Environmental Engineering And Compliance Blog

Above Ground Storage Tank Inspection: Be Prepared

Joe Heaney — Thu, 23 Feb 2012 15:00:00 GMT

Above ground storage tank (AST) inspection is an inevitable part of life if you’re maintaining large supplies of regulated chemicals. Taking some simple steps will ensure you’re fully prepared when it’s time for your next inspection.

Local regulatory agencies require proper registration of tanks and they routinely conduct above ground storage tank inspections to check for compliance with County and State rules. If they discover you’re not in compliance, they can issue you a Notice of Violations that includes fines and other penalties. Fines can be as much as $1000 per day for non-registered tanks, or $10,000 per tank for other infractions.

Clearly it’s worth your while to ensure everything is in order before someone appears to conduct your above ground storage tank inspection.

Just follow these simple guidelines:

Register each tank with the appropriate agency. If you’re within New York City, that’s the New York State Department of Environmental Conservation (NYS DEC); otherwise it’s your County health department.
Properly label every container.
Color code every fill port.
Conduct your own monthly, quarterly and annual above ground storage tank inspection, and maintain thorough records of your inspections.
Post your operating permit in a prominent place.

Note that some automotive fluids distributors will provide ASTs at no charge, including installation, as long as you purchase the products stored inside exclusively from them. Be aware, though, that you are still responsible for obtaining the proper permits and registrations required for those tanks.

Advance preparation ensures you’re doing the right thing. It’s not only smarter, it’s usually cheaper and ensures fewer surprises or problems, so you have one less thing to worry about.

Photo Credit: Al Pavangkanan

How To Maximize Environmental Data Collection Efforts With An EDMS

Joe Heaney — Tue, 21 Feb 2012 17:38:00 GMT

In our fast-paced digital world remediation project success depends on effective environmental data management. For site managers, environmental consultants, field crews, and clients alike, success hinges on thorough and accurate environmental data collection at the outset of the project.

An environmental database management system (EDMS) can ensure every project gets off to the right start. It can especially useful to help your geologists, hydrogeologists and engineers significantly improve the speed and accuracy of their soil and groundwater data collection. Using an EDMS can streamline every step of your work process.

Specifically, an EDMS can help your team make the most of your environmental data collection in these ways:

An EDMS helps manage environmental data collection workflow. Allowing team members to work independently or together supports more efficient time management and speeds up the overall process.
You can collect and import data much faster, from a variety of sources, directly to a central database. Mobile devices eliminate the need for maps and hand-written notes, instead using the latest technology to provide web-based data collection and management. You can record and transmit data immediately, or store it for later upload if internet access is unavailable in the field.
You can increase data accuracy by eliminating hand-entry, duplicate input and potential transcription errors. This can also provide considerable labor savings.
You can use your database to build a legacy reference library. It’s easy to upload or enter existing historical data, then add new data as it’s collected.
Data is easy to access, even remotely, at any time. With immediate access to reports, you can view historical data in the field.
The system performs data checks and quality assurance right at the point of collection, and it maintains a complete and permanent audit trail, including GIS references, indicating specifically who collected what data, where and when.
GIS interface also works in tandem with an EDMS. This enables engineers and other technical staff as well as non-technical users to clearly see events, geographic features and changes to remedial conditions, all in a visual format.
You can use your data to create inventories, landowner records, visualizations, reports and other documents, charts and graphs.
You can easily track ongoing monitoring efforts or investigations, regardless of size or complexity. Collecting large quantities of separate data groupings, even in inconsistent formats or metrics, is no longer a problem, because the system automatically converts the data as necessary to assure straightforward, consistent comparison.

An environmental database management system provides a level of flexibility and an ability to integrate work processes previously unheard of. It can greatly enhance environmental data collection, by reducing collection time and field costs, increasing data quality, and maximizing how -- and how quickly -- data can be used.

Photo Credit: US Fish and Wildlife Service

NYC Community Right-To-Know Filing: Sara Title III Requirements

Joe Heaney — Thu, 16 Feb 2012 15:00:00 GMT

To help ensure employee, public and environmental safety, NYC Community Right-To-Know Filing and SARA Title III requires that certain commercial, industrial and even public facilities fulfill these obligations:

Annual Inventory.

Your facility must file an annual Tier II or Facility Inventory Form (FIF) if you:

Maintain on-site during the year 10,000 pounds or more of any EPA-designated hazardous chemical that also requires a Material Safety Data Sheet (MSDS) according to the OSHA hazardous chemicals list, or
Operate a retail service station that sells gasoline and/or diesel primarily to the public for motor vehicle use and also stores at least 75,000 gallons of gasoline or 100,000 gallons of diesel (total of all grades) on-site. You may qualify for a new threshold if you meet Underground Storage Tank standards continuously during the entire year.

Note that the more stringent NYC Community Right-to-Know law also requires annual filing if you have hazardous substances or Extremely Hazardous Substances (EHSs) in amounts that meet or exceed their specific Threshold Reporting Quantitys (TRQs) at any one time during the entire reporting year.

What to do? Submit a Tier II or NYC FIF by March 1^st of each year and also submit an MSDS for each reportable chemical or substance to the NYC Department of Environmental Protection (DEP) and the NYC FD by March 1^st.

