In a formal survey by the American Industrial Hygiene Association (AIHA), about 1/3 of the Environmental Health and Safety (EHS) professionals who responded said they don’t have enough staff or resources to complete their job tasks.  In the same survey, the AIHA states, “…it’s no surprise to find that today’s EHS professionals have a lot of responsibilities on their plate.  With increased responsibilities, EHS professionals are constantly looking to identify hazards and mitigate risks.”

With staff limitations, mitigating risks becomes a greater challenge.  One of the more complex risks is managing compliance with the Clean Air Act (CAA) of 1970 (amended in 1977 and 1990).

CAA Penalties

Under the CAA, the EHS manager is tasked with anything from submitting a Title V Permit application to preparing for an eventual regulatory inspection and everything in between.  With as many responsibilities as the job entails, it can be straining to keep up with changes within the plant or facility and all the regulations that come with it.

While the current administration in Washington, D.C., has pushed much of the responsibility of enforcement to the state level, the fact remains that maximum penalties under the CAA are significant:  $95,284/day/violation.

The Air Quality Manual

Several years ago, while working with a client who expressed the need to create a document to track a number of issues regarding the CAA, Dragun developed an Air Quality Manual.  The purpose of this manual then and now is to help ease the burden of maintaining compliance with Federal, State, and Local air regulations.

Since our first manual, we have developed several other manuals, each specifically tailored to our clients’ operations and needs.

The purpose of the air quality manual is to help ease the burden of maintaining compliance with Federal, State, and Local air regulators.

The purpose of the air quality manual is to help ease the burden of maintaining compliance with Federal, State, and Local air regulations.

The Air Quality Manual has been helpful for our clients to:

  • Keep track of air emissions; document that the facility is not exceeding emission limits.
  • Demonstrate (provide the specific exemption) to a State or Federal regulator why a facility does not have or need a permit for a piece of machinery.
  • Fulfill record-keeping requirements for each piece of equipment, including air-emission calculations, diagrams, and other detailed information.

One Source to Keep You Compliant

In general, the manual is a helpful tool to keep records current and up to date.  It is organized in an easy-to-read format so EHS Managers do not have to waste time searching for a Permit-to-Install that was approved in, for example, 2002…or earlier.  Our clients don’t have to read through reams of regulations to find pertinent information relative to their company’s equipment; all the necessary information is included in the manual.

“Perfect”

My colleague, Khaled Chekiri, Ph.D., P.E., and I recently provided a client with a personalized Air Quality Manual for their facility.  We received positive feedback regarding the content of the manual as well as the overall simple organization of the information.  In the words of our client contact, the manual was “perfect.”  It felt rewarding to see that the effort put into this manual was considered beneficial.

Pain Points and a Solution

The AIHA survey that I mentioned at the beginning of this blog also states, “While lack of staffing and resources topped the list of operational pain points amongst EHS professionals, it doesn’t look like this situation is going to be resolved for many in the near future.”  EHS managers work tirelessly for their company to maintain compliance and to save other management staff many headaches over dealing with the regulators or environmental regulations.  Dragun strives to keep environmental regulation and compliance as painless as possible for our clients, and we have the feedback to prove the Air Quality Manual is an aid in that effort.

If an Air Quality Manual is something that might help you, or if you would just like to learn more, please contact us.  For general questions, feel free to contact me.  If you have more specific compliance questions, please contact Matthew Schroeder or Khaled Chekiri.  You can also reach us at 248-932-0228.

Finally, if you are looking for additional information on our compliance services, see our Environmental Compliance page and/or our Monthly Environmental Compliance Tips.