Comprehensive Environmental Compliance Program: A Case Study, 1996 Environmental Conference Proceedings

When a company is subject to environmental regulations, compliance can seriously affect its operations. The company is required to comply with numerous regulations, and noncompliance can lead regulatory agencies to levy severe penalties. A comprehensive regulatory compliance program, whether developed in house or with the help of an outside environmental professional, can ensure that the company is in day-today compliance with environmental regulations. The case study describes a forest products facility operating both a wood pressure-treating facility and a sawmill. As a largequantity hazardous waste generator, the facility is subject to Resource Conservation and Recovery Act (RCRA) operating and reporting requirements, as well as to other regulations, including those of the Occupational Safety and Health Administration (OSHA) and the Toxic Substances Control Act (TSCA). The treating plant stores and uses wood preservatives containing pentachlorophenol, creosote, and Chemonite (an arsenic-copper-zinc-ammoniate [ACZA] mixture). Sawmill operations use NP-1 preservative, paints, oils, solvents, and greases. In a cooperative effort between the environmental professional and the company’s management and operations team, a comprehensive environmental compliance program was instituted at the facility. The program includes environmental auditing; waste stream determinations and preparation of a waste management manual; development of an environmental filing system; regular meetings, inspections, and training; annual review of in-house plans; review of submittals to regulatory agencies; and assistance with permitting. The organization and training elements of the program give employees who have environmental responsibilities a thorough understanding of the facility’s compliance needs. The program is cost-effective and reduces the likelihood of serious violations or penalties.