it takes an expert outside observer to see something that’s out of place and to understand what needs to be done to fix it.
It may be tempting to put off inspections, investigations, environmental testing, mitigation, and remediation. You’d rather not spend the money now. You figure if there hasn’t been an issue yet, there won’t be one. Or it can wait until next quarter.
But that can be an expensive decision. State or federal regulators don’t mess around and are quick to issue fines and shut you down. And you could have a messy accident about to happen and not even know it.
That’s how we at Envision Environmental Inc. can help. By working with us now, you can pay a lot less than you would if an issue spirals out of control and requires more expensive clean up, remediation, and mitigation.
In a two-part series, I want to help you identify 10 potentially overlooked environmental issues and then give you some solid strategies and solutions for addressing them. We’ll tackle the first five here.
We made our mark in due diligence for buyers and sellers, working on projects totaling more than $12.5 billion in property transactions. And we’ve never had an issue come up post closing on any of those deals we worked on.
These are just some of the issues we’ve seen in our 20+ years in the industry.
1. Property History
You know those guys who’ve been at your facility for years… decades? They’re some of your best resources. They know where the old tanks are buried… what that old piece of equipment in the corner was for.
Take advantage of that institutional knowledge now by putting everything they know down on paper. Otherwise, when they retire you’ve lost it. Then, once you have solid foundation of knowledge of your facility, update it regularly.
Having this intact historical knowledge helps you:
- Identify potential problem areas now and in the future
- Plan in the short and long terms
- Figure out preventative measures you need to take – and which ones should be handled first
In one case we worked on, a client was ready to expand their facility and had hired contractors to start work. But when they dug the foundation, they hit some old tanks nobody knew were there. A year and a half – and thousands of dollars – later, the clean up was done and construction began again.
2. Inappropriate, Insufficient or Deteriorated Protective Measures
There it was, a hundred gallons of latex flowing into a stream in a small country town, turning the entire thing white. A nightmare for this manufacturing company that harmed their reputation in the community (I know latex is pretty harmless – but try telling everyday people that), brought intense scrutiny from local officials and state regulators, and required expensive remediation efforts over six months. All told the bill was into the six figures.
You see, a simple accident had reversed the flow of a pump, overflowing a rail car with that latex, which then flowed into the stream causing all the problems. It could have been prevented if this facility had installed the impervious containment system I had recommended.
Nobody at the facility had seen this accident waiting to happen, although it was immediately obvious to me and my team during our site inspection.
Do you have all the safety measures you need at your facility? Are you sure?
Another thing to consider is that containment systems and other preventative measures don’t last forever. It’s not one and done. You need to perform maintenance, run tests, inspect, and, if necessary, repair or replace.
As with most elements of safety, to make this process effective, you have to be proactive with your inspection and follow up programs.
3. Necessary Regulations for Your Facility – You Don’t Know About
Say you’re not a manufacturer. You don’t have drums of chemical solvents sitting around or anything like that. But many businesses, even though they don’t realize it, actually need certain permits to operate necessary functions, such as air permits or waste water discharge permits.
Warehouses, storage facilities, even restaurants, shopping plazas, and office buildings or office parks could be affected.
To give you one example, think of restaurants and all the oil they use for cooking. It can’t just be poured down the drain. Waste oil is clogging up sewer and water systems in cities around the world, necessitating expensive clean up of “fat bergs” that block the pipes. And now municipalities are making the offending restaurants pay.
Think you’re not affected? If you run an office building with a cafeteria… you have waste oil to worry about.
If you manage some other sort of facility, what permits have you overlooked?
Ignorance is no excuse – and not something any regulatory body will accept. Make sure your facility has all the proper permits by contacting an environmental consultant. They’ll also be able to help you remediate any issues that could prevent you from qualifying for the permits you need.
4. Remaining in Compliance Is Not Enough – It’s Not Elimination of Liability
You follow the rules and regulations. You follow the law. You have the permits and certifications. But doing the “bare minimum” is not the same as mitigating risk as much as possible.
So be in compliance – and keep accurate and detailed records – but taking the extra steps to implement preventative measures is important, too. That should be part of your comprehensive strategic plan to stop potentially devastating future problems or stop small issues from turning into big ones.
You do this by having a qualified outside inspector from a qualified environmental firm “look for trouble,” so to speak. They won’t always find issues – maybe you’re clean. But you should be glad when they do find an issue, because that usually means stopping a small problem from turning into a major one.
By the way, that’s a philosophy I encourage you to embrace when dealing with any sort of environmental issues. A firm like mine – we’re not the enemy. Better that we find and help you deal with problems before regulators get involved, a real estate transaction is halted, or a once minor issue turns into something requiring major clean up.
5. A Thorough Understanding of Current Risks
Just because something hasn’t gone wrong, doesn’t mean it can’t… and it could be very soon. A key part of facility management is to be always looking for potential risks to the environment. Even if you believe you have state of the art safety measures in place, outside inspection can often reveal issues that could impact profitability, safety, and the environment.
Take one chemical mix room we visited. It was totally self-contained… or at least they thought it was.
If there were a spill, a series of sumps and trenches would take care of it was how the system worked. But there was a weak link: a manhole in the middle of the room that allowed access to the storm water system. So, a spill in that room could easily discharge contaminants into a nearby stream. It was a straight line! Seems obvious… but nobody in the facility saw it.
Where to Go From Here
Not all of these issues will apply to you. But hopefully the points I brought up start you thinking… and looking around your facility with a more critical eye. What are the “hidden” issues that could be ticking time bombs? In my experience, most facilities have something.
In Part 2 of this series, we will cover five more overlooked environmental risks that could be at your facility right now. But in the meantime, you should check out our book, Overlooked: Hunting the Invisible Environmental Gorilla, for more details.