Emergency Planning.

If any EHS at your facility is at or above the Threshold Planning Quantity (TPQ) at any time during the reporting year, you must participate in community emergency planning.

What to do? Send a letter to the State Emergency Response Commission (SERC), stating you are in compliance with relevant requirements. Designate a Facility Emergency Coordinator to participate in emergency planning and provide their name to the NYC DEP or Local Emergency Planning Committee.

Emergency Release Notification.

Should your facility have a spill or release of any Reportable Quantity, of an Extremely Hazardous Substance at or above TRQ, or of a hazardous substance listed in the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA), you must report the accident right away.

What to do? Call 311 immediately. You must also provide a letter to the DEP and SERC.

Toxic Chemical Release Inventory.

You must comply with this requirement if:

Your facility falls within SIC codes 20-39, and
You employ at least 10 people, and
You used at least 10,000 pounds of a reportable toxic chemical or you manufactured or processed at least 25,000 pounds of a reportable toxic chemical during the year.

What to do? Submit Form R to both SERC and the EPA by July 1^st.

If you’re uncertain about compliance or filing requirements, an environmental consultant can help with specific details or developing a comprehensive compliance program.

NYC Community Right-To-Know Filing: Do You Need To File?

Joe Heaney — Wed, 15 Feb 2012 17:24:00 GMT

The NYC Community Right-to-Know Program is a comprehensive effort to protect the public, employees and emergency responders from potentially harmful effects in the case of an accident. But lots of businesses use chemicals, and it can be confusing to know whether your business has to file a Community Right-to-Know Facility Inventory Form (FIF) each year.

If you fall into one of these business categories, it’s a good bet you are required to file:

Utilities, industrial or commercial enterprises must report electrical equipment that contains dielectric fluids.
Commercial buildings, businesses, hotels and nursing homes must report paints, solvents or other cleaning products that contain regulated substances.
Auto body shops and automobile service stations must report regulated substances if you handle, use, process or store them on site.
Material supply stores must report regulated substances only if they are sold in non-consumer packaging.
Dry cleaners must report DF2000, perchloroethylene and spot remover.
Funeral homes must report any flammable or carcinogenic substances.

Note that in all cases reporting is mandated only if a substance is present at or above official Threshold Reporting Quantity (TRQ) levels. The substance need only be present at that level one time during the year to require reporting.

To confirm you’re a candidate for Community Right-to-Know filing, consider these additional criteria:

To be reportable, substances must appear on the NYC hazardous substances list or the physical and health hazards special list. Be sure to check both lists before deciding a substance does not have to be reported.
The “at or above TRQ levels” standard applies to both pure substances and those present as an ingredient in mixtures.
To report mixtures, you must include the mixture name and chemical abstract services (CAS) number, if there is one, plus the names, CAS numbers and concentrations (by weight %) of each hazardous substance within the mixture. You only need to include the hazardous ingredients that meet or exceed TRQs for that mixture. To determine whether your ingredient meets this standard, multiply the concentration weight percentage by the weight of the total mixture, then compare your number with the TRQ list.

NYC Community Right-To-Know Filing Compliance Guide

Joe Heaney — Tue, 14 Feb 2012 17:01:00 GMT

Even if you’ve filed Community Right-to-Know reports in previous years, it pays to review the requirements, to ensure you understand the nuances and are properly prepared to report this year.

Before you start:

Know the difference between a pure substance, solution and mixture. Each has to be properly reported.
Know the correct format. You must use the entire name as it appears on the container label or Material Safety Data Sheet (MSDS), no abbreviations, and include the chemical abstract services (CAS) number.
Know how to fill out the Facility Inventory Form (FIF). For pure substances, the chemical name goes on the first line, and the CAS number goes in the top box. For mixtures, put the name on the first line, then write “see attached” on the next line and use a separate Mixture Component Form. Write the substance name and list each reportable ingredient by percentage and CAS number. Put as many as you can in each section, rather than listing each ingredient in a separate section.
Refer to the container label to find manufacturer name and address, trade or chemical name and CAS number, concentration (whether pure or for each hazardous ingredient) and physical or health hazards.
The MSDS will tell you chemical name and CAS number, ingredient concentrations if it’s a mixture, physical state and physical or health hazards.

Community Right-to-Know reports must include:

Each substance stored or used at your facility that appears on the NYC Hazardous Substance List or the physical and health hazards special list. It doesn’t matter if the substance is pure or in a mixture.
Substances must be reported if they’re present at or above the Threshold Reporting Quantity (TRQ) any time during the reporting year. For mixtures, you must list the name and CAS number (if any) and also each hazardous ingredient’s name, CAS number, and concentration if it’s at or above the TRQ within the mixture.
If you aren’t sure, multiply the ingredient concentration (weight %) by the entire mixture weight, then compare your result to TRQ requirements.
For ingredients not on the Hazardous Substance list, you can identify the TRQ for that mixture by checking the physical and health hazards special list.

If you’re feeling overwhelmed, discussing your situation with an environmental consulting professional can alleviate uncertainty and ensure your annual reporting and year-round compliance are being handled correctly.

NYC Community Right-To-Know Filing: Who Must Comply?

