integrating green into routine compliance inspection programs · hazmat inspectors! existing...

76
Integrating Green into Integrating Green into Routine Compliance Routine Compliance Inspection Programs Inspection Programs Virginia St. Jean, CIH Virginia St. Jean, CIH Industrial Hygienist/DPH Green Industrial Hygienist/DPH Green Programs Manager Programs Manager SF Hazardous Materials Unified Program SF Hazardous Materials Unified Program Agency Agency [email protected] [email protected] www.sfdph.org/dph/eh/green www.sfdph.org/dph/eh/green www.sfgreenbiz.org www.sfgreenbiz.org

Upload: others

Post on 08-Oct-2020

1 views

Category:

Documents


0 download

TRANSCRIPT

Page 1: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Integrating Green into Integrating Green into Routine Compliance Routine Compliance Inspection ProgramsInspection Programs

Virginia St. Jean, CIHVirginia St. Jean, CIHIndustrial Hygienist/DPH Green Industrial Hygienist/DPH Green

Programs ManagerPrograms ManagerSF Hazardous Materials Unified Program SF Hazardous Materials Unified Program

[email protected]@sfdph.org

www.sfdph.org/dph/eh/greenwww.sfdph.org/dph/eh/green

www.sfgreenbiz.orgwww.sfgreenbiz.org

Page 2: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

CUPA PROGRAMS (local hazmat agency in CA)

Page 3: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

WHAT? ANOTHER HAT?WHAT? ANOTHER HAT?

Page 4: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Ready or not, the Green Train has Ready or not, the Green Train has left the station! left the station!

Who should educate businesses on Who should educate businesses on what is really green?what is really green?How can How can govgov’’tt do more with less do more with less resources?resources?How can we educate on compliance as How can we educate on compliance as well as green and still get our primary well as green and still get our primary work done?work done?Where should this function lie in your Where should this function lie in your areas?areas?

Page 5: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Hazmat Inspectors!Hazmat Inspectors!Existing familiarity with local sites and Existing familiarity with local sites and inventoriesinventoriesGreen questions already coming to us Green questions already coming to us during inspectionsduring inspectionsOpportunity to collaborate with businesses Opportunity to collaborate with businesses and other and other govgov’’tt on issues/goals in on issues/goals in commoncommonGreat PR and community relationsGreat PR and community relationsNeed a carrot to go with our enforcer Need a carrot to go with our enforcer stick! (green award programs)stick! (green award programs)

Page 6: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Why Hazmat Inspectors, cont. Why Hazmat Inspectors, cont.

Already mandated to inspect at regular Already mandated to inspect at regular frequencyfrequency-- have authority to be on site, have authority to be on site, oneone--onon--one training opportunityone training opportunityWell versed in with multiWell versed in with multi--agency/multiagency/multi--media pollutants/violationsmedia pollutants/violationsFamiliar with Familiar with chemschems and hazardsand hazardsOneOne--stopstop--shop service for businessesshop service for businessesCan serve as watchdogs for pollutants of Can serve as watchdogs for pollutants of concern! concern!

Page 7: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Barriers may seem too high!Barriers may seem too high!

Already too many regulatory hatsAlready too many regulatory hatsSome inspectors may not want to be Some inspectors may not want to be teachersteachers--takes more time and takes more time and training of inspectorstraining of inspectorsLearning curveLearning curve-- how to keep up with how to keep up with toxics info and greener alternativestoxics info and greener alternativesReally need to be industry experts to Really need to be industry experts to teach teach BMPsBMPs and safer alternativesand safer alternatives

Page 8: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Barriers may seem too high!Barriers may seem too high!Enforcer Enforcer vsvs consultant hatconsultant hat-- wherewhere’’s the s the line?line?Compliance assistance best when industry Compliance assistance best when industry specificspecific-- need local regulators to need local regulators to collaborate, varies greatly per industry collaborate, varies greatly per industry sectorsectorHow do hazmat agencies stay current with How do hazmat agencies stay current with latest P2 tricks/tools?latest P2 tricks/tools?Hard enough to stay current with our own Hard enough to stay current with our own regulatory regulatory oversiteoversite, but P2 issues also? , but P2 issues also?

