Have you ever wondered what environmental auditors usually discover during their assessments? Having conducted hundreds of environmental audits, I have consistently identified 10 common findings at almost every facility. All these findings have regulatory, environmental, safety, and liability risks in common and should be addressed appropriately.
1. Outdoor housekeeping issues, especially along loading docks and trash collection areas
Poor housekeeping practices can expose the environment to pollutants such oils, lubricants, leaking or spilled chemicals, trash and debris. These pollutants can be washed into storm drains and water bodies during rain events if they are not appropriately stored or cleaned up when spilled or released.
2. Unlabeled or improperly labeled used oil containers
Environmental managers know improperly labeled or unlabeled used oil containers pose significant risks and improper labeling can lead to a higher chance of mishandling, accidental spills, and potential exposure to harmful chemicals. Furthermore, improper disposal can lead to contamination of soil and water. Proper labeling of containers is a fundamental part of accountability and documentation. It also allows for better recordkeeping of materials identifying their origins, intended use, as well as proper storage, transportation, and disposal methods.
3. Unlabeled hazardous materials secondary containers (the ones personnel pour hazmat into at their workstations)
Similarly, labeling secondary containers for hazardous materials is crucial to avoiding dangerous reactions from improper chemical mixing, spills, or the release of toxic fumes. In the event of an emergency such as an accident, fire, or chemical spill, labeled containers help first responders and prevent delayed response times and further mishandling.
4. Loose or improperly containerized fluorescent lamps or open boxes of fluorescent lamps
Fluorescent lamps contain small amounts of toxic mercury, a potent neurotoxic that can have serious health and environmental consequences if lamps break. Loose or improperly containerized lamps can lead to regulatory violations or potential fines during an audit. The EPA has published steps that businesses can take to manage used universal waste lamps here.
5. Unlabeled or improperly labeled universal wastes such as batteries, pesticides, mercury-containing equipment, lamps, and aerosol cans
The EPA’s universal waste regulations help streamline standards for categories of hazardous waste commonly generated by a wide variety of establishments. While the standards are tailored to each type of universal waste for handlers, transporters, and destination facilities, all require proper labeling. See universal waste programs by state here.
6. Undated containers of universal waste
Typically, materials managed as universal wastes can be accumulated for 365 days before being sent off-site for disposal. A year is measured from the time the waste is either generated or the date it is received from another universal waste handler.
7. Improperly cleaned oil spills and leaks in outdoor equipment parking/storage areas
Oil and petroleum-based substances can seep into soil and may eventually reach groundwater or surface water bodies, posing long-term environmental consequences. Regulations often require prompt and thorough response to oil spills and leaks, and like many items on this list, failure to address these can lead to safety risks, regulatory violations, citations, fines, and legal consequences. If it is a large spill, it can potentially damage a company’s reputation. Additionally, delayed, or improper clean up can lead to more extensive (and expensive) remediation efforts in the future.
8. Lack of consistent inspection and corrective action documentation for SPCC, stormwater, and/or tank programs
The major insight facilities should take from environmental audits? Document, document, document. Inspection and corrective action for SPCC, stormwater, and tank programs help with operational safety, risk mitigation, audit preparedness, and future liability. Have thorough documentation to recognize where there may be hazards and safeguard your facility from emergencies.
9. Lack of training documentation for hazardous waste manifest signers, as well as SPCC, universal waste, and stormwater programs, where required
Various environmental regulations mandate that employees receive specific training in hazardous waste management, SPCC compliance, universal waste handling, and stormwater management. Employees need to be well-informed and competent in handling hazardous materials and managing environmental programs. For more information on the importance of environmental training for employees, visit our most recent blog article.
10. Lack of equipment calibration records, where required
A key part of quality management standards is regular calibration for certain equipment, particularly those involved in environmental monitoring, testing, or quality control. Demonstrate compliance and maintain an effective environmental management system by keeping track of calibration records.
Take Advantage of Environmental Training Opportunities
If you have one or more deficiencies in these areas, the good news is they can be reduced or avoided completely with consistent training for both new and existing employees. We offer annual training for SPCC, stormwater, hazmat and hazardous waste/universal waste programs to numerous facilities in a wide range of industries and we can provide you with environmental compliance consulting.
Braun Intertec is offering an opportunity for RCRA hazardous waste managers to attend a live, interactive training. This training will help you get to know all the essential rules and regulations which are continually changing and evolving. Register below.