ChemAlliance's feature articles provide useful information about effective regulatory compliance and environmental management strategies for the process industries. Articles cover topics ranging from new rule making, compliance strategies, tips for moving "beyond compliance" and timely perspectives from industry peers. All of our articles include relevant web links so you can "dig deeper" into the subject.
Recent Additions
Chemical Industry Awaits New Plant Site Security Rules
(originally appeared 12/20/06)
The chemical industry takes seriously the issue of maintaining an appropriate level of plant site security. Since the tragic events of 9-11, members of the American Chemistry Council (ACC) alone have invested more than $3.5 billion enhancing security at their facilities throughout the US. Trade associations such as the ACC, Synthetic Organic Chemical Manufacturers Association (SOCMA), National Association of Chemical Distributors (NACD) and the National Petrochemical & Refiners Association (NPRA) have developed various security management practices for their members to implement and maintain security programs, with implementation often necessary for continued membership. As much as 90% of industry companies have security programs in place at this time.
Hurricane Season Rapidly Approaches: Lessons Learned and Tips for Weathering the Next Storm
(originally appeared 05/22/06)
June 1 marks the official start of the U.S. hurricane season and forecasters expect it will be a busy one. That is not the news that chemical facilities wanted to hear after suffering through hurricanes Katrina and Rita in 2005. Many plants in the Gulf region have taken several steps to improve their ability to weather an intense storm based on lessons learned last fall. In this article from 2006, ChemAlliance contributor Cynthia Challener reviews some of the insights gained from Hurricane Katrina, and highlights actions that chemical process facilities might consider in preparing for the upcoming hurricane season.
Performance Track Offers Value for Chemical
Industry
(originally appeared 05/20/05)
The National Environmental Performance Track (NEPT)
program is a voluntary partnership program that recognizes and rewards
private and public facilities that demonstrate strong environmental
performance beyond current requirements. As NEPT approaches its 5th
anniversary in June 2005, the program operates under the premise that
government should complement existing programs with new tools and strategies
that not only protect people and the environment, but also present
opportunities for reducing cost and spurring technological innovation.
Slightly more than 10% of the 350 current members belong to the chemical
industry. In this article, Cynthia Challener talks with several of these
members about the benefits their organizations have experienced from
Performance Track membership.
Green Chemistry for Sustainability
(originally appeared 05/20/05)
Operating sustainable businesses that provide value-added
products and services with minimal or no environmental impact has become a
top priority for the chemical and process industries. A green approach to
the manufacture and marketing of chemical products is an important aspect of
a successful sustainability initiative. Green chemistry also offers chemical
producers a mechanism for connecting chemicals and chemistry to the consumer
in a positive way. In this article, Cynthia Challener discusses the
principles, benefits, and challenges of green chemistry, as well as
successful initiatives developed by the chemical industry and the EPA.
Building a Chemical Industry Management System –
The Successful Development of the Responsible Distribution ProcessSM
(originally appeared 04/13/2005)
One of the biggest undertakings to which an industry
sector can commit is developing a comprehensive environmental, health,
safety, and security program. For members of the National Association of
Chemical Distributors, the development of the Responsible Distribution
ProcessSM (RDP) in 1991 embodied the chemical distribution sector’s
commitment to improving its environmental and health and safety performance.
Through a program requiring member companies to take specific action steps
towards this goal, and have their actions verified by an independent
third-party, NACD members have successfully demonstrated improved
performance in toxic emissions and workplace incidents. Still, NACD
acknowledges that RDP alone is neither a guarantee in regulatory compliance
nor absolute protection against incidents or public perception. This article
by Bill Allmond, NACD’s Director of Regulatory and Public Affairs, provides
an inside look into how one sector of the chemical industry overcame
considerable challenges to develop a mandatory program and how it continues
to achieve success with its implementation.
Integrating Sustainability Principles in a Small
Chemical Company
(originally appeared 04/08/2005)
In spite of their size, small chemical companies bear
as much responsibility to conduct their businesses in a financially,
socially and environmentally responsible way as large manufacturers do.
