“Those who don’t know history are destined to repeat it.”
Truer words have never been spoken when it comes to environmental, health and safety at your facility.
In this case, we’re talking about property history. Knowledge of what happened at your facility in the past, is your most significant, yet most underused resource.Your facility’s past will affect its future. It impacts your planning, environmental programs, contamination remediation, assessments, and more.
Knowing your history helps you avoid repeating past mistakes. The most costly mistake is the one you repeat. Not only is there the expense of fixing the problem, but also the damage to your reputation.
In one case, we were called in after a building expansion project had stalled at a property, and for good reason. The facility was more than 100 years old. It had seen a lot over the years, but not much was known about that lengthy history.
It turned out that back in the 1960s and 1970s, underground storage tanks had been used to store solvents that were used in the former manufacturing processes at the site. Unfortunately, no one currently at the facility was aware of the tanks. They happened to be discovered after an architect had been hired to design the expansion and contractors were on site digging the foundation with the excavator.
Work immediately stopped so that the tanks could be removed. Unfortunately, during the removal, contamination was identified and the building expansion project was delayed for 1 ½ years to allow for the necessary cleanup. The tanks had leaked over the years, contaminating soil and groundwater.
Even a simple drawing of the site from back in the day that showed the possibility of tanks being present would have indicated to the facility that some additional research and investigation had to be conducted relative to the possibility of the presence of the tanks – probably bring out a ground penetrating radar to confirm the presence/absence of the tanks – before initiating the building expansion project..
The point is that as a facility/plant manager, accurate and up to date information is your friend, and property history is a key part of that facility knowledge.
Property history is something you can gain and build up through continual research and documentation. Don’t think that whatever happened before you were hired is not your responsibility. It may not be your fault, but unfortunately it may be your mess to address.
Property History is a Planning Tool
It can be scary to dig up the past, but ignorance is not bliss.
When you know about potential environmental issues that are likely to cause problems, like no longer used equipment, you can account for them in your planning and budgeting.
You can prioritize what to address first or alter your plan or schedule as needed. This prevents a small problem from turning into a bigger one.
A Great Assessment Tool
When we encounter contamination or another environmental issue at a site, we always look to the property history to help figure out the cause.
If you know property history – what happened at your facility in the past – you can help an environmental consultant determine the source of any impact, and save yourself a considerable amount of time and money.
What did you do in the past? Could that be the source of problems affecting you now? If you have that knowledge in your back pocket, you’ll be well prepared if you ever get an environmental consultant or regulator on site.
Preventative Maintenance and Improvements
With a thorough grounding in property history, you’ll know when equipment was installed and infrastructure constructed. You’ll be able to follow the recommended maintenance schedule and, most importantly, know the expected lifespan.
Armed with that information, you can budget and plan for major maintenance or even replace equipment. You’ll also be able to schedule this during down time or make other arrangements so your work is interrupted as little as possible.
Many facilities don’t bother to collect and maintain this information and instead, wait until the equipment fails and then scramble to fix it and pay for those repairs.
Collecting and Recording Property History
So where do you start to collect property history? If you are lucky enough to have a Phase I Environmental Site Assessment of your property, you’re golden, because a key component of a Phase I is property history. At this point, you need to keep it updated, documenting new items that are found or identified or any changes at your facility.
If you don’t have a Phase I of your property, you’ve got some work to do. You’ll be looking through the records in your office and backroom storage areas as well as using some online tools to conduct a thorough overview.
Start a collection of historic aerial photos of your site. You might have some in old files or they could be hanging up somewhere in the office. You can access them on Google Earth as well. Old plans and drawings of your site can also be a vital resource. Never throw out your old drawings! These records are like snapshots in time – they tell you where things used to be located and can even tell you how things used to be done.
You should have seen the look on one facility manager’s face when we told him that 20 years ago, his facility used to have storage tanks in one spot, drums in another, and a truck fueling depot in yet another location.
How did we see into the past? There were aerial photos in the facility’s lobby showing these areas!
Environmental, Health and Safety Reports
Always keep complete copies of all of your environmental, health and safety reports, not just the summaries from the reports. Yes, these reports can be quite lengthy, especially if laboratory data reports are included. But it is important that the entire report is maintained as a complete document. For example, if you had some assessment and remediation work conducted at your facility, make sure your report copy includes all text, figures, tables and all attachments/appendices. This will make your life easier should any questions relative to this work ever get raised in the future, especially by a regulator. In addition, these reports contain a tremendous amount of valuable information specific to your site. In fact, there may be information in these reports that could help you address a totally different, non-related issue at your facility – you never know!
Check with Regulators
The databases of state regulators or the USEPA, which are accessible online, can also help you understand your property history.
Once you access the regulators’ sites, simply type in your facility name and/or address and you can download all of the information an agency has about you. You might see evidence of previously unknown features at your site. Most importantly, you’ll also see if there has been a history of compliance issues.
When a storage tank is removed or closed, that should be noted in the database, with the size and former contents listed. If you see no notice of a closure in the regulator database, you should double-check your site to confirm that the tank was removed and all of the required paperwork was filed with the regulators to properly close-out the tank.
When I’m visiting a facility to conduct due diligence, we often obtain the most valuable information relative to property history from maintenance personnel and long-time employees. These folks know where the forgotten storage tanks are buried or what that piece of old equipment in the corner was for, and if it was ever properly decommissioned. They know how your facility “ticks” and what lurks in those dark corners!
Assure these employees you’re not looking for someone to blame. Explain that you’re on a mission to make the facility safer, more environmentally friendly, and more profitable. That’s job security for everyone, which is a great motivator.
Where to Keep Your Records
I recommend maintaining a central repository. It could be a filing cabinet in your office with these records or you can also digitize them to make it easier to share with environmental consultants and others. No matter which method you use, make sure to preserve the whole document and ensure that it’s legible.
Your record of property history should also be constantly updated. If something new or unexpected pops up, refer back to your records and if it’s not there, document it. At a minimum, you should revisit your files annually or semi-annually.
It doesn't take a lot of effort to do this. You probably already have the tools you need. Your attitude is the key to success here.
Be thorough in your research and be respectful to ensure you get employee buy-in.
To help you make sure you’ve looked in all the nooks and crannies for clues to your property history, we’ve put together a checklist that you can download now for free.
It’s a great way to kick off your property history search and it helps you keep everything you find well organized.
Download the Property History Checklist here.