Eileen Woodbury, founder and principle of Woodbury Consulting Group, has seen firsthand how taking environment, health, and safety (EHS) programs beyond compliance can result in great outcomes for both the environment and for business—and also witnessed too many hazmat responses gone wrong. For a special Earth Day “Faces of EHS” profile, we spoke with Eileen about her intersecting interests in environmental protection and public health, the challenges facing EHS training, and what Earth Day means to her as an environmental compliance expert.
While pursuing my undergraduate degree in biology at the University of San Francisco, I was drawn to the interaction between human activities and the consequences of bad outcomes passed onto the environment. As an undergraduate, I had many interests, and when I completed my biology studies, I added a second degree in history. I also felt a pull toward public service while interning at a local public health department. Public health was in my blood, as they say. My grandfather was a public health practitioner in a small town in Mexico; he provided vaccination clinics throughout a large rural area and also performed food preparation inspections and foodborne illness investigations at local restaurants and markets, among many other activities. Following graduation from university, I sought to both apply my degree and find an intersection between my backgrounds in science, environmental protection, and public health. To that end, I landed at Monterey County Environmental Health as a trainee environmental health specialist.
As a newbie environmental health specialist, I felt both overwhelmed by the magnitude of compliance rules I was responsible to learn and enforce but also pumped to expand my knowledge of all the hazardous materials regulatory programs. I enjoyed performing numerous deep dives into hazmat handling, hazardous waste management, worker safety, emergency response, and the interplay of human behavior within successful hazardous materials management systems that oversee compliance and safety. I also read the history of each regulatory rule and the many bad outcomes of improper practices and accidents that led ultimately to the path to regulation and the need for compliance and enforcement. I recall the days being quite long and needing prescription glasses early in my career as I read through the myriad local, state, and federal hazardous materials laws and regulations.
You specialize in compliance solutions in the ammonia refrigeration industry. What are some of the issues facing this industry, and do they affect other areas of EHS compliance, as well?
COVID-19 has been a challenge, and many in the industry have met this challenge well. Within my region of central California, the ammonia refrigeration industry has quite a heavy burden within environmental protection and worker health and safety compliance programs. The priority needs include the hiring and retention of ammonia refrigeration technicians and on-site engineers. These highly skilled technicians and on-site engineers oversee mechanical integrity, refrigeration controls, and system operations, among many other facility needs. I felt lucky to learn the industrial refrigeration process by 20- to 30-year experts in their field. These veterans actually used their hands to turn valves, continually adding oil to lubricate pumps and compressors to operate systems. Over time, these systems became computerized with remote monitoring via a computer screen or a tablet or phone.
The hands-on knowledge is still lacking for some in-house refrigeration personnel, and many rely on off-site contractors to maintain their refrigeration processes and act as the lead responder during an emergency event. Executing a safe emergency response to accidental releases of hazardous materials enhances worker safety and community health protection over the fence line; on-site qualified emergency responders are able to implement a safe and timely response to accidental releases of anhydrous ammonia—an important part of any facility compliance program. The presence of qualified responders prepared and ready to respond reduces the likelihood that a release will negatively impact (or has the potential to impact) human health, safety, and the environment. It’s my goal to provide on-site personnel with the appropriate training to safely respond to these emergencies, with the intent to control and contain the release within the responders’ capabilities.
We have one Earth, and as environmental stewards, we all have a responsibility to reduce our human footprint as much as possible while still living our lives. In many instances, this may be seen as a delicate balance within the context of compliance and my interactions with business. Going beyond compliance is a great start to find this balance.
As a former environmental compliance regulator, I was part of a local team to kick-start a regional Green Business Program for the vehicle service and repair industry. The program goals were quite lofty and novel for our area—compliance is the baseline state, and moving beyond this state will enhance environmental protection, as well as worker and community safety, all while improving businesses’ bottom line. Adopting measures to conserve and reduce energy and water usage, substitute materials with less toxic chemicals, improve handling practices, and minimize waste was among a few practices we prioritized. Initially, only a few businesses achieved the designation as a Green Business, but over time, the program grew, and the breadth of industries involved increased. Those first Green Businesses saw a net positive across worker morale, operating costs, and improved relationships with regulatory personnel.
Your firm, Woodbury Consulting, has a strong focus on training. What’s the biggest challenge that you see in the field when it comes to training, and how do you suggest EHS managers address it?
Online synchronous and asynchronous training has become a common mode of training delivery over the past year or so, and online training provides easy access to experts in any given field anywhere in the world. As of last year, I’ve fully adapted to offer all trainings online and live, with plenty of time for discussion and exercises.
The biggest challenge in online training is my attempt to translate the in-class experience online while maintaining the attention of participants. Seeing individual squares staring back at me is not the same as walking the classroom and making individual eye contact to ensure understanding of the topic at hand. While in the online setting, I make continual requests for feedback from the students, either through the chat box function or verbally. I also make time for a group exercise or quiz to ensure they understood and can apply the training. By doing so, I usually receive great feedback, and in some cases, we return to previous modules, as a group, to further review any areas needing clarification. Thus far, my efforts during the online training have been well-received. Overall, I feel more energy expended for preparation and delivery of online training in comparison to in person.
For those interested in furthering their online training offerings, I recommend spending time adapting their trainings to encourage interaction and make assessments throughout the training session. Again, creating a lesson plan that integrates small quizzes or requests for feedback via chat box (for those not comfortable expressing their views verbally), as well as continual “check-ins,” encourages participation and overall training satisfaction.