Because of their smaller size, these manufacturers can find the thought of
integrating sustainable development activities overwhelming. A myriad of
benefits, including reduced costs, make the effort worthwhile. Commitment
from top management and a thoughtful and practical approach can enable
smaller companies to successfully transform their organizations. Cynthia
Challener discusses the benefits, challenges and specific aspects of
implementing sustainable development into your operations.
What’s Ahead in Environmental Management for
2005?
(originally appeared 03/10/2005)
ChemAlliance recently spoke with contacts in various
government agencies and trade associations to determine what regulatory
developments, management trends, and “hot” issues will be facing
environmental managers in 2005. While no significant “new” issues are
expected in 2005, development of a plan for allocating resources still
remains critical in order for companies to properly manage their
environmental compliance. From the Clear Skies Initiative and chemical
safety to security, innovation and sustainability, Cynthia Challener
discusses the topics that are most on environmental managers’ minds this
year.
Keeping Current with Regulations – Online
Resources for Tracking Environmental Regulations
(originally appeared 09/27/2004)
Tracking all of the relevant environmental
regulations that a company must comply with can be a daunting task. Not only
are there a myriad of federal regulations to contend with, but each state
has its own requirements that must be met. Smaller companies typically don’t
have the resources that are available to larger corporations to maintain
awareness of the changes to existing regulations and introduction of new
legislation. However, it is critical that companies comply with applicable
environmental laws and regulations. In this article, Cynthia Challener
provides several basic strategies that can be utilized to help firms stay
abreast of the constantly evolving regulatory universe.
The Hows and Whys of Environmental Self-Auditing
(originally appeared 08/18/2004)
One of the most effective ways for a company to ensure that it is meeting its environmental compliance obligations is to conduct an environmental self-audit of its facilities and operations.
Monitoring compliance with environmental regulations through a self audit can provide several
benefits to both the environment and the company. In this article, Cynthia Challener discusses how to prepare for an environmental self-audit and the importance it plays in a company’s overall environmental management system (EMS).
Guidelines for Selecting an Environmental
Consultant
(originally appeared 05/28/2004)
The chemical process industries have myriad local, state and federal
regulations that must be complied with and that apply to small and large
companies alike. For small chemical manufacturers, environmental consultants
can provide invaluable assistance in addressing these requirements. Careful
selection of a consultant can provide even small firms with access to
environmental, technical and regulatory expertise that would be impossible
for most firms to maintain in-house. In this article, Cynthia
Challener provides some useful guidelines on selecting a consultant for your
next environmental project.
Miscellaneous
Organic NESHAP “the MON rule” (40 CFR Part 63, Subpart
FFFF)
(originally appeared 04/19/2004)
MACT standards for many chemicals were first
established in 1994. Since then, the EPA has focused its
efforts on regulating HAP emissions from various other
industry source categories. Major sources that did not fit
into a defined source category are regulated by a “catch
all” category for “miscellaneous organic” sources known as
MON (40 CFR Part 63 Subpart FFFF). This article explains
the new MON rule (Miscellaneous Organic NESHAP).
10-Year MACT
Standards for the Chemical Industry: Historical Background and Recent
Proposals
(originally appeared 01/30/2003)
The EPA has recently proposed a revised schedule for issuing 6 Maximum
Achievable Control Technology (MACT) National Emission Standards for
Hazardous Air Pollutants (NESHAPs) of relevance to chemical and plastics
manufacturers. The intent of these standards is to accelerate the use of
advanced technologies to reduce the emissions of Hazardous Air Pollutants
(HAP) and to thereby improve air quality. These standards have important
consequences for some chemical manufacturing facilities. This article
presents an overview of the new MACT standards.
Web-Based Environmental Regulatory
Updates: A 50-State Survey
(originally appeared 04/05/2002)
For environmental health and safety officials and others in the
trenches, state-level regulatory information may be just as important as
federal-level information. ChemAlliance staff performed a review of the web-sites of the 50 state environmental
agencies to determine the degree to which their web-based regulatory
information was accessible and user-friendly, including whether there
were timely updates on impending regulatory requirements and detailed information on rules and
regulations. This short article summarizes the results of our on-line
survey.
