At least with health & safety compliance, you really only have to worry about a single agency, OSHA.  Unfortunately, that’s not the case on the environmental & hazardous materials compliance side, where we can lump each of the following local, state and federal regulatory agencies into the mix:

  • EPA: Federal Environmental Protection Agency
  • TCEQ: Texas Commission on Environmental Quality
  • DOT: Federal Department of Transportation
  • Texas Depart of Public Health
  • Local Fire Department
  • Local Town or City

While most of these agencies focus  on Texas environmental regulations, some of them manage hazardous materials regulations.

These agencies mandate a range of requirements that Texas companies must manage,  including:

  • Permits
  • Plans
  • Inspections
  • Reporting & tracking
  • Employee Training
  • Record Keeping and Documentation

The list goes on and on, and the laws can change at any time.   It’s no wonder that small Texas manufacturers struggle to make sense of it all, let alone meet and manage them on a consistent basis.

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Given these challenges, let’s dive deeper into the consequences of failing to meet these requirements.  Each agency has it’s own unique set of options in their enforcement toolbox, including:

  • Fines:
    • Not capped and can run into the millions
    • Calculations made based upon:
      • Time period out of compliance (i.e.: $x per DAY x # of days out of compliance)
      • “Economic Benefit” (i.e: how much $ did the offending company save by not being in compliance for the entire period of time out of compliance)
  • Penalties:
    • Enhanced scrutiny and requirements
    • Cease or suspension of activities until violation abated
    • Extensive engineering/plant modifications

The most common issues during environmental compliance assessments for your sector are as follows:

  • Satellite accumulation area (SAA) and main accumulation area (MAA) maintenance and training not current
  • Lack of up-to-date chemical inventories and SDS
  • Storm water training/inspections/sampling out of date or not completed
  • DOT and RCRA training for employees signing chemical waste manifests outdated
  • Universal waste (batteries, thermostats, fluorescent lights, etc.) – storage, signage, collection not sufficient

Email us at rcarr@bes-corp.com or call 512-457-0374

 

We help companies manage OSHA Laws in Texas & Environmental Laws in Texas.