Even in a time of ever-tightening budgets and
the need to do more with less money and fewer staff members, the necessity for
compliance with environmental regulations never eases. In some instances, the
requirements for compliance have even increased in the form of new regulations,
despite the reduced resources to deal with environmental issues.
Environmental managers are faced with this stark reality every day. For
many, this means putting non-compliance-related environmental initiatives on
hold as resources are focused on maintaining compliance. Across the U.S. and
the world, construction/expansion activities have all but halted, as have the
related environmental permitting and compliance challenges.
While this results in a workload reduction, hiring freezes and
restrictions on the use of outside resources-combined with the increasing
regulations facilities must comply with-often result in an over-worked
environmental staff. What can manufacturers and environmental managers do to
bridge the gap between budget constraints and environmental stewardship?
Make Compliance a Part of the Business Model
Environmental regulations can make or break a project. If business
planners don’t take into account the timing required for permitting and the
cost of potential pollution control devices, the unanticipated costs associated
with regulatory compliance could kill a project. It is imperative to involve
the environmental staff in the planning phases of all projects.
Some environmental permits can take years to obtain and are often required
before construction can commence on a project. In addition, regulations can
drive a proposed project in a different direction once the costs of
environmental regulatory compliance are taken into account.
For example, the use of a less-expensive fuel in a proposed boiler may
look advantageous until it becomes evident that the pollution control equipment
capital and operating costs required by environmental regulations would more
than offset any cost savings. Making compliance analysis part of the up-front
consideration in a business or project allows analysis of options to maximize
operational flexibility and minimize environmental regulatory compliance costs.
Focus on Compliance
With
all the “green” initiatives and buzzwords propagating through trade
organizations, conferences, the media and society in general, it’s easy to get
caught up in the green tidal wave. If environmental compliance slips, however,
the cost savings and positive public relations associated with green
initiatives will quickly disappear. In fact, the less-touted aspect of
environmental compliance is included as a cornerstone to most green initiative
programs such as sustainability and environmental management systems. Green
initiatives cannot succeed where compliance is allowed to slip.
Stay Current with Environmental Regulations
Keeping up to date on regulations can be done
in-house or with outside assistance. Trade organizations often include
environmental outreach programs that help members stay current on existing
environmental regulations, as well as proposed or upcoming regulations that may
affect the industry. Larger companies may maintain a staff that follows
environmental regulatory changes as they apply to the business.
However, in a down economy and at a time when regulations are changing with
increasing frequency and scope, it can be difficult to adequately staff an
environmental department. A relationship with a good environmental consultant
can therefore often prove invaluable.
A good consultant provides expert advice on an as-needed basis without
the expense of a larger full-time environmental staff. These consultants can be
a source of information and advice that can save manufacturers and projects
money in the long run. Not having the latest information or understanding
regarding proposed or upcoming regulations can lead manufacturers down a costly
path of misappropriated funds, poor business plans, and wasted staffing and
economic resources.
Maintain a Good Relationship with the Environmental Agency
Agency personnel respect and trust in the
relationships that they build with regulated entities, which can often result
in counseling vs. penalties in a compliance situation. Manufacturers can
arrange meetings with agency personnel prior to a permit application process to
learn of the most up-to-date agency policies and procedures and the preferences
of the key agency staff members.
In addition to building the relationship between the manufacturer and
agency, these meetings can reduce the time and costs associated with the
rigorous process of developing an application by specifically focusing on the
items discussed during the session and ensuring that all of the necessary
information that would be requested is included in the application. By
maintaining a good working relationship with the environmental agency and
viewing compliance as a shared goal, manufacturers can protect themselves from
or minimize compliance enforcement actions.
Environmental Management Systems
Companies and organizations are being
scrutinized for their environmental practices, and “going green” has become
more than the politically correct thing to do-it’s good business. Not only do
customers demand good environmental practices, but company directors want to
avoid negative environmental publicity and employees prefer working for green
companies. In addition, good environmental plans and practices reassure
investors and insurers alike.
An environmental management system (EMS)
program helps a manufacturer evaluate its specific requirements. Once the
proper level is identified, a program can provide a plan for
compliance success and reinforce commitment. Environmental assessments and
audits are critical measurement tools of any EMS, but the development of an EMS
program does not have to be a daunting task. The EMS
program should be viewed as a series of levels or steps, ranging from the most
basic to a full ISO 14001 program. In addition, many states sponsor
environmental excellence programs that may offer greater flexibility in
permitting, more leniency in compliance situations and a measure of goodwill in
the community.
Auditing
Audits are the critical measurement tools of
any environmental management program. Audits conducted by an outside entity are
useful tools for gauging the effectiveness of the organizational structure and
management’s involvement in facility environmental affairs. A thorough audit
will assess compliance with specific permitting and regulatory requirements, as
well as “best management practices” currently utilized or that could be used to
improve the overall environmental program.
Audits allow a company to prioritize or triage its environmental efforts so
that resources can be efficiently allocated. In addition, the U.S.
Environmental Protection Agency (EPA) not only encourages audit programs, but
provides enforcement discretion for self-reporting infractions that are noted
during audits.
Training
One of the most important things
manufacturers can do for their employees is to educate them. Proper training
can mean the difference between low company insurance costs or high premiums, a
competitive EMR rate or a loss of potential work, or-at worst- the life or
death of an employee. It is important that manufacturers know which regulations
require training (including frequency and trainer credential details) and which
training records must be maintained.
A comprehensive training assessment allows a company to determine
training needs. Manufacturers can save money and time while increasing employee
morale by providing effective and function- and audience-specific regulatory
training. Appropriate training, including environmental compliance training,
can greatly improve employee efficiency and effectiveness, and reduce the costs
of lost work time and compliance enforcement fees due to material mishandling
or lack of proper documentation.
Sustainability
As with EMS, sustainability efforts should
focus on identifying and implementing measures that provide the greatest
benefit with the least cost, particularly in a tough economic climate. These
efforts offer an opportunity for environmental personnel to identify projects
that will save resources and operating expenses through the elimination of
waste.
In some instances, sustainability programs using analysis tools like
life cycle assessment (LCA) have even driven product development. For example,
a laundry detergent manufacturer conducted an LCA that showed that the
company’s largest environmental impact was in laundry detergent, due to the
energy used for heating the water during the wash cycle. This analysis led the
manufacturer to develop a cold-water detergent line, which is environmentally
responsible and offers consumers cost-reduction opportunities from energy (an
indirect cost savings that notably does not affect the company’s bottom line).
Sustainability is increasingly important in balancing environmental budgets by
allowing for cost savings in risk reduction, as well as lowered operating
expenses associated with asset management.
Prioritize Efforts
Manufacturers
and environmental managers faced with tight budget constraints, smaller staffs
and an ever-growing and ever-changing list of environmental regulations are
forced to prioritize environmental efforts. Following a few simple
recommendations can provide enhanced environmental compliance, even in the
toughest of economic times.
For additional information, contact Aegis
Environmental, Inc. in Virginia at 211 Ruthers Rd., Suite 202, Richmond, VA
23235; or in Florida at 731 Duval Station Rd., Suite 107-315, Jacksonville, FL
32218; call (800) 675-1220; fax (804) 675-1240; e-mail kbonds@aegisenv.com; or visit www.aegisenv.com.Links