Joe Heaney — Mon, 13 Feb 2012 15:00:00 GMT

If you own or manage any industrial, commercial or public facility within New York City that stores, processes, uses or handles hazardous or extremely hazardous substances, you are required by law to comply with the NYC Community Right-to-Know Program. That includes filing an annual report.

Community Right-to-Know reporting is necessary if the hazardous substance(s) is at your facility in amounts at or above the established Threshold Reporting Quantity (TRQ) even once during the reporting year.

There are four major compliance categories:

Annual Facilities Inventory.

Every facility as described above has to file a Facility Inventory Form (FIF) by March 1 of each year. You’re also required to file a Material Data Safety Sheet (MSDS) for each chemical or substance, with both the NYC Department of Environmental Protection and the Fire Department.

Labeling.

Any facility that is required to file a FIF is also required to label all hazardous substance containers, including mobile containers, with the chemical or substance name and chemical abstract service (CAS) number. If the substance is a mixture, the label must contain the same information about each reportable ingredient.

Filing Fee.

All facilities must pay the appropriate fee at the time of filing, with a check or money order. You can file online and pay with credit or debit card, which can save time and eliminate the $20 fee for a hard copy reporting packet.

Risk Management Plan.

All facilities that work with hazardous or extremely hazardous substances in quantities that meet or exceed established guidelines are also required to prepare and submit a Risk Management Plan. This rule includes facilities that use regulated toxic substances. The plan must include detailed Risk Assessment, Risk Reduction Plan and Emergency Response Program information.

If you own or manage multiple facilities that meet Community Right-to-Know reporting requirements, you must file a report for each location.

You can find a comprehensive Hazardous Substances List, information about filing fees and Risk Management Plans in the NYC Community Right-to-Know Laws and Regulations booklet.

NYC Community Right-to-Know Filing: 6 More Reasons To File Online

Joe Heaney — Fri, 10 Feb 2012 15:00:00 GMT

If you own or manage an NYC-based industrial, commercial or public facility that processes, handles, uses or stores certain hazardous substances, the NYC Community Right-to-Know Program requires you to file certain reports each year. You have to file a Facility Inventory Form (FIF) for each location if you have multiple facilities.

It’s your responsibility to know the regulations and meet the March 1 filing deadline if your facility deals with substances defined as toxic, hazardous or extremely hazardous, or mixtures of potentially dangerous chemicals. For some chemicals, the Threshold Reporting Quantities (TRQs) are quite low.

Good news! You can submit your annual, revised or updated reports electronically.

The NYC Community Right-to-Know Program has streamlined their online reporting system so it’s more straight-forward and user-friendly. Government reporting is never fun, but online filing offers distinct benefits, such as these:

It’s easy. The system walks you through the process step by step.
It’s faster. The system offers drop-down lists for key information such as storage codes and inventory quantities, so you can just select and click rather than spending hours tediously typing the information into a form.
It’s more accurate. Using the drop-down lists eliminates the possibility of data entry typos.
It’ll be even easier next year. The system retains your previous reports, so you don’t need to re-enter the same information over and over. You can simply update your records.
It’s cheaper. You won’t have to pay the $20 fee for a hard copy filing package.
You can even pay online. The system calculates your filing fee and produces an invoice you can pay with a credit or debit card or e-check.

You may also choose to submit a computer-generated report instead of the official FIF, as long as it contains all the required information and follows the FIF format.

First-time users need to register with the system, to acquire a unique username and create a password. From then on, any authorized user can tap into the system at any time to review information that’s been submitted in the past and to file new reports. “Authorized” users can be owners, operators, managers or corporate officers.

Is the NYC Community Right-to-Know filing deadline on your calendar? Online filing is certainly easier, but you still don’t want to wait till the last minute.

NYC Community Right-to-Know Filing: 6 Reasons To File Online

Joe Heaney — Thu, 09 Feb 2012 15:55:00 GMT

Good news! You can submit your annual, revised or updated reports electronically.

It’s easy. The system walks you through the process step by step.
It’s faster. The system offers drop-down lists for key information such as storage codes and inventory quantities, so you can just select and click rather than spending hours tediously typing the information into a form.
It’s more accurate. Using the drop-down lists eliminates the possibility of data entry typos.
It’ll be even easier next year. The system retains your previous reports, so you don’t need to re-enter the same information over and over. You can simply update your records.
It’s cheaper. You won’t have to pay the $20 fee for a hard copy filing package.
You can even pay online. The system calculates your filing fee and produces an invoice you can pay with a credit or debit card or e-check.

You may also choose to submit a computer-generated report instead of the official FIF, as long as it contains all the required information and follows the FIF format.

Is the NYC Community Right-to-Know filing deadline on your calendar? Online filing is certainly easier, but you still don’t want to wait till the last minute.

NYC Right-to-Know Filing: Hazardous Substances That Must Be Reported

Joe Heaney — Wed, 08 Feb 2012 14:30:00 GMT

The New York City Right-To-Know Program is all about hazardous substances. The point of the program is to ensure the best possible protection of employees, public health, the environment and emergency responders in the case of a spill, fire or other crisis.

Toward that end, industrial, commercial and public facilities that process, use, handle or store hazardous substances must file an annual report with the NYC Department of Environment Protection. There are several parts to the Community Right-to-Know report, but the key consideration is understanding which substances are considered hazardous. For reporting purposes, those are described in the compliance literature as:

Gasoline stored at retail gasoline stations in excess of 75,000 gallons.

