Legal or Regulatory Requirements as identified in our Environmental Aspects

[CLSTEWART]

As identified in our Environmental Aspects, we have, as an example, noise generated by our equipment. We have a OSHA consultant that we use and he monitors the noise level in the plant to be sure we are within regs for our PPE requirements. I am right in saying that the aspect is a legal/compliance obligation, correct?

We also have emissions. Our department of environmental protection said that we DO NOT need to regulate or report on our emission because of the composition of the product we use. Because we do not have to report, is it just an aspect or is this also a compliance/legal obligation?

How about heat generated by our processes? We do monitor heat within the plant but it never reaches a level that would dictate additional PPE's. Aspect or compliance/legal obligation?

What about sanitary waste water and municipal water use? None of our processes generate any effluent going out of the plant. We only have employee restrooms using/generating any water/waste water. Aspect or compliance/legal obligation?

Thank you.

 

[Randy]

What's the definition of environmental aspect in section 3? Your answer is there.

One thing for sure, OSHA level noise? Nope, not normally, mainly because it's not an environmental impact level and it's controlled by 29CFR in the US and not 40CFR.

There are no absolutes with aspects & there are no real wrongs.

Don't get your environmental stuff confused with health and safety because it looks like you're going down that treacherous path

 

[Jen Kirley]

As identified in our Environmental Aspects, we have, as an example, noise generated by our equipment. We have a OSHA consultant that we use and he monitors the noise level in the plant to be sure we are within regs for our PPE requirements.

Randy is correct, this is a safety issue and not an environmental one.

If the noise was outside the building and could be heard by neighboring interested parties, then it would be environmental. If that were the case, noise limits are usually set and enforced by the municipality or through agreement (such as with a lease in a business park), not by federal law.

 

[CLSTEWART]

So, a NO on noise inside the plant as an aspect but YES on outside noise.

YES on aspect for emissions but no on compliance/legal obligation?

So heat generated by equipment is a NO as an aspect. Only thing I see with that is we save money on heating in the winter because we use that heat source to warm the plant. So...

How about with waste water and water usage? ASPECT since we only use for sanitary purposes?

Is chemical usage an ASPECT or compliance/legal obligation because it is governed by OSHA. From what you said though, any disposal is a compliance/legal obligation, correct?

 

[Jen Kirley]

So, a NO on noise inside the plant as an aspect but YES on outside noise.

YES on aspect for emissions but no on compliance/legal obligation?

So heat generated by equipment is a NO as an aspect. Only thing I see with that is we save money on heating in the winter because we use that heat source to warm the plant. So...

How about with waste water and water usage? ASPECT since we only use for sanitary purposes?

Is chemical usage an ASPECT or compliance/legal obligation because it is governed by OSHA. From what you said though, any disposal is a compliance/legal obligation, correct?

No legal obligation under ISO 14001:2015 on noise unless it is outside noise AND such a requirement is established. Remember, inside=health and safety; outside=environment.

Emissions are usually regulated by the state, though there may be exceptions. For example, CFC emissions are regulated in the U.S. via control of refrigeration equipment, even if none of your units exceed 50-lbs refrigerant gas capacity. There are requirements to capture the refrigerant gases during servicing, even if there are no reporting requirements for non-captured leaks.

It is okay to list regulations as an aspect whether they are regulated or not.

Waste water is an aspect if it is regulated, usually by your municipality, but it is usually counted as fresh water usage under the consumption of natural resources concept.

Saving money on heating in the winter is considered an opportunity under ISO 14001:2015, because it could help consume less resources for heating. As such it could be considered a "positive aspect." Aspects and impacts do not need to be always negative.

As you can see, it is not just about the output (what goes out into the air etc.) but also the input (what is used).

 

[Ian_Morris]

Jen,

Just want to clarify a point - when you say noise inside is OHS and not Environmental, I assume you are talking about the effect on the recipient.

In the UK, it would not matter where the noise is generated, it is about whether your neighbours are affected by the pollutant (in this case noise).

Ian

 

[AMIT BALLAL]

As identified in our Environmental Aspects, we have, as an example, noise generated by our equipment. We have a OSHA consultant that we use and he monitors the noise level in the plant to be sure we are within regs for our PPE requirements. I am right in saying that the aspect is a legal/compliance obligation, correct?

We also have emissions. Our department of environmental protection said that we DO NOT need to regulate or report on our emission because of the composition of the product we use. Because we do not have to report, is it just an aspect or is this also a compliance/legal obligation?

How about heat generated by our processes? We do monitor heat within the plant but it never reaches a level that would dictate additional PPE's. Aspect or compliance/legal obligation?

What about sanitary waste water and municipal water use? None of our processes generate any effluent going out of the plant. We only have employee restrooms using/generating any water/waste water. Aspect or compliance/legal obligation?

Thank you.

Are you referring to EMS & OSHA both?

Because noise generated by equipment / heat generated by operations would be hazards (can harm human/cause injury) which would come under OSHA.

And emissions, waste water, etc. would be environmental aspects.

 

[CLSTEWART]

Thank you all for the clarification. Sometimes it is easy to get off on tangents.

Another question. We don't generate enough noise or odor for any measures to be taken for mitigation (at least not yet, see below). Our local township ordinances cover these two issues. In the ordinances, it states:

"Noises which is determined to be objectionable because of volume, frequency, or beat shall be muffled or otherwise controlled, except fire sirens and related apparatus used solely for public purposes shall be exempt from this requirement."

"No malodorous gas or matter shall be permitted which is discernible on any adjoining lot or property."

You can see the issue already that there are no measurables here to be certain our company doesn't violate the ordinances. It is solely arbitrary.

So, our ODOR and NOISE are Significant Environmental Aspects but how do you go about controlling them with the above ordinances?

 

[Randy]

Do whatever you want, you can only do too little and never too much

 

[Sidney Vianna]

but how do you go about controlling them with the above ordinances?

Key words to pay attention to:

"Noises which is determined to be objectionable because of volume, frequency, or beat shall be muffled or otherwise..."

"No malodorous gas or matter shall be permitted which is discernible on any adjoining lot or property."

Has anyone in the surrounding community complained about noise and/or odor emanating from the plant? If not, there is nothing to do.