Beyond RCRA: Prospects for Waste and Materials Management in the
Year 2020 - An Unofficial Executive Summary
(originally appeared 01/06/2002)
In 1999 the U.S. Environmental Protection Agency (EPA) established a
working group with state environmental agencies to explore the longer-term future of the Resource Conservation and Recovery Act (RCRA). A roundtable
meeting of experts on this subject was convened in Washington, D.C. in September 1999, whose insights were summarized in a separate paper. The
recently released white paper, "Beyond RCRA" follows up this work for the purpose of creatively engaging and stimulating dialogue on the future of our
nation's waste management system, by providing a broad outline of this future,
and the economic, technological and institutional forces that might shape it.
ChemAlliance staff member Barry Solomon provides a synopsis of the paper and how it might affect the eventual
reauthorization of RCRA.
Other Feature Articles
How to Build Performance Into the
Responsible Care® MSV Conformance
Standard
(originally appeared 02/13/01)
Critics of the ISO 14001 EMS standard point out that
the standard is a conformance standard (e.g., focusing on process and
procedure), not a performance standard (which mandates specific
outcomes). What happens when you take the best from each of these
differing approaches to management standards? In this article,
author Bob Pojasek compares the Responsible Care® standard (like
ISO 14001, a conformance standard) with an environmental
performance standard based on the Baldrige model. He goes on to
demonstrate that the best solution may just be one that marries the best
of both.
The National
Environmental Performance Track Program:
An Opportunity for Chemical Companies
(originally appeared 01/26/01)
The US EPA's National Environmental Performance Track Program is designed to motivate and reward top environmental performance. By encouraging a systematic approach to managing environmental responsibilities, taking extra steps to reduce and prevent pollution, and being good corporate neighbors, the program is rewarding companies that strive for environmental excellence. At the same time, many participating companies are finding that they are saving money and improving productivity. In this article, ChemAlliance staff member
Bo Yan and ChemAlliance Co-Director Barry Solomon describe this innovative program of the EPA, the benefits and costs for facilities to participate, and some special consideration for small businesses.
Metrics Will Matter
(originally appeared 10/04/00)
EHS managers pride themselves in utilizing
the very latest software systems to collect and track metrics. The displays are impressive and the reports may give one a good
feeling of being in control. But, according to author Richard McLean, some EHS managers may be winning the battle to efficiently sort
data, but loosing the strategic war to gain competitive advantage for their
companies. Metrics theory and practice has undergone a quiet revolution over the past five years and the
long term business implications are truly astonishing.
Crystal Ball
Gazing: A Critical Examination of the Environmental Profession in
the New Millennium
(originally appeared 10/04/00)
ChemAlliance contributor Richard McLean looks into his crystal ball to see
what's on the horizon for environmental professionals. Reprinted
with permission from EM, Air & Waste Management Association's
Magazine for Environmental Managers.
EPA’s New Chemicals
Program Under TSCA: The Basics
(originally appeared 09/21/00)
The New Chemicals Program is the U.S.
Environmental Protection Agency’s (EPA) program for management of
potential risk from chemicals new to commerce, as mandated by Section 5 of
the Toxic Substances Control Act (TSCA). Anyone who plans to manufacture or
import a new chemical substance for a non-exempt commercial purpose is
required under TSCA Section 5 to provide the EPA with notice before
initiating the activity. This article presents an overview of the New
Chemicals Program.
Understanding and
Using EPA's Chemical Industry Compliance Improvement Tool
(originally appeared 06/01/00)
In September 1998 the U.S. EPA's Office of
Enforcement and Compliance Assurance (OECA) developed the Chemical
Industry Compliance Improvement Tool (CIT). The CIT is a directory of
environmental regulatory resources that is designed to assist the chemical
industry sector and regulators with the task of improving regulatory
compliance. This article discusses three methods for improving compliance
that are presented within the CIT; namely: environmental auditing,
environmental management systems (EMS) and pollution prevention (P2).
EPA Revises
Policies on Self-Audits and Small Business Compliance
(originally appeared 06/01/00)
In the April 11, 2000 Federal Register, the U.S.
Environmental Protection Agency (EPA) issued its revised final Small
Business Compliance Policy and its Audit Policy, to expand the options
allowed under the Policies for discovering violations and to establish a
time period for disclosure. The purpose of this article is to provide the
reader with an outline of the background and distinguishing features that
characterize the revision of the two policies.
