Permitting, Fees, and Reports

1. Permitting, Fees, and Reports Cal Poly Lecture Tour Ron Scholtz Analog Devices, Inc.

2. I Didn’t go to College to be a File Clerk! • EHS professionals have a lot of responsibility in maintaining up to date permits, fees, and other records. • A great deal of time is spent dealing with paperwork. • There can be serious legal implications if permits, fees, and other required records are not properly maintained.

3. Permits • Air District Permit to Operate • POTW Waste Water Discharge Permit • Storm Water Permit • Waste Generator Permit • Waste Treatment Permit (Tiered Permit vs. TSDF) • Fire/Business Permit • Radiation Permit • Elevator Permit • Pressure Vessel Permit

4. Reports • Wastewater Monitoring Reports • Storm Water Monitoring and Inspection Reports • Air District Data Reports • SARA Form R Emissions Report • Hazardous Materials Inventory Statement • Groundwater Monitoring Reports • SB-14 Source Reduction Report

5. Reports • Hazardous Waste Biennial Report • Waste Treatment “Tiered Permitting” Annual Update • Tiered Permitting Financial Assurance • Contingency Plan for Emergency Response • Industrial Hygiene Monitoring Reports • OSHA 300 Accident Log

6. Fees • Air District Fee • POTW Fees • Hazardous waste fees and taxes (multiple) • Business taxes • Storm water fees • Department of Transportation fees (haz mat)

7. Records • Hazardous Waste Manifests • Hazardous Material Shipment Bill of Lading • Accident reports/OSHA 300 log • Medical records- ERT, Respirator • Material Safety Data Sheets • Training records • Spill and incident reports • Chemical usage records

8. Records • Wastewater pH and flow charts • Solvent fume abatement system temperature charts • Toxic gas monitoring system alarm reports • Respirator Fit Testing Records • Calibration records • Equipment maintenance records • Inspection Records • Corrective Action Records

9. Inspections • Regulatory Agency Inspections- Fire Department, POTW, Stormwater, CHP, DOT, FAA, OSHA, EPA, FDA • Internal Inspections- Forklift, Respiratory Protection, Lock-Out/Tag-Out, Confined Space, ISO 14001/OHSAS 18001 Audits • Regular Inspections- Weekly Hazardous Waste Storage, Weekly Hazardous Material Storage, Daily Tank, Gas Cylinder Delivery, Stormwater • Life Safety Inspections- Fire Protection Systems, Alarm Systems, Gas Monitoring Systems, Fire Extinguishers, Safety Showers, Emergency Lighting • Third Party Visits- Industrial Risk Insurer, Workers Compensation Insurer, Customers, ISO 14001/OHSAS 18001 Registrar, Community

10. Regulations • Need access to all applicable legislation, regulations, and codes- maintain a list • Most regulations are now available on the internet • Many agency websites have greatly improved and contain a wealth of information • Take some time to periodically review regulations- Update services, newsletters, etc. • Having a good reference library available is very useful

11. Being Organized is a Must! • You must have very organized files in order to keep up with all the paperwork. • Files in a centralized location • Files divided by “reports”, “permits”, “fees”, “records” • Have a system- i.e. color coded folders • Have a record retention system. You can destroy most old documents. • Maintain tracking calendars so that you know what is due ahead of time. • “High Level” Matrix of requirements and timelines • “Compliance Calendar”- Issued Annually, Updated Monthly • “Life Safety Calendar”- Issued Annually, Updated Monthly

12. Other Tips • Don’t let your paperwork pile-up. Give yourself time each day or each week to keep up. • Fill out forms completely. Blank spaces can come back to haunt you! Waste manifests in particular. • Have a review system so that documents are looked at by more than one person before signing. • Managers should periodically check department files to make sure everything is in order. • An organized looking office space is usually a good sign!