Complying with your air permit seems like an obvious need for any industrial facility. But depending on your facility’s operations, the State in which your facility is located, and, believe it or not, the State employee who’s been assigned to review your permit application and issue the permit, your permit’s record keeping and reporting requirements may be extensive and exhaustive. Larger corporations are likely to have dedicated, in-house environmental staff to handle these requirements. Small and medium sized business, who may own and operate a facility identical to one owned and operated by larger corporations, will have similarly extensive requirements, but they are not nearly as likely to have the same in-house staff.
At best, there may be an Environmental Health and Safety (EHS) Manager, someone who’s responsible for environmental remediation and compliance services issues, health issues, and safety issues. Any one of these is easily a 40 plus hour/week job. If the need isn’t immediate or life threatening, it understandably tends to be placed on the back burner. In that sense, complying with your air permit might be considered a larger burden for small and medium-sized facilities than it is for larger corporations given their resource constraints.
However, when the State environmental regulatory agency schedules an air quality inspection of your facility, and you haven’t been preparing or generating your monthly and rolling 12 month VOC reports, you can almost be guaranteed to receive a Notice of Violation, which can result in a fine or other penalties. Depending on several factors like the length of time that your facility’s been out of compliance, the severity of non-compliance, etc., those fines and penalties can be large and damaging.
In my experience, small and medium facilities typically rely on their size to stay “under the radar” when it comes to those State inspections, and there is some validity to that philosophy. Larger facilities tend to generate greater emissions, and State inspections are more common for larger facilities than smaller. But, that “under the radar” philosophy can and does break down over time. When you actively comply with your air permit’s record-keeping and reporting requirements, you’re demonstrating a good faith effort to protect the health of your surrounding neighbors, you’re proving that you’re operating in a manner consistent with your permit application, and you’re proving that you’re complying with the permit’s hourly and annual emission limits. But you’re also preventing the costly fines and penalties that disintegrate profits and damage your reputation.
How can we help?
360factors, Inc. helps companies improve business performance by reducing risk and ensuring compliance. Predict360, its flagship software product, vertically integrates all risk, compliance and operational functions allowing companies of all sizes to manage regulations and requirements, policies and procedures, risks and controls, audit and inspections, and on-line training and qualifications, in a single cloud-based platform. It enables automation through artificial intelligence. 360factors also offers consulting services in the areas of air, water, and waste permitting and compliance, site investigation and remediation, environmental and dredge material sampling and evaluation, engineering and geology, expert testimony, health and safety, and operational risk management. Its Managed Services incorporate outsourced risk and compliance services using Predict360.
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