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FLEXO Magazine : April 2009
PLANTS & PROCESSES must be certifi ed (signed). There may also be environmental com- pliance documents required as well: Spill Prevention and Hazard Waste Contingency Plan are two examples. ENVIRONMENTAL PERMITS A printer may be required to obtain an air quality and/or wastewater discharge permit. Some states also have registration requirements, even if a permit is not required. Printers are re- minded that the onus is on them to make the permit determina- tion, not the permitting agency. An SGP auditor will not review those permits; only see if you have them. The printer must make the determination on the need for these permits and then get them, if necessary. In the event that a permit is not required, a permit exemption letter from the agency is useful to show auditors or agency inspectors that you made the determination. In the case of stormwater, very few printers will need to get a stormwater discharge permit. If you do not store anything out- side that may contaminate stormwater (closed dumpsters, clean closed drums, and clean pallets are exempt), then a permit is not necessary. However, you are still required to fi le a No Exposure Stormwater Certifi cation every fi ve years. MONITORING COMPLIANCE SGP certifi cation requirements require printers to institute an EHS management system. To ensure that this system is working, printers must monitor routine compliance status. This means that printers must be conducting periodic facility inspections to identify EHS issues and implement corrective action in a reason- able time period. A checklist of inspection items with a space for summarizing corrective action is a useful tool. The inspection frequency depends on printer size and operations. In addition, SGP printers should be reviewing their EHS man- agement system annually to ensure that it is eff ective. This can take place during an annual EHS or SMS Committee meeting to discuss EHS management, how it’s working or not working, and what initiatives will be taken during the coming year. EMPLOYEE TRAINING Many of the major rules, particularly OSHA’s rules, have some employee training component. Despite the management pains associated with training and its logistics, OSHA has found time TABLE 1. Major EHS rules applicable to all printers. ENVIRONMENTAL Air Emissions and Permits Wastewater Discharges Stormwater Discharges and time again that training improves safety and employee mo- rale. Of course, there could also be training associated with per- mits or other printer operations. THE EHS AUDIT SGP requires that a comprehensive EHS audit be conducted at least every two years. The scope of that audit refl ects the need to objectively review a printer’s EHS compliance status. The audit can be conducted by an experienced EHS professional or per- formed internally. The key to SGP verifi cation is a comprehensive audit scope of applicable EHS requirements. The table of major rules is a good start. The audit report (a checklist can also be used) must provide a compliance snapshot of your operations. Do you need air and wastewater discharge permits? Do you have the required written compliance documents (Hazard Communication, Lockout/Tagout, Emergency Action Plan, PPE Hazard Assessment, etc.)? Do you submit annual reports to agencies, if required? Do you conduct and document employee training? Do you evaluate your wast- estreams for hazardous/nonhazardous characteristics and keep shipping documents of proper disposal? Have you evaluated work- place exposures to chemicals, dusts, and other hazards? These are just a few examples that should be included in the audit scope. Printers might ask; how does this help my company be sustain- able? The most obvious reason is that a company that is not comply- ing with EHS requirements is one that is not concerned about the environment or its employees. Employees are a critical component to a company’s overall commitment to sustainability and OSHA’s Lockout/Tagout requirements provide a good example. Those re- quirements were promulgated in 1990 because catastrophic injuries and fatalities were occurring from improper equipment de-energi- zation during servicing and maintenance. You expend some compli- ance resources upfront to prevent injuries and fatalities, which re- quire signifi cant resources later if they occur. Successfully managing your risk through EHS compliance reduces future resource needs, and that’s what SGP is all about. RECORDS, RECORDS, RECORDS An SGP auditor is required to verify a printer has not only HEALTH & SAFETY Hazard Communication Lockout/Tagout Personal Protective Equipment Fire Safety & Protection Machine Guarding Hazardous Waste & Waste Oil Handling and Disposal First Aid & Bloodborne Pathogens Universal Waste Handling and Disposal Aboveground Storage Tanks & Spill Prevention SARA Title III (Tier Two & Form R) DOT Hazmat Spill and Release Reporting Hearing Conservation Electrical Safety Forklifts & Pallet Jacks Emergency Action Plans Toxic Substances www. f le xography. org met the intent of the EHS compliance requirements by having a management system in place, but also any of the required specifi c EHS BestManagement Practices. This means records. The more documentation you have regarding EHS compliance, the easier it is for the SGP audi- tor. Focus on facility inspection records, writ- ten plans, documenting any of specifi c SGP BMPs (for example, using CONEG compliant inks), EHS Committee minutes, and make sure you keep plenty of training records. ¦ Flammable & Combustible Liquids OSHA Injury and Illness Logs ABOUT THE AUTHOR: Robert Fricke is an independent EHS consultant specializing in the printing and broadcast industries. A long time environmentalist, he believes that com- pliance is the fi rst stepping stone to a better environment. APRIL 2009 FLEXO 51