Getting Started

Compliance Tips for Beginners

Environmental compliance can be complex, especially for those new to the process. Here are some key tips to help beginners get started and ensure that their business remains compliant with environmental regulations:

1. Identify Applicable Regulations

• Understand Industry-Specific Requirements: Different industries (e.g., manufacturing, healthcare, warehousing) have specific environmental regulations. Identify which federal, state, and local environmental laws apply to your business. Key federal regulations include the Clean Water Act (CWA), Resource Conservation and Recovery Act (RCRA), Clean Air Act (CAA), Emergency Planning and Community Right-to-Know Act (EPCRA), and National Pollutant Discharge Elimination System (NPDES).

• Consult State and Local Authorities: Environmental regulations can vary significantly by state and locality. Contact your State Environmental Protection Agency or local regulatory bodies to learn about specific requirements in your area.

2. Conduct a Compliance Audit

• Perform a Self-Audit: Conduct an internal audit of your facility's operations to identify potential environmental risks, chemical storage practices, waste management procedures, and air and water discharges.

• Use Checklists: Use compliance checklists specific to your industry to systematically review various aspects of your operations, such as chemical storage, hazardous waste handling, spill prevention, and stormwater management.

• Hire a Professional: If you're uncertain about the compliance requirements, consider hiring an environmental compliance consultant to conduct a professional audit and provide tailored recommendations.

3. Create a Chemical Inventory

• List All Chemicals: Compile a detailed inventory of all chemicals stored or used in your facility. Include information such as chemical names, quantities, locations, and Safety Data Sheets (SDS).

• Review Reporting Thresholds: Compare your chemical inventory against federal and state thresholds for Tier II reporting (usually 10,000 pounds for hazardous chemicals). This will help determine if your facility needs to submit a Tier II report.

4. Develop a Compliance Calendar

• Track Reporting Deadlines: Identify key reporting deadlines such as Tier II reports (March 1st), TRI reports (July 1st), and Biennial Hazardous Waste Reports (March 1st of even-numbered years). Use a calendar or software to track these dates to avoid missed submissions.

• Schedule Regular Inspections: Set up regular inspections for chemical storage areas, waste disposal practices, spill response equipment, and stormwater systems. These inspections help you stay proactive in addressing compliance issues.

5. Implement Proper Chemical Storage and Labeling

• Use Secondary Containment: Store chemicals in areas with secondary containment to prevent leaks and spills. Ensure containers are compatible with the chemicals they hold and are clearly labeled.

• Follow SDS Guidelines: Reference the Safety Data Sheets (SDS) for each chemical to understand proper storage conditions, handling precautions, and emergency procedures.

6. Develop an SPCC Plan (If Required)

• Determine SPCC Applicability: If your facility stores more than 1,320 gallons of oil products, you are required to develop a Spill Prevention, Control, and Countermeasure (SPCC) plan.

• Create a Spill Response Plan: Include details on spill response procedures, containment measures, and employee training. Regularly review and update the plan to ensure it reflects current operations.

7. Establish Hazardous Waste Management Practices

• Identify Hazardous Wastes: Determine which wastes generated by your facility are classified as hazardous under the Resource Conservation and Recovery Act (RCRA). Common hazardous wastes include solvents, cleaning agents, and certain chemicals.

• Segregate and Label: Store hazardous waste in designated, labeled containers and segregate them from non-hazardous waste to prevent cross-contamination.

• Use Certified Disposal Services: Work with certified hazardous waste disposal companies to ensure proper disposal and obtain documentation for your records.

8. Train Employees on Compliance Procedures

• Conduct Regular Training: Provide training on chemical handling, spill response, hazardous waste management, and emergency procedures. Training ensures that employees understand the importance of compliance and how to handle materials safely.

• Keep Records: Document all training activities, including dates, topics covered, and attendees. This documentation may be required during inspections or audits.

9. Maintain Accurate Records

• Document Everything: Keep detailed records of chemical inventories, waste shipments, spill incidents, inspections, and maintenance activities. Accurate record-keeping is crucial for compliance and can help during regulatory audits.

• Review and Update Annually: Review compliance documents, such as your SPCC plan, Tier II reports, and stormwater management plans, at least annually or when significant operational changes occur.

10. Stay Informed About Regulatory Changes

• Subscribe to Updates: Subscribe to newsletters from the EPA, state environmental agencies, and relevant industry associations to stay informed about changes in environmental regulations.

• Join Industry Groups: Participate in industry groups or associations that focus on environmental compliance. Networking with peers can provide insights into best practices and new regulatory developments.

11. Develop an Emergency Response Plan

• Outline Procedures: Develop a clear emergency response plan for incidents like chemical spills, fires, and leaks. Include procedures for evacuation, spill containment, and notification of authorities.

• Conduct Drills: Conduct regular emergency response drills to ensure employees are familiar with procedures and can act quickly in case of an incident.

12. Invest in Compliance Software

• Compliance Management Tools: Consider using environmental compliance software to manage permits, track chemical inventories, schedule inspections, and automate reporting. These tools can simplify compliance tasks and reduce the risk of missing deadlines.

13. Seek Professional Assistance

• Consult with Experts: If you're unsure about any aspect of compliance, consult with environmental compliance professionals. They can provide guidance, conduct audits, and help implement effective compliance strategies.

By following these tips, beginners can develop a solid foundation for environmental compliance, ensuring their business operates safely, sustainably, and in accordance with all applicable regulations.