EPA and OSHA Compliance Regulations

Fear of the Unknown

A review of archived CTI newletters indicates many compliance-related topics: highlights of EPA and OSHA inspections, findings, and penalties; self-conducted audit tools to get a baseline on current compliance; employee training requirements; and information regarding new regulations and how to work them into your current operations. However, companies throughout Ohio continue to run afoul of compliance regulations in spite of all of the informational help that exists “out there”. In this article, let’s attack the non-compliance problem from another direction – the fear of the unknown.

Fear of the unknown can keep one from taking direct action on a problem at one time or another. Using several analogies, what is that noise under the hood of my car? If I go to the doctor about this headache, is he going to tell me something unpleasant? If I call a professional for my taxes, will they do a good job or overcharge me? Of course, there are numerous possible answers to the questions in these scenarios. We are going to ask you to relate these questions to environmental, health, and safety issues and focus on only two answers to these questions: the best and worst cases.

That noise from under the hood of your car is usually a warning that something is not working properly. This is the time to pull over, take a look, identify the cause, and gauge what can be done that will get your vehicle back into a safe, reliable condition. Maybe you can fix it yourself, or perhaps the problem requires a trip to a garage. Using another example, you have been getting terrible headaches for the last few weeks. You should not delay nor diagnose this problem on your own; this is the time to go to the doctor and determine the cause of the headaches before they begin to interfere with your daily activities or worse.

In either example, direct action on your part is certainly necessary. Ignoring either problem may have serious consequences. If you choose the “It will go away” or “What I don’t know won’t hurt me” approaches to these situations, the result could be dramatically bad. With the car, it might be a costly engine replacement instead of only the cost of a few quarts of oil or a belt replacement. The headaches could have been a warning of high blood pressure or maybe just an outdated eye prescription. The key is taking action to determine the level of the problem in order that a plan of action can be prepared and begun.

Moving our discussion to the EH&S world, perhaps a regulation is changed which you think affects your personnel exposure limits or hazardous material transportation. The question that is posed for you today is “What keeps you from determining if you have a problem or not, and then moving forward in adjusting your EH&S programs?”. Is inaction based in not understanding the regulation and not understanding what actually changes for your company? Is there a financial issue in that your company does not have a budget established or that you have no idea at all about the cost of the changes necessary to adjust your program? Perhaps the problem lies in approaching management in order to discuss the problems that you have identified.

Compliance Technologies, Inc. (CTI) can help you deal with any of these issues and more. Our team of experienced professionals can confidentially discuss with you what is needed to keep you in compliance. A brief meeting with a CTI representative costs nothing and can provide you with a qualified opinion about how you need to proceed. What is needed may be as simple as doing some sampling or some employee training, or it may be that a program overhaul is in order. It may be that your position requires a yearlong plan be effected to gain full compliance. At the least, you must have a plan of action in place, and remember, some action is better than no action. To recall the auto analogy, if you provide a repair, you no longer will be driving down the highway hoping not to have a major, costly breakdown.

It may be hard to imagine, but there is a benefit in hiring a professional, insured, EH&S consultant to remove the fear of the unknown. Let us show you how it works.


Published by Stephen Kovatch

Senior Client Manager  Stephen J. Kovatch focuses on assisting clients in establishing corporate regulatory compliance programs in the areas of air, water, and waste management. Mr. Kovatch also provides direction to industrial facility owners who are active in the transaction of contaminated property by defining objectives, coordinating soil and water sampling protocols, risk assessment, and remedial / cleanup activities. He frequently represents clients in property sales negotiations and regulatory agency and insurance proceedings.

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