EHS Services
Environmental Audits
An environmental audit is a snapshot of the level of regulatory compliance and/or of potential liabilities from past and current practices. The engineers, regulatory specialists, and environmental scientists at O’Brien & Gere perform a coordinated, on-site review of base documentation, processes, and management procedures. When performing audits, the facility is evaluated and its procedures examined including air, water, bulk storage, wastewater, hazardous waste, and universal waste. O’Brien & Gere began providing consolidated environmental, health, and safety (EHS) auditing and compliance assistance to our clients in higher education, healthcare, industry, the public sector, DOD, and federal facilities in the 1970s. The firm provides strategic compliance and environmental management plan development, compliance assistance, short-term and long-term on site staffing support, and other operational and pre-operational regulatory services. Our philosophy and practice of 3600 Project Delivery Solutions provides an avenue for our clients to integrate audit activities into long term compliance functions, and benefits for their facilities.
Environmental Compliance
Environmental compliance is an integral function in the life cycle of any project. Whether it is the planning and design of a facility, facility construction, operations and management, plant or corporate divestiture, or decommissioning and closure, there will be activities subject to federal, state or local environmental permits and approvals. O’Brien & Gere provides fully integrated environmental compliance and management support services, including the following programs:
- Solid waste and hazardous waste
- Above ground and underground bulk storage (petroleum and hazardous chemicals)
- Air emissions and emissions management
- Drinking water
- Wastewater and storm water
- EPCRA (Emergency Planning and Community Right-to-Know)
- PCB management
Our staff of over 100 experienced environmental compliance professionals have developed unique solutions to the environmental compliance issues of our clients, among them:
- Problems with a thermal discharge from a proposed new facility for a glass manufacturer? Our staff recommended combining the thermal waste stream with the discharge from a local municipal wastewater treatment plant that saved the manufacturer millions of dollars in cooling tower construction and O&M, and sealed the site selection.
- Our unique photolog program integrates with our environmental audit database; the result is a link between the photo of a potential compliance issue and the description of the issue, providing a tool for improved regulatory interpretation and training for our clients’ staff.
- The permit acquisition for the relocation of a stream with the concurrence and oversight of the U.S. Army Corps of Engineers allowed a client to expand the capacity of an existing facility.
- Careful review of actual operations and the preparation of air permit applications allowed a client the opportunity to cap out of Title V applicability for its facility, while maintaining flexibility for current operations and future growth while reducing the clients’ recordkeeping and reporting obligations, and costs.
- The preparation of EPCRA documentation allowed several clients to meet the terms of a national compliance initiative by the USEPA while developing a baseline of standard internal compliance practices to prevent future reporting errors.
- Experience with the USEPA’s audit policy have allowed our staff to assist industrial, municipal, higher education, healthcare, and K-12 school districts respond to USEPA and state environmental compliance enforcement initiatives.
Our services include:
- Permit negotiation, acquisition, modification and renewal
- Regulatory advice and interpretation, monitoring, recordkeeping, notification, reporting and instruction
- Environmental audits
- Compliance assistance for specific regulatory programs
- Develop and conduct required training programs for RCRA, SPCC, EPCRA and other regulatory requirements
- Environmental monitoring for landfills and water systems
- Waste stream characterization and evaluations
- Develop compliance calendars
- Prepare air emission inventories, statements, semi-annual and annual reports
- Perform air emission testing from multiple corporate testing hubs, including protocol and report preparation
- NESHAPS operation, maintenance and monitoring (OM&M) plans
- Risk Management Plans
- Start-up/Shutdown Malfunction Plan
- Prepare required planning documents, such as SPCC Plans, IECPs/ICPs, SWPPPs, and BMP Plans, Tank Maintenance and Inspection Manuals, RCRA Hazardous Waste Management Plans and Universal Waste Management Plans
- Prepare template recordkeeping tables.
- Prepare Environmental Impact Assessments or EISs
- Perform Consistency Determinations under Section 404 of the Clean Water Act
- Prepare Wetland Nationwide Permit Notifications and Permit Applications
- Prepare Underground Injection Control (UIC) Notifications and Permits (for drywells and other injection units)
- AST/UST registrations and closures
- Environmental Management Systems (EMS) gap analyses, evaluations and plans
- Radioactive Waste Management Plans
- Regulated Medical Waste Management Plans
- Chemical Hygiene Plans
For a fact sheet on Environmental Compliance, click here
SPCC and Petroleum Bulk Storage/Chemical Bulk Storage
Since the 1980s, O’Brien & Gere has been recognized for the breadth and depth of knowledge of its staff in spill control planning, bulk storage compliance, and the engineering design of bulk storage facilities and facility upgrades. O’Brien & Gere’s services to industrial, municipal, federal, defense, higher education, and healthcare clients around the country provide a substantial experience base for staff to recommend performance-based solutions to the compliance and engineering needs of its clients. It may be the preparation of an SPCC Plan, compliance with state regulations for petroleum or chemical bulk storage, design of new bulk storage facilities and delivery systems, compliance audits of ongoing programs, remediation of petroleum or chemical releases, or tank closure activities.
