EHS Support was contracted to perform comprehensive, multimedia environmental audits and evaluate the regulatory compliance status of each manufacturing facility. The audits evaluated compliance with federal, state, and local environmental laws and regulations, and company environmental policies and procedures. Regulatory programs of focus included:
- Air permitting
- Ozone-depleting substances
- Risk management plans
- Drinking water
- Wastewater
- Stormwater
- Aboveground storage tanks
- Spill Prevention Control and Countermeasure (SPCC) Plans
- Stormwater Pollution Prevention Plans
- Emergency Planning and Community Right-to-Know Act (EPCRA) reporting
- Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
- Toxic Substances Control Act (TSCA)
- Hazardous waste management
- Universal waste management
Depending on the size and complexity of the operation, EHS Support spent one to three days at each location. After the site visit, EHS Support prepared an audit report for each location consisting of a brief narrative summarizing the findings by media and severity, followed by a detailed table of findings with ratings, regulatory citations, descriptions of findings, and suggested corrective actions. EHS Support also recommended best management practices to improve facility control measures. The experience provided our client with a snapshot of how well the environmental programs were performing at these locations and gave the facilities a path forward for areas of improvement.