Page 9: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

SFDPHSFDPH’’ss GOALSGOALSIndustry specific resource guidesIndustry specific resource guidesNonNon--biased info hub for compliance, greener biased info hub for compliance, greener products/methodsproducts/methodsReinvent no wheelReinvent no wheel--use existing research use existing research when possiblewhen possibleCollaborate with industry and Collaborate with industry and govgov’’ttstakeholders stakeholders Select an agreed upon award program that Select an agreed upon award program that awards good compliance and green awards good compliance and green BMPsBMPsSite compliance verification prior to awardSite compliance verification prior to award

Page 10: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

SFDPH Clean and Green ProgramSFDPH Clean and Green Program

Launched in 2001 Launched in 2001 as pilot award as pilot award programprogram

Compliance Compliance excellenceexcellencePollution Pollution preventionpreventionToxics Toxics reductionreductionAuto repair Auto repair sector onlysector only

Page 11: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Why Start with Auto Repair?Why Start with Auto Repair?

Inspectors familiar with typical shop Inspectors familiar with typical shop operationsoperationsBusinesses already well associatedBusinesses already well associatedReg. agencies already working well Reg. agencies already working well togethertogetherNeed to educate sector on new Need to educate sector on new rule/rule/regreg changes and solvents/toxins changes and solvents/toxins of concernof concern

Page 12: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Why Auto RepairWhy Auto Repair-- cont.cont.

DTSC VSR ToolkitDTSC VSR Toolkit-- gave us Workshop gave us Workshop materials!materials!Used existing reporting data for SF auto Used existing reporting data for SF auto shopsshops--business plans, inventories, business plans, inventories, violation historiesviolation historiesDetermine leaders in industryDetermine leaders in industry-- association association officers, peer respected; invite to be officers, peer respected; invite to be stakeholders/industry expertsstakeholders/industry expertsUse existing reg. database to track Use existing reg. database to track work/P2 outreach work/P2 outreach

Page 13: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

SUCCESS!SUCCESS!

Businesses appreciative of:Businesses appreciative of:–– Industry specific multiIndustry specific multi--agency agency

compliance tipscompliance tips–– Info on automotive ingredients of Info on automotive ingredients of

concern in common products (hexane, concern in common products (hexane, toluene, chlorinated hydrocarbons, etc.)toluene, chlorinated hydrocarbons, etc.)

–– New waste reduction tips/toolsNew waste reduction tips/tools–– Empowered to choose greener optionsEmpowered to choose greener options–– Marketing edgeMarketing edge

Page 14: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Gave us Gave us confidence to confidence to try Green try Green Business Business Program in Program in SF!SF!

Page 15: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Next StepsNext Steps……..GBP..GBP

What primary partners to include?What primary partners to include?Find common goalsFind common goalsAsk for formal participation in GBP, Ask for formal participation in GBP, need to get buy in of higherneed to get buy in of higher--upsupsDifferent program agendas, budgets, Different program agendas, budgets, mandatesmandates…………what industry to serve?what industry to serve?More great PRMore great PR-- efficiency thru efficiency thru collaboration collaboration

Page 16: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

What is The Green What is The Green Business Program (GBP)?Business Program (GBP)?

GovGov’’tt sponsored recognition programsponsored recognition programRecognizes environmentally responsible Recognizes environmentally responsible businessesbusinessesUserUser--friendly industry specific friendly industry specific BMPsBMPsProvides expert technical assistance Provides expert technical assistance and educationand educationCompliance first!Compliance first!

Page 17: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Partnership ExamplesPartnership ExamplesIndustryIndustry-- associations, small to associations, small to medium businesses, suppliers to medium businesses, suppliers to business sectorbusiness sectorGovGov’’tt--CUPAsCUPAs, , FDsFDs, Air & Water Quality , Air & Water Quality districts, Health districts, Health DeptsDepts find common find common goals/standards, conduct site goals/standards, conduct site verificationsverificationsPublicPublic-- patronize local patronize local GBsGBs for services for services and supplies, comment on GB and supplies, comment on GB standard for that localestandard for that locale

Page 18: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Launched in 2004Launched in 2004SF Partners:SF Partners:–– SF Dept of the SF Dept of the

