Too Many Cooks in the Kitchen?

Keeping your project on track when you have stakeholder involvement You’re an environmental manager for your company, and you learn that a contractor doing repair work has caused a release from one of your pipelines which is located on private property.  You report the spill to the authorities, notify the landowner, and initiate cleanup activities.  The contractor files a claim with their insurance carrier. Following initial response actions, soil and groundwater is investigated and cleanup goals are established.  It sounds straightforward until the various stakeholders get involved.  The stakeholders include the construction contractor, their insurance company, the insurance company’s consultant, the regulatory agency, and the landowner, in addition to you and your environmental consultant.  All parties want the spill cleaned up but have different goals and objectives. In another case, no one knows exactly when the spill, or multiple spills, occurred, but the cleanup has been underway for years. Initial
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Avoiding Pitfalls in Environmental Reporting

We at W&M, somewhat affectionately, refer to the time period of January 1 – July 1 as “Reporting Season” due to the myriad of compliance deadlines all crammed into that timeframe.  As you will recall, it all begins on March 1 with the Emergency Planning and Community Right-to-Know Act (EPCRA) Tier II reporting and Annual Waste Summary (AWS) reporting deadline.  Shortly after is the March 31 deadline for Air Emissions Inventory Reporting (AEIR) and the Multi-Sector General Permit (MSGP) Stormwater Pollution Prevention Plan (SWP3) annual reporting.  As you would expect, there are a number of pitfalls that you will want to avoid when completing your reporting.  We’ll discuss more during the January Webinar, but here are a few to get you started: Pitfall #1:  Quality of Information Not all information is created equal and not all information is good information.  When gathering data, it is important to be specific as
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Proposed Changes to the Endangered Species Act

ASSESSMENTS AND ECONOMIC CONSIDERATIONS In July of this year, the federal government proposed an amendment to the Endangered Species Act (ESA) that redefines/streamlines the procedures and criteria for listing and delisting endangered species and designating critical habitat.  There are a handful of amendments that are proposed but the overall direction points to allowing the U.S. Fish and Wildlife Service (FWS) to make unique or tailored assessments based on the species, habitat, region, etc. when deciding to list or delist a species. Additionally, the ESA currently states that it will not take economic or other impacts into consideration when listing, delisting, or reclassifying a species.  That is not being changed at this time.  However, under the proposed amendments, the FWS acknowledges that there is value in referencing economic or other considerations such as ambient air studies, cost/benefits analysis, etc. By clarifying the criteria for critical habitat designations, the proposed changes aim
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Brace yourself for March, it’s just around the corner.

For Environmental Health and Safety (EHS) Managers or professionals, the new year brings a new outlook on your job, promises to yourself and your company, and the desire for improvement over the past year. Unfortunately, the new year also brings the crushing realization that March is just around the corner, almost taunting you for becoming cocky in November and December when few environmental reports are due to the State or EPA. March marks the beginning of the annual reporting deadlines. The reporting calendar begins with the Emergency Planning and Community Right-to-Know Act (EPCRA) Tier II report and the Annual Waste Summary (AWS) due March 1st, and then you dive right into the Multi-Sector General Permit (MSGP) Stormwater Pollution Prevention Plan (SWP3) Benchmark Monitoring (BM) reporting and Discharge Monitoring Report, and the Air Emissions Inventory Report (AEIR), all due on March 31.  Individually the reports are not overly difficult or time
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A.D.D.ing It All Up

We never thought we would want to write about this topic, much less need to write about it. Unfortunately, it is the reality we live in. We all spend much of our day in office areas with dozens of co-workers, a good portion of us are parents with school-aged children, and we spend a large part of our lives in congested areas (shopping malls – while they still exist, hospitals, churches, etc.) – each potentially susceptible to attack Adapting to an unfortunate reality Active shooter situations are occurring at an alarming rate and don’t appear to be limited to a specific race, culture, demographic, or even physical region. What makes active shooter situations so frightening is that there is no real outward rhyme or reason as to when and where they occur. They are unpredictable by nature. They typically involve only one or two shooters that have a plan (well developed
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Waste Management Needs Everyone’s Help! If Not, It’s Just a Waste!