Diesel fuel stored in retail gasoline stations in excess of 100,000 gallons.

Substances present in research laboratories, hospitals and other health care facilities which are not regulated by the federal Food and Drug Administration. This is a New York City Law.

Substances contained in mobile storage tanks.

Hazardous substances must be reported whether they are pure or present as an ingredient in a mixture, as long as they meet or exceed the specific Threshold Reporting Quantity (TRQ) for that substance. The TRQ level only has to be reached once during the entire reporting year to meet the reporting requirement.

A search of the NYC Hazardous Substances List, which is part of the Community Right-to-Know Laws & Regulations booklet, will help identify which substances must be reported. The NYC physical and health hazards list also identifies hazardous substances.

5 Community Right-to-Know Filing Guidelines for New York City

Joe Heaney — Tue, 07 Feb 2012 14:30:00 GMT

Every year on March 1^st, facilities within New York City that store or use hazardous substances are required to file reports with the City’s Department of Environmental Protection. These Community Right-to-Know (RTK) filings are designed to facilitate accumulation and rapid access to detailed information necessary to protect the public and emergency responders.

Community Right-to-Know filing is mandatory, and all industrial, commercial and public facilities must participate.

RTK guidelines stipulate five filing requirements:

Reporting hazardous substances stored or used at the facility, if amounts meet or exceed Threshold Reporting Quantities (TRQs) any time during the reporting year. A comprehensive NYC Hazardous Substances List can be found within the Community Right-to-Know Laws & Regulations packet. Hazardous substances are categorized as toxic, hazardous or extremely hazardous.

Listing any mixture containing hazardous substances. You must note the type and quantity of each hazardous component. More information on this is available in the Laws & Regulations packet, chapter 41-05.

Providing a Material Safety Data Sheet (MSDS) for each hazardous substance or mixture reported on the Facility Inventory Form (FIF). These have to be submitted to the Department of Environmental Protection, the NYC Fire Department and the State Emergency Response Commission (SERC). MSDSs only need to be provided to the SERC once.

Labeling hazardous materials containers. Labels must show the chemical abstract service (CAS) number and chemical name. If it’s a mixture, all ingredients must be identified by name and CAS number.

Maintaining MSDS copies on-site. This facilitates employee access for safety education and reference, ensures documents are readily available if an inspection occurs, and makes it easier to submit required updates.

Community Right-to-Know filing guidelines are reasonably straight-forward. However, facility owners and managers often find it useful to obtain professional assistance with this process, to ensure all requirements are fully understood and help guide gathering and organization of information required to complete the filing.

NYC Community Right-To-Know Filing Instructions

Joe Heaney — Mon, 06 Feb 2012 17:58:00 GMT

Filing a NYC Community Right-to-Know annual report is the same under both Federal and City law. For multiple facilities, you must file a separate report for each location.

The Facility Inventory Form (FIF) requires you to provide the following Community Right-to-Know information:

Owner/ operator name and contact information.
Emergency contacts, including a 24/7 phone number. This is critical.
Chemical description – list different states (solid, liquid, gas) separately.
Chemical abstract services (CAS) number.
You may claim a “trade secret” if you need to withhold the identify of a substance, but for “proprietary” information, you must get the formulation from the manufacturer.
Physical and health hazards – you’ll find this information on the container label or Material Safety Data Sheet (MSDS) for that chemical. Hazards include fire, sudden release of pressure or reactivity and may cause acute (immediate) or chronic (delayed) response.
Inventory – you have to report all amounts in pounds. Multiply the volume by the density to get weight for liquids or gases. For each substance, you must also indicate estimated maximum and average amounts present at your facility during the year, number of days on site (for the entire year use 365), storage location(s), storage code(s), container type(s), pressure and temperature.
Certification – the owner, operator or another officially designated person must personally sign the submission. Filings with stamped or photocopied signatures will not be accepted. If you use a consultant to prepare your filing, you still must sign it yourself.

You must pay a fee along with filing your report. Fees are determined by a matrix that takes into account the total number of hazardous substances you report, the highest maximum amount you report for any one substance, and whether any substances you report fall into the extremely hazardous category and were present at or above Threshold Reporting Quantity levels.

For many owners and facility managers, using a consultant to prepare Community Right-to-Know filings isn’t such a bad idea. You can get help from someone knowledgeable about chemicals, their coding and specific attributes. An environmental consultant is also very familiar with all the nuances of Community Right-to-Know and can help ensure your compliance procedures and filings are thorough.

Whether you hire a professional or do it yourself, if you haven’t started to prepare your 2012 RTK filing, now would be a good time to start. The deadline is March 1^st.

OSHA Inspection Process: What To Expect?

Joe Heaney — Thu, 02 Feb 2012 15:00:00 GMT

The OSHA inspection process strikes fear into the hearts of business owners and managers. But if you know what to expect there’s no reason to cower.