EnvironmentEnvironment–– SF Dept of Public SF Dept of Public

HealthHealth--CUPA and CUPA and EnvEnv HealthHealth

–– SF Public Utilities SF Public Utilities CommissionCommission

–– Bay Area Air Bay Area Air Quality Mgmt DistQuality Mgmt Dist

–– SF Fire DeptSF Fire Dept

Page 19: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

SF GreenSF GreenBusiness ProgramBusiness Program

Used SF Bay Area (ABAG) modelUsed SF Bay Area (ABAG) modelWait list from business interest! Wait list from business interest! Learned from Learned from ABAGABAG’’ss experienceexperienceStarted with offices, restaurants, Started with offices, restaurants, hotels, dentistshotels, dentistsNew sectors in 09New sectors in 09-- printers, auto printers, auto repair, garment cleaning, janitorial repair, garment cleaning, janitorial servicesservices

Page 20: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

GBP Criteria GBP Criteria

OnOn--site verifications by experts or site verifications by experts or compliance agency reps:compliance agency reps:

–– MultiMulti--media Compliancemedia Compliance–– Pollution Prevention/Toxics Pollution Prevention/Toxics

ReductionReduction–– Water ConservationWater Conservation–– Energy ConservationEnergy Conservation–– Solid Waste ReductionSolid Waste Reduction

Page 21: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

GBP ProcessGBP Process

EnrollmentEnrollmentPhone or site consultationPhone or site consultationBackground check/compliance Background check/compliance verificationverificationChecklist verification by GBP Checklist verification by GBP partnerspartnersAward/3 year cycle (chosen based on Award/3 year cycle (chosen based on compliance inspection frequency)compliance inspection frequency)

Page 22: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

BENEFITS!BENEFITS!

CUPACUPA-- good PRgood PRSets bar higherSets bar higher-- peer competitionpeer competitionEPPEPP-- better supply, reduced costsbetter supply, reduced costsReduced Carbon Footprint/Reduced Carbon Footprint/GHGsGHGsZero waste goalsZero waste goalsImproved Biz/Improved Biz/GovGov’’tt relationshiprelationshipCompliance agency collaborationCompliance agency collaboration

Page 23: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

BENEFITS!BENEFITS!

GovGov’’tt collaborations help avoid green collaborations help avoid green washing! washing! Inspectors already Inspectors already ““expertexpert”” in hazard in hazard evaluation, draw on their specific evaluation, draw on their specific areas of interestareas of interestReduce hazards and liability at Reduce hazards and liability at businessesbusinessesRevocation policy as neededRevocation policy as needed-- works works toward ensuring compliancetoward ensuring compliance

Page 24: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Current CAGBPCurrent CAGBPIndustry Sectors Industry Sectors

Auto repairAuto repairAuto bodyAuto bodyGarment cleaningGarment cleaningPrintingPrintingFood Food

establishmentsestablishments

HotelsHotelsOffices/retailOffices/retailLandscapersLandscapersDentistsDentistsJanitorial Janitorial ServicesServices

Page 25: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Future Sectors?Future Sectors?

FutureFuture–– Building/property managementBuilding/property management–– Salons/spasSalons/spas–– Marine facilitiesMarine facilities–– SchoolsSchools

Other sectors driven by local interest Other sectors driven by local interest and CAGBN priorities and CAGBN priorities

Page 26: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

StakeholdersStakeholders

Unique to each industry sectorUnique to each industry sectorMeet regularly to share compliance/BMP Meet regularly to share compliance/BMP updatesupdatesShare emerging issues before normShare emerging issues before normField Field greenwashinggreenwashing earlyearlyAssess program needs and capacity issuesAssess program needs and capacity issuesGet feedback from businessesGet feedback from businessesShare Resource GuidesShare Resource Guides

Page 27: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Low Hanging FruitLow Hanging Fruit-- Existing Existing ResourcesResources

HESIS Hazard Alerts HESIS Hazard Alerts www.cdph.ca.gov/programs/hesiswww.cdph.ca.gov/programs/hesis

DTSC ToolkitsDTSC Toolkitswww.dtsc.ca.gov/pollutionpreventionwww.dtsc.ca.gov/pollutionprevention

EPP listsEPP listswww.sfenvironment.org/sfapprovedwww.sfenvironment.org/sfapprovedwww.goodguide.comwww.goodguide.comwww.greenseal.orgwww.greenseal.orgwww.responsiblepurchasing.orgwww.responsiblepurchasing.org

