&EPA
The Environment and
Your Business: A Primer
For Building Compliance
into Your Operation
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United States Office of Compliance EPA-305-B-02-002
Environmental Protection (2224A) August 2003
Agency
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Table of Contents
Page
Section 1 - Background 1 -1
How will this document help my business? 1-1
EPA's Role in Protecting the Environment 1-2
EPA Programs for Small Businesses 1-2
Section 2 - Environmental Laws and Regulations 2-1
What are environmental regulations? 2-1
Where do I find federal environmental regulations? 2-2
To whom should I talk first? 2-2
Environmental Regulatory Summaries 2-2
What can you do to ensure compliance? 2-3
Section 3 - Getting Help 3-1
1. Understand Your Situation 3-1
2. Contact Your Assistance Provider 3-1
3. Get On-Site Assistance 3-2
4. Listen 3-2
5. The Small Business Compliance Policy 3-3
6. Establish a Program 3-4
Section 4 - Managing Your Business to Ensure Environmental Compliance
How can you manage environmental issues in your business 4-2
1. Characterize your facility 4-2
2. Evaluate the regulatory requirements 4-3
3. Determine your compliance status 4-3
4. Identify what actions are needed to achieve compliance 4-4
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5. Develop a strategy 4-6
6. Communicate these actions to other employees 4-6
7. Initiate the actions 4-7
8. Evaluate the program's successes 4-7
Section 5- Compliance Management Systems 5-1
Environmental Management Systems 5-1
Conclusion 5-2
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ACRONYMS
CAA Clean Air Act
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
CFR Code of Federal Regulations
CWA Clean Water Act
EMS Environmental Management System
EPA Environmental Protection Agency
EPCRA Emergency Planning and Community Right-to-Know Act
FIFRA Federal Insecticide, Fungicide and Rodenticide Act
HAPs Hazardous Air Pollutants
HSWA Hazardous and Solid Waste Amendments
HW Hazardous Waste
NCP National Oil and Hazardous Substance Pollution Contingency Plan (or National
Contingency Plan)
NPDES National Pollutant Discharge Elimination System
OPA Oil Pollution Act
OSHA Occupational Health and Safety Administration
P2 Pollution Prevention
PCBs PolychlorinatedBiphenyls
POTW Publicly-Owned Treatment Works
RCRA Resource Conservation and Recovery Act
SBO Small Business Ombudsman
SDWA Safe Drinking Water Act
SIC Standard Industrial Classification Group
SIP State Implementation Plan
SOP Standard Operating Procedure
SPCC Spill Prevention, Control, and Countermeasure
TRI Toxics Release Inventory
TSCA Toxic Substance Control Act
TSDF Treatment, Storage, and Disposal Facilities
USDA U.S. Department of Agriculture
UST Underground Storage Tank
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Section 1 - Background
As a small business owner, you may have already
encountered the issue of how to control waste.
Whether your business emits chemicals to the air
or produces solid or hazardous waste, you need to
know about federal rules that protect the
environment. Complying with environmental rules
is important to the health and safety of you and
your workers, for your business and your planet.
But where do you start?
Environmental Protection Agency (EPA) prepared
this document for you and your small business.
With business markets becoming more
competitive, both personnel and financial resources
are precious to the viability of many small
businesses. EPA understands that many small
businesses often do not have the resources or the
time to identify and understand all of the federal
environmental regulations that may apply to them.
Often the problem with understanding federal
environmental regulations is knowing where to
start. EPA wants to provide practical, streamlined
assistance to small business owners who understand
the importance of running an environmentally
responsible operation. This guide provides that first
step for small businesses unsure of their
environmental compliance status and
responsibilities.
How will this document help my business?
This primer should provide you with enough
information to get started in understanding the
federal environmental regulations that apply to
your business operations.
Businesses that are good environmental citizens
build community trust and good public relations,
and build good relationships with state and federal
regulators. This primer provides the first step to
understanding basic federal environmental
Document at a Glance
Section 1 Background
Section 2 - Environmental Laws and
Regulations < What are
They and Do They Apply
to My Facility?
Section 3 - Getting Help
Section 4 - Managing Your Business
to Ensure Environmental
Compliance
Section 5 - Compliance Management
Systems
requirements and describes an approach to
integrating environmental considerations into
your daily operations.
1-1
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EPA's Role in Protecting the Environment
EPA is the federal government agency responsible
for protecting the environment. EPA establishes
environmental safeguards in the form of regulations.
EPA then works with industries and the public to
make sure they understand how to comply with the
rules and requirements. EPA uses compliance
assistance documents, like this one, to assist
businesses in understanding how the rules affect
them.
EPA relies upon its ten offices around the country
to enforce the federal regulations. These regional
offices ensure compliance by supporting state
environmental programs and by conducting
compliance and enforcement activities. EPA's
regional offices also provide direct assistance to the
regulated community through various technical
assistance programs. EPA has given the primary
responsibility for compliance and enforcement of
many regulations to state and local environmental
regulatory programs. EPA also works closely with
the states and local governments to provide
compliance assistance.
In many cases, businesses must also comply with
state, local, and tribal laws. Tribes, states and
localities are the first source of information on their
requirements and procedures.
EPA Regional Offices
Region 1
One Congress St.
Suite 1100
Boston, MA 02114
(617)918-1111
Region 2
290 Broadway
New York, NY
10007
(212) 637-3000
Region 3
1650 Arch Street
Philadelphia, PA
19103
(215)814-5000
Region 4
61 Forsyth Street SW
Atlanta, GA 30303
(404) 562-9900
Region 5
77 West Jackson
Chicago, IL 60604
(312) 353-2000
Region 6
12th Floor
1445RossAve
Dallas, TX 75202
(214)665-6444
Region 7
901 North 5th
Street
Kansas City, KS
66101
(913) 551-7000
Region 8
999 18lh Street
Denver, CO 80202
(303) 312-6312
Region 9
75 Hawthorne St
San Francisco, CA
94105
(415)744-1305
Region 10
1200 Sixth Ave.
Seattle, WA 98101
(206) 553-1200
EPA Programs for Small Businesses
EPA is very interested in helping small
businesses understand and meet their
responsibilities. In 1982, EPA established a
Small Business Ombudsman (SBO) who
serves as a "first-stop shop" for environmental
compliance information. (www.epa.gov/SBO)
This office provides small businesses with a
point of contact, assistance in getting
questions answered, and assurance that small
business' views are considered during Agency
rulemakings. The SBO has a free hotline
(800-368-5888) that can answer specific
questions or connect you with an EPA
program expert or a regional small business
liaison in your geographic area. EPA also
supports ten on-line compliance assistance
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centers (see box on right) that provide
information on regulations and compliance
approaches as they apply to certain types of
businesses or activities.
As you talk to people at EPA, and as you read
this primer, you may become aware of certain
environmental responsibilities that you never
knew you had and that you have not satisfied.
As you review the requirements that follow, do
not become alarmed if you discover that you may
be in violation of some environmental laws.
EPA has many programs to help small businesses
come into compliance.
Are you concerned about contacting EPA
because you think if you ask them for help, they
may discover you are out of compliance and
impose large fines? EPA has a Small Business
Compliance Policy (discussed in Chapter 3)
which can result in a reduction or complete
waiver of fines if you follow certain procedures.
EPA wants to work with you to ensure a clean
environment.
RESOURCES
A variety of compliance assistance and
tools are available to help you comply with
federal environmental laws. These
resources can help you understand your
environmental obligations and find cost-
effective was to comply through the use of
pollution prevention and other innovative
technologies:
Compliance Assistance Centers:
Provide comprehensive, easy-to-
understand compliance information
targeted specifically to 10 industry and
governmental sectors.
www.assistancecenters.net
National Compliance Assistance
Clearinghouse: Provides an extensive
collection of compliance assistance
materials and contacts.
www.eDa.gov/clearinghouse
Small Business Environmental Home
Page: Helps small businesses access
environmental compliance and pollution
prevention information.
www.smallbiz-envirqweb.org
EPA Pollution Prevention Resource:
Provides resources on P2 programs and
technical assistance.
www.epa.gov/p2/resources/index.html
Pollution Prevention Resources
Exchange: Improves the dissemination of
pollution prevention information.
www.p2rx.org
1-3
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Section 2 - Federal Environmental Laws and Regulations - What Are They
and Do They Apply to My Company?
What are environmental regulations?
One of the most confusing aspects of federal
environmental regulations is understanding
how they come into existence. This short
description should help you better grasp this
process.
Federal, environmental laws are passed by
Congress and signed by the President in the
same manner as laws relating to education,
crime, taxes, highways, and so on. Congress
gives EPA the authority to write regulations
that implement the laws. EPA also has the
authority to enforce these regulations by
checking to see whether facilities are
complying with the rules. In many cases,
Congress gives EPA the authority to allow
tribes and states, and in some cases local
governments, to implement and enforce
EPA writes and enforces Federal
environmental regulations.
Example: "Used oil is not a hazardous waste but
must be managed according to EPA s
used oil regulations in 40 CFR..."
States often are given the authority to enforce
Federal regulations. They may also develop
more stringent regulations.
Example: "Used oil IS considered hazardous waste
in our state. You must follow the hazardous
waste regulations for storage and disposal
See section..."
Local authorities may add even more
stringent rules.
Eurasia: "Used oil may not be collected in areas
zoned for..."
Your operation must comply with ALL regulations.
2-1
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federal regulations. Tribal or state laws must
be at least as stringent as the federal ones, and
may be even more demanding.
Where do I find federal environmental
regulations?
The Federal Register is a daily publication
created by the federal government that lists
notices, federal actions, executive orders,
proposed and final regulations and general
information. It is intended for use by the
regulated community and the general public.
Regulations On-line
All Federal Regulations are maintained on the
Internet. Use the search engines to find
specific Federal Register or Code of Federal
Regulation references. The EPA homepage
(www.epa.gov) has links to the Government
Printing Office homepage which houses on-
line versions of the Federal Register and the
Code of Federal Regulations. The Federal
Register and the Code of Federal Regulations
can be accessed directly at the following sites:
www.qpo.gov/su docs/aces/acesl 40.html
&
www.access.qpo.gov/nara/cfr/index.html
All final regulations published in the Federal
Register are compiled into the Code of Federal
Regulations (CFR). Chapter 40 of the CFR
describes all of the environmental
requirements that have been developed by the
federal government. The CFR is updated on
an annual basis to reflect all new regulations
that were published in the previous year.
To whom should I talk first?
