Gap Analysis & Improvement Tactics for Your EH&S Program

Editor's Notes

• #4: Lisa All lines are muted, use the chat panel for tech issues. Q&A at the end, tweet questions using #EventsRule Unanswered questions will be answered on Twitter after the webinar. Webinar recording and slides will be emailed to you tomorrow morning.
• #6: Programs are good and bad Some ‘perfect’ programs do have small gaps Some good case studies Good take home advise Couple quick examples of what you can do now to analyze what is out there on your site. Stress this is an overview Light assessment of some common errors found – not all encompassing information
• #8: Start-Up EH&S Programs New to the Environmental business? Have some concerns or don’t know where to start? Need resources to get you off the ground? Small EH&S Programs Need some extra help? Don’t have to much money to spend on the service? Large EH&S Programs Need extra help? Need to consolidate resources and potentially outsource? Need a specific expertise? What you need to do & When you need to do it!
• #9: Via – consultant, friend, groups outside your organization Are you lucky enough to have all the resources at your finger tips Do other constraints come into play when you need more information and updated resources?
• #11: How to complete a basis Gap Analysis to identify issues. Where does the budget stand to do this type of work? What can I do right now to change the program & can I bring in some resources to fix them
• #13: What are the normal actions I do to stay in compliance? Completing permits, collecting waste, handling virgin stock material, assessing different research, clinical, or general lab space. Am I doing the work? Is a team doing the work? Do I have any way to complete it? Documentation is 90% of the game to prove something is done and how it is done. Do you have a calendar in place? Is it an excel spreadsheet, word document, in my super massive brain capacity? What prompts me to do the tasks? Reminder through e-mail, the feel of the weather, changing of the clocks or is it unfortunately inspection by inspection (reactionary and not pro-active) Am I doing enough? Am I doing too much? (Who does too much?) are my resources where they need to be?
• #14: Original slide: Emergency Response and Contingency Plan Trained personnel Updated plan Safety of People’s Environment Documentation of incidents or SOP’s for prevention Permits - up to date? Accurate? Need revising? Air, Water, etc. Inventory - per OSHA and the Hazard Compliance Standard. Active? Inactive? Do you have an inventory of all chemicals onsite per OSHA (HCS) Waste -municipal trash, recyclables, chemicals, biologicals, etc. Shipping off-site, drain disposal, etc.
• #15: Eyewash, safety shower, fume hoods, fire extinguishers Original Slide 2) What is out of compliance? Emergency Response and Contingency Plan Training and correct equipment Plan accurate? Safety of People’s Environment Can I prevent something before it happens Always reactive? Permits Renew schedule? Process change? Inventory Exist? Written on 1987 excel? Paper copy? Waste Know all waste areas? Process change? Paperwork
• #16: Kid – immunization records accurate? Pull the records! IRS – make sure you are accurate, have the documents with you! Permits – up to date? Accurate? Need revising? Inventory – per OSHA and the Hazard Compliance Standard. Active? Inactive? Waste – municipal trash, recyclables, chemicals, biologicals, etc.
• #17: Contantly reacting to problem? You ‘the Man or Woman’ onsite determining all these outcomes? Walk in to a situation that is completely out of control To diverse, to many hands in the pot? The person before you didn’t do much? Person before you thought they were doing the right thing? Walked into a great program and wondering what else can be done? Not Ghostbusters! But the EnvironmentalBusters!
• #19: Many people could say you need a team of 2, 5, 10 to run programs. Assessment is first tool success. Don’t over-hire-over commit right of the back Don’t go out and get all the latest and greatest yet (know that it is the DOT regulating the Shipping industry that until now, 2015, have they not really dug into e-manifesting? How much paperwork is signed to get rid of waste off the site?) Make educated decisions behind the work and get outside help when needed BIGGEST – regulations change and get updated – remember to stay up to date!
• #20: Correct equipment, asking the right questions, making sure all grounds are covered What was the exposure? What? How Long? Preventable? Or something new identified through new process or accident that needs to be re-evaluated? Employee safety…public safety…security camera’s, officers, follow through with plans cost money Engineering control failures will happen – how are you prepared to help? Are all of your fume hoods up-to-date with testing?
• #21: 1) 2) Knowledge is key so you know what to do and how to do it. Do you need to be an expert? No, but you need to have the basics to understand what needs to be done. 3) All permits come at a cost to receive, renew and ‘own’ over time – industry actions require specific permits ex: fume hoods – need to be in compliance with the CAA 4) Knowing your areas are key – cannot stay in the office all day, part of the job is walking the land and surveying, interacting with others.