New Jersey Chemical Industry
Project: A Sector-based Approach to "Cleaner, Cheaper, Smarter"
(originally appeared 03/17/00)
Beginning in 1995, the U.S. Environmental Protection Agencys (EPA)
Policy Office has been working with the New Jersey Department of Environmental
Protection (NJDEP), U.S. EPA Region 2, and a stakeholder group of industry, environmental
groups and community representatives on a project to help the batch chemical manufacturing
industry in New Jersey adopt a "cleaner, cheaper, smarter" approach to
environmental management. In this feature article, ChemAlliance staff Barry
Solomon and Bo Yan bring you up to speed on The New Jersey
Chemical Industry Project, and how a collaborative approach can make environmental
compliance more "user friendly."
Enforcement Alert: TRI
Reporting Requirements for Nitrate Compounds Includes "Coincidentally
Manufactured" Compounds
(originally appeared 03/18/00)
Under the Emergency Planning and Community Right-To-Know Act (EPCRA), Section 313, certain
facilities manufacturing, processing or using various toxic chemicals must submit reports
to the U.S. Environmental Protection Agency (EPA) and a State-designated agency.
These reporting requirements also apply to facilities that generate water
dissociable nitrate compounds as by-products during wastewater treatment processes. Data
from the TRI suggests that many facilities reporting chemicals such as ammonia, sodium
nitrite and nitric acid, may also have reporting obligations for nitrate compounds.
In this issue of EPA's Enforcement Alert, the reporting
requirements for firms which "coincidentally manufacture" nitrate compounds (for
example, through neutralization of nitric acid) are examined.
Chemical Accident Prevention: Site
Security
(originally appeared 03/18/00)
Facilities that handle chemicals are actively engaged in managing risks to ensure the
safety of their workers and the community. Most of their efforts focus on ensuring that
the facility is designed and operated safely on a day-to-day basis, using well-designed
equipment, preventive maintenance, up-to-date operating procedures, and well-trained
staff. Increasingly, though, facilities are addressing the risks posed by vandalism,
terrorism and sabotage. In this article, the US EPA's Chemical Emergency
Preparedness and Prevention Office (CEPPO) looks at what facilities can do to reduce
chemical risks due to terrorism and sabotage.
note: this article is in Adobe Acrobat (PDF) format.
Proper Monitoring Essential to
Reducing 'Fugitive Emissions' Under Leak Detection and Repair (LDAR) Programs
(originally appeared 12/14/99)
The Clean Air Act requires refineries to develop and implement a
Leak Detection and Repair (LDAR) program to control fugitive emissions. In this article
(adapted from EPA's "Enforcement Alert"), comparison monitoring conducted by the
U.S. Environmental Protection Agency's (EPA) National Enforcement Investigation Center
(NEIC) shows that discrepancies in monitoring methods may result in an under-reporting of
the number of leaking valves and components in some facilities.
Manufacturers, Customers Should Use
Caution in Making Anti-Microbial Claims
(originally appeared 12/12/99)
With increasing public attention on food safety and microbial contamination,
an increasing number of products are claiming to have anti-microbial properties. But
Micro Pen of U.S.A. Inc. recently learned the hard way that product claims that include
anti-microbial characteristics can bring attention from more than customers. The
U.S. Environmental Protection Agency (EPA) has settled an enforcement action with the
Buena Park, CA firm for selling unregistered pesticides. As a result, Micro Pen is
paying a penalty of $35,000...
New RMP Public
Meeting Requirements
(originally appeared 10/28/99)
Now that we've all made it
through the first submission deadline for Risk Management Plans, the topic may seem a bit
old hat. But with passage in August of the Chemical Safety Information, Site Security and
Fuels Regulatory Relief Act (Public Law 106-40), changes have been made to the
requirements for public disclosure of RMP information. Among other requirements, certain
facilities will need to hold public meetings by February 1st, 2000. This
article by Barry Solomon will orient you to these new RMP requirements, and provide links
to resources available to help you meet them.
