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Compliance: EHS - PROTOCOL
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The 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 categories:
1. Air Emissions Management
2. Cultural Resources Management
3. Hazardous Materials Management
4. Hazardous Waste Management
5. Natural Resource Management
6. Other Environmental Issues
7. Pesticide Management
8. Petroleum, Oil, and Lubricant (POL) Management
9. Solid Waste Management
10. Storage Tanks Management
11. Toxic Substances Management
12. Wastewater Management
13. Water Quality Management (potable water).

Each section is organized in the following format:

A. Applicability. This provides guidance on the major activities and operations included in the section and a brief description of the major application.

B. Federal Legislation. This identifies, in summary form, the key legislative issues associated with the compliance area in the Federal law.

C. 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.

D. 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 compliance category.

E. Key Compliance Definitions. This presents definitions taken from the Code of Federal Regulations (CFRs) for those key terms associated with each compliance category.

F. Records To Review. This lists documents and records that should be reviewed during the assessment process for each section.

G. Physical Features To Inspect. A list of facilities and activities that should be assessed for compliance with that section.

H. Guidance for Checklist Users. This is a table of contents for the following checklist.

I. 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.

The 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.