CEA offers an array of EHS compliance services to its Clients including providing Outsourced EHS Support, EHS Compliance Auditing, Preparation of Environmental Compliance Plans and Safety Plans (PSM/RMP), Environmental Permitting, Industrial Hygiene Services, and Hazardous Waste Management consulting.
Outsourced EHS Staffing Solutions
Our clients find that it will frequently make sense to outsource part or all of their EHS function to meet the increasing burden of EHS regulations. CEA can provide clients with an assigned and dedicated on-site EHS professional for a flexible number of hours per week, as deemed necessary by the client. Hiring an CEA on-site EHS professional allows companies cost-effective access to a seasoned EHS expert and ensures the fulfillment of all necessary compliance obligations efficiently and proactively without adding headcount. To facilitate the development of a productive, on-going relationship between our clients and on-site professionals, we ensure that the same professional works with each client every time.
CEA Consultants on-site professionals specialize in the following areas:
- Chemical Hygiene and Lab Safety
- Waste Management
- Radiation Safety
- Industrial Hygiene –Occupational
- Health & Safety
- Environmental Compliance Management
- Wastewater Permitting & Compliance
- Air Quality Permitting & Compliance
We do our best to match the best available staff with the client’s needs and understand that the HS professional must also be a fit with the firm’s existing EHS team and corporate culture. We have experience placing EHS professionals in these roles and will carefully tailor the individual to your needs. We understand that the CEA professional we send to your site becomes an extension of your staff and that their performance directly impacts the firm’s reputation.
EHS Facility Compliance Audits
CEA’s team of experts perform EHS Compliance Audits to determine whether a facility is in compliance with all applicable State and Federal laws, regulation and policies. Compliance auditing typically involves a review of all chemical usage and hazardous waste generating processes occurring at a facility as well as a review of all environmental discharges and/or emissions occurring at the facility and any associated permits. CEA then reviews all available monitoring data and records for the regulated discharges and emissions to assess compliance with the permits. CEA also performs inspections of chemical and hazardous waste storage areas for compliance with all applicable regulations.
CEA uses audit protocols which have been developed by EPA to assist and encourage facilities to perform audits and to promote consistency among regulated entities when conducting environmental audits. The protocols are also intended to ensure that audits are conducted in a thorough and comprehensive manner. CEA often discovers gaps in a facility’s compliance plans when conducting audits, such as identifying an upgraded or new process or system not incorporated into the current plan. This often occurs with large or small quantity generators for which contingency plans have been developed but may be obsolete due to a change in the volumes or types of wastes generated. CEA may then prepare a report which identifies areas of non-compliance and provides recommendations for correcting deficiencies.
Preparation of Environmental Compliance Plans
The regulatory framework facing our clients has become increasingly complex, requiring annual submittal of a wide variety of reports and plans to keep the operation compliant. CEA has the expertise and licensed staff to prepare the engineering reports and plans required to alleviate part of this ongoing burden. Two of the most common plans that clients are responsible for include:
SPCC Plan: Under 40 CFR 112, the Spill Prevention, Control and Countermeasures (SPCC) rule establishes requirements to prepare and implement SPCC Plans. The purpose of an SPCC Plan is to form a comprehensive oil spill prevention program that minimizes the potential for discharges. The SPCC rule applies to facilities that are non-transportation-related; have an aboveground oil storage capacity of more than 1,320 U.S. gallons or a completely buried oil storage capacity greater than 42,000 U.S; and could reasonably be expected to discharge oil to navigable waters or adjoining shorelines in quantities that may be harmful.
SWPPP (Stormwater Pollution Prevention Plan): The Clean Water Act requires that certain businesses (defined by industrial classification) prepare a stormwater pollution prevention plan to ensure appropriate erosion control, monitoring of discharges and regular inspections of facilities. These requirements are also intended to cover a broad array of new construction projects where more than one acre will be disturbed by the project. CEA has the engineering expertise to determine the requirements for your facility or project.
In addition to SPCC Plans and SWPPPs, CEA is well versed in other engineering and environmental plans and reports that are required by Federal and State regulations. The following are examples of these report requirements:
- Integrated Contingency Plans: An upgrade of the SPCC Plan required for certain facilities with larger above ground storage of petroleum or chemicals
- Hazardous Material Business Plans: Required in California for storage of defined hazardous materials
- Discharge Monitoring Reports: Required for NPDES regulated facilities to report on discharge of industrial pollutants
- Greenhouse Gas Reporting: Due to the increased pressure from customers and investors to have industry disclose emissions, our experts can help design and implement GHG inventories and reporting strategies for the Global Reporting Initiative (GRI) and the Carbon Disclosure Project (CDP).