As mentioned above, many environmental
laws allow tribes and states to implement and
enforce federal requirements. EPA has
established useful references for identifying
state environmental regulations, requirements,
and resources:
w\v\v.epa.gov/docs/epacfr40/find-aid.info/state
www.epa.gov/smallbusiness/
When you begin your inquiries about what
laws apply to your business, you will also
need to determine where there are applicable
local laws and regulations.
Environmental Regulatory Summaries
All businesses, regardless of size, are subject
to environmental regulations. It can be
difficult to understand how regulations apply
to your business. It also may be unclear how
regulations benefit the environment. In order
to help you understand and comply with these
regulations, the remainder of this section
provides a brief overview of the major federal
environmental programs established since
EPA was created in 1970.
What can you do to ensure compliance?
The first step in the process is to recognize
that there may be environmental regulations
(federal or tribal) that apply to your business
and may require some action on your part.
The flowcharts on subsequent pages are
designed to get you started. They are not a
comprehensive summary of regulations or
checklists that can be used to evaluate your
entire facility. You should contact an
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environmental professional, industry trade
association, or someone at your tribal
environmental office to help you get started
with specific questions. They can help you
work through the regulations, to determine
how they apply to your facility. The tribal
agency also may have a person to deal
specifically with small businesses like yours.
They will probably encourage you to conduct
an evaluation of your operations, a "self-
audit", to help you to determine if you are in
compliance.
Your goal should be to understand any
requirements that apply and integrate
environmental activities into the operation of
your facility. The next section in this
document provides more specific guidelines
on developing a system for managing
environmental compliance.
EPA Enforcement in Indian country
EPA ensures compliance with federal
environmental laws by appropriately
exercising its authority to take civil and/or
criminal enforcement actions against out-of-
compliance facilities. When a facility
regulated under federal environmental laws
is identified as being out of compliance,
EPA uses its authority to pursue: (1) an
administrative enforcement proceeding; (2) a
civil judicial suit; or (3) a criminal
investigation and referral for prosecution.
Regardless of the type of enforcement
response, the action taken is designed to
remedy the environmental harm, promote
nationally consistent enforcement, and deter
future noncompliance by the same facility
and other facilities.
EPA's enforcement actions in Indian
country are guided by multiple policies,
including the 1984 Indian Policy, the -
Guidance on the Enforcement Principles
Outlined in the 1984 Indian Policy (Civil
Enforcement Guidance), the Exercise of
Investigative Discretion policy (Criminal
Investigative Policy), and various program-
specific and Regional policies. These
policies outline how EPA works in
partnership with tribes to resolve current
facility noncompliance and deter future
noncompliance in Indian country in a timely
and effective manner.
The ownership and control of a
facility impacts the process EPA uses to
respond to non compliance. For facilities
that are owned or managed by private
parties, including tribal members, EPA
responds to the noncompliance as it would
anywhere else in the United States, after
consideration of the tribe's interest in the
facility. For facilities owned or managed by
tribal governments, EPA will work
cooperatively with the tribe and provide
compliance assistance to help the facility
comply, prior to filing a formal
administrative or civil judicial enforcement
action. Regardless of whether non
compliance arises at a private party or a
tribal facility, the availability and use of the
appropriate enforcement response is
designed to protect human health and the
environment in Indian country.
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CAA
Summary of Regulations
Carbon Lead
Monoxide
Oxides ol
as of
Ground-
level Ozone
Particulate Matter
trv -utirrtrral PH-totiLT f.xr;< t,ą\ut>,yw DC
Hazardous Air Pollutants (HAPs)
188 Chemicals Listed by EPA
Clean Air Act
Does your facility
emit dust or
chemicals to the
air?
Yes
Yes
Does your facility
use refrigerants?
No
Your operation may be subject to
regulations under 40 CFR Part 82.
including:
EPA certification for technicians who
repair refrigeration or air conditioning
equipment,
Recovery and recycling of refrigerants.
Safe disposal of refrigeration and air
conditioning equipment,
Repair of leaks.
Yes
Does your facility emit
organic chemicals.
hazardous air
pollutants.
participates (dust),
CO, NOX, SOX or lead?
Your facility may have permitting
requirements under several air pollution
programs under 40 CFR Parts 60-63,
including:
Emission limits or specific air pollution
control equipment, emission limits, and
work practices for certain industries
Additional requirements for facilities in
areas with poor air quality
Additional requirements for new
facilities.
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CERCLA
Summary of Regulations
Comprehensive Environmental Response,
Compensation and Liability Act
11 not contained on-site. chemicals released
to the environment may be a "Reportable
Release" under CERCLA.
AAA
Yes
It may be helpful to
prepare a list of
chemicals stored on-
site and the quantity
stored.
Once you've
prepared a list
Check the list in 40 CFR 302.4 to see if
any of your chemicals are on the list. If
so, your facility may be subject to several
requirements including:
Immediately reporting spills that exceed
the reportable quantity. 800-424-8802
(National Response Center)
Submitting reports to State and local
agencies responsible for emergency
response planning (if more than 10,000
ibs of any one hazardous substance is
stored on-site (40 CFR 370.21-.2S).
Conducting annual release reporting for
specific chemicals (40 CFR Part 375.35):
Does your
facility have
any
chemicals
on-site?
No
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WA
jmmary of Regulations
You must
TiaveTWateT
You may have g
storm water
requirements.
Not everything is
allowed to go down
the drain.
"Send your water to a local
waste water treatment plant?
They often have their own
requirements."
In order to do so you need to apply for,
be issued and operate in compliance
with an NPDES permit issued by EPA
or a State agency in conformance with
state requirements and federal
requirements set out in 40 CFR 1 22.
Facilities that discharge stormwater may
be required to develop and implement
a stormwater pollution prevention plan.
In order to do so you may be required
to apply for, be issued and operate in
compliance with a discharge permit from
the municipality that owns the sewage
treatment plant The permit may include
local, state as well as federal
requirements set out in 40 CFR Part
403. Additionally certain industries may
be required to meet specific discharge
standards set out in 40 CFR 405-471 .
Yes
Clean Water Act
Does the facility use
water or is any
wastewater or
stormwater
generated onsite?
TYes
Does your facility
discharge any water
or wastewater (either
process water or
stormwater) through
a pipe or from
another discrete
point to a water body
such as a lake or
stream?
No
Does your facility
discharge any water
or wastewater to a
sanitary sewer?
No
Does facility have
the ability to
impact water?
Yes
Does facility
generate domestic
sewage sludge from
onsite domestic
sewage facility?
Is the facility located
near a wetland
and/or planning any
activity that may
impact the wetland?
Facility may be ;
required to treat
sewage sludge use
and disposal
requirements that
are incorporated into
NPDES discharge
permit or a sludge only
permit issued pursuant [
to requirements in ;
40 CFR 501.
The facility may need
to apply for and be
issued a §404 permit
by the Army Corps
of Engineers for
actions impacting a
wetland such as
drying or filling in a
wetland.
1
Does the facility
store chemicals
above ground onsite
that could spill and
reach waters of the
U.S.?
'Yes
The facility may be
required to prepare
and implement a
SPCC Plan pursuant
to Oil Pollution
Prevention
regulations found at
40CFR112.
Does your facility
discharge to a
separate municipal
storm sewer?
Yes
>
No
In order to do so you may be required to
apply for, be issued and comply with a State
or Federal general permit or individual permit
issued pursuant to 40 CFR122. Additionally
you may be required to develop and
implement a stormwater pollution
prevention plan.
Are you. discharging
water or wastewater
into the ground or
any underground
injection well such
as a septic system,
dry well, etc?
Yes
In order to do so you may be required to
apply for and comply with a permit issued
in conformance with state and or SDWA
requirements.
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>CRA
:mmary of Regulations
Emergency Planning and Community
Right-to-Know Act
No
Planning Requirements:
(40 CFR 370.2-370.40)
Are there any chemicals on-
site for which the OSHA
regulations (health and
safety) require a Material i
Safety Data Sheet (MSDS)? |
1
Ho Are any of the chemicals
present at greater than
10,000 pounds?
Yes
No
Are any of the chemicals
considered "extremely
hazardous substances" and
present at greater than 500
pounds (55 gallons) or their
"threshold planning
quantity"?
See Appendices A & B to
40 CFR Part 355
You must submit a copy of
MSDS and other
information to fire
department and other
emergency planning
organizations
Release Requirements:
(40 CFR 372.1-372.45)
Is the facility included in the
SIC codes 10-39,4911,
4931,4939,9553,5169,
5171, or 7389?
I..
r.
Does the facility have 10 or
more full-time employees (or
the equivalent of 20,000
hours per year)?
Yes
No
Does the facility
manufacture, import,
process, or otherwise use
any of the toxic chemicals
listed in 372.45 in amounts
greater than threshold
quantities (25,000 Ibs/yr for
"manufacture, import, or
process'; 10,000 Ibs/yr for
"otherwise use"; 10-100
Ibs/yr for certain "persistent,
bioaccumulative, and toxic"
chemicals in 372.28: .1
grams for dioxins)
Yes
You must submit
annual report {Form
R) every July 1st on
releases to the
environment, both
routine and
accidental releases
No EPCRA
Requirements
The Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA) actually is an amendment to the Superfund law (CERCLA). The chief EPCRA
provisions relate to (1) emergency planning efforts at the State and local levels and (2) citizen access to information about potential chemical hazards In
their communities. The regulations written to implement the EPCRA law pertain to submitta! of chemical inventories by businesses so that, in the event of
an emergency, local emergency response personnel will know how to effectively deal with the emergency. Other EPCRA requirements relate to reporting
annual releases, or discharges, of hazardous chemicals to the air, water, or land. The resultant Toxics Release Inventory is accessible to the public for
information and research purposes. The annual release reporting requirements of EPCRA apply to businesses and industries falling within specific Standard
Industrial Classification (SIC) Groups, primarily the manufacturing sector. In addition, the requirements apply only to those specific facilities that manufacture,
import, process, or otherwise use toxic chemicals above a certain threshold quantity per year. The emergency planning provisions apply to facilities that
store chemicals for which Material Safety Data Sheets are required. As with the release reporting requirements, a facility must store amounts above the
soBRifieri threshold miantitv bnfnre the nlanninn ranulrements annlv.
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IFRA
immary of Regulations
Federal Insecticide, Fungicide and
Rodenticicie Act
Yes
Yes
Are any of the
pesticides classified
as "restricted use"
pesticides?
Anyone who mixes and applies restricted
use pesticides must be certified to do so
by EPA or a State with an EPA-approved
Certification Plan (40 CFR171).
The disposal of many pesticides is subject
to hazardous waste regulations (40 CFR
261 and 262).
No
Does your
facility use,
manufacture,
or store
pesticides?
