We all know that managing the complexity of a manufacturing plant is a tall order, and managing it completely within the guidelines of ever-changing environmental regulations is taller still. Even the best EHS manager may end up with an  EPA Notice of Violation (NOV) and the accompanying  Supplemental Environmental Program (SEP) fine. This is certainly no time for joy, but there is a way to make lemonade out of lemons.

Intelligent use of the SEP money can shore up the company infrastructure to prevent a recurrence. This is windfall money that ultimately increases the quality of your company and the company’s bottom line. 

Chemical Safety’s EMS software can and has been used as part of a company’s SEP in response to an EPA Notice of Violation. This is how it is done:

From the EPA website, the characteristics of an SEP are:

• There must be a relationship between the underlying violation and the human health or environmental benefits that will result from the SEP.
• An SEP must improve, protect or reduce risks to public health or the environment, although in some cases an SEP may, as a secondary matter, also provide the violator with certain benefits.
• The SEP must be undertaken in settlement of an enforcement action as a project that the violator is not otherwise legally required to perform.

Further information can be found here.  EMS can help correct a multitude of common violations, both directly and indirectly, including:

• Proper labeling of hazardous waste
• Maintaining adequate staff training records
• Maintaining inspection records
• Generating uniform manifests, LDRs and ERGs
• Generating accurate and timely regulatory reports
• Managing time limits (open waste containers, open manifests, permit due-dates, etc.)
• Flagging products/orderds based on regulatory restrictions (TSCA, FIFRA, REACH, etc.)

Having a system in place to avoid violations is preferred, but satisfying the enforcement settlement while improving processes is another intelligent option.  Please contact Chemical Safety for further information.