Joint CMA/EPA
Report Finds Lessons in Noncompliance
(originally appeared 09/01/99)
From August 1996 through October 1998, the US EPA and the
Chemical Manufacturers Association (CMA) worked together on an innovative pilot project
designed to identify the root causes of noncompliance with regulatory requirements in the
chemical industry. With the voluntary participation of more than two dozen chemical
facilities involved in 47 enforcement actions, the project team focused on a "lessons
learned" approach, hoping to find out what could be learned from these non compliance
events, both by industry and by the regulators. In this issue of Enforcement Update, ChemAlliance summarizes the findings of this
newly released report, and provides web resources that to help small manufacturers find
out what you can learn from other people's experience.
Error Propagation
in Air Dispersion Modeling
(originally appeared 08/16/99)
Air dispersion modeling has been an
important regulatory instrument, used to evaluate consequences of accidental and planned
releases. Lately, dispersion models have grown in importance as a result of the
consequence analysis requirements of the Clean Air Act's Risk Management Planning
requirements. But how good are air dispersion models? Author Milton Beychok
provides a provocative discussion of how small errors in some of the underlying
assumptions used in air dispersion modeling can result in large errors in predictions.
Facilities Urged to Review Systems for Risk of Check or
Butterfly Valves Safety Hazards
(originally appeared 08/16/99)
On June 22, 1997, a serious chemical
accident occurred at the Shell Chemical Company in Deer Park, Texas. The accident resulted
in injuries to several workers and more than $100 million worth of damage to the Shell
Plant. As a result of the accident, the U.S. Environmental Protection Agency (EPA) and the
Occupational Safety and Health Administration (OSHA) released a joint accident
investigation report, the "Shell Report" to determine the root cause and
contributing factors of the accident, and to make recommendations to prevent similar
accidents.
Complying with OSHA's New
Respirator Standard
(originally appeared 06/06/99)
Many chemical industry workplace situations involve
toxic substances for which engineering controls may be inadequate to control exposures.
Respirators are used in these situations as a back-up method of protection. Mark
Bordelon looks at the major requirements of OSHA's standard on respiratory
protection, as revised in 1998.
Chemical Educational Foundation Gets
the Word Out on Product Stewardship
(originally appeared 06/02/99)
Helping customers, suppliers and communities understand the
safe handling of chemicals and how they can reduce the risks is an important part of
environmental management. Jennifer Aleknavage of the Chemical Educational
Foundation describes some of the very useful resources available through the CEF's website
for helping your community understand chemical product stewardship.
Toxic Release Inventory Reporting
Requirements for the Chemical Sector
(originally appeared 05/28/99)
In May of 1997 the EPA issued a final rule that
expanded the reporting requirements of toxic chemical releases to several new segments of
the chemical sector. Qualifying commercial hazardous waste treatment facilities,
chemical and allied products wholesalers, petroleum bulk stations and terminals, and
solvent recovery service facilities are required to submit their first toxic release
inventory (TRI) reports as of July 1, 1999. Jeff Myrom reviews the
TRI reporting requirements under Section 313 of the Emergency Planning and Community Right
to Know Act (EPCRA §313).
Aquarium and
Pond Chemicals May Require Federal Registration and Labeling as Pesticides
(originally appeared 05/14/99)
Can marketing claims lead to regulation under FIFRA? Under
the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), pesticide products must be
registered with the EPA and bear EPA-approved labeling before they can be lawfully sold or
distributed in the United States. Products claiming to prevent, destroy, or repel
pests, including bacteria and viruses, are considered pesticides - regardless of their
toxicity or effectiveness. EPA has taken several enforcement actions involving the sale of
unregistered pesticides used to control algae and bacteria in aquariums and garden ponds.
Recent enforcement actions have included orders to stop the sale of certain products. Virginia
Bueno, Editor, EPA's Enforcement Alert Newsletter describes these
enforcement actions, and talks about registering and labeling these chemicals.
Designing P2 into the
Process
(originally appeared 10/20/98)
You don't need to wait change the process chemistry
to begin building pollution prevention into the process. Scott Butner
looks at why addressing pollution prevention during equipment design and
specification can often be a cost-effective route to building savings into the process.
Use this Checklist to Improve Your Process!
(originally appeared 10/20/98)
Rick Grote shares a checklist of pollution prevention strategies for chemical manufacturers.
