Joshi Environmental, Inc.

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Importance of baseline EHS assessments for new managers When an EHS manager takes over the new position he/she does not know the extent of environmental, and Health & Safety challenges that may be in store. The focus is on learning the job responsibilities, understanding management priorities, and making your recommendations count during management meetings. As time passes the EHS compliance rests squarely on your shoulders irrespective of the issues that you may have inherit...ed from your predecessor. There is a brief window, usually 6 months after assuming the responsibility, when you can position yourself as: (Insert name) to the rescue versus (Insert name) is responsible for the NOV. A new EHS manager’s priority should be to conduct the EHS audit himself/herself or to hire an experienced team of EHS consultants and get a baseline compliance assessment at the facility. There are definite advantages of hiring an outside firm for the baseline review. Mainly because: 1. You do not want to communicate non-compliance issues to the management at this stage. 2. You do not want to impact your working relationship with your co-workers. 3. You do not want to make your predecessor look bad, especially if he/she is still in the organization. You owe it to your future success to address the baseline EHS assessments as soon as you take the responsibility. This will greatly help you to set the record straight and show the value you bring to the organization going forward. Joshi Environmental, Inc. (JEI) consultants have decades of in-depth facility auditing experience. We strongly believe: we do not audit at youwe audit with you. JEI maintains a non-confrontational approach to auditing while providing value-added approach. Contact Sam Joshi at (267) 513-1898 to discuss how JEI can help you succeed in your career. See more

Stationary Refrigeration and Air Conditioning Rule Revisions. If your facility uses HFC-134a, a common HVAC refrigerant, it is subject to many provisions of the new regulations. EPA’s original refrigerant rule on this subject was published in 1993 and is codified at 40 CFR Part 82, Subpart F. The revised final rule, 400+ pages, is scheduled to be published in the Federal Register shortly and will change the refrigerant compliance management significantly. Following are the... highlights of few of the many changes that can impact your facility: 1. Refrigerant management requirements to include substitute refrigerants such as Hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and hydrofluoroolefins (HFOs). 2. Lowers the leak rate thresholds that trigger the regulatory requirement to repair, retrofit, or retire equipment containing 50 or more pounds of refrigerant. a. Lowers from 35% to 30% for industrial process refrigeration (IPR) b. Lowers from 35% to 20% for commercial refrigeration equipment c. Lowers from 15% to 10% for comfort cooling equipment 3. Requirements to submit a report to EPA detailing the repair efforts for chronically leaking appliances. 4. Annual or quarterly leak inspections requirements depending on the type and size of the equipment 5. Requires recordkeeping of recovered refrigerant during system disposal. 6. Sales restriction to HFCs and other non-exempt substitutes. It is recommended that all facilities subject to the revised rule have a refrigerant compliance program in place. If you have any questions, or would like to develop a Refrigerant Compliance Manual for your organization, please contact Sam Joshi at (267) 513-1898. See more

Importance of Responsible Official definition in Air Permitting Can anyone at the facility sign the air permit applications, compliance certifications, or deviation reports? The answer is in the Clean Air Act regulations, complex, strict, and can have serious consequences if not implemented correctly. Following is the definition of Responsible Official in federal and state regulations: Responsible official means one of the following: (1) For a corporation: a president, secr...Continue reading

The Air Permit Process: Do’s and Don’ts Facility subject to air permitting must follow certain procedural requirements during the initial permitting process and subsequent permit renewals. Otherwise, it risks losing the air permit and may need to reapply as a new source. Following is a bulleted list of procedural items that are very important for a valid air permit: 1. Equipment & Process must get a permit before starting construction. a. Minor source permit process can tak...Continue reading

Nitrogen Oxides Emissions Accountability (PADEP)

Real cost of a Notice of Violation (NOV). Direct Cost: Notice of Violation (NOV) letter: $200 Explanation to the Management on reasons for NOV: 10 hour Response to Management on other EHS compliance status: 40 hour... Management time to make decisions: 1 hour Procurement time to issue check: 1 hour New checks & balance instituted by Management to avoid NOV: 40 hour Total cost: $200 & 92 hour (@$100/hour): $9,400 Indirect Cost: Impact on investor relationship: $$$ Impact on public perception: $$$ Impact on operations due to increased enforcement & scrutiny: $$$ Impact on permitting schedule during facility expansions: $$$ Potential Cost to the EHS Manager: Disenfranchised supervisor and Management Transfer or loss of job As you may have recognizedthe real cost to the business is much more than the $200. Unfortunately, many fail to realize the significance of resource allocation to maintain environmental compliance and how important it is to never get an NOV. Joshi Environmental, Inc. (JEI) recommends that every facility should review its environmental compliance at least once every three years. A knowledgeable auditor can identify areas needing improvement and the audit report can be used as a guide to improve and maintain environmental compliance. To discuss the importance of environmental compliance assessments, or to schedule an environmental assessment of your facility, please contact Sam Joshi at (267) 513-1898. See more