Virtually
all environmental, safety, and health (ESH) management activities are
regulatory driven. The number and diversity of these regulations grows
increasingly complex. However, almost all ESH regulations share
at least one common thread: they require a written plan to ensure compliance.
Because these plans are generated to fulfill regulatory requirements,
they seldom prove to be useful to the facility beyond meeting these
requirements. However, we believe that these plans should not only meet
the letter of the law, but also intent. After all, what good
is a worker safety plan that is incomprehensible to facility personnel?
We have experience authoring all types of environmental
compliance plans, including:
-
AHERA/ASHARA Asbestos Operations & Maintenance (O&M) Plans
- Asbestos
Abatement Plans
- Stormwater
Pollution Prevention Plans (SWPPP)
- Soil
and Erosion Control Plans
- Spill
Prevention Control and Countermeasures (SPCC) Plans
- NPDES
Preliminary Engineering Reports
- NPDES
Best Management Practices (BMP) Plans
- Slug
Control Plans
- Corrective
Action Plans
- Facility
Closure Plans
- Process
Safety Management (PSM) Plans/Risk Management Plans (RMP)
- Contingency
Plans
Our engineers have the knowledge and experience
to ensure your facility’s compliance with these complex regulations,
providing maximum facility operational flexibility and safety.
The first step in developing any of these plans is the identification
of any and all regulations applicable to the facility that require a
compliance plan. Next, the required elements of the plan must be identified
and outlined. These regulations, as well as the compliance requirements,
are continuously being reviewed and rewritten. Because of this, we maintain vast computer databases that allow our staff
instant access to the most current regulations. Via the Internet, our
staff is able to monitor changing regulatory requirements and any guidance
documents associated with them. Of course, we also keep an eye on the
regulations the old-fashioned way by
maintaining ongoing relationships with personnel from the regulatory
community.
In the past, access to the information contained in one of these plans
required leafing through page after page of frivolous information. Often,
problems could have been corrected in the time it took to find, read, and follow
appropriate response procedures. All of this extra downtime affects
the facility’s performance. Recognizing
this problem, we are pioneering ways to minimize plant downtime. One
of our most unique technologies is our ability to deliver online products
- O&M Manuals and compliance plans on CD-ROM, where the information
is easily available to those who need it: plant personnel and operators.
Asbestos Management Plans
Our staff has been involved in the development of
compliance plans consistent with the requirements of federal asbestos
abatement regulations for over twenty-five years. During this time,
we have gained extensive insight into the complex issues associated
with these plans. Whether the requirement is an Operations & Maintenance
Plan, to ensure employee awareness and safety, or a full scale abatement
plan, we have the knowledge and expertise
to assist your facility with all aspects of regulatory compliance. By
maintaining a complete staff of licensed asbestos inspectors, management
planners, project designers, and abatement supervisors, we have the unique ability of being able to design flexible
compliance plans that incorporate the perspectives of all people potentially
involved with the project.
Stormwater Compliance Plans
Promulgation of rules governing the collection, treatment, and discharge
of stormwater has created yet another area of environmental regulation
that requires detailed plans in order to show compliance. Our engineers have been involved with the development of stormwater
compliance plans since promulgation of the stormwater regulations. We
know all aspects of stormwater compliance
plans including Stormwater Pollution Prevention
Plans and associated plans, such as sediment
and erosion control plans.
Process Safety Management / Risk Management Plans
The Clean Air Act Amendments of 1990 include regulations requiring a
risk assessment of all possible accidental releases of regulated substances.
The details of this process hazard assessment (PHA) are a portion of
what is required to be submitted as part of a facility’s Risk
Management Plan. The plan required by this regulation strongly parallels similar requirements from the Occupational Safety & Health Administration’s
Process Safety Management rule. Because of our experience
in the development of these plans, we can work with a facility to develop
the required documents.
Integrated Contingency Plan
The National Response Team (comprised of the Environmental Protection
Agency, Department of Transportation, Department of Labor, Department
of the Interior, Occupational Safety and Health Administration, U.S.
Coast Guard, Minerals Management Service, and Research and Special Programs
Administration) has jointly published the Integrated Contingency Plan
Guidance or "One Plan". This guidance is intended to be used
by facilities to prepare and consolidate the multiple emergency response
plans needed to comply with various regulations into one functional
plan or ICP (Integrated Contingency Plan).
Facilities may be subject to one or more of the following federal regulations
which require emergency response planning:
-
EPA Oil Spill Prevention Control and Countermeasure Plan
- EPA
Oil Facility Response Plan
- EPA
Hazardous Waste Contingency Plan
- EPA
Risk Management Plan
- EPA
Best Management Practices Plan
- OSHA
Emergency Action Plan
- OSHA
Emergency Response Plan
- OSHA
Hazard Communication Plan
- OSHA
Process Safety Management Plan
- USCG
Facility Management
- DOT/RSPA
Pipeline Response Plan
- MMS
Facility Response Plan
The ICP guidance is intended to minimize duplication in the preparation
and use of these plans at a facility.
Familiar with the provisions of
the ICP guidance, we are prepared to assist you in preparation of an
Integrated Contingency Plan to reduce the needless and oftentimes confusing
duplication of efforts.
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