The new version of ISO 14001 puts an incredible amount of emphasis on the top management of an organization. Previously, it was still well known that unless the top management is on board in terms of implementing and environmental management system (EMS), it’s nearly impossible to have an effective and well functioning EMS. The terms “top management”, “senior management” and “leadership team” have been used interchangeably in this article.
Based on my experience in five (5) different countries of auditing and consulting, I’ve witnessed some different scenarios:
1. Top management feels like the EMS and ISO 14001 certification is useless and nothing but a paperwork burden, a waste of time and energy. EMS is implemented at its bare minimum. The only reason it’s implemented is either because a customer or corporate requires it.
2. Top management appointed a person with no environmental background or training to implement the EMS on their own, and the person does not have the resources, the authority or the knowledge to do anything. In addition, the appointees are not supported by top management.
3. Top management is heavily involved and hands-on in implementing the EMS. They support the environmental department, they walk the talk, and they established a good bridge between the environmental department and the operations.
Of course, these are not the only scenarios that can be seen out there! It’s not that hard to guess which EMS will function well and be successful right? You guessed it, it’s number 3!
It’s so important to understand that without the full involvement and support of the top management, it just won’t work!
Let’s take a quick look of what ISO 14001:2015 requires from top management:
There has to be demonstrable evidence for these requirements. Obviously, trying to get ready three days before a registrar audit may not be a good idea!
How can the leadership team demonstrate these requirements? There are so many different ways. I will share the ones that I witnessed working the best for different companies:
These are just a few examples.
My advice to environmental staff who are working on ISO 14001: Please make sure that your leadership team is aware of all these requirements.
My advice to the members of the leadership team: Please understand and be aware of ISO 14001:2015 requirements and the environmental regulatory responsibilities of your company including the needs and expectations of all your interested parties.
Please support your environmental folks by empowering them with proper resources and authority. Always remember that establishing, implementing and maintaining an EMS is never only one person’s job, but it belongs to the entire company and ultimately, you, as the leadership team of the organization, are responsible for the success of your EMS.
Thanks for reading and good luck!
Mel DeGregorio ISO 14001:2015 Lead Auditor
Who says we have to do the training in a conference room when we can do it on a boat? We are in Florida after all!
We start out in our conference room here in Daytona Beach, then we take the course to sometimes to a cafe with an ocean view or a rooftop bar for with a panoramic view…
We definitely continue our course on a lovely boat cruising around, observing dolphins, pelicans and other wildlife in the area, while conducting our group work…
We offer delicious breakfast, and a variety of fun refreshments to look forward to throughout the day!
Come learn with us and have fun at the same time… Click here to see our upcoming course schedule
We completed this session with flying colors! Check us out! These pictures are from the last day of our training where we conducted parts of the mock audit while touring the beautiful Intercoastal Waters of Daytona Beach…
Below, please click on each link to see the schedule:
Environmental Protection Agency Region 1, created a presentation regarding Emergency Planning Community Right-to-Know (EPCRA), Risk Management Plan (RMP) and General Duty Clause (GDC).
I would like to personally thank Mr. Len Wallace, who is an amazing EPCRA Guru and so much more for this presentation. I have been attending his workshops as a consultant for years. He always has been an incredible resource, and has been so pleasant to speak with while sharing his knowledge.
Here it is:
Today is January 9th. The submission due date of March 1st for EPCRA Tier II reporting is approaching fast! Let’s have a refresher on Emergency Planing Community Right-to-Know Act (EPCRA) Tier II reporting requirements. Here is what we are going to talk about on this article:
EPCRA History You might have heard the same regulation as SARA Title III, Right-to-know report, chemical inventory reporting or EPCRA Section 312. They all refer to the same regulation. To find out about the history of EPCRA, check out these links:
EPCRA was passed by the Congress in 1986 two (2) years after an industrial disaster occurred in Bhopal, India. Check out this video to find out more about this disaster:
EPCRA Section 312 – Tier II Reporting Requirements
These requirements have been codified under 40 CFR 370. Let’s take a look at EPCRA Tier II requirements: In a nutshell, according to these requirements, if you stored:
1- Any hazardous chemical (per OSHA Hazard Communication standard) in the quantity of 10,000 lbs or more (no list, all OSHA hazardous chemicals required to have an SDS) or
2- Any Extremely Hazardous Substance (EHS – listed under 40 CFR 355 Appendices A & B) in the quantity of 500 lbs or threshold planning quantity (TPQ- see the EPA Consolidated List of Lists, whichever is less, at any one time at your site from January 1st until December 31st, you have to report this chemical the following year by March 1st to the:
1- State Emergency Response Commission (SERC),
2- Local Emergency Planning Committee (LEPC) and
3- Local Fire Department
* Please refer to the regulation for retail gas station requirements regarding diesel fuel and gasoline at retail gas stations.
Check out under the resources below to find out more about Tier II reporting requirements.
Lead-acid Battery Reporting
One of the most widely missed reporting requirements is reporting the lead-acid batteries. These batteries could be found in electric industrial trucks such as forklifts, and other industrial or construction vehicles.
The battery acid (sulfuric acid) in the electric forklift batteries is an EHS, and most importantly, whenever there is an EHS stored on-site, it has to be aggregated to see whether or not it exceeded the reporting threshold.
To calculate the quantity of the sulfuric acid, you can either:
– Check the SDS for the batteries,
– Call the manufacturer or
– As a rule of thumb, (I’ve learned this at an EPA training), you can take about 20% of the weight of the battery and calculate the amount of sulfuric acid
Remember to add up all other sulfuric acid that you stored during the previous calendar year at your site, to find the total quantity. Usually, one electric forklift battery could weigh about 2500-3000 lbs. so, even if you have just one forklift, you might be required to report.
Over reporting is not an issue, however, under reporting or not reporting at all is a violation of a Federal Act (EPCRA). EPCRA section 325 allows for civil and administrative penalties ranging from up to $21,916 – $164,3671 per violation per day when facilities fail to comply with the requirements.
There you have the Tier II reporting in a nut shell. There are so many other details, of course, to keep in mind. Everything you read above is my interpretation of the associated regulation. Please do not take this article as legal advice. Always refer to the most current regulation and consult with your attorney for any legal advice.
Based on my nationwide experience and observations, my goal is just to bring your attention to this very important regulation. Here is my advice:
Make sure you understand fully how to report and what to report to prevent any miscalculations or wrong reporting. If you choose to do the reporting on your own, great, just make sure you fully are comfortable with EPCRA Section 312 in its entirety. For a great refresher, check out our two (2) hour live webinar:
Most common findings and issues regarding EPCRA Section 312 that I observed
The resources below should also help greatly:
If you need help, or prefer a third set of eyes to take a look at your chemical storage and applicable Tier II reporting requirements to your facility, call or email us. We would be happy to do it for you. We have been reporting EPCRA Tier II and TRI reports for our nationwide clients since 2008. Just let us know.
Thanks for reading!
GreenUp Consultants, LLC – GreenUp Academy, LLC
Owner/ Principal Consultant
Exemplar Global certified Lead Auditor:
EMS – OHSAS – EHS Regulatory Compliance
QMS – e-Stewards/R2/RIOS Lead Auditor