在当前大流行,restricti旅行ons enacted and some working from home, regulatory compliance may be the furthest thought in your mind. However, this is a good time for a review of your facility’s written plans, programs, and procedures. These “desktop” reviews can identify gaps and allow incorporation of required information to bring the documents into compliance with current regulations and permit requirements.
When was the last time you reviewed the facility Spill Prevention, Control, and Countermeasure (SPCC) Plan; Notice of Registration (NOR) and waste management procedures; Stormwater Pollution Prevention Plan (SWP3); wastewater discharge and air permit reporting and recordkeeping requirements?
Desktop reviews can be customized to include one or more plan or program or even select areas of environmental regulations (federal, state, and local). A review of waste management could include written procedures for several processes: container management; labeling; inspections; waste tracking; and recordkeeping. The SWP3 and SPCC Plans can be reviewed to ensure all elements required by the permit/regulation are addressed. Wastewater discharge and air permits reporting and/or recordkeeping can be reviewed to verify that the facility is within its permit limits and adequately documented, recordkeeping logs are up to date, etc.
Depending on the scope of the review and availability of documentation, most of these desktop reviews can be completed within 3-4 weeks. A detailed report will identify areas where the plans/programs are deficient, provide a citation for reference, and include a recommendation for revision.
While these desktop reviews do not provide a comprehensive evaluation of a facility’s compliance as would typically be addressed in a regulatory audit, they can improve the written portion of the facility’s compliance program. Whether you remain at work at a facility included in the essential critical infrastructure or work from home, we can assist with maintaining compliance at your facility.
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