Earth-Friendly Shops
Bad record-keeping could earn you a big fine.
PATRICIA SMITH
SENIOR EDITOR
Most of the industry's attention these days is on emissions, but putting other environmental compliance issues on the back burner could be a costly mistake. For some time now, government officials have been stepping up enforcement of "anti-pollution" rules. One reason, no doubt, is steady pressure from environmental groups. But in the last year or so, the faltering economy and tight government budgets have also had an effect.
"Quite simply, [government environmental agencies] need more and more funds to operate and expand their programs," says David Augenstein of Automotive Environmental & Safety Engineering, a Findlay, Ohio, company that publishes guidebooks, reference manuals and training materials for shop environmental and safety compliance. Violating a state or federal rule is "not just a $10,000 fine anymore," he adds. "We're talking tens of thousands of dollars."
There is, for instance, the case of the Ohio trucking company that recently agreed to pay $41,000 in fines for several small infractions of waste water rules. Among other things, the company neglected to get a permit to install an oil/water separator. In Virginia, another trucking company ended up paying more than $12,500 because it didn't have a Spill Prevention, Control and Countermeasure (SPCC) plan for its above-ground fuel-storage tanks.
Then there's the Tennessee fuel transporter who reportedly faced more than $100,000 in fines for its lack of an SPCC plan. The oversight was discovered when late-night vandals shot a hole in one of the company's above-ground storage tanks and fuel spilled into a nearby creek.
Luckily, the flood of shop-related regulatory rules seems to have subsided. One change, made last summer, actually simplifies SPCC compliance for trucking companies that store fuel and oil. Under the old rules, you counted just about every container on the premises to determine if you meet the 1,320 gallon total that triggers the need for an SPCC plan. Now you only count containers that are 55 gallons or larger. Also, EPA dropped SPCC requirements for a single above-ground container of 660 gallons or more, setting a single threshold at 1,320 gallons.
While the lull may be temporary, it gives shop or environmental compliance managers a chance to get their houses in order. Where to start? With a plan, says Augenstein.
Even if you are in compliance with specific requirements, such as an SPCC plan or a storm water runoff permit, every trucking company with a shop, truck wash and/or fueling facilities should have an umbrella plan covering pollution prevention, emergency procedures and employee training, he advises.
"You need internal procedures in place, such as audits where you periodically inspect the shop and grounds for compliance," he advises. "You need procedures to keep track of permits and recording obligations." A plan, he adds, doesn't prevent pollution, "but it assures that if you do have a problem, you have written procedures so people know what to do."
Another too-common omission is training. "It's pretty obvious to me that many trucking companies do not have the budget and don't provide the time necessary to train their environmental managers, their facility managers and their technicians on the appropriate level of environmental good practices," he says. "There are all kinds of other training that has to be done, so environmental training often takes a back seat."
Last, but hardly least, many carriers don't pay enough attention to record-keeping. It should be no surprise to an industry accustomed to safety audits that paperwork plays a key role in determining whether or not a shop is in compliance with other government rules. "You don't want to forget record-keeping," says Augenstein. "When EPA comes in, they look at records. That's one of the major ways they find violations."
Fortunately, there are plenty of resources for assistance. A catalog of Automotive Environmental & Safety Engineering products and services is available on the Internet at www.EnviroSafeShop.com or by calling (419) 422-1200. Another commercial source for environmental compliance assistance is J.J. Keller & Associates, www.jjkeller.com or (800) 327-6868.
The American Trucking Assns.' Green Truck, located at www.greentruck.com, has environmental-related news, federal and state contacts and compliance guides. The EPA web site, www.epa.gov can be searched for regulations and compliance assistance. Most state environmental agencies have centers that can answer specific questions.
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