Milling & Baking News - June 30, 2009 - 26

Regulatory Affairs

Are you in compliance? A beginner's
environmental compliance list
BY ANNE GIESECKE

Ah, the sweet smell of summer and
a new crop of local, state and federal
environmental interns hit the food
plants. Evaluation of a plant's compliance status may save money and
prevent jail time. This article will list
rules that most commonly apply to
food facilities but will not include all
possible rules that might apply to any
specific plant (including office, kitchen
and restroom area), warehouse, depot
or thrift store.
Be hopeful, remember that you know
your business better than the government and 95% of the time if you run
your business cleanly and efficiently,
you will meet the regulations. One
such guide to prioritizing the work is
the "AIB International Consolidated
Standards for Inspection." The goals
of environmental compliance and a
food-safe processing facility are complementary.
Permits, plans and associated paper
work may be managed simply using
a loose-leaf notebook with a scanned
copy on and off-site. A plant manager
may quickly respond when visited by
an inspector. When an activity is referred to as permitted in this article,
it means that a piece of paper that is
a permit is needed; not that a plant
manager has permission to carry out
the task.
Many of the regulations referred to
require annual reporting. If the necessary paper work for the activities is not
present, compliance was never met and
fines begin at $25,000 a day per violation with variable jail times. Take a
deep breath, this is dense material.
Air quality compliance
In regards to air quality compliance,
here are some of the requirements that
may be necessary:
* Air permits to construct, modify
and operate a facility using yeast fermentation are usually issued for 5 or
10 years but must be renewed 6 to 9
months before they expire.
* Air control devices for ovens such
as catalytic oxidizers and dry ingredient silo baghouses used for flour are
permitted.
* Permits also may be required for
odor and outside visual emissions
such as the "smoke" that may be part
of a diesel startup.
* Boilers, steam generating units and
emergency generators are permitted.
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Milling & Baking News

* Refrigeration systems maintenance, refrigerant disposal and documentation are regulated. In addition,
ammonia systems require emergency
response plans as well as an Environmental Protection Agency Risk Management Plan and an Occupational
Safety and Health Administration Process Safety Management Plan.
* Hazardous chemicals such as
code and date stamp inks and oven
lubricants probably need to be
reported for air
permits, the Toxic
Release Inventory
Reporting and the
E.P.A. Hazardous
Chemical Inventory.
* Dust and noise
limits inside the
building are regulated by local fire
codes, the E.P.A.
and OSHA.
* Flour and air
compressors are
critical checks for
particulate concentrations.
* Asbestos is regulated. Radon testing is required in certain areas.
* Mold is bad; think food contamination and worker safety.
* Pesticides are regulated.
Requirements for water
The permits for drinking water and
discharge water also are wide ranging.
They include:
* Permits are required for the discharge of water from food processing, sanitary wastewater, boiler blow
down and storm water. A spill plan
is required to prevent any ingredient
such as vegetable oil and flour, oil from
the parking lot, material stored on-site
or any other delivery from reaching a
storm drain. Flour on the roof is bad;
think cost of flour, bugs, birds and a
storm water violation.
* The testing of drinking/processing
water and discharge water often is required. Reuse of gray water is becoming more common and the rules are
variable.
* Truck washing on-site is a regulated or an illegal activity.
* Above ground and underground
storage tanks are permitted and the
management of leaks is regulated.

* Locks, berms and security fencing
may be required.
Waste documentation is critical
Likewise, keeping up with documentation of waste management practices is critical. These requirements
may include:
* Hazardous substances require special storage and disposal. Documentation is critical.
* Disposal of electronics, including
lighting, air conditioners, cell phones,
computers and just about anything
with a chip is regulated and often
permitted. Fluorescent lights often are returned to
the manufacturer.
PCBs are a particular concern.
* Disposal
of
cleaning solvents,
used oils, paints,
and other hazardous
substances
must be documented. Disposal
of materials that
go to landfills, incinerators or for
animal feed must
not be exposed to
storm water and
the disposition of
the materials should be documented.
Requirements are wide ranging
Local, state and federal requirements not only vary but may be contradictory.
For more information on how to
comply with this burdensome list
check out www.epa.gov for several guidance documents, including
"Multimedia Environmental Compliance Guide for Food Processors"
and other documents available at
cfpub.epa.gov/clearinghouse/index.
cfm?TopicID=C:10:900:311
Rules for OSHA worker safety, Department of Transportation fleet management, U.S. Department of Agriculture for meats, Food and Drug Administration food safety, Homeland
Security and others may be researched
on their respective web sites. MBN

Anne Giesecke, Ph.D., is
a contributing editor at
Sosland Publishing Co.
bakingbusiness.com / world-grain.com

http://www.epa.gov http://cfpub.epa.gov/clearinghouse/index http://www.bakingbusiness.com http://www.world-grain.com

Milling & Baking News - June 30, 2009

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