Other national standards/checklistsOther national standards/checklistsProp 65/MSDSs Prop 65/MSDSs

www.oehha.ca.gov/prop65/prop65_list/Newlist.htmlwww.oehha.ca.gov/prop65/prop65_list/Newlist.html

Page 28: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Auto ShopsAuto Shops

DTSC Tool kitsDTSC Tool kits-- free training and free training and materialsmaterialsUse CAGBN checklist as a startUse CAGBN checklist as a startCompare with national and industry Compare with national and industry BMPsBMPs already out therealready out thereEPPsEPPs goodgood-- cheaper, effectivecheaper, effectiveGood compliance agency Good compliance agency coordination already in SFcoordination already in SF–– FD, CUPA, AD, WW, CARBFD, CUPA, AD, WW, CARB

Page 29: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

The GoodThe Good

Page 30: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

The BadThe Bad

Page 31: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

The UglyThe Ugly

Page 32: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Auto Shop ComplianceAuto Shop CompliancePermit ApplicabilityPermit Applicability

CUPA registrationCUPA registration--hazmats/hazwastehazmats/hazwasteFire DeptFire Dept-- flam storage, weldingflam storage, weldingOSHAOSHA-- compressor permit, compressor permit, hazcomhazcomWWWW-- oil/water separator, car oil/water separator, car washingwashingAir DistAir Dist-- spray booth, smog test, spray booth, smog test, FleetsFleets-- fuel dispensingfuel dispensingEPAEPA-- CFC recoveryCFC recovery

Page 33: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Inspector Observations!Inspector Observations!HW issuesHW issues-- inactive EPA ID numbersinactive EPA ID numbersHWHW-- RCRA waste for water parts RCRA waste for water parts washer???washer???Aerosols with Chlorinated Aerosols with Chlorinated HCsHCsBiodiesel for parts washingBiodiesel for parts washingNew generation H20 parts washingNew generation H20 parts washingConcrete slurries Concrete slurries vsvs epoxy coatsepoxy coatsRags/pads Rags/pads vsvs hydrophobic mopshydrophobic mopsRefillable aerosols updateRefillable aerosols update

Page 34: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Auto Body ShopsAuto Body Shops

DTSC Tool kit, training materialsDTSC Tool kit, training materialsCAGBN checklist CAGBN checklist EPPsEPPs OK, not yet OK, not yet ““acceptedaccepted””Mandated rule changesMandated rule changes-- use to use to generate interest in workshopsgenerate interest in workshopsHuge Huge EnviroEnviro footprintfootprintWorker health issuesWorker health issues

Page 35: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Auto Body ShopsAuto Body Shops

Confusing complianceConfusing complianceMultiMulti--media media enviroenviro impactsimpactsCompliance partners:Compliance partners:–– FD, CUPA, AD, WW, CARBFD, CUPA, AD, WW, CARB

Health advisory partnersHealth advisory partners-- HESIS, HESIS, CADPH, IRTA, OSHACADPH, IRTA, OSHAChallengesChallenges-- new technologies, learn new technologies, learn new techniques, more trainingnew techniques, more training

Page 36: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Auto Body ComplianceAuto Body ComplianceApplicabilityApplicability

Spray boothSpray booth-- FD, ADFD, ADVOC restrictionsVOC restrictions-- ADADSandingSanding-- AD, OSHA AD, OSHA Particulate trapsParticulate traps-- WWWWHazmats/hazwasteHazmats/hazwaste-- FD, CUPAFD, CUPAWeldingWelding-- FD, AD, CUPAFD, AD, CUPACFC recoveryCFC recovery-- EPA/CUPAEPA/CUPA

Page 37: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

The GoodThe Good

Page 38: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

TheThe……....

Page 39: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Inspector Observations!Inspector Observations!

Vacuum sandersVacuum sanders-- portables popularportables popularDrain particulate filter insertsDrain particulate filter insertsQuality better for H20 coatingsQuality better for H20 coatingsColors getting betterColors getting better?s about HW mgmt?s about HW mgmt-- paint and dust wastepaint and dust wasteSpray booth/spray gun maintenance!!!Spray booth/spray gun maintenance!!!New New ““greengreen”” solvents of concernsolvents of concernSpills/dustSpills/dust-- general housekeepinggeneral housekeeping

Page 40: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

PrintersPrinters

Difficult Sector!Difficult Sector!Air District Rule changesAir District Rule changesTechnology/equip/product advancesTechnology/equip/product advancesEPPsEPPs-- some better than others, still some better than others, still expensiveexpensiveChallengesChallenges-- expensive equip expensive equip upgrades, need quality print jobsupgrades, need quality print jobsHUGE ENVIRO. FOOTPRINT!!!HUGE ENVIRO. FOOTPRINT!!!