The OSHA inspection process reflects five priorities, in this decreasing order of severity:

Imminent danger. OSHA can do a “wall-to-wall” inspection in this instance, and they can shut down your facility.
Catastrophes and fatal accidents. This is triggered by an occupational accident resulting in death or at least three employees being hospitalized. You have eight hours to report this.
Complaints and referrals. The most common, these are generated by employees, neighbors, doctors, police, even other agencies such as DOT or EPA. Inspections may only include the area where the violation is alleged to be occurring.
Programmed inspections. Inspectors visit workplaces reporting unusually high incidence of injury-related lost-work days.
Follow-up inspections. Previously cited workplaces are re-inspected to confirm compliance.

OSHA doesn’t usually announce their arrival. Be prepared by:

Knowing your responsibilities. You can conduct a mock audit yourself or have a consultant conduct one for you. Conducting a mock audit helps you detect problems and your mock audit cannot be used against you, now or later.
Making sure your employees fully understand required policies and procedures, especially about HAZCOM. You must maintain complete training records.

If they come:

Verify the inspector’s credentials, a DOL identification card.
You don’t have to let them in, but they can return with a search warrant.
They must state the inspection reason. Unless it’s imminent danger, their authority is limited to the specific area in question. Lead them directly there.
The OSHA inspection process allows them to talk to your employees and see your HAZCOM training records. Do not offer them anything else.
The inspector will discuss findings with you, but not potential fines. Correct problems immediately, if you can.

If there are violations, OSHA will mail you a citation letter explaining details and the fine. Post your citation in a prominent place for the length of time specified. Fine amounts vary, but willful violations, where you knew about but ignored problems, are the most costly.

The OSHA inspection process allows you to simply pay your fine, request an extension or appeal the fine, formally or informally. Since the point is to create a safe workplace, an informal appeal can sometimes underscore your desire to do the right thing by making corrections rather than arguing. In some cases, this may significantly reduce your fine.

Community Right-to-Know vs Hazardous Communication

Joe Heaney — Tue, 31 Jan 2012 15:00:00 GMT

The details of Community Right-to-Know (RTK) and Hazardous Communication (HAZCOM) both affect how your facility functions.

HAZCOM is one of OSHA’s most important compliance requirements. Its education, training, chemical labeling and safety programs are all designed to increase workers knowledge and understanding, to protect them from exposure to potentially dangerous substances.

HAZCOM compliance includes creating and maintaining a binder that contains a material data safety sheet (MSDS) for every chemical product processed, stored or used at the facility. MSDSs are used to educate workers about what protective clothing or other precautions are needed as well as how to quickly deal with accidental exposure.

For example, workers in an auto body shop may potentially be exposed to harmful spray paint vapors if the ventilation equipment fails or is insufficient. In this case, workers can refer to the appropriate MSDS to determine how to protect themselves using respirators, etc.

Community Right-to-Know takes a broader view.

Whereas HAZCOM focuses on the workplace, RTK focuses on the community at large. Its purpose is to protect people, property and the natural environment from exposure to toxic chemicals during emergency situations. To do that, RTK requires all commercial, public and industrial facilities to take certain ongoing inventory and safety steps.

As with HAZCOM, Community Right-to-Know requires facility managers to maintain an MSDS for each chemical product stored or used on site. In addition, managers must maintain a complete chemical inventory, and file a detailed report with the New York City Department of Environmental Projection and the NYC Fire Department every year on March 1. The chemical inventory should include:

Chemical name
Amount stored
Substance characteristics (delineated by MSDS)
Safe treatment and handling methods
Potential negative health effects

Community Right-to-Know is based on the belief that education, training and precautionary measures greatly lessen the chance of accidents. And it promotes a clear and complete knowledge of where chemical products are located and in what quantities, enabling emergency responders to know what to expect in advance so they can be best prepared to deal with whatever situation arises and remain safe themselves.

Photo Credit: Tatiana Gerus

Annual Community Right-to-Know Filing Made Easier

Joe Heaney — Thu, 26 Jan 2012 15:00:00 GMT

New York City’s Community Right-to-Know (RTK) Act requires all commercial, industrial and public facilities that store or handle certain types and amounts of hazardous substances to inventory and track those chemicals and file an annual report.

The Community Right-to-Know filing process can seem overwhelming, but it doesn’t have to be. Here are some basic definitions to help you navigate the jargon:

MSDS: Material Safety Data Sheet – information about industrial chemical products including hazards, safety and emergency procedures.
FIF: Facility Inventory Form – one of the RTK reporting documents.
CAS: Chemical Abstracts Service – they maintain a registry of chemicals and assign a unique ID number to each one.
TRQ: Threshold Reporting Quantity – these levels determine whether or not you need to track and report on specific chemicals or products.
DEP: Department of Environmental Protection.

Penalties for failure to report can be significant, up to $20,000. So here are some tips to help you file as painlessly as possible:

OSHA requires you to create and maintain an up-to-date MSDS binder that’s readily accessible within your facility. This supports your RTK filing, too, because needed chemical information is right at hand.
You also need to maintain a current inventory of all chemical products that enter your facility. Updating your inventory will be easier if you clearly label everything, including compressed gas canisters and storage tanks. Good labeling is also important for safety.
Store similar chemical products together. Better organization facilitates faster inventory, especially if you keep storage areas clear and dispose empty boxes or other containers.
Community Right-to-Know specifically requires reporting of any “especially hazardous substances” in your inventory that appear on the Threshold Reporting Quantity (TRQ) list. If you use any of these chemicals in quantities over the designated “threshold” level, you must also create and submit a Risk Management Plan that explains your risk assessment program, risk reduction program and emergency response program.

