Know your regulatory acronyms By Carmen Daecher

Here's a quiz: What do the following mean? SARA; CERCLA; RCRA; SWPPP? What constitutes a hazardous material as related to the environment? What is the threshold number of pounds of hazardous materials stored on-site that requires emergency planning provisions? Do you know?

If you can't answer some or all of these questions, you had better brush up on your EPA and OSHA regulations. The answers to the above questions and more define the EPA and OSHA regulations that apply to you as a motorcoach operator. You should become familiar with these regulations just as you have become familiar with the regulations from the Department of Transportation.

For starters, here are some basic considerations that you must address to comply with EPA regulations:

  • Management and proper disposal of wastes such as antifreeze, used oil filters, used oil, absorbents, solvents, paint wastes and filters, scrap tires, batteries, lavatory waste and all other wastes generated.
  • Management and proper disposal of wastewaters such as service bay drain wastewaters, tank bottom waters, vehicle washwaters and stormwater.
  • Management of fuel storage and liquid storage systems such as underground and aboveground storage tanks and containers used to store used oil or hazardous wastes.
  • Compliance with clean air requirements for air conditioning servicing, automotive refinishing operations, Stage I and II vapor recovery at gasoline dispensing facilities, use of proper fuels and applicable alternative fuel requirements.
  • Community Right-to-Know reporting of hazardous materials stored on site.
  • Requirements for recycling of solid wastes and waste minimization.

Here are 14 additional points that you need to consider in combination with the above elements to make sure that you have an effective program:

  • A statement of environmental and safety responsibility endorsed by top management and communicated to all employees;
  • An environmental and safety management program established throughout your organization;
  • Environmental and safety responsibilities delegated to a person(s) within the organization;
  • Appropriate resources and budget authorized and established by the organization;
  • Provisions for periodic facility audits and reviews to monitor compliance, measure performance and control costs;
  • Periodic education, training and awareness at all levels of the organization;
  • Program objectives that are clearly communicated and responsibilities delegated to appropriate individuals;
  • Established methods to ensure timely reports and permit renewals to all government agencies;
  • A procedure for the organization, maintenance and storage of all records;
  • Procedures to prepare for an EPA, OSHA or DOT inspection;
  • Procedures for responding to notices of violation and other orders from government agencies;
  • Procedures to evaluate and inspect firms providing waste transport, treatment, storage and disposal of regulated wastes;
  • Procedures to limit environmental liabilities from the purchase, lease or transfer of real estate;
  • Policies that are enforced and incentives (or penalties) to maximize employee compliance.

Audit thyself

One of the most important elements of an environmental workplace management program is the audit. A comprehensive self-audit should be conducted at least semiannually or whenever there is a change in facility coordinators. The value of an audit is only as good as the person conducting it and the checklist or procedure used. A good audit will indicate areas that may not be in compliance or which may require further evaluation or corrective action.

Environmental workplace audits are important tools and should be included in your organization's tool chest of management solutions.

If you have let your programs slip regarding environmental and employee health and safety, fix them. And if you don't have such programs, build them. From where I am sitting, complying with necessary environmental and workplace laws not only gives you peace of mind, but creates the type of environment within which your employees and others can perform their work safely and in good health.

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