Note that you do not have to be in actual compliance to get ISO 14001 certification.
Identifying Legal Requirements–Read the Fine Print
The most practical approach is to ask the who, what, when, where, and how questions. Ask yourself: Who tracks your organization’s legal requirements? Is it the legal department? If so, how is that information transmitted to the plants? What do they track, and how often do they track it? Where do they obtain their information?
There are many ways you can identify your requirements. The most obvious and direct way is to review all your environmental permits. Read the fine print, including the boilerplate language. Very often this is where many requirements are embedded. It is amazing how many permitholders never bother to read their own permits and end up being fined by an agency for failing to adhere to certain reporting requirements.
If you are the corporate environmental manager, you may need to summarize the permit requirements for your plant. If there are certain permit conditions that you are not sure about, contact the agency right away and obtain clarification. Don’t wait for the agency inspector to clarify them for you in the middle of an inspection.
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Other sources from which your employees can obtain legal requirements include Title 40 Code of Federal Regulations (paper copies or CD), agency websites, industrial association newsletters, etc. Many industrial associations have their own environmental committees that monitor regulations that may affect their industries.
This is an excellent source of information that comes with your association membership. For example, many industrial associations have been working with the EPA in developing the maximum achievable control technology (MACT) standards required under the Clean Air Act’s National Emissions Standards for Hazardous Air Pollutants program for their industries. These new standards have significant costs and compliance implications for the affected industries.
Don’t forget local and state legal requirements. Many state and local agencies have legal requirements in addition to the federal requirements. This is because federal programs allow states and local agencies to impose more stringent requirements. Always check with your state agencies.
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The manner by which your employees gain access to legal requirements often plays a critical role in your organization’s environmental performance. The issue here is ownership.
Do your plant personnel have ownership of such information?
Do they take proactive steps to obtain such information themselves or do they rely on corporate headquarters to feed them the information?
Worse yet, do they wait for the agency inspector to tell them?
Plants that have some level of information ownership by employees generally perform better than those that rely solely on others.
See tomorrow’s Advisor to for using this information to help you set environmental objectives and targets for ISO 14001 compliance.
In the case of reducing chemical spills, you must get the support of everyone who handles chemicals. Set up an awareness program so that all your employees understand the safe handling procedures and the various reporting requirements in the event of a spill. For example, you may want to assign someone in the receiving department the responsibility of reviewing the material safety data sheet/safety data sheet for safe storage requirements before a new chemical is stored in the warehouse.
This article is adapted from an article written by Norman Wei, owner and principal instructor at Environmental Management and Training, LLC. You can contact Mr. Wei at norman@proactenv.com, or visit the website at www.proactenv.com.