Here’s some great news. It’s easy to register and file online, even if you have multiple facilities (you file separately for each one) and whether you’re filing an annual, revised or updated. The system is designed to facilitate filing by using drop-down lists to eliminate typing, and it retains your information to make future submissions even faster and easier.

Photo Credit: Sean McGrath

NYC Community Right to Know Act: Why Do We Do It?

Joe Heaney — Tue, 24 Jan 2012 15:00:00 GMT

In the 1970’s, the public began to express increasing concern about the health of our natural environment as well as potential dangers to human health resulting from exposure to hazardous wastes and other toxic chemicals released by catastrophic events.

These concerns generated significant changes in public policy, government regulation and related industry practices. By the late 1980’s, Congress had passed legislation called the Emergency Planning and Community Right-to-Know Act (EPCRA), to ensure better preparation for potential disasters and further protect human health and our environment.

Local regulatory agencies, such as the New York City Department of Environmental Protection (NYC DEP), followed with their own Community Right-to-Know (RTK) regulations. These were specifically aimed at better safeguarding the health and safety of people and property in NYC, along with the local environment, against exposure to hazardous substances from fire, hazardous chemical spills or other releases.

The importance and value of NYC’s Community Right-to-Know Act were underscored in a horrendous way when the now-infamous 9/11 attacks occurred. The resulting building collapses and fires released a number of hazardous substances into the environment, exposing hundreds of emergency response personnel.

The Community Right-to-Know Act requires all NYC public, commercial and industrial facilities that handle hazardous substances to file an annual report detailing what chemicals and related products they store or use at their facility, and in what quantities. This information is used for emergency planning, risk identification, and the prevention and control of fires, accidents and spills, to protect both response personnel and the general public in the case of fire, spill or accidental chemical release during or after any kind of emergency.

To busy facility managers, the annual RTK filing may seem like just one more time-consuming business regulation. But in fact we are protecting the health of both our community and our environment.

Photo Credit: Kevin Dooley

3 Reasons You May Need An Environmental Database Management System

Joe Heaney — Thu, 19 Jan 2012 14:00:00 GMT

You’ve probably heard or read about environmental database management systems (EDMS). But maybe you aren’t at all sure adopting this new technology makes sense for your operation.

Consider the following three scenarios:

You represent a large company or agency responsible for multiple environmental stewardship efforts and/or projects designed to establish, determine and manage remedial options.

You generate impressive amounts of hydrogeologic and chemistry data – measurements and observations as well as research. You need to “work” your data on a project-by-project basis, but it would be most helpful if you could also archive it for future reference.

The people you oversee and report to are geographically widespread, but everyone needs access to the data and analyses you’re developing. And different players need to extract different information in different formats.

You manage a smaller operation or consulting firm, but the work you do is much the same as the larger-scale scenario described above. You don’t have the resources or consistent need to justify in-house procurement of an extensive new database management system.

You operate a lab or small consultancy. Among other things, you’re responsible for reporting data regarding spills, remediation efforts and so on to NYSDEC. You must adhere to their strict electronic reporting format, but it takes time and can be frustrating to get things done right.

One of these scenarios probably describes your working environment. And as it turns out, whether you’re conducting site assessments or groundwater and soil investigations, striving to comply with regulations surrounding fuel oils or chemical storage, or providing scientific support to other environmental health professionals, you could benefit significantly by implementing an environmental database management system.

Here’s why.

Typically within the environmental industry, science-based consulting teams work alongside private enterprise or public administration-based owners and managers to identify problems and design effective solutions. Facilities and property managers need to analyze and condense findings into documents and graphics on which to base near-term decisions and long-term management planning.

Consultants need to keep clients, civic leaders or other decision-makers in the loop with documents they can readily understand. Sometimes you have to produce graphics in the form of 3D visualizations to support litigation, remediation plans or risk analysis. And you may have to meet a variety of regulations governing facility operations as well as reporting requirements.

Your work product has to be entirely accurate, completed as quickly and cost-effectively as possible. Reliable results are crucial, because your reputation depends on quality.

An environmental database management system provides a comprehensive interface that bridges potential communication gaps to smoothly coordinate and speed up your work process and produce better results.

Detailed customization makes handling even the most complex projects a snap compared to traditional methods, even when each project varies in scope and scientific details. An EDMS enables permanent data archiving to plot remediation progress or identify trends. You can upload and store historical data, too, building a truly useful resource library.

An EDMS eliminates the need for time-consuming “clerical” work such as data entry and conversion, and assists with calculations for cost estimates. And it can assure your reporting submittals are always correctly formatted.

Embracing an environmental database management system can be a budget-friendly business decision.

Whether in-house or outsourced, converting to an EDMS can provide substantial savings. Saving labor saves money. And allowing skilled personnel to focus on skilled tasks helps improve job satisfaction, reducing the risk of costly turnover.

Ultimately, an EDMS produces efficiencies that translate into shorter project turnaround. You’ll be able to take on more work and generate more revenue.

