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This guide, A Self-Help Guide to Environmentally Sound Chemical Operations, is a compilation and distillation of a tremendous amount of technical and complex environmental regulatory information. Figuring out how all the regulatory requirements and other environmental information fits together and impacts your facility can be a daunting task. EnviroChem Ohio presents much of this information in an easy to read, systems-oriented guide that business owners and managers can readily use in achieving an environmentally sound chemical operation. What is an environmentally sound chemical operation? Essentially, it is one that complies with all environmental regulations, provides a safe place for employees to work, operates in an efficient and orderly manner, is a good "neighbor," continually reduces waste and lowers emissions, and prevents pollution at the source. Environmentally sound chemical operations not only benefit the facility, but also the neighboring community. The challenges facing most manufacturers, suppliers, and users of chemicals is not their willingness to improve operations or comply with regulations – it is knowing what to do and how to do it. The days of willfully not complying with environmental regulations are, for the most part, long gone. These days, every chemical company should want to do the right thing. Hence, the need for this self-help guide. Although regulatory compliance is important to your success, the ultimate goal of EnviroChem Ohio is to help you move your chemical operations beyond compliance. This guide should be a valuable asset in creating a process that not only demands regulatory compliance, but also strives for continuous improvement throughout your chemical operations. EPA/CMA Root Cause Analysis Project From 1986 through 1998, the U.S. Environmental Protection Agency ("U.S. EPA") and the Chemical Manufacturers Association ("CMA") collaborated on a project to identify the root causes of the chemical industry’s non-compliance with regulatory requirements ("EPA/CMA Root Cause Analysis Project"). The four main types of non-compliance events were: Report Submissions and Reporting, Exceedances, Operations and Maintenance, and Recordkeeping. Among the ten root and contributing causes of these four non-compliance events were many that might have been mitigated or avoided with better institutional control:
The study results showed a strong relationship between the implementation of a facility environmental management system ("EMS") and successful compliance. The structure and operational discipline gained from an EMS could have prevented many of these non-compliance events. Further, the surveyed chemical companies asked for "plain language" rules and more useful management tools (i.e. self-audits, compliance worksheets, etc.) to help them work through environmental management and compliance issues. However, even a well-documented EMS does not, by itself, ensure 100 percent compliance with environmental operations. Once your facility has established the policies, procedures, and tools needed in an EMS, your employees must be properly trained and your management must demonstrate support for the EMS. No EMS will be effective without top management support and employee involvement. The Benefits of an Environmental Management System It takes time and effort to fully understand the potential impact of your chemical operation on the environment. It’s also an effort to understand and avoid the potential liabilities you face as an individual, as well as a business, if you ignore environmental impacts. There is no question that environmental liabilities, such as clean-up costs for improper waste disposal or penalties for violating regulatory requirements, can negatively impact your business. Avoiding these liabilities can be accomplished through an effective EMS. There’s a lot to be gained from an EMS and an environmentally sound operation, and there are strong incentives beyond merely complying with legal requirements. A sound operation can reduce liability, improve working conditions for employees, lessen the impact on the environment, conserve raw materials, prevent the generation of pollution and waste, enhance the environmental friendliness of the company’s products, and reduce costs that are associated with environmental issues. Major benefits of an environmentally sound operation include:
An EMS needs to be part of your facility's future. Refer to Chapter 1 of this guide for more information on environmental management systems. Moving Forward With EnviroChem Ohio EnviroChem Ohio addresses many of the recommendations of the before mentioned EPA/CMA Root Cause Analysis Project. It is also a timely response to the numerous requests for assistance from the managers of small chemical operations. Though much of EnviroChem Ohio is compliance based, the guide's strength is in providing a systematic approach for addressing the myriad of compliance and non-compliance environmental issues faced by your facility. EnviroChem is not meant to be an all-encompassing regulatory guide that will prevent your facility from having regulatory problems. It is meant to provide a systems-based approach for assessing and managing your environmental affairs through the use of tools designed specifically for this guide. Although EnviroChem Ohio does not address the intricate details of every regulation, it will help you clearly identify many of the regulations that apply, how to comply, and who to contact if you have any questions. Will strict adherence to EnviroChem Ohio ensure regulatory compliance? No, but it can ensure that your management team has at least been given the basic information, references, and tools needed to make informed decisions in moving towards an environmentally sound chemical operation. EnviroChem Ohio can help you achieve both broad, company-wide goals as well as more narrow, process-based objectives. Applying the principles and processes of the EnviroChem Ohio guide to your operations will allow you to reap the rewards of lower costs, less pollution and waste, less regulatory burden, and improved environmental health and safety for your employees and the public. We hope you find EnviroChem Ohio to be an integral tool in helping you manage your company’s environmental issues. Creating an environmentally sound chemical operation must be your path forward. Good Luck! Disclaimer EnviroChem Ohio is intended to be a tool to assist the chemical industry in reviewing and improving compliance with environmental regulations, and improving the overall operations as they relate to environmental issues. EnviroChem Ohio does not include a comprehensive listing of all environmental regulations that are applicable to the chemical industry. A comprehensive listing would be dependent on many case and business specific factors which are beyond the scope of this guide. EnviroChem Ohio will identify general areas of regulations, as well as processes and systems that can be used to enhance environmental wellness. Further research by your company on specific topics in many instances is expected. Completion of the guide's management processes is not a guarantee that a company meets all applicable state and federal regulations. The management processes are intended as tools to assist a facility in evaluating initial compliance and in determining areas requiring improvement. Top of Page
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