Page 41: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

PrintersPrinters

Very organizedVery organized-- PINC, PNEACPINC, PNEACEPP supplies not readily availableEPP supplies not readily availableGreenwashingGreenwashing-- soy content, low soy content, low VOC, but toxicVOC, but toxic……New disposal questionsNew disposal questions-- solvent solvent impregnated cloths for cleaning impregnated cloths for cleaning presses, ink wastepresses, ink waste

Page 42: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Lithographic PressLithographic Press

Page 43: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Printers Compliance ApplicabilityPrinters Compliance Applicability

Hazmats/hazwasteHazmats/hazwasteFlammable materialsFlammable materialsForklift propaneForklift propanesilver treatment, ink/water separation, pH silver treatment, ink/water separation, pH control control Ammonia gasAmmonia gas-- RMP (Risk Management RMP (Risk Management Plan) Plan) Air CompressorAir CompressorVOCVOC’’ss-- AD permit/VOC limits for sitesAD permit/VOC limits for sites

Page 44: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Inspector Observations!Inspector Observations!RCRA waste manifests!!! RCRA waste manifests!!! New methods for cleaning New methods for cleaning blankets/pressesblankets/pressesSoy cleaners goodSoy cleaners goodLower Lower VOCsVOCs-- AD rule changes confusing to AD rule changes confusing to businessesbusinessesStill technically allowed to use Still technically allowed to use solvent/chlorinated parts washers***solvent/chlorinated parts washers***

***legal, but they add to total site VOC ***legal, but they add to total site VOC calculationcalculation

Page 45: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Garment CleaningGarment Cleaning

Slow industry acceptance for green Slow industry acceptance for green cleaning methodscleaning methodsExpensive equip upgradesExpensive equip upgradesPetroleum machinesPetroleum machines-- FD & Class IIIBFD & Class IIIBWet machinesWet machines-- WWWWSpotting agents toxicitySpotting agents toxicitySmall business woesSmall business woes-- customer trust customer trust at risk, loans hard to come byat risk, loans hard to come by

Page 46: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during
Page 47: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Explosion at dry cleaning facility in Illinois on April 21, 2009.

Page 48: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Garment Cleaning Garment Cleaning Compliance ApplicabilityCompliance Applicability

Combustibles need FD Combustibles need FD permit/approvalpermit/approvalCombustibles need AD registrationCombustibles need AD registrationPercPerc phase outphase out-- 20102010Halogenated Spotter phase outHalogenated Spotter phase out--NOW!NOW!All still regulated by CUPAAll still regulated by CUPAAir compressorsAir compressors-- OSHA permitOSHA permit

Page 49: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Inspector Observations!Inspector Observations!

Green cleaners being sold as nonGreen cleaners being sold as non--hazhazLikely to still need FD, AD, CUPA Likely to still need FD, AD, CUPA permitspermitsWarningWarning-- nPBnPB, Green Earth, Green EarthSpottersSpotters-- new, old, compatibilitynew, old, compatibilityWaste ?sWaste ?s-- are DF2000 and Green are DF2000 and Green Earth wastes hazardous?Earth wastes hazardous?RCRA manifestsRCRA manifests-- residual chlorinated residual chlorinated HydrocarbonsHydrocarbons

Page 50: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

HOTELS!HOTELS!

All partners will like this sectorAll partners will like this sectorHuge Huge EnviroEnviro. footprint. footprint-- energy, energy, water, waste water, water, waste water, HMsHMs, solid , solid waste, toxic cleanerswaste, toxic cleanersMany national modelsMany national models-- good and good and bad!bad!ComplianceCompliance-- complicated and multicomplicated and multi--agency! agency!