Photo Credit: Highways Agency

Environmental Database Management System: Do You Need One?

Joe Heaney — Tue, 17 Jan 2012 18:13:00 GMT

If you’re in the business of dealing with environmental concerns, you’re working with a stunning amount of data. And whether you’re responsible for determining if remediation is needed or using site investigation results to make property management or legal decisions, your success depends on accurate, thorough data analysis.

Using an environmental database management system (EDMS) can provide comprehensive efficiencies for every stage of your work, from data capture and long-term storage to retrieval, reporting and analysis.

Just as the name implies, environmental database management systems are specifically designed to handle the kinds of complex projects that engineers, geologists and hydrogeologists typically tackle, even projects of the greatest magnitude. But perhaps the most outstanding value of an EDMS is its ability to facilitate faster and more accurate data analysis.

Streamlined processes support better analysis in several ways:

With a centralized environmental database management system in place, everyone associated with each project can easily and immediately access exactly the information they need, in reporting formats that make the most sense for them, from virtually any location.
Field data is electronically uploaded and metrics are automatically converted as necessary for consistent comparison. This is a huge time-saver, eliminating the need for extensive, tedious and costly data entry. Instead, highly trained technical staff can concentrate on using their knowledge and experience to find creative or innovative solutions to the problem at hand.
Removing the possibility of human error also ensures greater accuracy.
Standardized reporting enables all project stakeholders to clearly understand the issues revealed by soil or groundwater investigations as well as more easily compare potential solutions.
Using an EDMS provides confidence that your firm is correctly adhering to variable reporting criteria and other compliance requirements.

An environmental database management system enhances data analysis by allowing you to:

Pose highly customizable, detailed queries to elicit precisely the information you need.
Quickly generate detailed reports.
Identify variances or other anomalies that may pinpoint problems or affect potential solutions.
Perform specific calculations to help you compare possible resolution options.

In particular, varied EDMS reporting formats enable:

Creation of charts, graphs or other two-dimensional presentations.
Generation of visualizations in a variety of GIS, contouring or 3D presentation formats. Modeling can be especially helpful for all project team members, from engineers and other technical professionals to site owners, project managers and regulatory officials, more easily grasp the problem at hand.
Immediate mapping of analytical results, taking the hassle out of making changes and illustrating revised results.

Anyone who works in a science-based field or uses hard data to formulate action plans can readily appreciate the value of innovative technology. The accelerated data processing and reporting provided by an environmental database management system can substantially shorten project turnaround while actually boosting analytical quality, ensuring better-informed decision making.

Better-informed decision makers enables best solutions. And completing the assessment process faster conserves money and other valuable resources.

Analyzing data is the keystone of every job that relates to discovery or remediation of environmental concerns. An environmental database management system is the best tool available to strengthen, streamline and expedite your work, from initial data collection in the field to development of each project’s final resolution.

Environmental Database Management System vs Traditional Records Storage

Joe Heaney — Thu, 12 Jan 2012 14:00:00 GMT

We work in an increasingly technology-based world, where people concerned with environmental stewardship or remediation are learning that an environmental database management system (EDMS) can make their work faster, more accurate and more productive.

In fact, an EDMS proves that innovative automation can provide myriad improvements over traditional environmental records storage and retrieval.

The traditional way is ponderous.

Generating lots of paper – documents, data, large maps, photos, etc. – requires lots of physical storage space and can make review unwieldy.
Only one person or co-located group at a time can view data, reports, etc.
Because data is usually quite complex, it’s not always clear to non-technical project stakeholders or decision makers. You often have to re-purpose technical reports for presentation to non-technical decision-makers or other stakeholders, or for use as courtroom testimony, etc.
Doing everything by hand devotes countless hours to clerical work and arithmetic calculations, driving up labor costs, inefficiently deploying highly skilled technical staff, and increasing risk of human error.
Often data isn’t retained except as needed for each project, frustrating potential opportunities for cross-program assessments, long-term tracking, identification of broader trends, etc.
Lengthy project turnaround time can cause considerable delay in completing remediation or other work. Time is money for everyone concerned, especially when work needed to resolve problems can cost millions.

An EDMS helps your team work smarter and faster.

An environmental database management system supports every stage of your work, including comprehensive permanent archiving.
Because everything is 100% digital, it’s easy to quickly capture and store even more field data, photos, etc. There’s no need for conventional mapping and logging because photos can be used to generate contouring and other dimensional visualizations. The ability to gather and retain more information also expands long-term learning opportunities.
An EDMS supports off-site project management by enabling multiple points of contact at every step. Everyone has nearly real-time access to field data and can easily generate customized reports, from anywhere, any time. And the wide range of 2D, 3D and GIS reporting and presentation alternatives allows all team members to clearly visualize site conditions.
Consistent collection and storage enables broader and more productive use of data, including establishment of a legacy data repository. Standardized deliverables make comparison of analytical results easier and help you meet important compliance requirements.
It’s easy to add new data, so you can easily identify and assess alternative potential resolutions and estimate costs.
EDMS-assisted conversions, calculations and analysis produce more reliable data, improving your ability to identify anomalies, plot trend analysis and establish more definitive baselines.
Accelerated data review and evaluation enables earlier decisions for remedial action. It shortens turnaround of data availability and lowers labor costs.

