Hazardous Materials Management

Compliance is Key – Don’t Stick Your Head in the Sand

Maintaining environmental regulatory compliance is critical to the overall success of any industrial or business operation. Environmental regulatory compliance begins with forming corporate strategies to ensure resources are committed to create compliance awareness and pinpoint focus. We actively support our clients with federal and state environmental compliance needs by assisting them understand the complex intricacies of the various rules and regulations governing hazardous materials and waste management, and underground and above ground storage tanks.

We utilize our resources at the local, state and federal levels to stay fully apprised of current and changing regulations and standards.

Environmental Compliance Audits

The Blackledge Group understands the importance of conducting environmental compliance audits in order to identify potential environmental liabilities and regulatory deficiencies associated with a facility’s operation. A thorough compliance audit will assist an owner or facility manager identify and correct potential issues that may lead to regulatory liability.

Our environmental regulatory compliance audits are performed to the ASTM E2107-06 scope and focus on identifying proper handling, storage and/or disposal of hazardous materials; faulty or misused equipment leading to spills or releases of hazardous substances; human health risks; record keeping deficiencies; and permit compliance. Local and state-specific hazardous waste inspection processes are also reviewed when performing a compliance audit.

Environmental Compliance Training

Environmental compliance training is a vital part of any environmental compliance program. Teaching employees the importance of environmental compliance builds the foundation for ensuring a facility continues to operate safely and in compliance with facility permits.

The Blackledge Group tailors each training program to the individual needs of the client – environmental compliance training is NOT a “one size fits all” effort. Training should be specific to your facility and industry. Our training programs typically cover, at a minimum, SPCC plans, SWPPP plans, RCRA concepts, air permits, hazardous materials and discharge reporting, and recycling procedures.

Our goal is to make training fun and interactive, encouraging participation from training attendees. Our programs are aimed at raising employee awareness of what they’re doing and encouraging them to become active participants in the facility’s environmental compliance program.

Hazardous Waste Management

Our clients have partnered with The Blackledge Group to help manage their hazardous waste and hazardous materials compliance programs. Working as a team, we help our clients plan, develop, and implement customized programs that assure compliance, minimize waste streams, and reduce risk and costs.

Spill Prevention, Control and Countermeasure (SPCC) Plans

To prevent the accidental release of oil to the environment, 40 CFR 112 requires the development of a SPCC plan if a facility has 1,320 gallons total or more of oil storage (ASTs), or 42,000 gallons underground storage (USTs). Storage containers may include tanks, containers, and oil-filled equipment (hydraulic jacks, transformers), if they have the capacity to hold 55 gallons or more, including all tanks located on-site even if they are empty.

Because “oil” can mean petroleum, animal fats, vegetable oils, used oil, and oil mixtures (like oily water), even agricultural institutions can be required to develop an SPCC for the storage of vegetable and animal oils.

The Blackledge Group has developed SPCC Plans for industrial and commercial facilities, as well as local state and federal agencies. Our experience with transportation-related facilities, including bus maintenance, marine port and aviation authorities, and railroad facilities, gives us first-hand knowledge of spill control measures involved on active sites with a lot of moving parts.

Failure to develop and maintain your SPCC plan can result in expensive fines and penalties. At The Blackledge Group we help our clients ensure their facilities are compliant with the federal regulations found at 40 CFR 112, and develop plans that meet state and local environmental emergency planning requirements.

Working with your staff, we will develop cost-effective approaches to best manage your facility’s spill response program. If you lack secondary containment, we will help you design it. If you have old tanks, we will help you remove them in an environmentally friendly manner.

Facility Response Plan

The Facility Response Plan (FRP) rule requires certain facilities that store and use oil to prepare and submit an FRP. An FRP demonstrates a facility’s preparedness to respond to a worst-case oil discharge. FRPs are complex plans designed specifically for each facility.

At The Blackledge Group , our seasoned professionals understand the complexity of preparing FRPs and will assist your facility with preparing and complying with EPA regulations and codes for FRP compliance.

Emergency Planning and Community Right-to-Know Act (EPCRA) SARA Title III
SARA Title III, Tier II Chemical Inventory Report

Emergency Planning and Community Right to Know Act of 1986 (EPCRA) – also known as Title III of the Superfund Amendments and Reauthorization Act (SARA), contains requirements within Section 311 and 312 to report specific quantities of hazardous chemicals stored at a facility.

EPCRA Section 312 requires chemical inventories to be developed and regulated chemicals present above reportable quantities to be included with supplemental information in aTier II report which is submitted annually to a state emergency response or local emergency response/planning commission, or local fire department. EPCRA Section 311 is a one-time report that requires safety data sheets for the same chemicals reported under Section 312 to be submitted to the appropriate state and local agencies.

Our professionals understand the nuances associated with performing chemical inventories, inventory tracking and management, report preparation, and specific Tier II reporting requirements.