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Response Plan Compliance Tracking and Submission

Posted on Thu, Dec 15, 2016

Regulatory Compliance is Not Optional

Month after month, companies are reminded through assessed fines and mandated enforcements that regulatory compliance is not optional. In August 2016, the U.S. Environmental Protection Agency (EPA) settled with an oil and gas equipment company for hazardous waste violations at five Texas facilities. The company was assessed a penalty of $237,980 for violations regarding improperly generating, transporting and disposing of hazardous waste.

These types of cases are not restricted to one industry. If regulations apply to operations, non-compliance fines can be assessed. The most widely applicable regulations to industrial companies are those under the realm of the Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA).

 

Typical Industrial Requirements

Below are a sample of the EPA requirements that may be applicable to industrial operations:

  • National Pollutant Discharge Elimination System (NPDES) - Permitting program designed to control water pollution by regulating point sources that discharge pollutants into waters of the United States. Industrial, municipal, and other facilities must obtain permits if their discharges go directly to surface waters.
  • Facility Response Plan (FRP) - Requires an owner or operator of a facility that could reasonably be expected to cause substantial harm to the environment by discharging oil into or on the navigable waters or adjoining shorelines to prepare and submit a facility response plan.
  • Resource Conservation and Recovery Act (RCRA) - The primary governing law that oversees the generation and containment of solid and hazardous waste.
  • Spill Prevention Control and Countermeasure Plans (SPCC) – Requires developing site specific plans for oil storage facilities that describe spill prevention and response procedures.
  • Emergency Planning and Community Right to Know (EPCRA) - Establishes requirements for federal, state and local governments, Indian tribes, and industry regarding emergency planning and "Community Right-to-Know" reporting on hazardous and toxic chemicals to enable a more effective emergency response planning process.

 

Response Plan Submissions

A simplified regulatory submission process is highly beneficial when companies have multiple facilities in various locations. Despite similar operations within the same industry, each site may need to comply with specific local, state, and/or federal regulatory mandates. Companies should have a systematic method to itemize these varied regulations and include categorical information that satisfies that regulation. Implementing a web-based planning system with a regulatory tracking element can eliminate redundancies across converging compliance requirements and minimize dedicated administrative time.

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Compliance Tracking System

Using database technology allows association of each regulatory requirement to applicable facilities. Additionally, updating evolving regulatory information can be effectively managed across multiple facilities with the use of a database. At a minimum, a web-based tracking system should contain the following components:

  • Operational Category: Categories can range from air quality and hazardous materials, to construction safety and general safety and health. Depending on the detail required by the regulations, further subcategories may be utilized.
  • Applicable Regulation Level: Regulations should be further broken down to federal, state or local regulation categories. 
  • Update History: Date that each regulation was last updated.
  • Compliance Task: Tasks that needs to be completed for compliance.
  • Compliance Feedback: Applicable notes.
  • Industry Standard: Industry standards or best practices that apply to the specific -regulatory requirement.
  • Cross-reference: Itemized list of additional regulations that may be applicable to the information provided.
  • Facility Compliance Responsibility: Person(s) responsible to maintain compliance for each regulatory requirement.
  • Action Item Reporting: Provides a list of outstanding and completed action items, along with due dates and persons assigned. Reports should have filters to customize queries as required by the users.

The ability to track company-wide compliance and streamline the regulatory submission process is administratively advantageous for the individual company, as well as the multiple regulatory agencies. With required response plans in an easy to use electronic format, companies can ensure compliance and easily adhere to new, and future regulatory submission policies.

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Tags: Response Plans, Regulatory Compliance