Management Systems Internal Audits – Going Beyond the Annual Physical Reply

EH&S Management systems standards are developed to proactively address and continually improve how to protect the environment and how to establish and maintain a safe and healthy workplace. The environmental management system, ISO 14001, and occupational health and safety management system, OHSAS 18001 – soon to be converted to the new ISO 45001, help to manage risks and take advantage of opportunities. Just as an annual EH&S audit can be related to an annual physical, internal systems audits can be related to the ongoing monitoring of your overall health. Working with a general practitioner to consistently improve a functional area of one’s health mandates a certain amount of effort. However, if this area is of highest risk to us, we will devote that time.

Commitment to internal auditing has huge potential for risk reduction and continual improvement, just as commitment to ongoing monitoring of your health. Part of this commitment is ensuring that your EH&S management system is functioning as intended to promote environmental protection and a safe and healthy workplace. Having an effective management system achieves this.

Management systems are most successful when all those affected in some capacity by the system embrace the procedures and best practices shared with them from the system – making the role of an internal auditor for management systems essential. They can act as another set of eyes to review operations and to act as the catalyst to best practices and improvement.

The internal auditor has the platform to point out an internal audit finding, such as emergency procedures not being executed as stated in documentation. They also have the responsibility to identify areas where there are opportunities for improvement, such as posting significant aspects in areas affected by those aspects to increase awareness.

In order to show continued improvement for an organization’s management system or an individual’s health, concrete evidence of steps taken to do so are very important. In a management system, objective evidence that procedures are being followed and are effective is a must-have. Internal audit findings are meant to take an organization’s EMS to the next level of best practices and demonstrate improvement of the system.

Having a management system, or working with a healthcare provider, won’t be of value if we simply carry on with business as usual. We cannot expect there to be improvements each time we have an annual appointment or audit without acting to correct or address issues identified. The value comes from embracing the guidance from the internal auditor or healthcare provider to see the most concrete improvements.

Embracing this guidance means continually improving the management system itself, and for this scenario, improving the preparation, execution, and documentation of internal audits. Managing audit documentation, corrective actions, and audit schedules in discrete, siloed, files leaves room for error and inconsistencies. Tools are now available to transform the way in which this is accomplished. A tool like the EHS-DashboardTM has the capability to schedule audits, log findings, communicate internally to address corrective actions, and store documentation, while simultaneously linking each piece together.

If you have questions about internal audits for management systems or how to implement tools to enhance your existing systems, please don’t hesitate to reach out to our experts. Linda Swift can be reached at lswift@capaccio.com or 978-621-6433 and Cristina Mendoza can be reached at cmendoza@capaccio.com or 774-249-2418.

August 7, 2017 – UST Deadline Reply

The August 7, 2017 deadline for closure of single-walled steel underground storage tanks (USTs) is rapidly approaching per the Massachusetts Department of Environmental Protection (MassDEP) UST Systems regulation 310 CMR 80.15. This regulation applies to all in-service and temporarily out-of-service USTs, with the exception of consumptive use tanks and tanks that were relined prior to August 8, 2007 in accordance with API 1631, 1983 Edition providing that the owner has a permit and approval from the Fire Department and a current, legally valid warranty for the relining.

At this juncture, if you are the owner of an UST that is not exempt from this regulation, the UST should have been or should be scheduled to be properly closed in accordance with MassDEP requirements. If not, you still have time to avoid MassDEP enforcement activity.  The MassDEP is granting extensions of the August 2017 deadline until July 1, 2018 to those who:

  • Take the UST out of service by August 7, 2017
  • File a Single-Walled Steel Tank Out-of-Service Notification to MassDEP within 30 days of the out-of-service date
  • Submit to MassDEP no later than August 7, 2017 a fully executed and signed contract for removing or closing the UST(s) on or before July 1, 2018

Remember that as part of the UST closure regulations, an assessment for contamination is required to be conducted upon in-place closure or, for removed USTs, within 24 hours after the UST is removed and prior to excavation backfill. The results of this assessment need to be reported in an UST Closure Report. Although the assessment is not required to be completed by a Licensed Site Professional (LSP), the UST removal contractor must be knowledgeable in the MassDEP release reporting criteria under the Massachusetts Contingency Plan (MCP). In all cases, if a reportable release condition is identified, an LSP must be involved in conducting remedial actions.

CAPACCIO’s EHS-Dashboard™ software solution can help you track regulatory deadlines associated with UST compliance as well as record monthly inspection data so that you can be ready to demonstrate compliance in real time. Please visit http://www.ehsdashboard.com to schedule a demo of our dashboard or contact Chris or Dawn whose contact information is listed below.

CAPACCIO is available to assist you in determining whether this regulation applies to you, assist you in meeting the August 7, 2017 deadline, and/or providing LSP services and assistance in the UST closure assessment process. Please contact Chris Walton, PE, PCEE at 508-970-0033 ext. 139 or cwalton@capaccio.com or Dawn Horter, PG, LSP at 508-970-0033 ext. 118 or dhorter@capaccio.com for additional information.

