Connections

Issue 2 • Volume 3 • April 10

ENVIRONMENT

Regulatory Compliance
By Pete Siegmund, vice president, Oldcastle Southwest Group, Inc.

Fueling Station Every month, it seems we are hearing of companies similar to ours being fined for some regulatory or environmental related violation. State and local environmental agencies are currently assessing major fines for being out of compliance with air quality and emissions. Consequently, massive fines have been assessed due to violations of Storm Water Pollution Prevention Plans (SWPPP) and violations of Spill Protection, Control and Countermeasure (SPCC) plans.

Whatever agency or regulatory body oversees your operations, you likely can sense there is a genuine movement by regulators to ensure the industry is complying with or within the limits of your permits.

Regulations and compliance are not new to our industry. If you were involved with the permitting of a gravel pit recently, you probably have experienced extreme scrutiny of your operations. CRH/Oldcastle is committed to complying with all regulations and regulatory agencies, and our commitment to the environment is impressive. Annually, the environmental managers of all companies answer an extensive CRH environmental questionnaire. This information is a large part of the annual Corporate Social Responsibility (CSR) report.

We find there have been no major changes to most of the regulations under which we operate. We have seen some changes and amendments to the SPCC rules recently, but none that were major. Additionally, we have seen some minor changes in the SWPPP and Clean Water Act, but how allowable air emissions are calculated has not changed drastically over the years.

Why are there so many fines for violations to permits being issued by regulators? I strongly believe we have been operating under the assumption that if we have a permit in hand, we must be approved, and we can operate the way we feel is the best for the company. Permits are issued and ignored, therefore not fully understood. In addition to our companies not understanding our permits, regulators have put a lot more emphasis on the compliance of those permits.

We must comply with the permits that we previously agreed to abide by or the consequences could be serious. The consequences are not solely monetary. Previously, I mentioned permitting a gravel pit. Imagine going in front of local officials for a new gravel pit and your opposition comes forward and informs the officials of various violations your company has been fined for, such as unlawful water or excess air emission discharges. It could be devastating to the company and the ability to obtain the permit for that gravel pit.

How do we overcome this? It starts with education and training. If managers and plant operators don’t know the requirements of the permit, we can’t expect them to be in compliance with it. It should be the responsibility of each company’s environmental manager to administer the needed training. The environmental managers are the main contact with regulators and are typically the most familiar with permit requirements and regulations. Environmental managers should educate and train managers and plant operators to ensure they know permit regulations for their sites and plants and the requirements for record keeping and reporting. With this education and training, managers and plant operators will be responsible for daily, monthly and annual record keeping and reporting as part of their job description. The environmental manager will need to utilize their authority to set a system in place for managers and plant operators to learn permit requirements and implement a system of accountability.

Regulatory compliance is becoming increasingly important in our industry and cannot be overstated. With the recent movement of regulators focusing on compliance, it is only a matter of time before they will be on site for an inspection. Every individual company is responsible for its environmental health, permit compliance and detailed record keeping.

The CRH Environmental Policy

Comply, at a minimum, with all applicable environmental legislation and continually improve our environmental stewardship toward industry best practice.
Ensure that our employees and contractors respect their environmental responsibilities.
Proactively address the challenges and opportunities of climate change.
Optimize our use of energy and resources through efficiency gains and recycling.
Promote environmentally-driven product and process innovation and new business opportunities.
Be good neighbors in the many communities in which we operate.

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