EPCRA
EPCRA is intended to provide communities with information that can help improve their awareness of chemical storage and usage by companies in their midst. Compliance with EPCRA can be complex given the range of chemical, intermediates and by-products that are subject to the jurisdiction of the legislation and its implementing regulation. O’Brien & Gere brings a thorough knowledge of chemistry and manufacturing processes and operations to the compliance process. As important is the fluency of our regulatory specialists in the precedents used in regulatory interpretations. With experience in preparing complex Section 311/312 and Form R submissions for chemical and pharmaceutical manufacturers, power generation facilities, primary metals plants, and food and beverage operations, to name just a few of our client sectors, O’Brien & Gere is prepared to take on any EPCRA assignment, or train a client’s staff to do so in the future.
Health & Safety Audits and Compliance
A Health & Safety (H&S) audit provides valuable information to management concerning the overall H&S program status and identification of program elements, work conditions, or employee training requiring improvement.
The focus of H&S audits may be characterized with a compliance or management orientation. A H&S compliance audit focuses on regulatory-required programs, training, and work conditions, whereby a management audit focuses on the administration and execution of the H&S programs. To be most effective, a H&S audit should not be used to assign blame, but to identify needs and build solutions for employee safety and business compliance.
H&S audits are frequently conducted by businesses to:
- provide a periodic H&S program status check,
- establish benchmarking, or
- provide due diligence for a business ownership transfer.
O’Brien & Gere’s Certified Industrial Hygienists (CIHs) and staff auditors typically use several types of auditing checklists for on-site activities. The checklists may be used for screening or in depth analysis of specific program elements. O’Brien & Gere may also reference ANSI/AIHA Z-10-2005 or OSHAS 18000 guideline documents.
Generally, an overall audit objective is to improve the H&S program through identification of targeted areas to expend business resources. O’Brien & Gere’s H&S auditors not only identify deficiencies, but can also provide compliance assistance and solutions, and interface with state-of-the-art science and engineering resources available within O’Brien & Gere to provide recommendations for 360o solutions associated with work area findings.
Fact sheets on Environmental Health & Safety Compliance:
Worker Exposure Monitoring
The five classical elements of industrial hygiene (IH) consist of anticipation, recognition, evaluation, prevention, and control of health hazard agents in the work environment. Worker exposure monitoring to measure chemical, biological, and physical agents is the basis for the identification of exposure risks, and the reason for control methods. It is also the first step in providing clients with 360o solutions to their IH issues.
Prior to conducting worker exposure monitoring, O’Brien & Gere’s CIHs and Certified Safety Professionals (CSPs) work with clients to establish a strategy for the monitoring program. Information collection must directly relate to the issue at hand, and focus on a resolution. The key for practitioners is to collect information that will provide a full understanding of the manufacturing operation generating the hazardous agent. This process can identify work conditions or product variables that may impact the sample collection or detection method, skew the measurements, and under or over report the exposure values. It is important that the measurements provide an unbiased and representative exposure value. Committed to providing representative data, O’Brien & Gere uses only American Industrial Hygiene Association - accredited laboratories to perform sample analyses.
Chemical agents typically sampled include:
- Volatile or semivolatile organic compounds
- Metals
- Metal working fluids
- Asbestos
- Acids/bases
- Gases
- Dusts
Biological agents typically sampled include:
Physical agents typically sampled include:
- Sound levels
- Ionizing radiation
- Electromagnetic and ultra-violet radiation
- Heat stress
Fact sheets on Industrial Hygiene and Workplace Safety, click here
Indoor Air Quality
O’Brien & Gere has provided Indoor Air Quality (IAQ) evaluation services for over 15 years to various business and academic locations throughout the country. During site evaluations, our investigators have recorded a wide variety of environmental conditions associated with worker IAQ complaints.
Based on our extensive IAQ investigation experiences, O’Brien & Gere has developed an IAQ investigation protocol to identify environmental and operational conditions that may initiate worker IAQ concerns. The O’Brien & Gere investigation protocol is a snapshot of existing environmental conditions in a building or work area. Investigation elements cover the following topics:
Ventilation System Review
The quality and quantity of make-up air can impact employee worker satisfaction within their work environment.
Chemical Products Review
Cleaning products, pesticides, maintenance-related materials, and photocopying products can contribute to the degradation of IAQ.
Business Operations Observations
Electrical equipment and furnishings can contribute outgassing products to the work environment.
Work Environment Observations and Monitoring
The design of a work environment can cause worker stress by such agents as poor ergonomic design, inadequate lighting, glare, background noise, inadequate cleaning, and a congested work area.
Mold Growth Investigation
Persistent moisture within the office building envelope from outdoor intrusion or an indoor source can result in mold growth.