What do you see as the main emerging trends, both positive and negative, affecting the future of the EHS industry?
Over the years, I have seen an increasing switch away from boilerplate or template-style written plans and programs to site-specific plans and programs. This may seem like a trivial trend—it is not! I’ve been present for too many emergency responses gone bad as a hazardous materials specialist. When the site is returned to the facility to resume operations, we often see these boilerplate plans with no clear procedures or steps for important considerations, from on-site and off-site notification to evacuation, first aid, and a safe incident approach to gather further information. The lack of site-specific emergency response procedures with clear lines of responsibility for the facility response team to follow and act upon to their level of capability is a true problem.
There is a dire need for facilities to act as their own response team to safely evacuate and then safely size up the situation through investigating the emergency. Even though a facility may not have trained and capable hazardous materials technicians or specialists, there is space to act as a first responder through the awareness or operational levels of the Occupational Safety and Health Administration (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) standard. The more information provided to the first responders (e.g., fire department or other contractor), the quicker the emergency can be mitigated through containment, control, or stopping the release. These critical and timely efforts aid in reducing the potential impact of the release on- and off-site.
How has the COVID-19 pandemic changed things on the environmental compliance front, and what do EHS professionals need to do to adapt?
Adaptability to confront new challenges and provide appropriate solutions is the hallmark of any EHS professional. COVID-19 has taught us all the need to pivot and pivot again while adjusting tools and skill sets and utilizing new technology and methods of communication. A facility audit, for instance, can easily be conducted (at least partially) over videoconference. Remote audits have benefited both the consultant and the facility in the efforts to streamline the process of conducting the compliance audit while anywhere. Documentation review and interviews can easily occur online and live.
While some aspects of audits were better-suited to these remote methods, others, not so much. From my perspective, the operational inspections and monitoring of the interaction between the facility personnel and the equipment is difficult to capture. Also, an experienced auditor must also set a specific and detailed agenda to carefully establish the remote vs. on-site activities needed to represent a full audit. Remote audits or inspections can be integrated as part of a compliance audit, but there is no substitute to an on-site walk-through and face-to-face interaction.
What’s your favorite job-related story that you like to tell others?
I have over 20 years of experience within the EHS industry as a former local regulatory inspector and now an environmental compliance consultant supporting the ammonia refrigeration industry, and my favorite story to tell took place early on in my career.
I was conducting an initial compliance inspection at a vehicle service and repair facility. The owner of the auto repair shop was speaking Spanish to his employee, instructing him to place the used oil absorbent, hidden at the back of the shop, into the dumpster. I completed the interior portion of the inspection, and prior to finishing, I politely asked to continue the inspection outside. I walked toward the dumpster and asked the owner to open it. Inside was a mound of used oily absorbent, which is classified as a hazardous waste in California. The owner claimed he didn’t know how it got inside the dumpster. I let the owner know I am fluent in Spanish and overheard him instructing his employee to illegally dispose of hazardous waste. The owner appeared shocked and said he didn’t realize I spoke Spanish and profusely apologized while removing the used oily absorbent.
The lesson there, of course, is not to judge a book by its cover! And to use every tool in your toolkit to do the job well.
Do you have any advice for people who are either considering or transitioning into a career in EHS, especially those who plan to focus on environmental compliance?
The environmental compliance profession is vast and includes various local, state, and federal rules. These rules are enforced by local, state, and federal agency inspectors from such agencies as California Certified Unified Program Agencies (CUPAs), the California EPA, the U.S. EPA, OSHA, Cal/OSHA, and the Chemical Safety and Hazard Investigation Board (CSB), to name just a few. For those interested in pursuing their career in EHS, I recommend becoming familiar first with the rules, their agencies, and then the industries regulated by those rules. To get the full breadth of the industries covered, I do recommend beginning your career at the agency level. At some point, you may want to niche down to an industry based on where your curiosity may take you—like agriculture, for example. Either way, I recommend you start and see what the future holds for you!
|Eileen Woodbury is the founder and principle of Woodbury Consulting Group, LLC, providing comprehensive EHS compliance services to the ammonia refrigeration industry. Eileen started her career with the Monterey County CUPA, a hazardous materials regulatory agency, and has over 19 years of diverse hazardous materials compliance and chemical safety experience. The goal of Woodbury Consulting Group is to build and maintain trust and lasting working relationships with industry at every level. Eileen is a registered environmental health specialist (REHS) in California, a California Specialized Training Institute (CSTI) Certified Hazardous Materials Specialist, and an Associate Safety Professional. In addition, Eileen is a proud member of the American Society of Safety Professionals (ASSP) San Jose Chapter, a Women in Safety Excellence (WISE) member, a member of the Refrigerating Engineers and Technicians Association (RETA) Monterey Bay Chapter, and a member of the Salinas Valley Ammonia Safety Day Planning Committee. She has a BS in Biology, a BA in History (emphasis in Latin American studies), and an MS in Environmental Management from the University of San Francisco.
While not promoting compliance and health and safety, Eileen spends many hours as a “Google Elementary School” teacher’s assistant, a PE coach, an art supplies-getter, a cheerleader, a tutor, an IT support specialist, and a short-order cook, helping her two kids, Luke and Isabella, navigate and succeed with distance learning.
Would you like to be profiled in a future “Faces of EHS” and share your experiences, challenges, etc.? Or, do you know anyone else in EHS you think has an interesting story to tell? Write us at ehsposts@SimplifyCompliance.com, and include your name and contact information; be sure to put “Faces of EHS” in the subject line.