Monthly Archives: May 2016

Keeping Your Environmental Program on Track

Environmental regulations often require permit(s) that in turn require record-keeping and often reporting to the issuing agencies. These obligations are part of doing business. In contrast, businesses that fail to obtain to meet permit conditions have an unfair business advantage. The same goes for skirting permit and/or environmental regulatory requirements. In our book, non-compliance is never worth the risk but countless time businesses make the news and not in a favorable way due to ill-advised decisions. Often we find that conditions that lead to regulatory citations are due to pressure upon manages and rank-and-file alike to focus on production at the expense of compliance. Our advice is to take  hard look at your business culture and determine whether there are conditions that could lead to mistakes in judgement – and fix them.

On the other hand, the best methods for managing an environmental management system include meeting reporting timelines, competently maintaining records related to permit conditions and also, having a robust, dynamic and effective management system in place. Key elements in keeping your management system responsive and capable include:

  • having competent people administering the management system and/or program elements;
  • visible and consistent management support;
  • consequences for failing to meet goals and objectives;
  • Effective, concise and up-to-date documents that identify policy and procedure;
  • periodic internal review of the System with an eye on continual improvement

There are just some important elements. Most of all, make sure that your management system elements are tailored to your specific business and goals and objectives. Avoid cookie-cutter EHS documents that too often have gaps, errors and omissions.

Environmental, Health and Safety – Value Added

If your company has not had the best success meeting environmental, health and safety (EHS) goals and objectives, and/or has had difficulty keeping EHS professionals, it is likely time review your methods. The long and short of it is that we repeatedly find that companies tend to undervalue and under-appreciate the role of the EHS professional. Alternatively, a company may have focused on the EHS role with a hefty wish list of duties and responsibilities but fails to offer attractive compensation.  Without competent EHS personnel who in turn are visibly and consistently supported by corporate leadership, efforts in that important aspect of your business may easily flounder.

One reality check is to examine your company web site and see how well you present EHS goals and objectives. Some companies fail to even mention the value of a safe and health workforce or staying compliant with environmental regulations.  If your company values page fails to mention those aspects, you may have to do some corporate rethinking to adjust to a more realistic and frankly, competitive mindset.

Company vehicles

Your company may operate fleet vehicles – everything from passenger cars to delivery trucks or tractor-trailer rigs. Your company may also have employees who use their personal vehicles for company business. When your employees (or contractors) drive vehicles for your company, you have a risk exposure. Certainly vehicles with your company name on the side can advertise both good driving habits and those that you’d rather not advertise. That’s why it is important to properly vet your drivers and maintain timely information on their driving record.  The same goes for employees who drive their own vehicles for company business. That exposure may extend to sales staff who use their own vehicles to employees who run errands for the company.

Your vehicle and driver program should include elements regarding how drivers are selected, how driving performance is assessed, a driver training program and other formal and written aspects such as driver rules and requirements.

Your vehicle and driver program should also include a documented vehicle inspection and service component – even for vehicles not governed by DOT rules. Do you have drivers inspect key safety functions and features of vehicles prior to operation? Do you have a formal vehicle service and maintenance tracking process? How about accident response end investigation? Do your drivers know how to respond to a vehicle accident? Do you document your accident investigation process? And do you require mandatory post-accident drug and alcohol testing?

This is just summary information and does not include all possible best practices. Ask us to assess your fleet, vehicle and driver procedures with the goal of reducing your exposure and risk.

Fume Hoods

Fume hoods are used to capture potentially hazardous chemical fumes, mists and dusts and remove them from the breathing space of the operator. Therefore, properly engineered fumes hood ventilation as well as effective use and maintenance of fume hoods is of critical importance. The typical laboratory fume hood includes a working space within the hood and a fume hood sash that can be raised or lowered at the face of the hood. Proper placement of equipment and chemicals inside the hood can affect the effectiveness of the air flow to keep hazardous chemicals from entering the breathing space of the operator. Additionally, the design and maintenance of the ventilation system and the effective use of the fume hood sash are also important aspects to consider.

Time and again we find commercial and/or custom fume hoods that are not performing as desired due to a number of reasons such as:

  1. poor design;
  2. inadequate maintenance;
  3. disabled or missing flow indicator;
  4. lack of training on the proper use of a fume hood and sash to control laminar air flow;
  5. operator unfamiliarity with or misuse of the equipment.

In some cases, the roof-top discharge of chemical fume hoods has been placed too near HVAC systems designed to introduce clean air into the building and as a result, the HVAC system draws in exhaust from the fume hoods and degrades indoor air quality.

In order to produce optimal results, fume hood flow rate must be evaluated on a regular basis. This is a documented, specific analytical and diagnostic process. Appropriate and calibrated flow measurement equipment must be used. Fume hoods must have a working flow indicator to alert the operator of the function of the local exhaust associated with the hood.

 Ask us to conduct comprehensive fume hood ventilation surveys for your business.

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