How often do you walk through your facility and spot an unlabeled or open waste container? As you walk through your plant and waste storage areas, do you see problems with waste and product management, such as missing signage or products stored outside of secondary containment. You think, “These problems weren’t here last week!”, and “What am I going to do, we have an internal audit is next month!!” As an ESH professional, it’s easy to “see” these items are not in compliance with the regulations. However, do the workers and supervisors understand the requirements AND the results if an outside agency finds them? For better or worse, most ESH professionals are responsible for all three areas of compliance – environmental, health and safety. Environmental compliance is a big responsibility, and one person can’t be in the entire facility every moment of every day. You need help! You could ask
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ESTIMATING MONETARY COSTS AND LIABILITIES FOR ENVIRONMENTAL MATTERS

W&M experts Andy Adams, CHMM and Gene Murray, P.G. hosted a fascinating look at the ASTM E2137-17 guidance on Estimating Monetary Costs and Liabilities for Environmental Matters.  Cost and Liability estimating is often completed as part of long term environmental investigation and cleanup, but is also used in many mergers, acquisitions, divestitures, and liability swaps. It is an essential piece of the Tiered process for Environmental Site Assessment, from identification through investigation and into remediation/cleanup. The ASTM guidance lays out a framework for cost estimating and provides the user with valuable information associated with environmental liabilities. The webinar included a review of the ASTM guidance and the basic concept of the tiered process for environmental site assessment, evaluations, and remediation, and how this process meshes into the estimation of costs and liabilities. Further, the webinar explored some of the basic frameworks used for estimating and how the established ASTM guidance
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Municipal Setting Designations

What is the most cost-effective way to address groundwater contamination? One cost-effective option is the use of a Municipal Setting Designation (MSD). An MSD is a state-approved deed restriction applied to a Site located within a municipality or its extraterritorial jurisdiction (ETJ) which restricts the use of groundwater for potable purposes. Any water used for drinking, bathing, cooking, or for the irrigation of crops is considered potable water. MSDs are commonly used in areas where shallow groundwater is not used and potable water is supplied by municipalities, and saves money by avoiding costly remediation. Additionally, MSDs may save time by closing sites sooner since remediation activities and subsequent groundwater monitoring could take years. Before pursuing an MSD there are a number of factors to consider that include: Does the local municipality have an MSD ordinance What are the chemicals of concern present in groundwater and what are the concentrations Is potable water
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Design With The Audience In Mind

When working on permits, plans, and reports for clients, we need to keep in mind how that material will be read and interpreted by our clients. They may be seeking environmental services because they don’t have the in-depth understanding of the programs, and, beyond just seeking someone to write reports for them, they need a way to understand and engage the material to upkeep their sites accordingly.  This can be essential to the client’s ability to stay compliant – if forms, documentation, and recordkeeping are essential permit requirements, they need to be user friendly to ensure they are completed accurately. While this may seem like a given, a basic concept that should already be occurring intuitively, we can all think of times we have had difficulty with understanding something because the materials were not designed with the audience in mind.  And the consequences of that poorly designed form, figure, or
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The Dreaded Words…We Are Being Audited!

It happens all the time: you hear about an audit (internal or external) and your brain starts racing and your “to do” list quickly double or triples in length and your blood pressure shoots through the roof. It doesn’t have to be that way. While touring facilities and conducting environmental, safety and health (EHS) audits over several years, I’ve identified several items that routinely appear as non-compliant findings that are things that you can tackle every day. These items, some minor and some major, have either been missed or overlooked or you simply just run out of time. A sample of these observations include:   Mislabeled/unlabeled waste and product containers Open waste containers Releases into secondary containment not removed promptly Missing/incomplete signage at waste storage areas Missing/illegible labels on power tools Improperly stored flammable products Damaged slings/lifting devices Missing/incomplete markings on cranes Improper storage of respiratory protection Prompt access to
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