1
NO
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CRA
;mmary of Regulations
Resource Conservation Recovery Act
WASTE
Does your facility
produce waste
materials or do you
store petroleum
products in
underground
petroleumstorage
tanks?
Is your waste
defined as a solid
waste under 40 CFR
Part 261 .2?
1
No
\
I
'Yes
Yes
r
Could your waste be
classified as
hazardous waste?
No
i
If your solid waste exhibits a characteristic of
ignitability, corrosivity, reactivity, or toxicity or
if it is on EPA's lists of hazardous wastes, it
may be subject to regulation (40 CFR Part 261).
If you generate less than 100 kilograms (about
22 gallons) per month, requirements are
minimal (40 CFR 261.5).
If you generate more than 100 kilograms per
month, you are subject to:
- Tank, container and drip pad requirements
- Time and quantity accumulation limits
- Labeling
- Recordkeeping and reporting.
Hazardous wastes must be shipped, off-site for
recycling or treatment and disposal. Waste
must be managed by an authorized transporter
and taken to a facility authorized to treat or
dispose of hazardous waste (40 CFR 263-265).
On-site treatment of hazardous waste may
require permit (40 CFR 270).
Waste disposal must
be done according
to state and local
requirements, which
generally prohibit
open dumping and
open burning.
TANKS
Yes Is the tank capacity
__ greater than 110
gallons?
No
1
The tanks may be subject to requirements
including:
Installation specifications
Monitoring requirements
Leak detection, and
Clean up of spills under 40 CFR Part
280.
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CA
Summary of Regulations
Toxic Substance Control Act
Does your company
have or renovate any
PCB-containing
materials, lead
paints, or asbestos-
containing
materials?
No
Yes
PCBs
LEAD
I
ASBESTOS
Does your facility
have any electrical
equipment made
before 1978?
Yes
Do you plan to
abb* buildings that
may have lead-based
paint?
No
Yes
If you have equipment
containing fluids with greater
than 50 ppm PCBs, you will
be subject to regulations
including labeling and
inspecting equipment,
notifying local emergency
response groups, and having
a PCB leak response plan,
with trained personnel (40
CFR Part 261).
Does your company
renovate residences
that require you to
disturb 2 ft2 of lead-
based paint?
Do you plan to do
any demolition or
renovation of
buildings?
Yes
Only ERA certified individuals
can conduct renovation .
actMies1n\i8tving lead-based
paints (29 CFR1926).
Paint cljips-fiontaining lead
may be'subjactto regulation
261).
No
Yes
Your company's staff must
be trained and certified in
accordance with EPA
requirements {40 CFR 748).
No
Your facility may contain
asbestos in plaster, vinyl tiles,
shingles, and insulating
materials. Any demolition/
renovation that involves
asbestos-containing must
bedonebyEPA-certified
technicians (29 CFR 1926).
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Section 3 - Getting Help
You have discovered that you may have
environmental regulatory requirements that
apply to activities at your facilities. So what
now? If you're like most people, you may
want help in understanding the exact
requirements, the obligations for your
company, and the best approaches for meeting
these obligations. EPA has developed several
resources that can assist you in learning about
the regulations that apply to your company.
These resources include assistance from
experts, self-help documents and guidance
manuals, and web resources. You may want
to access these resources to better understand
your requirements and to identify common
approaches to compliance.
This section is intended to help you use the
programs that EPA has established to assist
you. We've broken this discussion into several
steps to walk you through your first contact
with an assistance program.
O
Understand Your Situation
If you have identified a business practice that
EPA or a tribe may regulate, you should be
able to describe the nature of the process and
the regulations you think may apply. You
should be able to:
1. Describe the nature of the activities
involved.
2. Provide information on the chemicals used
or output generated by the activity.
3. Review equipment specifications to
determine operation conditions and review
product loss or emission rates.
4. Understand usage patterns for chemicals
especially those released to the air or water.
5. Document your current management
practices for all materials in question.
6. Identify which regulations you think may
apply to your processes, wastes, or chemical
uses.
7. Identify which assistance program is best-
suited for your question. Keep in mind that
federal and tribal regulations often vary. You
will probably need to contact both EPA and a
tribal regulator. A list of references for EPA
assistance programs is provided in Appendix
A.
tŁF Contact Your Assistance Provider
When you call for help, you should:
1. Describe your situation and ask them to
clarify the requkement(s).
2. Ask whether or not they provide on-site
compliance assistance or process reviews like
pollution prevention opportunity assessments.
If they do not, ask whether they know of any
local organizations that do.
3. Ask if on-site assistance is confidential and
non-regulatory. EPA and many non-federal
organizations, including states offer technical
assistance without the threat of enforcement
for violations found during the assistance
visit.
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4. If you are uncomfortable with the thought
of receiving on-site assistance, ask for any
guidance that they may have concerning the
requirements that apply to you.
13ij Get On-site Assistance
If you decide to invite a technical assistance
person to evaluate your operation, you should
understand that they will investigate your
operation to determine how regulations apply,
identify practices that may reduce your
environmental impacts, and suggest
approaches you might consider to ensure your
company is compliant with the requirements.
To prepare for an assistance visit, you should:
1. Compile information on the operation of
your facility or processes that will be
evaluated. Include such information as the
amounts of chemicals used, loss of chemicals,
flow rates of waste water, amounts of
chemicals vented to the atmosphere, amounts
of wastes generated, and locations of releases
to the environment.
2. Compile Material Safety Data Sheets for
review by assistance staff. At a minimum,
you'll need to know what chemicals are used
in your processes.
3. Be comfortable with the assistance staff
walking through your operation and looking at
your activities.
4. Ask questions of the assistance providers
and make sure that you understand the
requirement and your options to attain
compliance.
5. Be prepared to answer hard questions.
Assistance staff will ask you about the
practices you have employed to control
materials and wastes. Be prepared to
answer truthfully and help them to
understand your situation.
6. Remember that you are doing this to
attain compliance with regulations. Don't
be shy about your information and the
process. Assistance providers realize that
you may be out of compliance. They want
to help you get into compliance.
vListen
Non-regulatory compliance assistance
programs were created to help companies
just like yours. When discussing your
company or participating in an on-site
evaluation, pay attention to the process
followed, questions asked, and the
information you provide. Regulators and
assistance providers do not ask questions or
collect information for no reason. For
example, if an assistance provider asks
questions about the paints you use, the
amounts used, the frequency of painting,
and how fumes are vented, they are probably
trying to determine your status under air
regulations. That is, does your painting
process and subsequent release of paint
solvents to the air constitute a regulated unit.
The figure on the next page lists the types of
information that are critical to understanding
your regulatory status.
As you talk with the regulator or technical
assistance provider, take notes on the
conversation. Make sure you understand
which regulations may apply and list all the
data you will need to adequately identify
your regulatory status. Assistance
organizations may also provide you with
strategies for resolving issues, information
on permitting procedures, and approaches
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for reducing the amount of waste that you
generate. Reducing waste at the source is
important because you may be able to change
your regulatory burden by reducing the
volumes of waste produced.
The Small Business Compliance
Policy
EPA established a Small Business
Compliance Policy to help small businesses
that discover they are out of compliance
through self-inspections or compliance
assistance. Use this policy to your advantage.
If an assistance program finds that you are out
of compliance, the Small Business
Compliance Policy offers you a chance to
avoid or reduce fines if you quickly correct the
problem. The relief from penalties offered by
the Small Business Compliance Policy is not
available however, to businesses that are
determined to be non-compliant through a
routine inspection by federal or tribal
regulators.
Can You Use the Policy?
The policy applies to facilities owned by small
businesses. For the purposes of this policy, a
small business is a person, partnership,
corporation, or other entity that employs 100 or
fewer individuals. EPA has similar policies for
facilities operated by small communities or local
governments, (see,
(www.epa.aov/compiance/incentive/
smallcommunities/)
The Small Business Compliance Policy is
intended to promote environmental
compliance among small businesses by
providing incentives for them to make use of
compliance assistance programs,
environmental audits, or compliance
management systems (CMS). The policy is
intended to encourage small businesses to
participate in any activities that may increase
their understanding of the environmental
requirements with which they must comply.
The Policy accomplishes this in two ways: by
waiving or reducing civil penalties to which a
small business might otherwise be subject,
and by deferring to tribes, states and local
governments that offer incentives consistent
with the criteria established in this Policy.
Small Business Policy Restrictions
The Policy does not apply if the small business
has been subject to any of the following:
Receipt of a warning, letter, notice of
violation or citation for a violation of
the same requirement within the past
three years;
A penalty reduction under this Policy
(or a similar state or tribal policy) for a
violation of the same or similar
requirement within the past three
years;
Any two enforcement actions in the
past five years, or an enforcement
action for the same violation as the
one just uncovered ; and
Violation(s) were already discovered
by a regulatory agency through
information requests, inspections,
investigations or other methods.
Or, the violation:
Caused actual serious harm to public
health, safety or the environment; or
May present an imminent and
substantial endangerment to public
health, safety or the environment; or
Involves criminal conduct.
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EPA may eliminate or reduce civil penalties
in several ways including:
Waiving or reducing civil penalties in
cases of good faith efforts; and
Reducing penalties where small
businesses are unable to pay fines
without harming the business; or
Reducing the civil penalty to the
amount of economic benefit the
business received by not complying.
EPA anticipates that a situation where
a small business would realize
significant economic benefit through
noncompliance will rarely if ever
occur.
EPA will enforce all regulations for violations
not remedied within the specified time frames
established in the policy. For a complete
version of the Small Business Policy (see
www.epa.gov/compliance/incentives/smallb
usiness/.
Š Establish a Program
Once you've gotten assistance, go back and
evaluate your entire facility. Develop a
program that includes all f acility activities and
operations. The remainder of this document
will give you some ideas on how to establish
a comprehensive environmental compliance
management system.
3-4
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Section 4 - Managing Your Business to Ensure Environmental Compliance
As we discussed earlier in this document,
small businesses may be subject to a number
of environmental regulatory programs. EPA's
Small Business Compliance Policy favors
companies that are vigilant in identifying and
complying with all applicable requirements
(See the discussion of the Small Business
Compliance Policy in Section 3 of this
document). EPA also supports companies that
put forth a "good faith effort" to address all
environmental requirements. A "good faith
effort" involves educating oneself about the
basics of the various regulatory programs,
assessing current site operations to determine
if any environmental regulations apply, and
"fixing" those aspects of the business
operations that are not in compliance.
EPA encourages all regulated facilities to plan
for and address environmental requirements as
part of their business operations. Companies
that comply with requirements as part of their
facility operations reduce their costs, face
fewer risks, and have a lighter regulatory
burden than companies that only react once
regulators conduct inspections.
