10 Tips to Manage Risk

Joseph Catanese

For many, New Year's is more than just a time to sing Auld Lang Syne off-key. It's a time to make New Year's resolutions and improve upon old habits. For waste management professionals, the new year also can be an appropriate time to renew a commitment to improve on managing your business' risks.

Of course, effective risk management practices help keep the environment and employees healthy and safe, but they also can prevent potential financial losses and control insurance costs.

Insurance firms are good sources for identifying risk management areas that require the most attention. Here are 10 ways waste professionals can improve on risk management, and control potential liabilities:

1. Keep up-to-date on applicable environmental regulations. Environmental regulations change frequently and, by staying informed, you can help control costs. For example, you can more effectively manage environmental consultants if you understand the regulations affecting an operation. Environmental regulation information is available from state environmental agencies, other waste facility managers and on the Internet. At a minimum, a copy of the state's solid waste regulations will help you prepare for a review.

2. When hiring an environmental consultant, carefully define his role. Create an ironclad contract that details the consultant's tasks, and monitor progress to ensure the project stays on track and within the contracted budget. Also, be familiar with federal, state or local regulatory agency contacts because consultants typically interact with them to ensure their progress. Remember, even if management personnel isn't present when the consultant and regulatory agency negotiate a settlement, the company still is responsible.

3. Develop an orientation program for contractors and subcontractors entering your site. An orientation program should identify the party responsible for contacting the utilities, areas the contractors should refrain from entering and activities that should not be conducted unless approved by management. If a consultant supervises a contractor, be sure the consultant enforces these provisions. The consultant also should provide management with a daily log outlining the contractor's activities.

4. Develop plans for spill prevention, control and countermeasure (SPCC), stormwater pollution prevention (SPP), and other advanced emergency response programs. Storage tanks (aboveground and underground) can negatively impact surrounding surface water bodies or groundwater aquifers through spills, leaks or catastrophic failure. In addition, lagoons or other impoundments that fail could harm adjacent properties and waterways. Developing SPCC and emergency response plans can lessen potential financial and environmental impacts.

5. Provide secondary containment and integrity testing for aboveground storage tanks (ASTs). Do not assume that storage tanks are indestructible because they are new or have passed integrity testing. Tanks must be visually and mechanically tested regularly, and secondary structures must be provided to minimize the environmental impacts of a tank failure or accidental release. Companies always should document inspections. A concrete pad installed under and adjacent to the tank (or fuel dispensing area) will minimize impacts of fuel seeping into the soil, groundwater or surface water through spillage.

Also, affix signs required by state or local regulatory officials. If inventory control is the preferred method, only continuous documentation will highlight lost inventory and potential leaks.

6. Train employees continually. Training can minimize future environmental and health and safety complications. Train employees in fire extinguisher use, Washington D.C.-based Occupational Safety and Health Administration (OSHA) Hazwoper first responder techniques, hazardous waste identification, emergency response techniques, general first-aid and bloodborne pathogens. These techniques can minimize landfill disruption, costly remediation and workers' compensation claims. Documenting an employee training program demonstrates that the company is serious about maintaining a safe facility, in addition to adhering to OSHA requirements.

7. Establish a hearing conservation program as part of a health and safety plan. Monitor workplace noise levels and determine potential employee exposure. Decibel levels near a truck, compactor, backhoe or bulldozer can exceed 100 decibels, and personnel exposed to these levels daily may experience hearing loss. Show employees how to use hearing protection equipment and insist that it be used.

8. If applicable, have a designated health and safety officer (HSO) who can track personnel training, monitor consultants' onsite activities and review site specific health and safety plans (SSHASPs). Prepare these plans when hazardous onsite activities take place and to prevent dangerous practices. HSOs can relieve the operations manager from overseeing all onsite construction.

9. Create a screening program to teach landfill scalehouse workers to recognize unacceptable incoming loads. In addition to ensuring compliance with state and Subtitle D regulations, a screening and load inspection program warns illegal dumpers that the landfill is watching for unauthorized wastes. Equipment operators should document a load inspection at least once per week or according to state regulations.

10. Dedicate a space for your environmental, health and safety records. Segregate incoming waste profile and scalehouse information, compliance monitoring information, vehicular and equipment maintenance, training documentation, and landfill personnel records. A sure way to receive a notice of violation (N.O.V.) or OSHA site audit is to have your records in disarray. Make sure records are up to date and in order.