Page 51: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

HOTELSHOTELS

Motivated sector, national awarenessMotivated sector, national awarenessMaintaining complianceMaintaining compliance-- not easy, not easy, many/frequent staff changesmany/frequent staff changesEPP products great!EPP products great!Customers requesting ECO!Customers requesting ECO!National pushNational push-- Carbon offsets from Carbon offsets from traveltravelGreat composting/zero waste Great composting/zero waste potentialpotential

Page 52: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Hotels Hotels

Page 53: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Hotels Compliance ApplicabilityHotels Compliance Applicability

High riseHigh riseGarment CleaningGarment CleaningHazmat/Hazmat/hazwastehazwasteBack up generatorsBack up generatorsFlammable storageFlammable storageCompressors/water treatmentCompressors/water treatmentCleaning/maintenance productsCleaning/maintenance products

Page 54: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Hotels Compliance ObservationsHotels Compliance Observations

Lots of inventoryLots of inventory-- labeling/labeling/hazwastehazwaste, , secondary containment, gas cylinderssecondary containment, gas cylindersFlammables/open containersFlammables/open containers-- flam flam cabinetscabinetsMaintenance storeroomsMaintenance storerooms--signage, signage, incompatablesincompatablesTraining recordsTraining records-- housekeeping and housekeeping and maintenance staffmaintenance staffCan accrue many violations if large hotel!Can accrue many violations if large hotel!

Page 55: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

RestaurantsRestaurants

All partners will want to work with All partners will want to work with this sector! this sector! Compliance maintenance difficultCompliance maintenance difficultHuge Huge EnviroEnviro. Footprint. FootprintGreacycleGreacycle potentialpotentialMultiMulti--agency complianceagency complianceEPP products not always OK with EPP products not always OK with HDHD’’ss

Page 56: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

RestaurantsRestaurants

Many locales banning Many locales banning styrofoamstyrofoamCompliance assistance welcomeCompliance assistance welcomeNeed recognition for business Need recognition for business advantageadvantageGreat compost/zero waste potentialGreat compost/zero waste potentialConservation saves moneyConservation saves moneyFood scores/GB awardFood scores/GB award-- public public awareness high in SF!awareness high in SF!

Page 57: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Back

of the house

Front of the house

Page 58: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Restaurant FOGRestaurant FOG

Page 59: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during
Page 60: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Restaurants Compliance Restaurants Compliance ApplicabilityApplicability

Propane, CO2, NitrogenPropane, CO2, Nitrogen-- FD/CUPAFD/CUPAFOG issuesFOG issues-- WW, Health DeptWW, Health DeptCleaners/sanitizers over 55 galsCleaners/sanitizers over 55 gals--CUPACUPAHealth Dept compliance issuesHealth Dept compliance issuesGreener sanitizers/cleanersGreener sanitizers/cleaners--WARNING!WARNING!

Page 61: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Inspector ObservationsInspector Observations

Over concentrating cleaners and Over concentrating cleaners and sanitizerssanitizersToo much sanitizing before cleaningToo much sanitizing before cleaningCustomerCustomer’’s reusable containerss reusable containersTemps controlsTemps controls-- keep legal!keep legal!Electrolyzed water systemsElectrolyzed water systemsEmerging sanitizersEmerging sanitizers--soon to be soon to be approved!approved!

Page 62: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

DentistsDentists

Small officesSmall officesLarge Large EnviroEnviro footprintfootprintEPP complicatedEPP complicated-- need to be HD approvedneed to be HD approvedUse local mandates for P2 outreach effortsUse local mandates for P2 outreach effortsDigital Digital XraysXraysSafer cold sterile solutionsSafer cold sterile solutionsMail back amalgam programs convenientMail back amalgam programs convenient

Page 63: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Dentist Dentist BMPsBMPs

Gas storageGas storage-- can they reduce?can they reduce?DisinfectantsDisinfectants-- newer peroxide newer peroxide formulations replacing formulations replacing glutaraldehydeglutaraldehydeDigital XDigital X--RaysRaysMilder cleaning products (when Milder cleaning products (when disinfection not needed!)disinfection not needed!)

Page 64: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Amalgam SeparatorsAmalgam Separators

Page 65: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Dentist Compliance Dentist Compliance ApplicabilityApplicability

CUPACUPA-- depends upon amount of gas, depends upon amount of gas, HW, HW, HMsHMsMed WasteMed Waste-- sharpssharpsFDFD-- gas cylinder storagegas cylinder storageWWWW-- amalgam traps/separatorsamalgam traps/separatorsXX--RaysRays-- State license (radiation)State license (radiation)XX--Rays photo wasteRays photo waste-- onon--site site trmttrmt vsvsoffsite disposaloffsite disposal

Page 66: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Inspector Observations!Inspector Observations!

