Permitting, Fees, and Reports

Cal Poly Lecture Tour

Ron Scholtz

Analog Devices, Inc.

I Didn’t go to College to be a File Clerk!

EHS professionals have a lot of responsibility in maintaining up to date permits, fees, and other records.

A great deal of time is spent dealing with paperwork.

There can be serious legal implications if permits, fees, and other required records are not properly maintained.

Permits

Air District Permit to Operate POTW Waste Water Discharge Permit Storm Water Permit Waste Generator Permit Waste Treatment Permit (Tiered Permit vs.

TSDF) Fire/Business Permit Radiation Permit Elevator Permit Pressure Vessel Permit

Reports

Wastewater Monitoring Reports Storm Water Monitoring and Inspection

Reports Air District Data Reports SARA Form R Emissions Report Hazardous Materials Inventory Statement Groundwater Monitoring Reports SB-14 Source Reduction Report

Reports

Hazardous Waste Biennial Report Waste Treatment “Tiered Permitting” Annual

Update Tiered Permitting Financial Assurance Contingency Plan for Emergency Response Industrial Hygiene Monitoring Reports OSHA 300 Accident Log

Fees

Air District Fee POTW Fees Hazardous waste fees and taxes (multiple) Business taxes Storm water fees Department of Transportation fees (haz mat)

Records

Hazardous Waste Manifests Hazardous Material Shipment Bill of Lading Accident reports/OSHA 300 log Medical records- ERT, Respirator Material Safety Data Sheets Training records Spill and incident reports Chemical usage records

Records

Wastewater pH and flow charts Solvent fume abatement system temperature

charts Toxic gas monitoring system alarm reports Respirator Fit Testing Records Calibration records Equipment maintenance records Inspection Records Corrective Action Records

Inspections

Regulatory Agency Inspections- Fire Department, POTW, Stormwater, CHP, DOT, FAA, OSHA, EPA, FDA

Internal Inspections- Forklift, Respiratory Protection, Lock-Out/Tag-Out, Confined Space, ISO 14001/OHSAS 18001 Audits

Regular Inspections- Weekly Hazardous Waste Storage, Weekly Hazardous Material Storage, Daily Tank, Gas Cylinder Delivery, Stormwater

Life Safety Inspections- Fire Protection Systems, Alarm Systems, Gas Monitoring Systems, Fire Extinguishers, Safety Showers, Emergency Lighting

Third Party Visits- Industrial Risk Insurer, Workers Compensation Insurer, Customers, ISO 14001/OHSAS 18001 Registrar, Community

Regulations

Need access to all applicable legislation, regulations, and codes- maintain a list

Most regulations are now available on the internet Many agency websites have greatly improved and

contain a wealth of information Take some time to periodically review regulations-

Update services, newsletters, etc. Having a good reference library available is very useful

Being Organized is a Must!

You must have very organized files in order to keep up with all the paperwork.

– Files in a centralized location– Files divided by “reports”, “permits”, “fees”, “records”– Have a system- i.e. color coded folders– Have a record retention system. You can destroy most old

documents.

Maintain tracking calendars so that you know what is due ahead of time.

– “High Level” Matrix of requirements and timelines– “Compliance Calendar”- Issued Annually, Updated Monthly– “Life Safety Calendar”- Issued Annually, Updated Monthly

Other Tips

Don’t let your paperwork pile-up. Give yourself time each day or each week to keep up.

Fill out forms completely. Blank spaces can come back to haunt you! Waste manifests in particular.

Have a review system so that documents are looked at by more than one person before signing.

Managers should periodically check department files to make sure everything is in order.

An organized looking office space is usually a good sign!