Modern Change Management: Planning for Environmental Compliance

June 12, 2017
A comprehensive management of change process is critical to ensuring efficient and effective facility upgrades, expansions or process improvements.

Whether adding a new manufacturing line, evaluating product formulation changes or upgrading facility utilities or infrastructure, a defined process whereby all internal stakeholders participate is key to including all pertinent factors in the planning and decision-making process. One area that may be overlooked or brought into change management late in the game is environmental regulatory compliance. Environmental factors simply may not be on the radar screen of project management teams.

Environmental regulations can, however, have a significant impact on proposed changes at a facility, in that they often require special permits, registrations or reporting, mandate specific designs or operating standards or prohibit certain activities altogether. While other pieces of the management of change (MOC) process historically have received top billing, when it comes to prioritizing each component, incorporating environmental considerations into your MOC process can be very useful in helping to avoid potentially costly project delays or a required project redesign.

Even if your facility does not have a formal MOC process, identifying environmental considerations and beginning to establish guidelines for evaluating projects can help environmental or facilities managers ensure environmental compliance by considering key factors through the right lens when making facility or operational changes.

Identifying Environmental Considerations

The first step in establishing a process to maintain environmental compliance through facility changes is to identify potential circumstances or conditions that could impact an existing environmental compliance obligation or trigger a new one. For example, if a facility is subject to the requirement to maintain a spill prevention, control and countermeasure (SPCC) plan, installing a new oil storage tank, such as a tank associated with a boiler or an emergency generator, would require updating the SPCC plan. But if a facility was not already subject to the SPCC regulations, the addition of a new oil storage tank could place the facility over the regulatory threshold and trigger new obligations.

Don't only consider the regulatory requirements to which your facility already is subjected be aware of potentially applicable regulations and what could pull your facility into the regulated realm. Be sure to consider all programs and media, including chemical/oil usage, storage, manufacturing and importing, waste generation, wastewater discharges, stormwater impacts and air emissions.

Developing a tool so you don't need to begin from scratch each time a new project is proposed also is helpful. Create a comprehensive checklist of environmental considerations that could be involved with potential projects at your facility during the installation or construction phase of the project and in its ongoing operation. If your company has an environmental management system (EMS), some of this information already may be captured in your assessment of environmental aspects and compliance obligations. It usually is most helpful to organize your checklist by program/media.

If waste will be generated as part of project construction, development or implementation, there are some questions to ask to proactively identify and plan for new or changing waste management requirements, including:

  • What types of wastes will be generated (soils or remediation materials, construction and demolition debris, hazardous building materials, chemicals/process waste) and in what quantities? List constituents for any process wastes.
  • Will wastes be generated over a long period of time?
  • Where and how will the wastes be stored onsite?
  • Is the facility or a contractor responsible for arranging disposal?
  • Are there restrictions for on site excavation due to environmental land use restrictions based on past contamination?

If waste will be generated from a new ongoing process, then these questions need to be answered:

  • What types of wastes will be generated? Are the waste streams consistent or changing?
  • What are the constituents for any process wastes? Do these have an impact on other environmental requirements such as those associated with toxic release inventory reporting or wastewater discharges?
  • Is the waste stream generated continuously or intermittently? What quantities will be generated? Do the quantities change the site's generator status?
  • If a satellite waste accumulation area is required, where will it be set up?
  • Are there any special environmental or safety requirements for storing the waste in the satellite area or storage area?

This is just a start, and each of these questions can lead to additional questions. The important thing to consider is your facility's circumstances, and develop questions that will allow you to evaluate potential projects for environmental regulatory impacts.

If your facility doesn't happen to have in-house staff with the knowledge to develop the checklist, hiring a compliance specialist to conduct an assessment for your facility is a great way to identify environmental considerations and points of vulnerability. While some may be reluctant to spend money for this service, the return on investment you will see from avoiding penalty fees, project delays or unexpected permitting costs can make it worth it in the long run.
Establishing a Process

Once your checklist of environmental considerations is developed, it must be incorporated into the facility's existing MOC process. To facilitate smooth integration, try to coordinate with existing MOC processes as much as possible. For example, some facilities use spreadsheets with different tabs for the different areas of consideration during the MOC review: sheets for safety, contracting and operational impacts, for example. Adding an environmental sheet to the review won't disrupt the existing process.

If your facility does not have a formal MOC process, you still can use your environmental considerations checklist to evaluate the potential impacts of a proposed change by working with the project team members to obtain the information.

Whether part of a formal or informal MOC process, involving the right people at the right time is critical to conducting an effective evaluation. Determine who at your facility is likely to have the knowledge necessary to properly evaluate the potential environmental impacts during the MOC process and be sure to include them in your review. General management, engineering and facility maintenance staff, lean teams, safety managers and others may have pertinent information for your MOC evaluation.

Good and frequent communication also is critical. Once project teams are exposed to the environmental considerations checklist a few times, they proactively may seek you out when planning new projects.

Even small changes potentially can have a large impact on your regulatory requirements; so, it's important to have a process that's scalable for projects of any size. While you obviously want to apply MOC to the installation of a new emergency power generator, something as simple as changing a chemical in a process can have significant implications that should be evaluated. The new chemical could impact air emissions limits, create a new hazardous waste, affect your wastewater treatment system, require changes to written environmental plans or trigger Tier II, Toxic Release Inventory or Toxic Substances Control Act reporting.

And these only are the potential environmental impacts. Even a change as simple as introducing a new chemical can have far-reaching impacts on your health and safety program and even could make your facility subject to Department of Homeland Security or Department of Transportation regulations.

Including this evaluation of environmental considerations early in the project planning process can be critical to a given project's schedule. For example, an air permit may be required prior to installing a new emissions source, such as a boiler, and the permitting process can take several months. If this requirement is not identified early on, costly delays can be incurred. Working closely with project teams and operations personnel so they understand the importance of identifying and evaluating environmental implications up front will help them in defining a more comprehensive project scope and accurate timeline. 

Change is inevitable at any place of business. Through careful planning and coordination, change does not have to be at odds with maintaining compliant environmental programs.

Identify environmental considerations potentially applicable to your facility, develop a tool or checklist to consistently evaluate how the environmental considerations may be impacted by proposed facility changes and work with your management team to incorporate this evaluation early in the project planning process. Everyone will benefit through avoidance of extra costs and project delays and improved environmental compliance.

Becky Corbin, CHMM, CPEA, is a project manager on Woodard & Curran's Compliance Services Team. She works with clients nationwide, helping them identify and manage their environmental, health and safety responsibilities and to develop and implement EHS programs and management systems.

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