In this age of consolidation and personnel reduction, regulatory personnel are also feeling the pinch. Businesses are trying to do more with less - less inventory, less lead-time, less overhead. For locations with both a safety and an environmental person, more and more often, these positions are being consolidated into one. While there is much overlap between these areas, there are sufficient differences. Typically, at the base level, safety compliance, since it deals with cultural change and people issues, tends to be more people-oriented. Environmental compliance, on the other had, tends to be more of an exercise in intellect. That is not to say that environmental professionals are smarter than safety professionals - far from it. However, environmental compliance tends to focus on meeting specific regulatory limits, using specifically identified methodology. Safety compliance, on the other hand, deals with behaviors of the individual, and therefore, the successful safety professional must, in my opinion, be more empathetic. So, with these differences being what they are, what does the safety professional need to know to make sure you are the one who remains if consolidation of responsibilities does occur? Using what Darwin teaches, you must be "the fittest" to survive. You must be more adaptable than your counterpart, and to do that, you must have the most useful knowledge.

What are the Major Environmental Programs?

As anyone who has looked at the Code 40 of the Federal Regulations, there are many, many different regulations. As with 29 CFR, it knowing what does and does not apply takes time and understanding. However, there are 6 primary regulatory areas that everyone should have an understanding of:

  • Resource Conservation and Recovery Act (RCRA)

  • Air Emissions Control

  • Risk Management Plans (RMP)

  • Spill Prevention, Countermeasure and Control (SPCC)

  • National Pollution Discharge Elimination System (NPDES)

  • Emergency Planning and Community Right-To-Know Act (EPCRA)

You must understand - the information presented in this paper merely scratches the surface of what you must know. To be fully informed of all the requirements would involve many hours of training. This information is designed to provide you with a broad-brush understanding of the requirements.

The Resource Conservation and Recovery Act

The Resource Conservation and Recovery Act, known as RCRA, was passed in 1976. It was designed to ensure that hazardous wastes are controlled, limited, and minimized from "Cradle to Grave" - in other words, from the moment that the material becomes a waste (no longer able to be used or sold), until its is no more. These regulations are covered in 40 CFR 262 - 265.

One mistake that many have experienced when dealing with RCRA regulations is the understanding of what we mean when we say "GRAVE" in "cradle to grave". Many have assumed that once the material has been sent to the disposal company, their responsibilities are over. There is nothing further from the truth. Just look at the number of companies that get identified as Primary Responsible Parties, or PRP's, in major environmental cleanups.

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