New Stewardship Action Council Reply

There is a new association in the sustainability space. It is called the Stewardship Action Council (SAC). It is competing with the Corporate Responsibility Officers Association (CROA) and the GreenBiz Executive Network. SAC has an interesting mix of companies, state organizations, non-governmental organizations and universities. Participating members must set improvement goals and report progress against the goals. This looks similar to the now defunct Performance Track Program (US Environmental Protection Agency).

It is interesting to note that Level 3 members must have an environmental management system in place and it must be verified by a third party. These members must have independent audits conducted every three years and self assessments in interim years. These companies must also have no criminal violations in the past three years and no more than three notices of violation in any three-year period.

SAC has a “concept paper” that outlines the following goals:

• Create a sustainability standard that lays out the elements of and a path for achieving sustainable business practices

• Provide a mechanism to share company efforts to improve performance

• Create opportunity for collaborative efforts to address social and environmental issues that an organization cannot adequately address alone

• Provide a forum where different stakeholders can work together to accomplish common goals

There seems to be a decided focus on the environmental responsibility that is one of three responsibilities in a sustainability program. We’ll have to wait to see a glimpse of the sustainability standard that the members of this fledgling group are working on. With the recent release of ISO 26000 social responsibility standard, and the final voting on the ULE 880 (Sustainable Manufacturing Standard), we can look for some more choices in this very active area.

RELATED LINKS:

Stewardship Action Council:

http://www.stewardshipaction.org

Corporate Responsibility Officers Association:

http://www.croassociation.org

GreenBiz Executive Network: http://www.greenbiz.com/intelligence/

ExecutiveNetwork ISO 26000: http://www.iso.org/iso/iso_catalogue/management_standards/social_responsibility.htm

ULE 880:  http://www.ulenvironment.com/ulenvironment/eng/pages/offerings/services/organizational/ule880/

New ISO Handbook/CD Package Unveils ISO 14001 for Small- and Medium-sized Enterprises 2

As more companies begin to track environmental issues through the supply chain, there is a growing need to address environmental management at small- and medium-sized enterprises (SMEs).  The automotive industry required its supply chain to certify to ISO 14001, however, other industries are not quick to follow suit even though ISO 14001 certification now stands at nearly 250,000 companies in 2009 – an increase of 18% over the previous year. 

ISO has issued a handbook and CD designed in the form of a checklist to guide the SME in asking and answering a series of questions regarding the environmental activities of their organization.  The checklist is in 16 parts.  Each part covers a particular ISO 14001 requirement and begins with an explanation of the requirement as well as guidance on how to incorporate this guidance into an EMS that meets the needs of the organization and, perhaps, its customer.  The CD provides the convenience of electronic navigation through the requirements and enables responses to each question to be saved and then printed in pdf format.  This could provide evidence to the customer that there has been progress in implementing an EMS.

It is well known that companies have improved their operations and reduced the impact of their activities, processes, products, and services on the environment by using a systematic approach that seeks continual improvement. The benefits of addressing environmental issues, however,  not only cover protection of the environment, but are also linked to business performance and profitability while improving the company’s image, enhancing access to export markets, providing a common reference for communicating environmental issues with customers, regulators, the public and a host of other stakeholders.  So, what’s not to like!

SMEs are afraid of the cost associated with implementing an ISO 14001 program.  Even while there is an eventual payback associated with the efforts, there will be a considerable amount of up-front money.  They know that they will have to purchase the standard and make a lot of changes in how they operate.  Believing that one has to be certified in order to get credit for using ISO 14001 keeps many companies from considering this important standard.  They only need to certify if a customer requires certification.  Using a checklist could be of value even if the ultimate aim is not third-party certification of the standard.  To order this checklist, you can go to the ISO website:  http://www.iso.org/iso/publications_and_e-products/checklists.htm#PUB100268 

 Some companies are taking a more direct approach with the SMEs in their supply chain.  A consulting firm is hired to perform a gap assessment at each facility in the first tier.  The suppliers will realize that they are already doing many of the things that are required for an ISO 14001-conforming EMS.  It might be easier for them to use the recommendations for improvement to assemble a sound EMS.  In time, the SME will have a viable EMS in place.  At that time, they can decide to use ISO 14001 to check their own system for conformance.  The customer can have a “second party audit” performed to help the SME further improve its program.  All of this can be accomplished without ever seeking third party certification. 

There are a number of internet resources available to SMEs when their customer does not get directly involved as described above.  No matter what the motivation, SMEs can gain some significant recognition from their customers by paying attention to their EMS.

New Regulatory Vapor Intrusion Guidance Reply

ThroughoutMassachusetts, releases of materials containing volatile organic compounds (e.g., petroleum products, dry cleaning fluids, industrial solvents) have impacted soil and/or groundwater.  When these releases occur near buildings, volatilization of contaminants in the subsurface can result in the intrusion of vapor-phase contaminants into indoor air spaces and can pose a risk to workers and other building occupants.

In June 2010, the American Society for Testing and Materials (ASTM) updated its Standard Practice for Assessment of Vapor Intrusion into Structures on Property Involved in Real Estate Transactions (E2600-10).  This guide defines a procedure to identify, during a Phase I property assessment, whether a vapor intrusion condition exists, likely exists, cannot be ruled out, or can be ruled out because a vapor intrusion condition does not or is not likely to exist.

In response to the regulated community’s questions and concerns, in December 2010, the Massachusetts Department of Environmental Protection (MassDEP) issued an Interim Draft Vapor Intrusion Guidance document to provide regulatory guidance on assessing and mitigating vapor intrusion pathways at sites regulated by the Massachusetts Contingency Plan (MCP). This document addresses approaches to the assessment and remediation of vapor intrusion in order to maintain compliance and eventual site closure within the MCP.

Both the ASTM guide and the MassDEP guidance documents can be applied to property with existing structures, property with structures that will be substantially rehabilitated, property without existing structures but having planned structures (e.g.,, property in development), or property without existing structures and with no planned structures (e.g.,, undeveloped property with no planned development).

Following receipt of public comments, due by March 1, 2011, the MassDEP will finalize the Vapor Intrusion Guidance document.  If you have a concern about the potential for your existing or planned property to have a vapor intrusion impact, call Dawn Horter at 508.970.0033 ext. 118.

Guidance on Spill Prevention Control and Countermeasure (SPCC) Plans Reply

There’s a hole in my bucket, dear Liza, dear Liza,
There’s a hole in my bucket, dear Liza, a hole.
Then fix it, dear Henry, dear Henry, dear Henry…

Well you can look up the rest of the poem, but what if that bucket is a tank and it’s leaking oil…now what do you do?  Hopefully, this won’t happen to you, as it did in Dorchester, Massachusetts recently, but you may be asking yourself a few questions right now:

  • Is there something I should be doing to prevent a leak?
  • Is there a plan I should have in the event of a leak?
  • What should I do if my tank is actually leaking?

CAPACCIO can help you answer these questions.  Our staff of engineers has prepared numerous Spill Prevention Control and Countermeasure (SPCC) Plans which are required for sites with over 1,320 gallons of aboveground oil storage. For smaller facilities, we can conduct inspections of oil storage tanks to determine their risk of failure.  In the unfortunate event of a spill, our on-call Licensed Site Professional (LSP) is available 24/7 to answer your questions and assist with reporting and clean-up requirements.   

If you would like more information on SPCC Plans and whether your facility is required to have one, click here. For general information regarding SPCC Plans and tank inspections call Josh Fawson at 508.970.0033 ext. 120.  For LSP services, call Dawn Horter at 508.970.0033 ext. 118.