From: William Bertele, P.E. (email@example.com)
Date: Sat Feb 19 2000 - 07:34:32 CST
One of the best ways to ensure compliance is by means of annual
environmental compliance audits by outside environmental consultants.
For those printing operations where Monitoring & Reporting records of VOC
emissions are required, monthly or quarterly audits of the records is
recommended, in addition to the constant supervision of compliance
requirements, while on site.
For those firms that have on site environmental management or supervisiory
personnel, periodic auditing by outside environmental consultants is
recommended, as well as membership in various industry & environmental
organizations, i.e. PNEAC, AWMA.
To keep up to date with regulations and environmental technology,
subscriptions to trade & environmental journals as well as attendance at
trade and environmental conferences & seminars is also recommended.
Accurate records of permit applications as well as documentatoin of why or
where permits are not required, should be maintained. These records should
include a reminder file or schedule of permit renewals, as well as a
schedule of required enviornmentally required actions, i.e. periodic
monitoring & reporting report summaries, annual emission statements, removal
of stored HazWaste materials.
William Bertele, P.E., DEE
163 North Sugan Road
New Hope, PA 18938
----- Original Message -----
From: Kevin Dick <firstname.lastname@example.org>
Sent: Friday, February 18, 2000 2:50 PM
Subject: Re: Effective compliance assistance tools
> It's important to place compliance assistance tools in perspective. A
> screwdriver may be a good tool for one job, a hammer for another. Neither
> one is any good if the user doesn't know what's broken or what they're
> trying to fix, or where the screwdriver or hammer is located.
> I don't think it's possible to decide which is better overall.
> I think the context in which tools are provided and used is perhaps more
> important. Compliance and pollution prevention are processes of
> improvement. Our program has found that relationships are established
> businesses over time and that the businesses typically address different
> compliance or P2 issues over time. Therefore having a place to call or
> someone to work with on-site is important. We've found seminars and
> newsletters to be very effective as well. All these components work
> together. Businesses need to have confidence in the source of the tool.
> You probably wouldn't trust a tool very much that you bought at the 99
> store. Reputation of the source is important.
> During each type of contact we have with business we provide information
> in most cases compliance assistance tools. We find that typically tools
> most effective if they aren't preachy, thou shalt, or threatening of other
> consequences. These turn business people off. The best materials are to
> the point, not to much information about regulations they don't need to
> know, but what they need to do, or should consider doing, and how to do
> The best tools are tailored to the businesses they are provided to. This
> means state and local requirements are addressed and appropriate contacts
> included. Businesses need to know where to go, so phone numbers,
> etc of vendors or additional sources of information are included. The
> suggestions provided need to work, be proven, and cost-effective.
> The most effective tools are ones that are used by and motivate businesses
> to improve their operations. Businesses respond when they believe the
> or information provided are designed with their best iterests in mind.
> Again the source reputation or that of the program or person delivering
> information is very important. Businesses are in business to provide a
> product or service. Too many materials are designed with the perspective
> that the business focus is protecting the environment.
> It's easier to identify tools that I don't think are very good.
> Interesting information which I don't consider to be useful tools include
> demographics and enforcement statistices by EPA Region, compliance manuals
> that include the history of RCRA or CAA legislation,
> huge studies that evaluate alternative product formulations and provide
> chemical characteristics of the products and not product names a business
> can identify.
> Some folks seem to really like teleconferences, especially at the national
> level. I don't. The conferences can't be at a good time in every time
> zone, and the marketing and logistics can't be justified for the low
> turn-outs we've had at teleconferences vs. our training seminars. We find
> that few people respond with calls or faxes of questions and that the
> information may not be targeted to the concerns of our businesses. I'd
> rather get videos we can loan.
> Some of my thoughts, right or wrong,
> Kevin Dick
> Business Environmental Program
> Nevada SBDC
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