To strengthen your environmental program,
you should try to integrate environmental
factors into daily decision-making and both
short and long-term planning. This is an
efficient means of ensuring that your site
remains in compliance, instead of reacting to
incidents of non-compliance, which can be
costly and dangerous.
For example, if your facility is planning to
renovate an old warehouse, you must consider
not only the cost of the new building
materials, the labor costs, and the potential
effect on productivity, but also whether the
renovation may involve disturbing asbestos-
containing materials. If so, you will need to
determine whether the renovation can be done
without disturbing these materials. If not, you
may want to re-evaluate the renovation effort.
It would be better to perform this examination
before the renovation is initiated, rather than
somewhere in the middle when you risk
exposing workers to asbestos. You do not
necessarily need to know all the details of the
asbestos regulations. Instead, you need to
know whether asbestos is an issue at your site.
Waiting for issues to arise into problems also
can result in expensive fines, damaged
property, lost public relations, and lost
productivity. For example, if hazardous
material is not appropriately handled and
eventually spills, the facility must use
valuable time, personnel and money to contain
the spill, clean it up, contact the appropriate
regulatory agencies, pay any resulting fines,
and purchase more material. A proactive
approach helps to avoid this kind of situation.
The information presented below provides you
with common sense ways to incorporate
environmental considerations into the
standard operating procedures in your
business.
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How can you manage environmental issues
in your business?
N.
There is nothing magical about managing
environmental issues. The concepts are much
like the ones used to manage employee safety
and health, a business budget, or quality
concerns. Integrating environmental issues
into a site's activities simply takes some
planning and cooperation from management
and other site personnel.
In an ideal situation, your business would
have the resources and time to appoint a
person or a team of people whose
responsibility is addressing environmental
concerns. This may not be feasible for a small
business (e.g., six-person shop would likely
not be able to devote a full-time person to
environmental compliance). However, EPA
cannot excuse non-compliance due to staff
shortages. An environmental compliance
position maybe worth exploring, especially in
a franchise or chain organization where one
individual could be responsible for
environmental issues at several small
operations.
Characterize your facility
To begin, it is critical to understand how your
business generates non-product outputs or
wastes. Wastes often lead to environmental
impacts that may be the target of regulatory
requirements. While most managers or
owners understand their processes, they may
not have ever characterized all of their non-
product outputs and how these wastes result
from their operations.
Steps to Managing
Environmental Issues in
Your Business
Characterize your '.
facility
Evaluate the
regulatory
requirements
o
1
Determine your
compliance
status '
O
Identify what
actions are needed
to achieve
Develop a
strategy
0- "- *
^^ Communicate |
these actions to |
other employees j
1
Initiate the actions
^^^^^^Bm^i LW.isjf in "^ ~ T
Evaluate the
action's success
4-2
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Identify non-product outputs by listing all of
the places in your process that result in:
Solid wastes - material that are
drummed, collected in dumpsters, put
in trash bags, or similarly collected
and disposed of;
Liquid wastes - free-flowing outputs
discharged to sewers, floor drains,
storm sewers, rivers, ponds or any
other receiving waters; and
Gaseous wastes - vapors or fumes of
gases released to the environment
through vents, exhaust fans, fume
hoods, open windows or doors, or
other openings used to ventilate an
area.
Once your wastes are identified, the next step
is to characterize the composition of your
facility's wastes. Start by identifying which
chemicals and materials are likely to
contribute to the waste. The composition of
the waste will be important in determining
which regulations apply.
At this point, several steps may be helpful:
Quantifying the amount of waste
generated - important for determining
regulatory status;
Calculating costs for materials lost -
important for documenting losses in
profitability due to loss of raw
materials or products;
Identifying procedures that
contribute to wastes (equipment clean
outs, chemical change outs, batch
changes, maintenance, etc.); and
Identifying people responsible for
wastes - important for determining
how to change current procedures.
Evaluate the regulatory
requirements
Take the list you generated in step 1 and
divide the waste streams into discharges to
"land, air, and water." Now, review the
regulatory summaries presented in Section 2.
For each waste stream, note which regulations
might apply to it. For example, if there are
discharges to a floor drain in your facility, the
discharge would qualify as a wastewater
stream. Then, after examining the regulatory
summaries, you may discover that the
discharge is subject to regulation.
Going through this process, did you find areas
of concern in any of these categories?
G Hazardous waste
Q Air emissions
Q Wastewater or stormwater discharges
Q Presence of PCBs or asbestos on site
Q Use of other toxic substances
As was mentioned above, the regulatory
summaries are provided to help you grasp the
major requirements for each federal
regulation. They are not a substitute for
reading the actual regulations and speaking
with an environmental professional. Also,
remember that some state regulations may be
more stringent than the federal regulations.
Call your state agency to discuss your
regulatory situation.
* Determine your compliance status
Examine the flow diagrams that accompany
each of the regulation summaries in Section 2.
Work through the diagrams with the waste
stream list you develop. The purpose of this
effort is to determine any area where you
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might be out of compliance with the federal
environmental regulations. For example,
assume the floor drain mentioned above runs
directly into a ditch leading to a small stream
on-site. Using the CWA flow diagram, you
determine that the discharge from this drain is
entering a water body such as a lake or stream.
It, therefore, may require a permit.
Document the results of this effort by making
notes of your findings for all activities at your
facility. This will help you discuss
environmental issues with your state agency or
trade association. It also provides a written
record that can help you target specific
environmental compliance issues. At this
point, it may be helpful to review your
findings with an environmental professional,
a trade association representative, or state
compliance assistance liaison to confirm
applicability of the regulations and areas of
non-compliance.
9 Identify what actions are needed to
achieve compliance
You have documented your facility's areas of
non-compliance. You now have to decide
what specific actions are necessary to become
compliant. There are two major ways to
achieve compliance. The first is called an
"end of the pipe" approach. This method does
not examine the reasons why the pollution is
created, it simply provides for installation of
a device or system to remove the pollutant
before it is discharged into the environment.
For example, in the floor drain example
above, if a treatment filter was installed at the
end of the drain pipe, it could remove the
contaminant before it reached the stream.
You will still need a permit and may have to
meet continuing permit requirements to
operate this filter and drain.
A related example is that you may find you
generate regulated quantities of hazardous
wastes (e.g. cleaning solvents). You will need
to assess your requirements as a hazardous
waste generator. It may be that the solvent is
very effective for your specific operation and
that an adequate substitute is not available. In
that case, you would need to check with your
state to confirm what actions you need to take
(e.g., get an EPA I.D. number, manage your
spent solvents in the appropriate, labeled
containers, arrange to have your waste
manifested off-site to a hazardous waste
treatment facility or recycler, and comply with
biennial reporting requirements). This
example is similar to an "end of the pipe"
approach because it achieves compliance by
focusing on the generated wastes, not by
reducing the amount or type of chemical used.
The other major way to achieve compliance is
through pollution prevention (P2). P2 focuses
on reducing or even eliminating pollution by:
Improving process efficiency,
Using less toxic products and raw
materials,
Improving facility housekeeping,
Recycling waste chemicals, and
Controlling the use and storage of
chemicals.
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The following chart provides some starting points for thinking about P2 at your site.
APPLYING POLLUTION PREVENTION
What should I do?
Why?
1. Get managers or other people in charge to
support the P2 approach.
Without support from managers, employees may be reluctant to change.
Vocal support from all levels of managers sends a clear message that P2
is a priority.
2. Get the program started by looking at
operations throughout the company, developing a
written P2 plan if possible, and training
employees in P2.
The existence of the P2 program as a way to achieve environmental
compliance must be known throughout the company. The person
heading the P2 campaign must inspire all employees so that they
understand that P2 is going to be the foundation for conducting
business. Employees have to know that they will be held responsible for
identifying chemical or process changes, and that such changes will be
encouraged and supported.
3. Assess your operations to determine the raw
materials used and points of waste generation.
Use that information to define a baseline
inventory to be used in setting P2 goals.
In order to minimize environmental risks and to maximize cost savings,
you have to know what you are working with. It is critical to re-think
each step of your operation, whether it is manufacturing a product or
providing a service, to assess the raw material and energy inputs and the
waste outputs.
4. Get ideas from the employees about possible
P2 opportunities.
Employees are the ones most familiar with the details of operations.
They are also in the best position to suggest how things could be done
differently. Some research likely will be required as the P2 possibilities
are identified. An excellent source of help on P2 is EPA's EnviroSense
program.
5. Determine costs of waste management and
disposal.
To institute changes to the operation, you will need the data that proves
P2 will yield cost savings. You must have a baseline against which you
can measure progress after putting P2 techniques in place.
6. Select the best P2 options for the company and
implement those choices.
It probably will not be feasible to implement all of the P2 options that
are identified. A cost/benefit analysis may help in selecting P2 projects
that will yield the most benefits in the shortest period of time. If there
will be capital expenditures (e.g., purchase of a new in-line recycling
device), you will need to calculate the "pay-back time". You may
decide to invest in projects that have a pay-back time of less than 5
years.
7. Document performance of each P2 project
You will want to measure the changes in waste generation and energy
usage that result from using P2 techniques. You can then translate these
changes to money saved. If the changes aren't what you anticipated,
some adjustments may be necessary.
8. Maintain and sustain the P2 program for
continued growth and benefits to the company.
As the P2 approach becomes a normal part of the operation, it may be
possible to initiate the lower priority P2 projects to yield even more
environmental and cost benefits. Thoughout this process, it will be
necessary to make sure employees "stay on board." It is their
commitment that will contribute to the success of the P2 program.
9. Re-evaluate the program as economic
situations change and/or process equipment
requires upgrading.
As with most aspects in the competitive business arena, you must be
regularly assessing your P2 program to see if there are further
technological advances that should be tried that will give you a
competitive advantage. In addition, as your equipment ages and needs
to be replaced, remember to re-evaluate P2 opportunities relating to that
aspect of your operation.
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The P2 approach, which is also called "waste
minimization," is generally an effective and
efficient way to manage environmental issues.
Some of the benefits associated with this
approach include decreased disposal costs,
energy savings, improved regulatory
compliance, and reduced environmental
liability.
* Develop a strategy
Environmental requirements can be complex
and confusing even for small facilities. If
your facility is subject to several requirements,
it may make sense to develop a plan of attack
for addressing requirements. This plan may
include:
Identifying environmental tactics for staff,
Determining who needs training,
Identifying equipment and resource needs,
Developing procedures and policies,
Documenting incentives and penalties for
superior and poor environmental
performances, respectively,
Determining who monitors compliance
within your organization, and
Establishing a schedule for achieving
compliance and ongoing maintenance of
environmental compliance.
