Transcript Environmental Permitting, Fees, and Reports

Permitting, Fees, and Reports
Cal Poly Lecture Tour
Ron Scholtz
Analog Devices, Inc.
I Didn’t go to College to be a File
Clerk!



EHS professionals have a lot of responsibility
in maintaining up to date permits, fees, and
other records.
A great deal of time is spent dealing with
paperwork.
There can be serious legal implications if
permits, fees, and other required records are
not properly maintained.
Permits









Air District Permit to Operate
POTW Waste Water Discharge Permit
Storm Water Permit
Waste Generator Permit
Waste Treatment Permit (Tiered Permit vs.
TSDF)
Fire/Business Permit
Radiation Permit
Elevator Permit
Pressure Vessel Permit
Reports







Wastewater Monitoring Reports
Storm Water Monitoring and Inspection
Reports
Air District Data Reports
SARA Form R Emissions Report
Hazardous Materials Inventory Statement
Groundwater Monitoring Reports
SB-14 Source Reduction Report
Reports






Hazardous Waste Biennial Report
Waste Treatment “Tiered Permitting” Annual
Update
Tiered Permitting Financial Assurance
Contingency Plan for Emergency Response
Industrial Hygiene Monitoring Reports
OSHA 300 Accident Log
Fees






Air District Fee
POTW Fees
Hazardous waste fees and taxes (multiple)
Business taxes
Storm water fees
Department of Transportation fees (haz mat)
Records








Hazardous Waste Manifests
Hazardous Material Shipment Bill of Lading
Accident reports/OSHA 300 log
Medical records- ERT, Respirator
Material Safety Data Sheets
Training records
Spill and incident reports
Chemical usage records
Records








Wastewater pH and flow charts
Solvent fume abatement system temperature
charts
Toxic gas monitoring system alarm reports
Respirator Fit Testing Records
Calibration records
Equipment maintenance records
Inspection Records
Corrective Action Records
Inspections





Regulatory Agency Inspections- Fire Department, POTW,
Stormwater, CHP, DOT, FAA, OSHA, EPA, FDA
Internal Inspections- Forklift, Respiratory Protection, LockOut/Tag-Out, Confined Space, ISO 14001/OHSAS 18001 Audits
Regular Inspections- Weekly Hazardous Waste Storage, Weekly
Hazardous Material Storage, Daily Tank, Gas Cylinder Delivery,
Stormwater
Life Safety Inspections- Fire Protection Systems, Alarm Systems,
Gas Monitoring Systems, Fire Extinguishers, Safety Showers,
Emergency Lighting
Third Party Visits- Industrial Risk Insurer, Workers Compensation
Insurer, Customers, ISO 14001/OHSAS 18001 Registrar,
Community
Regulations





Need access to all applicable legislation, regulations,
and codes- maintain a list
Most regulations are now available on the internet
Many agency websites have greatly improved and
contain a wealth of information
Take some time to periodically review regulationsUpdate services, newsletters, etc.
Having a good reference library available is very useful
Being Organized is a Must!

You must have very organized files in order to keep up
with all the paperwork.
–
–
–
–

Files in a centralized location
Files divided by “reports”, “permits”, “fees”, “records”
Have a system- i.e. color coded folders
Have a record retention system. You can destroy most old
documents.
Maintain tracking calendars so that you know what is
due ahead of time.
–
–
–
“High Level” Matrix of requirements and timelines
“Compliance Calendar”- Issued Annually, Updated Monthly
“Life Safety Calendar”- Issued Annually, Updated Monthly
Other Tips





Don’t let your paperwork pile-up. Give yourself time
each day or each week to keep up.
Fill out forms completely. Blank spaces can come back
to haunt you! Waste manifests in particular.
Have a review system so that documents are looked at
by more than one person before signing.
Managers should periodically check department files to
make sure everything is in order.
An organized looking office space is usually a good
sign!