Concrete inFocus - Spring 2015 - (Page OC2)

infocus online connections: enviroscene www.nrmca.org/news/connections Your Biggest Environmental Threat in 2015 is NOT Who You Think! Douglas Ruhlin W hen we're conducting environmental training or doing site inspections, I regularly ask concrete producers what they view as their biggest threat regarding environmental compliance. It's a great question, since if you don't know who or what to be concerned about, you can't really be adequately prepared. And if you're not prepared, you're probably headed for trouble. You can probably guess the answer I normally get. The state or local environmental regulator. Think about it for a minute. The same inspector, who has been visiting your facility, possibly for years, who you've maybe gotten to know, and could just be penciling in his or her inspection report, is your biggest concern? Hardly. Sure you might get a new inspector who is tougher, or there may have been a complaint, or maybe you have operations in a state that's cracking down on compliance issues. But by and large, this is very likely a person who has grown accustomed and comfortable with you, your level of environmental commitment and performance, and your compliance level. He or she knows you and your operation, and probably won't rock the boat. How about USEPA inspectors? I get it infrequently, but it's possible they could be a concern at your operation. The USEPA has oversight over nearly all environmental regulations in the U.S., so you can be inspected at any time by someone who may have never been to your site before. He or she may have never even been to a facility like yours before. Or might be coming in deliberately looking to find something to issue a violation on. Sounds pretty scary, right? However, these visits are few and far between from what I've seen over the years. Unless you're near a field office, or there's some sort of specific enforcement action going on, the chance of having a USEPA inspection is much, much lower in most places than your state or local guy. USEPA inspectors carry a lot of authority (i.e., they can issue some pretty steep enforcement penalties, including BIG fines), but since you rarely see them, they're not the reason to lose sleep at night. So who does that leave? Neighbors? Maybe, but they usually have to resort to complaining to your state or local inspectors. So who then? Your biggest environmental threat in 2015 is organized, third-party environmental groups. Ever run into one of them at your operation? If not, consider yourself lucky, but be very wary. They just might be the future of environmental regulation. These folks have a very definite agenda, and they usually don't play nice. Not fully in compliance with an environmental regulation? In cases I've seen and read about, these groups have the ability to pursue legal action against you for failing to comply with every detail of your permit (or worse if you don't have a permit!), including the ability to sue for damages. While your state or USEPA inspector might be willing to give you some leeway to get into compliance, or overlook small issues, these third-party environmental groups might not. Imagine an army of zealous environmentalists poring over every detail of your operation and compliance status. This information is easily available online, in government offices and found using Freedom of Information Act liberties. It's not too hard to do. These folks, very easily, can determine if you are in compliance with every little detail of your permit. After some research, they'll follow up with a lawsuit against you for environmental violations. Bottom line is, if you're out of compliance and one of these environmental groups finds out, you could be a huge target. In my experience, these environmental groups have done things like serve lawsuits to facilities for fines in the multi-million dollar range, demanded access to the facility in the future to ensure absolute ongoing compliance, and have required implementing environmental management systems to stay in compliance, etc. Certain regulations allow these groups to get away with this stuff. They should be taken very, very seriously. So what can you do to protect yourself? First and most obviously, find out if you're in compliance with everything that could apply to your operation. If you're not sure, have a professional conduct a thorough environmental audit of your operation to find out. If you do find you're missing a permit, approval or some sort of plan, get it ASAP. If you find you've not been doing something completely or adequately? Correct it, change your operation's culture and make sure your staff knows how to be in compliance. If something at your facility needs to be repaired to comply with your permit requirements, then fix it immediately. I know what you're thinking, that's all going to cost time and money. And you're right. However, what time, money and energy you'll put into fixing the issue now will be a fraction of the hassle it will be should you get a certified letter or environmental watchdog showing up at your facility one day. ■ OC2 ı SPRING 2015 http://www.nrmca.org/news/connections

Table of Contents for the Digital Edition of Concrete inFocus - Spring 2015

Ready Mixed Plant Innovations
Data Security of Credit Card Processing in the Concrete Industry
Oldcastle Material Group
How the Concrete Paving Industry is Incorporating Sustainability into Our Practices
Index of Advertisers
The Trail to Your Future Business Should be Paved with Concrete
Your Biggest Environmental Threat in 2015 is NOT Who You Think!
Why is the Air There? Thinking about Freeze-Thaw in Terms of Saturation

Concrete inFocus - Spring 2015

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