 

EPA Haz Waste Generator Rule Updates Reply

The Environmental Protection Agency’s (EPA) Resource Conservation and Recovery Act’s (RCRA) hazardous waste generator regulatory program was originally promulgated in 1980. Since that time, the EPA has become aware of the need for more clarity, consistency, and flexibility within the program. EPA’s final rule, which was promulgated on May 30, 2017, revises the hazardous waste generator regulations making them easier to understand, and providing greater flexibility in how hazardous waste is managed.

Some key provisions where EPA is finalizing flexibility are:

  1. Allowing a hazardous waste generator to avoid increased burden of a higher generator status when generating episodic waste provided the episodic waste is properly managed, and
  2. Allowing a very small quantity generator (VSQG) (previously called conditionally exempt small quantity generators) to send its hazardous waste to a large quantity generator under control of the same person.

This program update is also implementing some Improvements to environmental protection and, therefore, several of the revisions to the hazardous waste generator regulations are more stringent than those in the previous version. One such revision requires Small Quantity Generators (SQGs) to periodically re-notify the EPA regarding their generator status every four years (SQGs needed to only notify once under the previous system).

You may Click Here for additional information on the RCRA Program Updates.  Please note that though the Federal regulations are currently in effect, the Massachusetts Department of Environmental Protection (MassDEP) has indicated they will not be adopting these updates until 2018.

We can help! Capaccio has RCRA experts that can assist you with the reporting and planning challenges associated with Federal and state hazardous waste programs.  If you have any questions about these programs and updates, please contact Alexis Dallaportas at 508-970-0033 ext. 142 or adallaportas@capaccio.com.

 

 

Why your wastewater treatment system may need a check-up Reply

Industrial wastewater treatment systems serve a key purpose by treating pollutants not capable of being handled by the local municipal treatment system. This helps to reduce pollution and cost to taxpayers to operate and maintain municipal collection and treatment systems.

Why would your wastewater treatment system need an Annual Checkup?

When you receive an annual physical, the doctor checks you for basic vitals…heart rate, blood pressure, body temperature, height and weight. A typical wastewater treatment system audit will perform the same function, ensuring that:

  • Permits are current
  • Facility is complying with the key portion of the permit
    • Sampling has been performed
    • Reports have been submitted
  • Regulations are met
    • 257 CMR 2 – Wastewater Grading/Staffing/Operator Certifications
    • 314 CMR 7 – Sewer System Extension and Connection (Permits)
    • 314 CMR 12 – Operation and Maintenance of the IWPS
    • 360 CMR 10 – MWRA Specific Requirements (if applicable)
    • Local regulations
  • System functioning as expected
    • Have alarms been triggered? If so, how frequently?
    • Have there been any discharge violations? Were they reported?

Provided there are not any obvious issues, the doctor (or the auditor) will generally give you the okay and send you on your way. But what happens when the issues are not so clear?  What happens when you complain of some neck and back pain?  Well, you get sent to a specialist where they perform more testing and review more specific symptoms.  The same can be true for a focused review of your industrial wastewater treatment system and programs…take it a step or two beyond the typical audit.

A more effective audit/review should include evaluating the treatment system periodically.

Many treatment systems are designed, installed, and rarely revisited during the lifespan of a facility. This can lead to a variety of lingering problems.  You can treat the symptoms (adjusting the existing treatment system) or you can rid yourself of the disease by addressing the problem causing those symptoms (updating the system itself).  Some problematic areas to review include:

  • Process changes affecting the system’s treatment ability
  • Out-dated controls
  • Alarm notifications when operator is not nearby
  • Lack of secondary containment around chemical addition equipment
  • Limited automation of the system– increasing operator difficulty
  • Manual log maintenance by the operator

Performing an engineering evaluation of your treatment system and identifying/prioritizing areas for improvement can help increase the ease of operation of the system, increase safety to the operators, proactively provide flexibility for future process/manufacturing expansions and improve compliance of the system. Consider the cost in lost production, if the wastewater treatment function was no longer operating.

Just like you need to take care of yourself with an annual check-up, your wastewater treatment system also needs TLC to keep it functioning properly.

As part of our 25th Anniversary, CAPACCIO is offering a free one-hour industrial wastewater treatment system review to ensure it is still performing as it should. These evaluations also provide TCHs for your operators.

To schedule your free evaluation, please contact Matt Melvin, PE, at mmelvin@capaccio.com or 508-970-0033 ext. 143.

Additionally, 2017 is also a TCH renewal year for wastewater treatment operators. Please visit our website at http://www.capaccio.com/services/training/wwt_index.html or contact Matt if you would like to enroll in any of our courses or obtain your TCHs through the free evaluation.