* Communicate these actions to other
employees
Line-staff personnel and managers often have
numerous job requirements. It is absolutely
critical that you educate the employees about
their part in gaining environmental
compliance. This may be simply a matter of
posting reminders hi the work area (e.g.,
"Don't mix used oil and spent solvents!").
Intensive training may be required initially,
and regular refresher training provided as
well, to enforce the point that the business is
serious about sticking to the policies and
procedures. If your company has a formal
policy that says environmental compliance is
part of everyone's job, make sure your
employees know it!
Once the employees are trained, they need to
know what is expected of them with regard to
environmental compliance. They need to
understand how they are responsible for
ensuring the company's compliance with
environmental regulations. Tying
environmental compliance to performance
evaluation can be a very effective strategy.
Furthermore, it will be difficult for personnel
to add environmental compliance
requirements to their jobs if management does
not appear committed to complying with
environmental regulations. There are many
ways in which management can demonstrate
commitment. For instance, time can be set
aside during meetings to discuss
environmental issues; abasic statement signed
by management highlighting the need for
environmental compliance can be posted for
all workers to see; and/or employees can be
congratulated or rewarded for reducing the
company's environmental liabilities and costs.
Once employees see how important
environmental issues are to management, they
will then place more emphasis on these
topics.
* Initiate the actions
Once all of your employees are informed of
your company's environmental policies and
procedures, it is time to intitate them. For the
first week or so that the new policies are in
place, you will have to be very attuned to your
employees' actions and correct them where
4-6
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necessary. However, this transition period
should be fairly short if you have invested the
appropriate time in educating and informing
your employees of the policies.
At the same time policies and procedures are
put into place, staff may also be bringing new
equipment on-line to address specific
requirements. It is critical that staff
understand how all efforts are part of the
company's efforts to comply with
environmental requirements, protect the
community, and, if applicable, improve
profitability by using pollution prevention
technologies.
of environmental requirements through the
Code of Federal Regulations. In some cases,
the regulations do not change very much. At
other times, the rules can be altered
drastically. You should check with sources
like trade associations, state agencies,
environmental professionals, or EPA, which
can alert you to regulation changes. In most
cases, you should contact your state
environmental regulatory agency at the
beginning of each year for an update on their
regulations or monitor regulation changes
through the Internet.
* Evaluate the program's successes
The last, and perhaps most important, step is
to evaluate your environmental program's
success. You should regularly evaluate your
system for successes and flaws. When the
program is first put in place, you should
perform an analysis within the first month.
This is to chart the progress of your initial
program and make any necessary corrections.
After the program is working smoothly, you
should only have to assess it and make
changes twice a year.
You should also perform an analysis of your
environmental program when you make major
changes to your operating process. For
example, if you are a small-scale parts
manufacturer, adding an additional production
line would force you to incorporate changes
into your environmental program. If this
production change occurs when you have not
revisited your environmental program for
some time, you should spend the extra effort
to review the whole process.
You should also review your environmental
program when the environmental regulations
change. Each year EPA releases a revised set
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Section 5 - Compliance Management Systems
As you evaluate your facility's environmental
compliance situation, you might find that a
more formal process is needed. Section 4
outlined a series of practical environmental
considerations for you to initiate in your daily
operations. However, there is a more formal
method to account for environmental
compliance issues in your management
structure; this is commonly referred to as a
Compliance Management System (CMS)
(You may also have run across the term
"Environmental Management System" (EMS)
which is an even more formal type of
management system that includes
organizational structure, planning activities,
achieving, reviewing and maintaining the
environmental policy. For the purposes of this
document, you may think of a CMS as a
simplified subset of an EMS).
A CMS is a continual cycle of planning,
implementing, reviewing and improving the
actions that an organization takes to meet its
environmental compliance obligations. While
there are several costs associated with the
creation of a CMS, the benefits include:
improved environmental performance,
improved environmental compliance,
new customers and markets,
increased efficiency and reduced costs,
enhanced employee moral,
enhanced public image, and
enhanced reputation with regulators.
The CMS is traditionally divided into several
different components or steps. These
components are described below, so that you
might better understand how it functions.
Environmental Policy: An
environmental policy is your
management's declaration of
commitment to the environment. The
policy should serve as the foundation
for your CMS and provide a unifying
vision of environmental concern by
the entire organization.
Planning: In this step, you examine
your environmental aspects and legal
requirements, set your objectives and
targets, and create your environmental
management program.
Implementation: This step creates
the accountability structure for the
CMS, implements the training
program and communication system,
documents the CMS, and establishes
your control and emergency response
procedures.
Checking and Corrective Action:
This step establishes the CMS's
monitoring and measurement system,
corrective and preventative action
system, organizes relevant records,
and conducts compliance audits. For
additional help concerning audits,
please see EPA's Protocols for
Conducting Environmental
Compliance Audit series
(www.epa.gov/oeca/compliance/
incentives/auditing/protocol.html)
Management Review: Your CMS
must be reviewed by management
from time to time to stay "healthy."
Management reviews are the key to
continual improvement and to
ensuring that the system will meet
your organization's needs over time.
Evaluation of Performance: A CMS
is designed and implemented to
achieve compliance with
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achieve compliance with
requirements. As such, you should
evaluate how well your management
system performs in meeting
environmental regulatory
requirements.
Conclusion
EPA knows how confusing environmental
compliance can be, especially for small
businesses. Small businesses face many
special situations which make compliance
difficult, including lack of time and resources,
difficulty in understanding the regulations,
lack of environmental staff, etc. EPA
understands these problems and wants to help.
This document is one of many resources EPA
can provide to assist your compliance efforts.
More information can be found in the
Compliance-Focused Environmental Program
Checklist that follows this section and EPA's
website (www.epa.gov). Good luck in your
business and thank you for your interest in
environmental compliance.
Please remember that while a CMS may seem
overwhelming, its complexity and depth are
determined by the size of your company and
the number and type of environmental issues
that your facility faces. In many cases,
smaller companies may be able to skip or
simplify steps because the size of the
organization eases communication and
implementation requirements.
The Compliance-Focused Environmental
Program Checklist on the next page may help
you develop a CMS for your operation.
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Listed below are a few ideas that you might
find particularly useful for your small
business. This list is based on work done by
theNEIC.
Compliance-Focused Environmental Program Checklist
Environmental Program
Element
Questions to ask employees for each Element
1. Management Policies & Procedures
Environmental Policy
Site-specific Environmental
Policies & Standards
Environmental compliance
program
Ongoing means of
communicating
environmental issues and
information to personnel.
Specific actions to be taken to
improve communication
regarding environmental
compliance.
Does an environmental policy exist?
How is the policy communicated to all staff?
Are you familiar with the environmental policy?
What does the environmental policy say?
How does the policy affect you?
How has the policy been communicated to you?
What documentation exists regarding general policies,
rules, and procedures for environmental principles
and practices?
Who is responsible for environmental compliance?
Who will pay for penalties imposed as a result of
noncompliance?
Have fines been imposed?
How do fines affect operations and bonuses?
How do you receive information regarding changes in
the environmental program?
How do you know what is important and pertinent to
your operations?
Describe the communication system withing the
facility .How do you know what is important?
2. Organization, Personnel, and Oversight of the Environmental
Policy
Outlines formal organization
for managing the
environmental program
Do you know how the environmental policy is
implemented and maintained?
How does management advocate the policy?
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Identify duties,
responsibilities, and
authorities of key
environmental program
personnel.
What are the lines of authority?
Who has ultimate authority to enforce environmental
directives?
3. Accountability & Responsibility
Specifies accountability of
plant management for
environmental protection
practices and corrective
actions implemented in their
area of responsibility
Specifies potential
consequences of departure
from specified operating
procedures
What level of responsibility do you have for
environmental protection?
What are the consequences of not following written
Standard Operating Procedures (SOPs)?
4. Environmental Requirements
Process for identifying,
understanding, and
communicating
environmental requirements
and changes in those
requirements to affected
operations.
Describe the process.
Show where this has been done.
Specifically, how do you detect and deal with
environmental requirement changes?
What sources are used to identify environmental
requirements?
Did you check with your EPA, a tribal agency and
trade organization?
a
5. Assessment, Prevention, and Control
Identify the ongoing process
for:
- assessing
- monitoring and measuring
operations as they relate to
environmental protection and
regulatory compliance
What are the major environmental concerns/risks at
the facility?
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Identifying operations and
waste streams where
equipment malfunctions and
deterioration, operator errors,
and discharges or emissions
may be causing, or may lead
to releases of HW or
hazardous constituents to the
environment, or a threat to
human health and the
environment. Performing
root cause analysis of
identified problems to prevent
recurring issues.
Process for developing and
approving documented
operating criteria for activities
that could cause
environmental impacts and/or
non-compliance.
What are the environmental concerns/risks related to
your job or work area?
What are the procedures for follow-up on an
environmental incident?
Do you have any reporting requirements?
Where are records kept?
How are these records reviewed?
How do you develop criteria for operations that could
have an environmental impact?
Describe the system for
conducting routine self-
inspections by department
supervision and
environmental coordinators.
How was the system initially
developed?
How was the system developed?
Who conducts inspections?
Who receives inspection reports or results of
inspections?
How are deficiencies communicated and resolved?
Describe the inspection process.
What inspection responsibilities do you have?
Process for ensuring input of
environmental concerns and
requirements in planning
design, and operation of
ongoing, new and/or changing
buildings, processes,
maintenance activities, and
products.
Describe the process for ensuring environmental
concerns are considered.
How are environmental issues incorporated into daily
planning and operating activities, purchases,
maintenance, new processes, etc.?
6. Environmental Incident and Non-compliance Investigations
Outline standard procedures
and requirements for:
- incident reporting
- non-compliance reporting
- investigation and
development and tracking of
corrective and preventative
actions
Who develops the procedures?
How, by whom, and how often are they updated?
What procedures are in place?
Describe incident reporting - what do you do?
What is an incident?
5-5
-------
7. Environmental Training, Awareness, and Competence
Identify specific education
and training for personnel
Document training provided,
including employees in non-
environmental departments
with environmental
responsibilities. List overall
and environmental job
responsibility.
How is necessary training and education determined?
How is competence evaluated?
How are specific training programs evaluated and
identified?
Who is trained?
How do you know who has to be trained?
What training do environmental department personnel
have?
What training have you received?
8. Maintenance of Records and Documentation
Identify types of records
developed in support of the
environmental policy.
Specify system for recording
and tracking:
- any internal waste tracking
or manifest systems
- environmental data
- HW determinations
Who maintains the records and where are they
maintained?
What training do they have?
Are there formal policies and procedures to operate
the system?
What protocols exist for responding to outside
inquiries?
Is the tracking system accessible to all employees?
