USACERL Environmental, Health and Safety Protocols
are organized in a similar manner and for the purposes
of illustration the following is a description of
the Environmental Team Guide. The chapter associated
with the Occupational, Safety and Health protocol
for the Construction Standard may
be reviewed here
and the General Industry Standard
is located here.
Facilities engage in many operations and activities
that can cause environmental impacts on public health
and the environment if not controlled or properly
managed. Many of these activities and operations are
regulated by Federal, state, and local regulations,
and by internal regulations/policies.
After a review of these activities at facilities,
it is apparent that there are major categories of
environmental compliance into which most environmental
regulations could be grouped. The Team Guide is divided
into 13 sections that correspond to major compliance
Air Emissions Management
Cultural Resources Management
3. Hazardous Materials Management
Hazardous Waste Management
Natural Resource Management
Other Environmental Issues
Petroleum, Oil, and Lubricant (POL) Management
Solid Waste Management
Storage Tanks Management
Toxic Substances Management
Water Quality Management (potable water).
Each section is organized in
the following format:
Applicability. This provides guidance
on the major activities and operations included
in the section and a brief description of the major
Federal Legislation. This identifies,
in summary form, the key legislative issues associated
with the compliance area in the Federal law.
State/Local Requirement. This identifies
the typical compliance areas normally addressed
in state and local regulations. This section does
not present individual state/local requirements.
An assessment of state and local requirements must
be conducted and supplemental questions prepared
to cover these requirements. The guide is prepared
in loose-leaf form to allow state and local requirements
to be inserted easily.
Key Compliance Requirements. This
summarizes the significant compliance requirements
associated with the regulations included in the
checklist. It is a brief abstract summarizing the
overall thrust of the regulations for that particular
Key Compliance Definitions. This
presents definitions taken from the Code of Federal
Regulations (CFRs) for those key terms associated
with each compliance category.
Records To Review. This lists documents
and records that should be reviewed during the assessment
process for each section.
Physical Features To Inspect. A
list of facilities and activities that should be
assessed for compliance with that section.
Guidance for Checklist Users. This
is a table of contents for the following checklist.
Compliance Assessment Checklists.
The final portion of each section and its appendices
contain checklists composed of requirements or guidelines
that serve as indicators to point out possible compliance
problems as well as practices, conditions, and situations
that could indicate potential problems. These checklists
are intended to focus attention on the key compliance
questions and issues that should be investigated.
Please click here
for a download of a sample portion of the Team Guide
including the checklists.
Explanation of Layout/Content.
The checklist portion of the assessment section
is divided into two columns. The first of these
is a statement of a requirement. This may be a strict
regulatory requirement, in which case the citation
is given, or it may be a requirement that is considered
to be a good management practice to maintain compliance,
but which is not specifically mandated by regulation.
The second column gives instructions to help conduct
the compliance assessment. These instructions are
intended to be specific action items that should
be accomplished by the investigator. Some of the
instructions may be a simple documentation check
that takes a few minutes; others may require physical
inspection of a Federal facility.
Checklist Item Numbering. The checklist
items are each assigned a three-part number. The
first part of the number indicates the section the
checklist item is in (i.e., SO for Solid Waste Management,
HW for Hazardous Waste Management). The second part
of the number indicates the topic within the section.
For example, in Appendix 3, the first topic is All
Federal Facilities (SO.1). In Appendix 4, the requirements
for small quantity generators (SQGs) are spread
out among several topic numbers. This second part
increases by increments of five to provide for room
to add new topics to the checklist. The third number
indicates the placement of the checklist item within
the topic. These checklist item numbers will be
kept static from this year to next year. New checklist
items will be added at the end of topics or inserted
as entirely new topics.
Standard Checklist Items. The first
checklist item under the first three headings (i.e.,
SO.1.1 and SO.2.1) of each section of the guide
are standardized. The first heading item (SO.1.1)
requires a review of any previous assessment documents
and agreements. The second heading item (SO.2.1)
provides a place for assessors to write up findings
that are based on regulations that have been promulgated
since the publication of the guide or regulations
not included in the guide. Appendix 3 provides an
example of these two checklist items as found in
the Solid Waste Management section.
Inserting and Deleting Pages. Each
section is structured so an assessor does not have
to carry the whole section while doing the assessment.
For example, if the assessor was reviewing compliance
at an SQG of hazardous waste (see the provided sample
checklist items in Appendix 4) and knows that the
facility does not generate any restricted wastes,
the checklist items pertaining to restricted wastes
at SQGs can be pulled out of the guide without deleting
any checklist items pertaining to other topics.
Pages from the Agency-specific Supplements or state
guides can be inserted in the appropriate chapters.
assessment procedures are designed as an aid and
should not be considered exhaustive. Use of the
checklist requires the assessor’s judgment
to play a role in determining the focus and extent
of further investigation. A review of appropriate
state regulations should be conducted so additional
review questions that reflect the substantive requirements
of state/local regulations pertinent to individual
facilities can be included in the checklists.