About Russell Carr

How A Sales Guy Transformed Into An Environmental, Health & Safety Expert & Advocate For Small Businesses I've spent my entire 30+ year career working within the manufacturing and “industrial services” sectors. The first 15 years of my career focused on sales of hazardous materials related products and services to the manufacturing sector, then for the last 16+ years transitioned into entrepreneurship, founding 3 small industrial services related contracting businesses. As you’ll see below, running these companies eventually lead me to found yet a 4th business, but more on that in a minute…. Here’s a brief description of the first 3 companies: Berg Environmental Services, Inc.: hazardous waste disposal & transportation services, founded in August of 2003 3rd party wind energy operations & maintenance services provider to utility scale wind farms throughout the US, founded in September 2007 3rd party oil & gas exploration & production services provider, founded in August of 2011 Each of these companies operated in extremely dangerous working conditions and exposed my employees to a wide range of serious health & safety hazards on a daily basis. To complicate matters, 2 of the companies also exposed the environment to significant potential harm. In other words, I learned very early the critical importance of managing environmental, health and safety issues so as to ensure the safety of our employees and the environment, as well as minimizing related risks. But I also learned how incredibly difficult and challenging this endeavor can be due to the wide range of complicated and continually changing environmental, health and safety rules and regulations that impacted the companies. To summarize the challenges: First I had to determine which regulations applied to each company, then I had to build compliance programs to meet those regulations, and finally I had to ensure that the programs were being managed and followed by our staff on a daily basis. All while trying to run and grow 3 profitable businesses…. It was overwhelming and I always struggled to keep up. To make matters worse, throughout this time I also witnessed the devastating price that companies, management and ownership can pay for failing to manage EHS compliance. This included seeing one of my hazardous waste management clients get sent to jail over environmental issues, another client’s management team threatened with jail time, a direct competitor get fined $378,000 by OSHA fine after an employee was nearly killed, and many others face major fines and penalties. Full disclosure, one of my companies got fined by OSHA at one point, & another was cited by TCEQ, so I know how it feels. In summary, I learned first hand how incredibly difficult it is for small companies to manage EHS compliance due to a common lack of the critical expertise, time and resources that are needed to keep up, and how this situation then ends up exposing them to these potentially catastrophic risks that can literally destroy lives and businesses. This later inspired me to found my 4th company, Berg Compliance Solutions in 2012, which is dedicated to helping other small businesses, and business owners, to manage EHS compliance and risk. Education BA, Philosophy, University of Colorado, Boulder, December, 1990. Summary of Professional Experience & Qualifications: 30+ years serving the manufacturing & industrial services sectors 30+ years of sales and marketing experience 16+ years as small business owner & entrepreneur: Founded and operated 4 small businesses since 2003. Environmental, Health & Safety Compliance & Program Related: 19 plus years of hazardous waste management including EPA, TCEQ & RCRA regulations 8 years of DOT/FMCSA compliance experience, including hazardous materials transportation 8 years of combined experience implementing and managing OSHA health and safety compliance programs for 2 high risk energy services businesses Successfully implemented and gained ISO 9001 Quality Management Certification and OHSAS 18001 (Occupational Health & Safety Advisory Service) Certification for wind energy maintenance business. Regulatory Enforcement Related Experience: Served as expert witness in criminal environmental compliance enforcement cases Superfund-CERCLA OSHA enforcement inspections, investigations and resolution in following industries: industrial services, manufacturing & construction. TCEQ enforcement inspections, investigations and resolution in manufacturing.

Top 10 Hazardous Waste Violations In Texas

Hazardous Waste Fines and Penalties Will Follow If Your Company Fails To Keep Up Here are the top 10 hazardous waste violations impacting Texas manufacturers which can result in major fines, penalties & disruptions: Failure to determine the company’s waste generator status (CESQ, SQG, LQG) Failure to create Waste Determinations to identify & characterize all waste streams Failure to properly label waste containers Failure to train employees on DOT hazardous materials shipping requirements Failure to create a Contingency Plan and Emergency [...]

DOT Hazardous Waste-Materials Training Requirements

Shippers of Hazardous Waste Must Get Training on US DOT Hazardous Materials Regulations The US department of Transportation, or US DOT, requires extensive employee training for companies who are involved with shipping of hazardous materials. This applies to anything that meets US DOT Hazardous Materials Regulations (aka: HMR) from paints, chemicals and hazardous products, to hazardous wastes. There’s a wide range of impacted companies and activities that fall under this training requirement, but this blog only discusses training issues impacting [...]

By |2021-10-13T17:21:02-05:00July 29th, 2021|Berg Environmental News, Hazardous Waste Management, OSHA Health & Safety, Texas Environmental Regulations, Texas Hazardous Materials Regulations|Comments Off on DOT Hazardous Waste-Materials Training Requirements

EPA and DOT Hazardous Waste Labeling Requirements

Learn How and Why To Label Hazardous Waste Containers Throughout my 22 years working in the hazardous waste industry I’ve learned that the most obvious and common sign that a company isn’t properly managing their hazardous waste obligations is failure to properly label waste containers. In other words, if a company isn’t labeling properly, it almost always means that the company isn’t managing their other EPA/RCRA requirements either, including determining their generator status, completing waste determinations, training employees, developing waste [...]

By |2021-07-28T10:48:52-05:00July 21st, 2021|Good To Know|Comments Off on EPA and DOT Hazardous Waste Labeling Requirements

OSHA Safety Training Requirements

Let's Talk Workplace Safety Training Programs So what exactly are OSHA’s health and safety training requirements? Unfortunately it’s not a simple answer because OSHA’s safety training regulations are actually fairly extensive, but we’ve done our best to summarize the most important points below. Before getting into the details, let’s quickly cover some very common mistakes that companies make when trying to manage safety training which can end up leading to lots of problems like serious injuries and major fines: Only [...]

By |2021-10-13T17:18:18-05:00July 19th, 2021|OSHA Health & Safety, OSHA Texas Laws & Regulations, Safety Training, Texas OSHA Compliance|Comments Off on OSHA Safety Training Requirements

What Does It Mean To Be OSHA Compliant?

Learn everything you need to know about OSHA Compliance & Guidelines in this comprehensive blog post In short, the answer is an emphatic “yes” because companies who fail to do so put their employees at needless and significant risk for serious injuries or even death, not to mention major fines and penalties that can literally run into the $10s or even $100s of thousands of dollars. Being negligent about safety can also put the company and ownership at risk for [...]

By |2022-03-21T13:03:55-05:00July 18th, 2021|Good To Know, OSHA Health & Safety, OSHA Texas Laws & Regulations, Safety Training, Texas OSHA Compliance|Comments Off on What Does It Mean To Be OSHA Compliant?

Texas TCEQ Industrial Waste Determination Requirements

This blog post will discuss and summarize the #2 Hazardous Waste Violation in Texas All Texas manufacturers, big and small, generate industrial wastes.  These wastes can include simple “plant trash” (paper, plastic and cardboard), recyclable wastes such as scrap metal, batteries, spent bulbs and in many cases, hazardous wastes such as spent paints, solvents, acids, bases or solids contaminated with hazardous substances. In Texas. all manufacturing facility wastes, even plant trash, are considered “industrial wastes” and are therefore must be [...]

By |2021-08-02T17:10:29-05:00June 30th, 2021|Good To Know|Comments Off on Texas TCEQ Industrial Waste Determination Requirements