How are SOPs currently available to all employees?
Who will respond to outside inquiries?
Where is the following information kept:
* waste tracking
* manifests
* TRIdata
* other environmental data
9. Pollution Prevention Program
Describe internal program for
reducing, reusing, and
minimizing waste and
emissions, including
procedures to encourage
material substitutions. The
section also includes
mechanisms for identifying
candidate materials to be
addressed by program.
Describe the program.
How and when was it developed?
Do you tap your employees for pollution prevention
ideas?
What are the results?
Describe any baseline assessments.
How do you track progress?
Are there additional areas that you are considering?
5-6
-------
10. Continuing Program Evaluation
Determine if the
environmental program is
periodically reviewed.
Annual program review schedule - who is involved
and how will it happen?
What prompts a review to occur?
Are annual reports prepared?
What are their distribution?
Who is responsible for their preparation?
Are results presented to upper management - how?
5-7
-------
Appendix A
State Assistance Program Reference List
ALABAMA
OMBUDSMAN
Gary Ellis
AL DEM/Admin. Div.
P.O. Box 301463
Montgomery, AL 36130-1463
gellis@adem.state.al.us
Director of SB AP Technical Program
Mike Sherman
AL DEM/Admin. Div.
P.O. Box 301463
Montgomery, AL 36130-1463
mhs @adem.state.al. us
Voice #
334-394-4352
(N) 800-533-2336
334-271-7873
(N) 800-533-2336
Fax*
334-271-7873
334-271-7950
ALASKA
OMBUDSMAN
Bill Smyth
Small Business Advocate
555 Cordova St.
Anchorage, AK 99501
bsmvth@envircon. state, ak.us
Voice*
907-451-2177
(S) 800-520-2332
Fax*
907-269-7600
Director of SBAP Technical Program
Tom Chappie
Alaska Dept. of Environ. Conserv.
555 Cordova Street
Anchorage, AK 99501
tchanple@envircon.state.ak.us
907-269-7686
907-269-7687
ARIZONA
OMBUDSMAN
(vacant)
DEQ/Customer Service
3033 N. Central Avenue
Phoenix, AZ 85012
Director of SBAP Technical Program
Ira Domsky
(Dual Role as Ombudsman and SBAP Principal)
Voice*
602-207-2365
800-368-5888
602-207-2254
(S) 800-234-5677 (x4337)
Fax*
602-207-4872
602-207-4872
-------
Frances Dominguez
Business Assistance
Pima Co. DEQ
130 West Congress St.
Tucson, AZ 85701-1317
fdomingu@igate.co.pima.az. us
520-740-3344
520-882-7709
Richard Polito
Maricopa Co. Env. Serv./SBEAP
1001 N. Central Ave.
Suite 500
Phoenix, AZ 85004
rpolito @ mail.maricopa. sov
602-506-5102
602-506-6669
Donald P. Gabrielson
SBAP Director/SBO .
Pinal Co. APCD
P.O. Box 987
Florence, AZ 85232
pcaqcd@evergreen.com>
520-868-6760
520-868-6754
"Other" Contact
Maureen Lynch
Maricopa County SBEAP
1001 N. Central Ave.
Suite 500
Phoenix, AZ 85004
mlvnch@mail.maricoDa.gov
602-506-5150
602-506-6669
ARKANSAS
OMBUDSMAN
Ron Alexander
Small Bus. Asst. Manager
ARDPE
P.O. Box 8913
Little Rock, AR 72219-8913
ralexander@adea.state.ar.us
Voice #
501-682-0866
(N) 888-233-0326
Fax*
501-682-0880
Director of SBAP Technical Program
Ron Alexander
Chief, Customer Service Division
ARDPE
P.O. Box 8913
Little Rock, AR 72219-8913
ralexander@adea.state.ar.us
501-682-0866
501-682-0880
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Other
Amanda Gregory
ARDEQ
P.O. Box 8913
8001 National Drive
Little Rock, AR 72219-8913
agregorv@adeq. state, ar.us
501-682-0709
(N) 888-233-0326
501-682-0880
CALIFORNIA
OMBUDSMAN
Kathleen TschogI
CA Air Resources Board
2020 L Street
Sacramento, CA 95812-2815
ktschogl @ arb.ca. gov
Voice #
916-323-6791
(S) 800-272-4572
Fax*
916-322-4737
Director of SBAP Technical Program
Larry Kolczak
CAEPA-AirRes.Bd.
Stationary Source
2020 L Street
Sacramento, CA 95814-4219
lkolczak@arb.ca.gov
909-396-3215
(S) 800-388-2121
LaRonda Bowen
Public Advisor
SCAQMD/SBAP
21865 E. Copley Dr.
Diamond Bar, CA 91765
lbowen@aamd.gov
Cynthia Specht
Manager of Desert Program
Mojave Desert AQMD
15428 Civic Dr.
Victorville, CA 92392
mdaqmdq @eee.ors
Terri Mitchell
Sacramento County Business
Environmental Resource Center
10425 Norden Ave., Bldg. 3492
Mather, CA 95655-1101
tmiichell@sacberc.org
Paul Davis
San Diego APCD
9150CheapeakeDr.
San Diego, CA 92123
sacberc@sna.com
909-396-3235
(N) 800-388-2121
909-396-3335
760-245-1661 x5597
760-243-8907
916-364-4106
916-364-4115
619-694-3339
619-694-2730
-------
Erin Craig
Director, BEAC
UC Extension
3120DeLaCruz
Santa Clara, CA 95054
beac@cats.ucsc.edu
Francis Gilliland
Santa Barbara County APCD
26 Castillian Dr.
Suite B-23
Goleta,CA93117
gillilandf@sbcapcd.org
Christine Schaufelberger
Bay Area AQMD
939 Ellis St.
San Francisco, CA 94109
cschauffelberger@baaQmd.goy
Nola Oriola
SCAQMD/SBAP
21865 E. Copely Dr.
Diamond Bar, CA 91765
noriola@aqmd.gov
408-748-2161
408-748-7388
805-961-8838 (Direct) 805-961-8801
805-961-8868 (Bus. Asst.)
415-749-4779
415-928-0338
909-396-2382
(N) 800-388-2121
909-396-3335
COLORADO
Voice #
Fax#
OMBUDSMAN
Nick Melliadis
Dept. of Public Health and Environment
OCS-INF-A1
4300 Cherry Creek Drive - South
Denver, CO 80246-1530
nkk.rne11iadis@state.co.us
Director OF SBAP Technical Program
Chuck Hix
Air Pollution Control Division
Dept. of Public Health & Environment
APCD/55/B-1
4300 Cherry Creek Drive - South
Denver, CO 80246-1530
chuck.hix@state.co.us
303-692-2135
(S) 800-886-7689
303-691-1979
303-692-3148
(N) 800-333-7798
303-782-5493
"Other" Contact
Doug Ryder
Dept. of Public Health & Environment
4300 Cherry Creek Drive - South
APCD/55/B-1
Denver, CO 80246-1530
doug.rvder@state.co.us
303-692-3144
(N) 800-333-7798
303-782-0278
-------
CONNECTICUT
OMBUDSMAN
Tom Turick
SBAP/DEP
79 Elm St.
Hartford, CT 06106-5127
tom.turick@po.state.ct.us
Voice*
860-424-3382
(8)800-760-7036
Fax*
860-424-4063
Director of SB AP Technical Program
Tom Turick
Sm. Bus. Asst. Prog.
Dept. of Env. Protection
Env. Quality Div.
79 Elm St.
Hartford, CT 06106-5127
860-424-33382
(S) 800-760-7036
860-424-4063
"Other" Contact
Sharon Roe-Johnson
Small Bus. Asst.
Dept. Env. Prot.
79 Elm St.
Hartford, CT 06106-5127
sharon.roe-iohnson@po.state.ct.us
860-424-3302
(S) 800-760-7036
860-424-4063
DELAWARE
OMBUDSMAN
Kim Finch
DE/DNREC
89 Kings Highway
Dover, DE 19901
kfinch@dnrec.state.de.us
Voice*
302-739-6400
800-760-7036
Fax*
302-739-6242
"Other" Contact
Bob Banish
DNREC
715 Grantham Lane
New Castle, DEI 9720
bbarrish@dnrec.state.de.us
302-323-4542
302-323-4561
"Other" Contact
Andrea Kreiner
DE/DNREC
89 Kings Highway
Dover, DE 19901
akreiner@state.de.us
302-739-6400
302-739-6242
-------
CaraWaddell
Jefferson County
Sm. Bus. Assistance
810 Barrett Ave.
Louisville, KY 40204
nmbudapc@iglou.com
502-574-5164
502-574-8188
LOUISIANA
OMBUDSMAN
Jim Friloux
DEQ, Small Bus. Ombudsman
P.O. Box 82263
Baton Rouge, LA 70804
iim f@deo.state.la.us
Voice*
225-765-0735
(S) 800-259-2890
Fax#
225-765-0746
MAINE
OMBUDSMAN
Ron Dyer
Dept. Env. Prot.
Office of Pollution Prevention
Station 17
State House
Augusta, ME 04333
ron.e.dver@state.me.us
Voice*
207-287-4152
(S) 800-789-9802
Fax*
207-287-2814
Director of SB AP Technical Program
Julie M. Churchill
Coordinator, SBAP
Dept. of Env. ProL
State House Station #17
Augusta, ME 04333
roy.krout@state.me.us
207-287-7881
(S) 800-789-9802
207-287-2814
"Other" Contact
Jim Brooks
Dept. of Env. Prot.
Bureau of Air Quality Mgmt.
Station 17
State House
Augusta, ME 04333
iames.D.brooks@state.me.us
207-287-2437
207-287-7641
-------
MARYLAND
OMBUDSMAN
Don Jackson
Director, Office of
Community Assistance
MDDept. ofEnv.
2500 Broening Hwy.
Baltimore, MD 21224
diackson@mde.state.md.us
Voice*
410-631-3165
(8)800-633-6101 x3165
Fax*
410-631^477
Director of SBAP Technical Program
Andrew Gosden
Environmental Permits Service Center
MD Dept. of Env.
2500 Broening Hwy.
Baltimore, MD 21224
agosden @ mde.state.md.us
410-631-4158
(N) 800-633-61201 x4158
410-631-4477
Laura Armstrong
Coordinator
Baltimore, MD Pollution Prevention
Sm. Bus. TAP
MDDept. of Env.
2500 Broening Hwy
Baltimore, MD 21224
larmstrong@mde.state.md.us
410-631-3114
410-631-3936
MASSACHUSETTS
OMBUDSMAN
VACANT
Director of SBAP Technical Program
Exec. Office of Env. Affairs
100 Cambridge St., Suite 2109
Boston, MA 02202
Voice*
800-368-5888
Fax*
"Other" Contact
Nancy Wrenn
Dept. of Env. Prot.
