We have a saying around here:
If it wasn’t documented, it didn’t happen.
Any kind of environmental health and safety or workforce compliance program requires proof. Without sufficient documentation, your programs mean nothing to anyone outside of your organization. That includes regulators such as the Occupational Safety and Health Administration, which imposes strict record keeping standards.
Documentation is critical everywhere (it’s shown up in all 3 parts of this series so far), but particularly in relation to any element of your business that can’t speak for itself. Your employees can speak for themselves—they can provide information about training, incident response, and so on.
Your drums and containers? Not so much.
Rather than wait for inanimate objects to develop vocal cords, heed these environmental documentation best practices:
1. Ensure Safe and Compliant Waste Management
Perhaps it goes without saying, but the things you’re documenting should be safe and legal in the first place. Make sure that all your environmental procedures align with state and federal law, such as OSHA standards and the Resource Conservation and Recovery Act.
Start by mapping out your organization’s waste management program, considering basic questions such as the following:
- Where are your hazardous materials stored?
- How do you dispose of hazardous waste?
- What about non-hazardous waste?
- Which vendors or members of your organization are responsible for waste management?
For detailed guidance on waste management, read OSHA’s rules and Hazardous Waste Operations and Emergency Response (HAZWOPER) standards.
Additionally, be sure to familiarize yourself with the RCRA and the Environmental Protection Agency’s waste management guidelines.
2. File All Your Paperwork on Time
Organizations cannot simply share information about their environmental programs whenever they feel like it. If your business generates hazardous waste, you’re subject to a number of federal and state rules and regulations, each with particular timing requirements. You’ll need to file permits with the EPA and your state regulatory authority by certain deadlines. Don’t wait until the last minute—there are multiple, work-intensive steps in obtaining a permit.
If your organization experiences a spill, chemical release, or other environmental violation, you’ll need to file timely reporting paperwork for that, too.
3. Follow Overfill Protection Rules
Storing waste underground? Be aware of your overfill prevention requirements. According to the EPA, any underground storage tank filled with more than 25 gallons of product at one time must be equipped with one or more tools—alarms, float restrictors, and positive shut-off valves are the most common. Note that different rules apply based on when the tank was installed. For more information, click here.
4. Create an SPCC Plan
If you use, drill, gather, process, refine, distribute, or store oil at any of your facilities, your business faces yet another EPA obligation. Federal spill prevention, control, and countermeasure rules require certain organizations to prepare SPCC plans, which detail what a facility will do in the event of a spill. To determine if these rules apply to your business—and for a regulatory overview, reference materials, FAQs, and additional resources, click here.