In essence, an environmental database management system combines the best of traditional methods with the latest technological advances. The EDMS helps conduct much of the factual analysis, so the humans on your project team can focus on “thoughtful” analysis using their specialized education, training and experienced insight.

An environmental database management system provides numerous significant benefits over traditional records storage. Working faster yet more accurately assures more cost-effective investigations as well as solutions.

Remedial actions can be completed sooner, and possibly more thoroughly, assuring better long-term care of the environment. And cost efficiencies enable all parties to operate in a more business-like manner, producing much stronger ROI for both private and public entities.

Using An Environmental Database Management System To Stay Organized

Joe Heaney — Wed, 11 Jan 2012 20:39:00 GMT

Engineers, geologists and hydrogeologists simply have to be well-organized. You’re handling massive amounts of data that has to be recorded, analyzed, compared and reported in any number of different formats. Everything has to be filed for easy access as well as long-term safe-keeping.

An environmental database management system (EDMS) is essentially a centrally located electronic file storage unit with virtually unlimited capacity for expansion. But unlike traditional physical filing systems, the electronic nature of an EDMS makes data immediately accessible by anyone who needs it, regardless of where they’re located.

And with an environmental database management system, storage is just the beginning. It also supports project management, data analysis and evaluation of solutions options. Here are some ways an EDMS can help you stay organized:

It functions as a storage and resource library that houses both historical and incoming data. Once historical data is entered it’s available to anyone, forever. And newly acquired field data can be automatically uploaded, electronically, so it’s available right away.
Chances are you’re juggling multiple projects and your colleagues are located at multiple (perhaps even far-flung) sites. And different users need different information for different purposes. An EDMS allows you to use and share files simultaneously. Anyone can instantly retrieve existing reports or create new ones.
Information is always right at your fingertips. An EDMS allows easy, quick access to information.
An environmental database management system streamlines work processes, helping you achieve more effective time management. You don’t have to hunt down what you need. You won’t inadvertently overlook or miss important data because it’s out of place or in someone else’s hands.
An uncluttered working environment helps you think more clearly and focus on the most important activities, so you can work more productively and get your work done faster.
Whether you’re working in a commercial or public agency environment, you’re better able to serve potential clients or your own constituents if you’re efficiently organized. You’ll be fully prepared and poised for action, regardless of the impending scope of work.
An EDMS even helps keep your budget organized, by reducing wasted time and making the best use of limited resources. And you won’t have to pay for hard-copy filing supplies or constantly-growing need for physical file cabinets and storage space.

Especially when you’re working with scientific data and the resulting complex reports, staying organized is critical. Effective organization helps you produce a better work product. And it can save you time, money and -- some days -- even your sanity.

An environmental database management system can help you create efficiencies and manage your work in ways you never thought possible.

Benefits of Analysis with an Environmental Database Management System

Joe Heaney — Tue, 03 Jan 2012 13:00:00 GMT

When you’re performing site assessments, groundwater or soil investigations, or working to meet regulatory remediation compliance requirements, each of your jobs is different. But they’re all highly complex. An environmental database management system (EDMS) can help you clearly see the character and extent of each problem and better evaluate your options, so you can design the most effective solutions.

Digital technology is becoming the norm for environmental analysis. An EDMS represents automation at its best, using innovative technology specifically tailored to your needs, to capture, store, query, analyze and visualize information.

An environmental database management system allows you to:

Save time. Import data in minutes, and free up engineering and other professional staff to focus on more productive activities.

Save money. An EDMS is affordable and cost-effective to maintain and manage.
Strengthen collaboration. Widely dispersed colleagues can easily retrieve, sort and analyze information in formats they can readily understand and use.
Produce better results. An EDMS can handle projects of any size or complexity, eliminating human error and offering extensive customization and flexibility.
Produce faster results. Produce lightning-fast analytical results you can rely on, to evaluate and compare potential solutions sooner and more effectively.

An EDMS is an intelligent and powerful working partner that provides:

Automated upload of field and lab data and efficient migration of historical data from varied sources in varied formats.
Storage and organization of voluminous data.
Easy information access.
Data conversion into consistent units.
Quick, easy visualizations in 2D, GIS or 3D.
Ability to design highly specific queries or generate customized reports in minutes.
Assistance with data review and interpretation and calculations.
Automatic detection of variances outside required guidelines.

Environmental database management systems are particularly valuable for geologists, hydrogeologists and environmental engineers whose responsibilities combine extensive field work with equally extensive data analysis and reporting, often to non-technical colleagues. That includes:

Entities with extensive historical information in differing formats that needs to be consolidated and/or multiple reporting sites whose data needs to be easily accessible by various decision-makers.
Environmental consultants that need centralized data storage and access but don’t have the resources to support an in-house system.
Labs or consultants who report to NYSDEC or other state and federal regulating agencies and need assistance producing submittals in required formats.

Implementing an environmental database management system makes good business sense.

The right EDMS stores and organizes data and helps you quickly and efficiently produce comprehensive analytical results that are reliably accurate and easy to understand.

It can create significant efficiencies, making far better use of staff resources and boosting your bottom line (or keeping you within budget constraints). Once you acquire an EDMS, you may well wish you’d converted sooner.