1 Winter Street
Boston, MA 02108
nwrenn@state.ma.us
617-292-5587
617-292-5778
MICHIGAN
OMBUDSMAN
Susan Holben
MI Jobs Comm.
Victor Ctr., 4th R.
201 N. Washington Square
Lansing, MI 48913
siolben@state.mi.us
Voice #
517-335-5883
Fax*
517-335-0198
-------
Director of SB AP Technical Program
Dave Fiedler
MDEQ
Environmental Assistance Div.
P.O. Box 30457
Lansing, MI 48909
fiedlerd@state.mi.us
517-373-0607
(N) 800-662-9278
517-335-4729
"Other" Contact
Donna Davis
Env. Asst. Div.
MI/DEQ
P.O. Box 30457
Lansing, MI 48909-7957
517-373-2784
(N) 800-662-9278
517-335-4729
MONTANA
OMBUDSMAN
Charlie Kennedy
MPCA/OEA
520 Lafayette Rd.
St. Paul, MN 55155-4194
charlie. kennedv@pca.state.mn.us
Voice*
651-297-8615
(S) 800-985-4247
Fax*
651-297-8324
Director of SBAP Technical Program
Troy Johnson
MPCA/MDRF/SBAP
520 Lafayette Rd.
St. Paul, MN 55155
troy. Johnson @pca.state.mn.us
651-296-7767
(S) 800-657-3938
(hotline) 651-282-6143
651-282-6247
"Other" Contact
Phyllis Strong
MNPCA
520 Lafayette Road
St. Paul, MN 55155-4197
phvllis.strong@pca.state.mn.us
612-282-5847
612-297-7709
"Other" Contact
Barb Loida
MPCA/MDRF/SBAP
520 Lafayette Rd.
St. Paul, MN 55155
barb.loida@nca.state.mn.us
651-282-2604
(S) 800-657-3938
651-282-6247
-------
"Other" Contact 651-296-85777
Michael Nelson (S) 800-657-3938
MPCA/MDRF/SBAP
520 Lafayette Rd.
St. Paul, MN 55155
michael. nelson @pca.state.mn. us
MISSISSIPPI Voice* Fax*
Dual Role as OMBUDSMAN and SBAP Principal 601-961-5167 601-961-5742
Jesse Thompson (N) 800-725-6112
MS DEQ
P.O. Box 10385
Jackson, MS 39289-0385
jesse thompson@deq.state.ms.us
"Other" Contact 601-961-5166 601-961-5541
Randy Wolfe (N) 800-725-6112
Air Quality
Office of Policy Control/DEQ
P.O. Box 10385
Jackson, MS 39289-0385
Randv Wolfe@deq.state.ms.us
MISSOURI Voice* Fax*
OMBUDSMAN (N) 800-368-5888
VACANT
Office of the Governor
P.O. Box 720
Jefferson City, MO 65102
heffna@mail.gov.state.mo.us
Director of SBAP Technical Program 573-526-6627 573-526-5808
Byron Shaw (N) 800-361-4827
MO. Dept. of Natural Resources
Technical Assistance Program
P.O. Box 176
Jefferson City, MO 65102
nrshawb@mail.dnr.state.mo.us
MONTANA Voice* Fax*
OMBUDSMAN 406-444-3641 406-444-6836
Bonnie Rouse (N) 800-433-8773
Dept. of Env. Quality
Small Bus. Ombudsman
1520 E. 6th Ave.
Helena, MT 59620-0901
brouse@mt.gov
-------
Director of SBAP Technical Program 406-444-3641 406-444-1499
Bonnie Rouse (N) 800-433-8773
Dept. of Env. Quality
Air Quality Division
MetcalfBldg.
1520 E. Sixth Ave.
Helena, MT 59620
brouse@mt.gov
NEBRASKA Voice* Fax*
OMBUDSMAN 877-253-2606
Tom Franklin
Public Advocate
(Dual role as Ombudsman and SBAP Principal)
Dept. of Env. Quality
P.O. Box 98922
Lincoln, NE 68509-8922
tfranklin@mail.deq.state.ne.us
MarciaWilhite 402-441-8188 402-441-8323
Lincoln/Lancaster Co.
Health Dept.
3140 N Street
Lincoln, NE 68510
mwilhite@ci.lincoln.ne.us
SBAP Technical Program 877-253-2606
Tom Franklin
(Dual role as NE Ombudsman and SBAP Principal)
SBAP Director-Lincoln/Lancaster County 402-441-8644 402-441 -8323
Phil Rooney
Health Dept.
3140 N Street
Lincoln, NE 68510
nroonev@ci.lincoln.ne.us
"Other" Contact 402-471-0275 402-471-2902
Tom Lamberson
DEQ Asst. Dir.
P.O. Box 98922
Lincoln, NE 68509-8922
deci 112@mail.deq.state.ne.us
-------
NEVADA
OMBUDSMAN
Marcia Manley
Div. of Environmental Protection
333 West Nye Lane
Carson City, NV 89706-0851
mmanlev@ndep.carson-citv.nv.us
Voice #
775-687-4670x3162
(S) 800-992-0900 x4670
Fax*
702-687-5856
SBAP Technical Program
Janet Goodman
Technical Assistance Coordinator
Div. of Env. Prot.
333 West Nye Lane
Carson City, NV 89706-0851
isoodman @ ndep.carson-citv.n v.us
775-687-4670 \3067
(S) 800-992-0900 x4670
702-687-5856
"Other" Contact
Kevin Dick
BEP-NSBDC, UNR
6100 Neil Rd.-Suite 400
Reno, NV 89571
dick@unr.edu
702-834-6677
702-834-6689
NEW HAMPSHIRE
OMBUDSMAN
Rudolph Carrier, Jr., PE
(Dual Role as Ombudsman and SBAP Principal)
Air Resources Div.
Dept. of Env. Services
6 Hazen Drive-P.O. Box 95
Concord, NH 03302-0095
rcartier@des.state.nh.us
Voice*
603-271-1379
(S) 800-837-0656
Fax*
603-271-1381
NEW JERSEY
OMBUDSMAN
Chuck McCarty
Office Bus. Advocacy
Commerce and Economic Growth Comm.
P.O. Box 839
Trenton, NJ 08625-0839
cmccartv@commerce. state, nj. us
Voice*
609-292-3863
(N) 800-643-6090
Fax*
609-777-4097
Director of SBAP Technical Program
KyAsral
Pollution Prevention - Permit Coord./SBAP
NJDEP
PO Box 423
Trenton, NJ 08625-0423
kasral@dep.state.ni .us
609-292-3600
609-777-1330
-------
Director of SBAP Technical Program
Marian Mudar, Ph.D.
Env. Program Manager
NYS Env. Facil. Corp.
50WolfRd.-Rm.598
Albany, NY 12205
mudar@nvsefc.org
518-402-7462
(S) 800-780-7227
518-457-8681
"Other" Contact
Patrick Lentlie
NYS DEODAR
50WolfRd.-RmllO
Albany, NY 12233
rixlentli@gw.dec.5tate.nv.iis
518-457-7450
518-457-0794
NORTH CAROLINA
OMBUDSMAN
Edythe McKinney
Office of Sin. Bus. Ombudsman
Dept. of Env. and Nat. Res.
P.O. Box 29583
Raleigh, NC 27626-0583
edvthe mckinnev@n2pavs.org
Voice*
919-733-0823
(N) 877-623-6748
Fax*
919-715-7468
Director of SBAP Technical Program
Tony Pendola
Dept. of Env. and Nat. Res.
P.O. Box 29583
Raleigh, NC 27626-0583
tonv pendola@p2pavs.org
919-733-0823
(N) 800-623-6748
919-715-7468
"Other" Contact
Karen Davis
Office of Small Bus. Ombudsman
Dept. of Env. and Nat. Res.
P.O. Box 29583
Raleigh, NC 27626-0583
karen davis@D2pavs.org
919-733-1267
(N) 800-829-4841
919-715-7468
-------
NORTH DAKOTA
OMBUDSMAN
Dana Mount
Div. of Env. Engr.
Env. Health Sect.
ND DH&CL
1200 Missouri Ave.
P.O. Box 5520
Bismarck, ND 58506-5520
dmount@state.nd.us
Voice #
701-328-5150
(S) 800-755-1625
Fax*
701-328-5200
Director of SBAP Technical Program
Tom Bachman
NDDept. of Health
Div. of Env. Engr.
1200 Missouri Ave.
P.O. Box 5520
Bismarck, ND 58506-5520
tbachman@state.nd.us
701-328-5188
(S) 800-755-1625
701-328-5200
OHIO
OMBUDSMAN
Mark Shanahan
OH Clean Air Res. Ctr.
Room 1901
50 West Broad St.
Columbus, OH 43215
mark.shanahan@aqda.state.oh.us
Voice #
614-728-3540
(8)800-225-5051
Fax#
614-752-9188
Director of SBAP Technical Program
Rick Carleski
OH EPA Div. of Air Pollution Control
Lazarus Government Center
Post Office Box 1049
Columbus, OH 43216-1049
rick.carleski @epa.state.oh.us
614-728-1742
614-644-3681
"Other" Contact
Bob Hodanbosi
OEPA/DAPC
Lazarus Government Center
P.O. Box 1049
Columbus, OH 43216-1049
614-644-2270
614-644-3681
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OKLAHOMA
OMBUDSMAN
Steve Thompson
OKDEQ-Suitel212
1000N.E. lOthSt.
Oklahoma City, OK 73117-1212
steve. thomnson@deqmail.state.ok.us
Voice #
405-702-7100
800-899-1400
Fax*
405-271-8425
Director of SBAP Technical Program
Steve Thompson
OKDEQ
Customer Services Division
P.O. Box 1677
Oklahoma City, OK 73101-1677
alvvin.ning@deamail.state.ok.us
405-702-7100
(N) 800-869-1400
405-271-1317
"Other" Contact
Kyle Arthur
OKDEQ
Customer Services Division
1000 N.E. 10th St.
Oklahoma City, OK 73117
kvle.arthur@deqmail.state.ok.us
405-702-6100
(N) 800-869-1400
405-271-1317
OREGON
OMBUDSMAN
Rich Grant
ODEQ
811S.W. 6th Ave.
Portland, OR 97204-1390
rgrant@deo.state.or.us
Director of SBAP Technical Program
Jill Inahara
ODEQ
Air Qual Div.
811S.W. 6th Ave.