Process Safety Management/Risk Management
Facilities that utilize above threshold quantities of hazardous materials are required to comply with OSHA process safety management requirements and in many cases must also comply with the USEPA Risk Management Program planning requirements. The OSHA PSM requirements are focused on trying to protect worker health & safety and to ensure the process equipment meets appropriate standards, is routinely tested and that emergency measures are in place should a release occur. The RMP is intended to protect the neighbors of facilities that manage large volumes of hazardous chemicals as part of the manufacturing process. Essentially the RMP is a planning process that attempts to predict the extent of impacts exterior to the plant should a catastrophic release occur. The RMP also identifies mitigation measures to reduce the impact of the potential catastrophic release, and provides an emergency measures plan should an exterior release occur. CEA’s engineers and industrial hygienists have the experience to perform the following scope of services to support clients’ PSM & RMP needs:
- Screening to determine applicability of PSM and RMP programs
- Process hazard analysis to determine critical components involved in managing and processing hazardous chemicals
- Evaluation of Leak Detection Program for PSM Compliance
- Develop PSM Program to comply with OSHA requirements
- Perform Off site Consequence Analysis for RMP
- Review operations to recommend risk reduction measures
- Prepare RMP plans to comply with CAA requirements
- Provide PSM/RMP training
CEA can provide updates to your PSM and RMP plans to reflect changes to chemical used, manufacturing processes or procedures.
Environmental Permitting (CAA, NPDES, USTs, RCRA, CWA, NEPA)
Capital project expansions require careful planning and coordination, as well as a complete understanding of environmental review and permitting requirements. CEA has the subject matter experts to assess the environmental permitting requirements for a new project or permit modifications required for permit renewal or plant expansion. Environmental permitting requirements can include water, wastewater, air, solid and hazardous wastes, process safety, stormwater, noise, and underground and above ground storage tanks. Larger capital projects may require more elaborate state or federal environmental review to determine project need, and can require a comprehensive approach for project permitting.
The CEA team has routinely worked with our clients to obtain the following environmental permits/approvals that are required for commercial and industrial operations:
- NPDES Permit for Wastewater discharges
- CAA Air Permits under New Source Performance Standards or National Emission Standards for Hazardous Air Pollutants
- State Permits for Above ground and underground storage tanks
- State and local permits for storage of chemicals or petroleum
- RCRA Permits for TSDF facilities
- Army Corps of Engineers Wetlands Permits (Section 404 of the Clean water Act)
- Mining permits for borrow or large excavations
- Stream crossing permits
- Cultural resource review
- NEPA Assessments
CEA understands that permitting is a time sensitive activity that is mission critical for project start or continuation of facility operations. As such, the CEA permitting team is highly responsive, adept at advocating our client’s position and focused on meeting project deadlines.
Hazardous Waste Management Compliance
CEA provides hazardous waste management consulting services to our clients primarily by establishing procedures for the handling of potentially hazardous chemicals at their facility. Such services are designed to assist a facility in complying with all applicable hazardous regulations, and to facilitate protection of the environment and the community. CEA services include: auditing and review of current waste generation and on-site handling practices, review of waste tracking processes, development of waste management plans, third-party waste inspections, and determination of waste disposal options.
Industrial Hygiene Services
CEA’s team of certified industrial hygiene professionals (CIHs) perform a broad array of industrial hygiene services at commercial and industrial facilities. In many instances our industrial hygienists are required to assess occupational risk within the workplace. These occupational exposure assessments are intended to assess the health effects associated with working with various chemicals, materials, equipment noise, physical hazards, and radiation in the workplace. Because the impact of any occupational exposure is dependent on the duration of the exposure and the dose, the industrial hygienist will obtain samples on the manufacturing floor from a cross section of the exposed population to understand potential health effects.
The level of assessment performed can range from a more qualitative exposure assessment where only a few representative samples are collected to a more quantitative exposure assessment where intensive sampling over multiple shifts is performed. The results from the sampling program are compared to various short to long term exposure criteria to assess whether the risk to workers exceeds regulatory thresholds. CEA’s CIHs can provide the following industrial hygiene services:
- Perform noise surveys for hearing conservation programs
- Evaluation of respiratory protection programs (including FIT testing)
- Assessment of PPE and monitoring programs
- Design and implement occupational exposure sampling and analysis program
- Develop mitigation programs to reduce or eliminate occupational risk for certain jobs or tasks
- Ascertain occupational exposure risk to workplace population subsets
- Develop machine guarding program to reduce injuries
- Prepare biosafety program to comply with OSHA requirements
CEA’s CIH’s are seasoned professionals that have decades of experience within a variety of industries and can handle a wide range of challenging occupational issues.