Much less gas storageMuch less gas storageMore digital XMore digital X--Ray useRay useMail away amalgam wasteMail away amalgam waste--popularpopularPeroxide disinfectants replacing Peroxide disinfectants replacing glutaraldehydeglutaraldehyde cold sterile cold sterile solnssolnsSharpsSharps-- mail away popularmail away popularDisposables Disposables vsvs disinfecting? disinfecting?

Page 67: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Offices/RetailOffices/Retail

Partners liked this sector/CUPA not!Partners liked this sector/CUPA not!Easier to green, less complicatedEasier to green, less complicatedLess Compliance issuesLess Compliance issuesSafer Safer janitorialsjanitorials avail, but not always avail, but not always used by Service providersused by Service providersRecycling/composting hard in multiRecycling/composting hard in multi--tenant spacestenant spacesNot always in control over water Not always in control over water fixturesfixtures

Page 68: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Common ViolationsCommon Violations

Page 69: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during
Page 70: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Offices/Retail ComplianceOffices/Retail ComplianceApplicabilityApplicability

HMsHMs over CUPA thresholdsover CUPA thresholdsMW Collection (pharmaciesMW Collection (pharmacies--sharps)sharps)Retail shopsRetail shops-- universal/E wastesuniversal/E wastesHWHW-- sports shopssports shops-- bike repairbike repairGas/flam storageGas/flam storage-- hardware storeshardware storesRetails with Biodiesel dispensingRetails with Biodiesel dispensing

Page 71: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Inspector Observations!Inspector Observations!

Retail sites/officesRetail sites/offices-- little little understanding of MSDS, understanding of MSDS, HMsHMsNeed help with U, E WasteNeed help with U, E WasteGas storage surprisesGas storage surprisesUsually can reduce inventoryUsually can reduce inventory-- allow allow more time and training on proper more time and training on proper disposaldisposalNeed lots of help with greener Need lots of help with greener optionsoptions

Page 72: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

Statewide GBP EffortsStatewide GBP Efforts

CAGBNCAGBN-- assoc of CAGB coordinators assoc of CAGB coordinators meet regularlymeet regularlyBetter coordination of standards and Better coordination of standards and programs programs Statewide metrics/tracking databaseStatewide metrics/tracking databaseAssistance with new industry sector Assistance with new industry sector BMPBMP’’ssShare case studies, pros/cons, Share case studies, pros/cons, lessons learnedlessons learned

Page 73: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

CAGBN Database!CAGBN Database!

Need for tracking enrolleesNeed for tracking enrolleesNeed for tracking statusNeed for tracking status-- compliance compliance and conservation auditsand conservation auditsNeed for measuring resultsNeed for measuring resultsNeed for transparencyNeed for transparencyNeed for start up assistance for new Need for start up assistance for new county GB programscounty GB programsConsistent checklists/standards in CAConsistent checklists/standards in CA

Page 74: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during
Page 75: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

FINAL WORDSFINAL WORDS

Keep Resource guides available.Keep Resource guides available.Use Free HELP! Use Free HELP! Cap Number of businesses in each Cap Number of businesses in each sector!sector!Meet regularly with partners and Meet regularly with partners and stakeholders.stakeholders.Partner with schools and universityPartner with schools and university--mutual benefits and great PR!!mutual benefits and great PR!!

Page 76: Integrating Green into Routine Compliance Inspection Programs · Hazmat Inspectors! Existing familiarity with local sites and inventories Green questions already coming to us during

FINAL WORDSFINAL WORDSFind interns for research projectsFind interns for research projectsKeep tabs on the motivated and worthyKeep tabs on the motivated and worthy--seek out inspector referralsseek out inspector referralsFind common ground with partnersFind common ground with partners-- keep keep in mind whatin mind what’’s in it for them when times s in it for them when times get tough (budget issues!)get tough (budget issues!)Use rule changes as compliance training Use rule changes as compliance training opportunityopportunity-- WORKSHOPS!WORKSHOPS!Keep upper managers, mayors, small Keep upper managers, mayors, small business groups onbusiness groups on--boardboard