Portland, OR 97204
inahara.iill@deq.state.or,us
Voice #
503-229-6839
(8)800-452-4011
Fax#
503-229-6945
503-229-6147
(8)800-452-4011
503-229-5675
"Other" Contact
Marianne Fitzgerald
ODEQ
Reg. Oper. Div.
811S.W.6thAve.
Portland, OR 97204
fi tzgerald.marianne@deq.state.or.us
503-229-5946
503-229-6124
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PENNSYLVANIA
OMBUDSMAN
Bruce McLanahan
Asst. to PA SBO/Office of P2 & Compl. Asst.
RCSOB, 15th Floor
P.O. Box 8772
Harrisburg, PA 17105-8772
b.mclanahan@dep.state.pa.us
Voice #
717-772-5942
Fax#
717-783-2703
Director of SBAP Technical Program
Gerald Laubach
PRC Env. Mgmt. Inc.
6th Floor
1800 JFK Blvd.
Philadelphia, PA 19103
glaubach @ ttemi .com
717-772-2333
"Other" Contact
Scott Kepner
Bur.of AirQual.
Dept. of Env. Prot.
P.O. Box 8468
Harrisburg, PA 17105-8468
Kepner.Scott@al .dep.state.pa.us
717-772-1663
717-772-2303
PUERTO RICO
OMBUDSMAN
VACANT
Administrator of Commercial Development
Administration Office P.O. Box 4275
San Juan, PR 00902
Director of SBAP Technical Program
Angel Berrios-Sivestre
PREQB-SBAP
HC-91, Box 9197
Vega Alta, PR 00692
pr sbap@hotmait.com
Voice #
800-368-5888
787-767-8025
.Fax*
787-294-0148
787-772-9497
RHODE ISLAND
OMBUDSMAN
VACANT
Dept. of Env Mgmt.
Office of the Director
235 Promenade Street
Providence, RI02908
Voice #
800-368-5888
Fax#
401-222-6802
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Director of SB AP Technical Program
Joe Antonio
Dept. of Environment Management.
Office of Technical & Customer Assistance
235 Promenade Street
Providence, RI02908
iantonio@doa.state.ri.us
401-222-6822x4410
401-222-3810
"Other" Contact
Joe Antonio
Office of Technical & Customer Assistance
235 Promenade Street
Providence, RI 02908
iantonio@dem.state.ri.us
401-222-6822 x4410
401-222-3810
SOUTH CAROLINA
OMBUDSMAN
Phyllis T. Copeland
Small Business Ombudsman
South Carolina DHEC
2600 Bull Street
Columbia, SC 29201
copelapt@CQlumb30.dhec.state.sc.us
Voice #
803-896-8982
(N) 800-819-9001
Fax*
803-898-3939
Director of SBAP Technical Program
James Robinson
SC Dept. of Health & Env, Control
2600 Bull Street
Columbia, SC 29201
robinsic@columb30.dhec.state.sc.us
803-898-3981
(N) 800-819-9001
803-898-3939
Permitting Liaison: "Other" Contact
Willie J. Morgan
SCDHEC
2600 Bull Street
Columbia, SC 29201
morganwi@columb30.dhec.state.sc.us
803-898-3957
(N) 800-819-9001
803-898-3939
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SOUTH DAKOTA Voice* Fax#
OMBUDSMAN 605-773-3836 605-773-6035
Joe D. Nadenicek (S) 800-438-3367
Sm. Bus. Ombudsman
SDDENR
Joe Foss Bldg.
523 East Capitol Ave
Pierre, SD 57501
ioen@denr.state.sd.us
Director of SB AP Technical Program 605-773-6706 605-773-5286
Rick Boddicker (S) 800 438-3367
SDDENR
Joe Foss Bldg.
523 East Capitol Ave.
Pierre, SD 57501
rroddicker@denr.state.sd.us
TENNESSEE Voice* Fax#
OMBUDSMAN 615-741-5262 615-532-8007
Ernest B lankenship (N) 800-734-3619
TN Dept. of Env. & Conservation
L&C Tower/8th Fl.
401 Church St.
Nashville, TN 37243-1551
eblankenship@mail.state.tn.us
Director of SB AP Technical Program 615-532-0779 615-532-8007
Linda Sadler (N) 800-734-3619
Small Business Assist. Program
8th Floor
L&C Annex
401 Church Street
Nashville, TN 37243
lsadler@mail.state.tn.us
TEXAS Voice # Fax#
OMBUDSMAN 512-239-5319 512-239-3165
Israel Anderson (N) 800-447-2827
Director,
' Office of Small Business and Environmental Assistance
TNRCC (Mail Code 106)
P.O. Box 13087
Austin, TX 78711-3087
ianderso@tnrcc.state.tx.us
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Director of SBAP Technical Program
Tamra Shae-Oatman
Small Bus. Tech. Asst. Prog.
TNRCC (Mail Code 106)
P.O. Box 13087
Austin, TX 78711-3087
toatman@tnrcc. state, tx. us
512-239-1066
(N) 800-447-2827
512-239-1065
"Other" Contact
Kathy Ramirez
Small Bus. & Gov't. Asst.
TNRCC (Mail Code 106)
P.O. Box 13087
Austin, TX 78711-3087
kramirez@tnrcc.state.tx.us
512-239-3047
512-239-1055
UTAH
OMBUDSMAN
Renette Anderson
UTDEQ
Small Bus. Ombudsman
168 No. 1950 West
Salt Lake City, UT 84114-4810
randerspn@deq.state.ut.us
Voice*
801-536-4478
800-458-0145
Fax#
801-536-0061
Director of SBAP Technical Program
Ron Reece
Environmental Engineer
Utah Dept. of Env. Qual.
Div. of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
rreece@deq.state.ut.us
801-536-4091
(N) 800-270-4440
801-536-4099
VERMONT
OMBUDSMAN
VACANT
Voice*
800-368-5888
Fax#
Director of SBAP Technical Program
Judy Mirro
VT Env. Asst Div.
Laundry Bldg.
103 S. Main St.
Waterbury.VT 05671
iudvm@dec.anr.state.vt.us
802-241-3745
(S) 800-974-9559
802-241-3273
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"Other" Contact
Kevin Bracey
APCD/ANR
Building 3 South
103 South Main Street
Waterbury, VT 05671-0402
. kevinb@dec.anr.state.vt.us
802-241-3841
802-241-2590
VIRGINIA
OMBUDSMAN
John Daniel
VADEQ/Air Division
Manager, Small Bus. Assistance Program
P.O. Box 10009
Richmond, VA 23240-0009
irdaniel@deo.state.va.us
Voice #
804-698-4311
(S) 800-592-5482
Fax*
804-698-4510
Director of SB AP Technical Program
Richard Rasmussen
Air Division
Director
VA Dept. of Env. Quality
P.O. Box 10009
Richmond, VA 23240-0009
rgrasmusse@deq.state.va.us
804-698-4394
800-592-5482
804-698-4510
VIRGIN ISLANDS
OMBUDSMAN
VACANT
VI Dept. Planning & Natural Resources
Division of Environmental Protection
Wheatley Shopping Center n
Charlotte Amalie,
St. Thomas, V.I. 00802
Director of SBAP Technical Program
Marylyn A. Stapleton
VI Dept. of Planning & Natural Resources
Div. of Environmental Protection
Wheatley Shopping Center II
Charlotte Amalie.St. Thomas, VI00802
"Other" Contact
Jasmine A. Blyden
VI Dept. of Planning & Natural Resources
Div. of Environmental Protection
Wheatley Shopping Center n
Charlotte Amalie,
St. Thomas, VI00802
Voice #
800-368-5888
Fax#
340-774-5416
304-774-3320X5167
340-714-8529 (Hotline)
340-777-4577
340-774-5416
340-774-5416
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WASHINGTON
OMBUDSMAN
Bernard Brady
Dept. of Ecology
P.O. Box 47600
Olympia, WA 98504-7600
bbra461 @ecv. wa.gov
Voice*
360-407-6803
Fax#
360-407-6802
Director of SB AP Technical Program
Bernard Brady
Dept. of Ecology
Air Quality Prog.
P.O. Box 47600
Olympia, WA 98504-7600
bbra461 @ecv.wa.gov
360-407-6803
360-407-6802
WEST VIRGINIA
OMBUDSMAN
Terry Polen
WV DEP Small Business Ombudsman
1356 Hansford Street
Charleston, WV 25301
Tpolen@mail.dep.state, wv.us
Voice #
304-759-0510 Ext.341
Fax*
304-558-3998
Director of SBAP Technical Program
Gene Coccari
WV DEP, Office of Air Quality
Small Business Assistance Program
7012 McCorkle Ave., S.E.
Charleston, WV 25304
gcoccari @mail.dep.state.wv.us
304-926-3731
(S) 800-982-2474
304-926-3637
"Other" Contact
Gene M. Coccari
Technical Specialist
WV Office of Air Quality
7012 McCorkle Avenue
Charleston, WV 25304
gcoccari @ mail .dep.state. wv.us
304-926-3731
304-926-3637
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WISCONSIN
Voice #
Fax#
OMBUDSMAN
Pam Christenson
WI Dept. of Commerce-SBCAAP
P.O. Box 7970-6th Floor
Madison, WI 53707-7970
pchristenson@commerce. state, wi. us
608-267-9384
(N) 800-435-7287
Director of SBAP Technical Program
Renee Lesjak Bashel
WI Clean Air Asst. Prog.
Dept. of Commerce
201 W. Washington Ave.
6th Floor
P.O. Box 7970
Madison, WI 53707-7970
iakbashel@commerce. state, wi. us
608-267-6153
(N) 800 435-7287
608-267-0436
"Other" Contact
Hampton Rothwell
Director,
Bus. Development Assistance Center
WI Dept. of Commerce
P.O. Box 7970
201 W. Washington Ave.
Madison, WI 53707-7970
hrothwell@commerce.state.wi.us
608-267-0313
(N) 800-435-7287
608-267-0436
WYOMING
OMBUDSMAN
Dan Clark
Dept. of Env. Quality
Small Bus. Ombudsman
Div. of Air Quality
122 W. 25th Street
Cheyenne, WY 82002
dclark@missc.state, wv.us
Voice #
307-777-7388
Fax*
307-777-3773
Director of SBAP Technical Program
Charles Raffelson
Dept. of Env.Quality
Div. of Air Quality
122 W. 25th Street
Cheyenne, WY 82002
craffe@missc. state, wv.us
307-777-7347
307-777-5616
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"Other" Contact 307-777-7391 307-777-5616
Dan Olsen
WY Dept. of Env. Quality
Div. of Air Quality
122W.25thSt.
Cheyenne, WY 82002
dolseng'missc.state.wv.us
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