Workshop W Passionate about Safety: Love All Your Jobs! Successful Integration of Safety & Environmental … Managing Risks for Both Tuesday, March 24, 2020 3:30 p.m. to 4:45 p.m.
Biographical Information Anita Evenson, Senior Consultant Trinity Consultants, Inc. 1717 Dixie Highway Suite 900, Covington, Kentucky (859) 341-8100 x 116 aevenson@trinityconsultants.com Anita serves as a senior consultant in Trinity’s Covington/Greater Cincinnati office as an experienced air permitting and compliance expert with more than 15 years of high-level performance in the environmental consulting and engineering fields. This includes project management and technical experience in air quality permitting, emission inventories, regulatory compliance support, multi-media environmental assessments, and complex permitting compliance efforts surrounding CAM plans, several MACTs, Title V renewals, synthetic minor permits (including NSR and PSD analysis), and other engineering projects. Routinely assists clients in complying with complex environmental regulations. Develops air emission inventories for plastics, resins, coating, steel mills, automotive, food and flavoring clients that involves site evaluations, process analysis, extensive records review, and detailed calculations of potential and actual emissions. Anita is a graduate of Rose-Hulman Institute of Technology with a B.S. in Chemical Engineering. Sherry Vaughn, HS&E Manager The J.M. Smucker Company 5204 Spring Grove Avenue, Cincinnati, Ohio (513)482-8035 sherry.vaughn@jmsmucker.com Sherry served our country in the Army and worked as an EMT in Cincinnati prior to beginning her career at The J.M. Smucker Crisco facility in 1997. At that time the operations were owned by Proctor and Gamble. In 2001, Smucker purchased the Crisco and JIF brands. She has expert knowledge of the St. Bernard facility working as a refinery and packing line operator, fire protection technician, IH&S coordinator, and now HS&E manager. Sherry is a graduate of Thomas More with a B.S. in Business Administration.
Love All Y our Jobs! Integrating and Managing Risk for S afety and Environmental Programs March 27, 2020 S ession W
Introductions Anita Evenson – Senior Consultant ˃ S tarted at Trinity December 2017 via acquisition of QS EM ˃ Experience serving a wide range of industries and clients across Indiana and Ohio ˃ B.S . Chemical Engineering Rose-Hulman ˃ Based out of the Covington, KY / Greater Cincinnati office
Introductions Sherry Vaughn – HS&E Manager ˃ U.S . Army Reserves 1991-1998 ˃ S tarted at P&G in January of 1997 ˃ The J.M. S mucker Company acquired the Jif and Crisco brand in 2001 ˃ B.S . Business Administration, Thomas More College ˃ Works for Cincinnati plant in the Ivorydale facility in S t. Bernard, Ohio
Presentation Agenda ˃ Commonalities Training Audits/ inspections Recordkeeping and reporting Regulatory changes ˃ Environmental Resources Regulatory programs Best practices ˃ S afety Resources Regulations Fire S afety Regulations Fire and Environmental Disasters
Environmental and Safety Commonalities
Training Effectiveness Lecture – 5% Reading – 10% Audio‐visual – 20% Demonstration – 30% Discussion Group – 50% Practice by Doing – 75% Immediate Use of Learning – 90%
Training Basics ˃ Audience ˃ Goals Meet OS HA and EP A regulatory requirements Drive positive outcomes- no inj uries, no violations S pecific to facility ˃ Types Demonstrations On-line modules Classroom/ presentations ˃ Frequency New hires Calendar based As necessary
Training Best Practices ˃ Lead by example ˃ Have an agenda ˃ Know your students ˃ Knowledge/ retention checks ˃ Use technology/ aids ˃ Vary teaching styles ˃ Employee engagement Assign individual/ group responsibilities Incentive programs
Audits and Inspections
Types of Audits ˃ Environmental ˃ Health and S afety ˃ Management S ystems ˃ S upplier/ Vendor Audits ˃ S tandard Operating Procedures ˃ Cultural Assessment ˃ Due Diligence ˃ Regulatory Inspections
Why Conduct an Audit? ˃ Identify and assess compliance with applicable regulations and requirements ˃ Identify areas of risk or liability ˃ Identify opportunities to reduce costs ˃ Response to stakeholder requests for increased disclosure ˃ Audits required as part of enforcement proceedings ˃ Audit privilege/ self-disclosure
Identifying EHS Issues - The Hard Way ˃ Regulatory inspection findings ˃ Enforcement actions against you ˃ Enforcement actions against others Other company facilities Competitor facilities