Mold
Mold growth is a problematic issue from a risk management perspective: there are no mold thresholds established by any regulatory body, potential health impacts are questionable or inaccurately portrayed, and there is no standard of care for remedial action. Couple the foregoing with an influx of uninformed and poorly trained practitioners, and mold conditions can result in a liability to property owners or work-place managers.
However, O’Brien & Gere draws on the experience of practitioners within the industry, and consultation with experts that have best influenced the development of quality procedures in this field. The most critical issues associated with mold growth are:
- Establishing the root cause of mold formation and correcting it
- Thoroughly remediating the mold that is present
- Monitoring the situation to ensure that the condition has been corrected and does not reassert itself
- Using good science to communicate risks
O’Brien & Gere’s CIHs are sensitive to the concerns of workers, residents, students, and parents when mold issues arise in the workplace, the home, or in schools. To be effective at addressing these concerns, O’Brien & Gere helps formulate a response that is scientific, forthright, and credible. It is critical to focus on the issue at hand rather than promote incorrect information. Services provided by O’Brien & Gere include:
- Evaluating designs to determine the potential for mold formation
- Providing recommendations for moisture control in building construction
- Developing Indoor Mold Growth Prevention and Management Plans (IMGMP)
- Collecting mold samples and interpreting analytical results
- Developing mold remediation plans
- Mold remediation oversight
- Post event site monitoring
For a fact sheet on Mold Prevention Services, click here
Environmental Impact Analysis/Environmental Impact Statements (EIS)
The key to effective compliance with NEPA and similar state programs is to establish a regulatory strategy and engage the relevant agencies as early as possible in the timeline of a project. This approach has an advantage in that it helps to minimize regulatory concerns and potential public objections. Often, by applying this strategy, the amount of environmental documentation to be prepared can be focused and reduced, and project schedules maintained and advanced. It is important, if not critical, that a project proponent, whether in the public or private sector, capitalizes on O’Brien & Gere’s knowledge and experience to establish a cost-effective regulatory strategy, as well as to perform the administrative and technical tasks associated with compliance. Using this approach, O’Brien & Gere has successfully guided clients through the maze of NEPA and state programs for major, often controversial development projects.
This basic approach is often accompanied by public information activities, assistance with regulatory requirements for the environmental review process, and participation in public meetings and hearings. Once the existing information about a project site has been obtained and reviewed, the need for site-specific studies is considered. Depending on the nature of the project being evaluated, one or more of the following special studies may be necessary, and can be performed by in-house O’Brien & Gere staff:
- Air quality analysis
- Noise impact assessment
- Survey of habitat, vegetation, and/or wildlife
- Hydrogeologic investigation
- Traffic and transportation study
- Visual impact analysis
- Water quality impact evaluation.
O’Brien & Gere has the in-house capability to perform these special studies. When a particularly sensitive issue requires special expertise, a network of outside experts can be called upon, as needed, to assist O’Brien & Gere. O’Brien & Gere’s support to clients continues throughout the environmental review process, including response to questions on the environmental impact assessment; participation in public meetings, hearings, and regulatory agency meetings; assistance with public information activities, regulatory compliance for filing documents, and giving public notice of the environmental review process.
Environmental Management Systems (EMS)/ISO 14000/14001
An environmental management system (EMS) is intended to provide an organization with the means to operate in an environmentally efficient and cost-effective manner. Guidelines such as those provided by the U.S. Environmental Protection Agency (USEPA) may be voluntarily implemented by an organization, no matter its size, location, or the nature of its business. EMS programs offer an opportunity to document the processes, procedures, and plans that constitute an environmental or a coordinated environmental, health, and safety (EHS) program, including the ability to more easily demonstrate compliance with applicable regulatory requirements and the management of complex facilities.
The International Organization for Standardization (ISO) has developed EMS standards that serve as the benchmark for the development of a program that can establish consistency in environmental management as time passes and personnel change. The 14000 series of ISO standards are chiefly related with the management of issues of environmental significance. ISO 14001 is the standard that prescribes the management system procedures by which an organization may identify and evaluate those aspects of its operations that affect its ability to function in an environmentally sound manner, make changes where necessary, document its efforts, and train its employees.
O’Brien & Gere has been the consultant of choice for development of EMS and ISO 14001 programs by national and multi-national clients, having assisted them with the preparation and implementation of a program to achieve registration to the ISO 14001 standards. Typical services include:
- Strategic planning
- Gap analysis
- Drafting procedures to identify and rank environmental aspects and impacts
- Identifying and ranking environmental aspects and impacts
- Developing Environmental Policies
- Developing materials for General Awareness Training
- Assisting in the selection of Internal Audit Teams
- Providing Internal Audit Training
- Preparing databases for tracking non-conformances
- Providing management review support, Stage I & II certification audit support, and corrective action assistance
- Providing management review and third party certification assistance
- Performing start-up and continued oversight
- Organizing resource allocation, budgeting, scheduling, financial responsibility, and project reporting
- Supporting EMS awareness and communication
- Performing root cause analyses
- Developing recommendations for corrective and preventive actions