• #22: Fire department will give you a big smile and check mark – larger departments are better when your on their good side (fyi) BIDMC – ETO spill. Bad reaction to problem, over-reaction to problem, but lead to good follow up discussion and improvements later on Recent webinar done on inventory by Schuyler Stuart – highlights ways to do inventory Save money – less multiples of chemicals on your site, sharing, safety of flammables and more high hazard chemicals, overall decrease in needs for volumes Does the volume you ship out the only waste you produce? What about the drains? Fume hoods? HVAC systems? Others? More than one option and way for it to get outOriginal slide: Inventory costs money to complete Accurate inventory key for success Also can save you money What comes in must go out Accuracy of volumes Options for disposal…correct options for disposal HAP report? (Hazardous Air Pollutant) Who needs to submit and why? http://www.epa.gov/oaqps001/permits/obtain.html Definition help: http://www.epa.gov/region9/air/permit/defn.html
• #23: Unlabeled inventory, drum, container Black smoke omitting from a stack somewhere – or weird smell?
• #26: Who are you? What are you researching? Where are you located? How big is your industry?...can I get your phone number, slip them ours… What does this mean? Do you know about chemicals? Do you know about water discharge? We ask: Do you know about CAA and recent fines leveed within the biotech/research field you are in? Found this particular site did not have any SAA’s or MAA’s per regulation. Storage area’s yes, collecting waste yet, but up to compliance…eh not really
• #27: Making sure you take periodic walks to know the site Pay attention to the details – design specific days around specific areas to focus on, don’t do it all at once Ask questions and inquire – don’t promise the world but have good follow up and follow through Original Slide Walk around and access your site Look, head up, smile: Unmarked containers Processes that people are doing Trash receptacles Public interaction Outside grounds Walking person…observing an area
• #28: Making sure you take periodic walks to know the site Pay attention to the details – design specific days around specific areas to focus on, don’t do it all at once Ask questions and inquire – don’t promise the world but have good follow up and follow through
• #30: Do you even know if you had a previous inspection? By whom and when? Did we pass? Obviously we do OK…but not great because they want to review! You would be so lucky to know this was happening. Occasionally it does (heads up) Most of the time they just show up Do you know where everything is? Could you call it up within a reasonable time-frame? This is a case where they did call the day before and inquired about a 3 month window where the waste being generated and shipped was too high (SQG) Didn’t I file a report? I thought I did…let me check…as a SQG do you know you need to file an exemption report if and when you go over your generator status? Couldn’t find anything but had enough resources to reach out immediately, figure out why it was over (project based) building gut and removal (PCB’s, lead, Asbestos) Made correct documentation, everything else looked real good and overall they found little findings elsewhere. Overall = good report What if no-phone call comes in Talk BIDMC study where a phone call came to me as a team member…more immediate, react quickly. Leads to onsite program
• #31: Do you even know if you had a previous inspection? By whom and when? Did we pass? Obviously we do OK…but not great because they want to review! You would be so lucky to know this was happening. Occasionally it does (heads up) Most of the time they just show up Do you know where everything is? Could you call it up within a reasonable time-frame? This is a case where they did call the day before and inquired about a 3 month window where the waste being generated and shipped was too high (SQG) Didn’t I file a report? I thought I did…let me check…as a SQG do you know you need to file an exemption report if and when you go over your generator status? Couldn’t find anything but had enough resources to reach out immediately, figure out why it was over (project based) building gut and removal (PCB’s, lead, Asbestos) Made correct documentation, everything else looked real good and overall they found little findings elsewhere. Overall = good report What if no-phone call comes in Talk BIDMC study where a phone call came to me as a team member…more immediate, react quickly. Leads to onsite program
• #32: Not only stay in compliance but regularly service Always have shock (Reference EPA call actually DEP) Understand what can and will happen during an inspection Move quickly to check out what needs to done, where will they go first – tidy up or help out with something immediate In this case we had people on 5 days a week for 40 hours…lots of resources – call to me, call to my office, call to others to help… More resources the better – onsite program constantly keeps people in the loop and up to date Some time or a lot of time? How often? More of a support vs. onsite time? What level of experience to do you want/need? Customized and unique program
• #33: Not only stay in compliance but regularly service Always have shock (Reference EPA call actually DEP) Understand what can and will happen during an inspection Move quickly to check out what needs to done, where will they go first – tidy up or help out with something immediate In this case we had people on 5 days a week for 40 hours…lots of resources – call to me, call to my office, call to others to help… More resources the better – onsite program constantly keeps people in the loop and up to date Some time or a lot of time? How often? More of a support vs. onsite time? What level of experience to do you want/need? Customized and unique program
• #35: Permits, manifests, SOP’s Training of you and others around you Too much work? We all have it but does it hinder your chances to stay in compliance Background knowledge of 20 years? Just out of school? Need more training and resources? Know where to start?
• #38: Not one type of program will fit all your needs. Fine tune what resources you need and when you need them Larger places may need people on site every day Smaller places may need a person who shows up 1xmonth Do you need help with permits, sampling, program writing, OSHA work? Waste pick-ups, inspections, BBP’s