Pollution Engineering - September 2008 - (Page 20)

ENVIRONMENTALMANAGEMENT By Norman Wei Five Reasons for Noncompliance The federal government and one of the nation’s largest agencies have identiﬁed the ﬁve most common root causes for environmental noncompliance. Let’s look at each one and see how we can avoid them. PA and the Chemical Manufacturers Association – now called the American Chemistry Council (ACC) – conducted a survey some years ago on identifying and evaluating the root causes of environmental noncompliance. The agency’s Office of Enforcement and Compliance Assurance and ACC surveyed 27 facilities that had been involved in 47 enforcement actions. The survey identified the following most frequently cited root causes of noncompliance. E “ The liability associated with the wrong choice is much higher than that when you purchase the wrong paper clips. The first root cause of noncompliance occurs because many plant personnel do not read their permits. Rather, they spend the money to hire consultants to negotiate environmental permits for them. Once these permits are issued by the agencies, many facilities just file them away and ignore them. Management should make a point of reading their permits. At the very least, ask the consultant to summarize what must be done to stay in compliance with all the permit conditions. The second cause of noncompliance is human error resulting from poor professional judgment. This happens when plant personnel are not familiar with their job requirements. They do not understand what is required. Many major chemical accidents have occurred because of human errors. Lack of training is a big contributing factor. The third common cause is operating procedures not being followed by the company. A contributing factor is budget cuts. When faced with insufficient funds, operational staff tend to shortcut operating procedures. The fourth common cause of noncompliance is from third party contractors. Many companies select their vendors by going with the lowest of three bidders. This ” may be a sound purchasing policy to follow when it comes to buying paper clips. But it does not bode well when it comes to selecting environmental vendors. Never select an environmental vendor solely on price. The liability associated with the wrong choice is much higher than that when you purchase the wrong paper clips. It is important to perform some level of due diligence before retaining the service of an environmental vendor or contractor. The fifth common cause of noncompliance is the most difficult one to overcome. It is a direct result of an antagonistic attitude a company can adopt with respect to the agency. The plant manager views environmental regulations as obstacles to his production goals. This negative and antagonistic attitude is passed on down to his organization through staff meetings. Before you know it, the working relationship between the plant and the agency ceases to be professional and cordial. All of these five most common root causes of noncompliance can be avoid by doing the following: 1. Paying attention to permit conditions. 2. Making sure the employees receive the appropriate level of training. 3. Providing sufficient budget to the operational staff. 4. Performing due diligence before hiring environmental vendors. 5. Making sure your plant management has the right attitude about regulatory agencies. PE Norman Wei is the founder and principal instructor at Environmental Management and Training LLC – a consulting firm based in Union, Wash. He conducts environmental regulations seminars throughout the country. He also consults for corporations and provides litigation support to law firms. He can be reached at Norman@proactenv.com. His company website site is www.proactenv.com and his blog is http://normanswei.wordpress.com. Visit www.pollutionengineering.com and electronically forward a copy of this article to a colleague or customer. 20 Pollution Engineering SEPTEMBER2008 http://www.proactenv.com http://normanswei.wordpress.com http://www.pollutionengineering.com

Table of Contents Feed for the Digital Edition of Pollution Engineering - September 2008

Pollution Engineering - September 2008 Contents The Editor’s Desk Reader Comments EnviroNews PE Events Legal Lookout Environmental Management The Green Files Guest Dialog 500-Year Storm Control How Do You Clean Up 100 Years of Pollution? SPCC: Don’t Wait and See The Next Wave in Air Purification An Invitation to the Windy City Flood Control Infrastructure Saves ‘Green’ Puts a New Spin on Pest Control Instrumentation Products Material Safety and Storage Equipment PE Products Classified Marketplace Advertisers Index State Rules

Pollution Engineering - September 2008

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