Identifying EHS Issues –A Better Approach Voluntary Audits ˃ Routine internal reporting and review ˃ Compliance management system reviews ˃ S elf-inspections ˃ Peer / industry contacts and sharing ˃ Certification ˃
Common Audit Findings ˃ Improper waste handling and labeling ˃ Lack of permitting ˃ Missing records ˃ S afety specific findings Unguarded equipment Equipment not secured Electrical Ladders S afety equipment
Recordkeeping and Reporting
Managing Environmental Records ˃ Example Records: ˃ Common Issues: Unable to locate Inspection reports Records kept in Maintenance records multiple locations Log books Multiple sources of Lab/ test reports similar data Training records / conflicting records Disorganized records Monitoring records Incomplete records Report repositories Inaccurate records Processed manifests Manufacturer’s procedures
Develop Recordkeeping System ˃ One-stop shop for all safety and environmental records ˃ S elect technology ˃ Develop S OP Users/ access File organization ˃ Define key record attributes Location or process for locating Frequency Owner/ responsible position Format ˃ Clearly Identify compliance/ regulatory data ˃ Periodic record reviews ˃ QA/ QC process
Compliance Calendar Benefits ˃ Track key deadlines and have a process to keep it current ˃ Alert stakeholders Operations S upervisors Management ˃ Use technology to enhance visibility of deadlines to multiple interested stakeholders; make it easy for stakeholders ˃ Consider development of interim/ internal milestones or deadlines for maj or reports or other multi-step regulatory tasks ˃ Implement hierarchy of notifications ˃ Integrate the use of compliance calendar for status and planning meetings
Best Practices for Reporting Calculations ˃ Multiply & divide numbers as well as units of measure ˃ Carry at least 5 sig figs in intermediate calculations ˃ Report 2 sig figs ˃ Report calculated numbers to either: The number of digits required by instructions The number of sig figs determined by the lowest sig fig number in the calculation ˃ Rounding: If the 1st digit to be discarded is 4 or less do not round up is >5 or if 5 and the next digit is not 0,then round the last digit you report up by one Is exactly 5 followed by a 0, only round up if an odd number
Recordkeeping Best Practices ˃ Document, Document, Document! Always assume that someone with little knowledge of your processes is going to need to read and understand any chemical inventory determinations ˃ Manage your S DS in a centralized location that will safe-guard against inadvertent compliance concerns ˃ Cross-check your programs against others that are completed on-site ˃ Conduct quarterly (or more!) meetings among program leads ˃ Centralize calculations that are applicable to multiple programs for maximum efficiency and consistency ˃ Consider a site-specific spreadsheet/ database/ software solution for automating threshold calculations where possible
Recordkeeping Best Practices ˃ Centralized system ˃ Use EMS ˃ Involve operators Train Assign roles ˃ Date stamp & sign incoming mail ˃ QA all records
Regulatory Changes
Identify Regulatory Changes ˃ Example Changes: ˃ Common Issues: New federal No knowledge of the regulations change ♦ EP A Misunderstanding the ♦ OS HA regulatory applicability New state regulations Not incorporating EP A memos appropriate and Regulation and policy timely changes into changes processes / training
Develop Regulatory Change Assessment Process ˃ S creen and evaluate regulatory changes ˃ Develop a standardized process: S creening: categorically not applicable, document non- applicability Applicability: complete an applicability assessment Impact Assessment: understand the regulation Implementation Plan: Develop and implement change plan ˃ Utilize consultants’ expertise ˃ Ensure any changes are communicated to key personnel ˃ Leverage subscription services ˃ Document findings for future reference
Environmental Topics
Facility Resources ˃ Internal ˃ Corporate ˃ Environmental management system ˃ File review at local/ state level
Federal Resources ˃ Environmental Compliance History Online (ECHO)/ Envirofacts ˃ Federal Register (FR) ˃ Electronic Code of Federal Regulations (eCFR) ˃ TRI Explorer ˃ RS EI Model
Ohio Digital Resources ˃ Electronic permits ˃ Engineering Guides ˃ Ohio eBusiness Air S ervices eDMR eDrums
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