Q: What is today’s greatest environmental compliance challenge for those working in the chemical processing arena?
A: The trend to affirmative line-by-line compliance certification is the greatest challenge. This is especially true for obligations which require hundreds or thousands of data values per year to demonstrate compliance, such as emissions or operating limits under Title V. Also, these obligations require coordinated deviations reporting for values which are potentially non-compliant, which significantly increases data management complexity. Regulatory agencies are required to enforce compliance obligations and many consumers want to buy from an environmentally responsible company. And, with the impending greenhouse gas legislation, that compliance pressure will only get worse.
Q: Why are some corporations succeeding while others are faltering and regularly risking penalization?
A: While many, if not all, corporations recognize the complexity of their facilities’ requirements, some have not realized that it is virtually impossible to manage these obligations with checklists and spreadsheets. These companies are using different methods PC-based, Internet-based, client server, and internally developed systems to track the thousands of requirements across air, water, waste, health, and safety programs and haven’t consolidated these obligations into one standard system. By putting all these requirements, data, calculations, and tasks into one system, accessible anytime, anywhere throughout the organization, they will have an unprecedented level of transparency that won’t allow them to falter.
Q: Please provide an example of a successful company and what it’s doing to be successful.
A: With a corporate goal of zero for deviations and emissions, DuPont is always looking for ways to improve its environmental process. The company’s TRI (Toxics Release Inventory) program covers 74 facilities with more than 600 Form R reports to submit annually. Using Enviance’s Internet-based data management system for TRI, DuPont saves time by entering data only once, ensures data quality with automatic warnings and real-time compliance status, and simplifies the reporting process with electronic submittal. Looking forward, the company is currently integrating Title V with the same system as TRI and evaluating the solution to integrate water and waste reporting as well consolidating all TRI information into one solution. DuPont is creating this all-inclusive solution to improve efficiency within the TRI program and improve compliance for the organization as a whole.
Q: What advice would you give companies regarding environmental compliance?
A: If you’re responsible for managing one or more programs, continuously review your processes to verify that you are properly aligning technical, technological, and human resources so that your best assets your judgment and the judgment of all employees are put to work. The benefits of streamlining data and process management include peace of mind and mitigated financial risk. If regulations are changing, or you are being subject to a new obligation or permit, anticipate the requirements and permit conditions, understand how you would report on them, and assign resources behind those tasks before you rush to certify. The key to successful compliance is to enable data to move freely within your organization and be acted upon. It’s vital to leverage existing systems such as work order systems, maintenance systems, existing ERP, or desktop systems. And you’ll need to find a technology solution that fits the size/scale of your operation. But it’s important to understand that technology cannot solve organizational gaps, and a culture of compliance is also critical. The compliance process is dynamic and cyclical, and successful management is possible only when accountability structures are clear. It is important to remember that technology cannot “do” compliance. Technology allows people to meaningfully evaluate data. Not everything that might appear to be a problem from a database perspective is a problem from a compliance perspective. Technology sifts. People judge. Compliance is a human decision.
Q: What do CHEM.INFO readers need to know about Title V and voluntary compliance?
A: Title V requires that facilities demonstrate, in one document, their compliance with all applicable regulations and requirements of the act. To receive their Title V permits, many organizations dutifully outlined how they monitor their processes and what controls they have in place to manage potential sources of non-compliance. There is a temporary sense of relief when the permit is issued. However, the issuance of a Title V permit is really only the beginning of a process. That process involves an ability to demonstrate ongoing compliance with the controls outlined in the application process: the conditions of ongoing compliance. It is soon realized that effective data management is key to effective compliance. But, it is also realized that the enormous volumes of data involved threaten to make that task impossibly complex and time-consuming. This reiterates the importance of having an information system in place to support Title V. However, similar practices are necessary to effectively support other corporate compliance activities, including water, waste, health, and safety efforts mandated by the Superfund Amendments and Reauthorization Act (SARA), the Right-To-Know Act, the Toxic Release Inventory, the Resource Conservation Recovery Act, Hazardous and Solid Waste Act, and the National Pollutant Discharge Elimination System permitting program.
Q: What’s important about the Cap & Trade program?
A: Cap and Trade is also referred to as emissions trading, and it is a program used to control SO2 (and other) emissions to achieve reductions. Typically with a cap and trade program, a central authority sets limits on the total amount of the pollutant that can be emitted. Chemical processing companies would be issued emission permits detailing the amount of pollutant (and equivalents) it can emit. If a company emits or knows it will emit more than it is allowed, it must buy emission credits from another company that pollutes less than their allowance. So, the governing body has capped emissions, but it allows others to trade its credits with those who will exceed their individual permitted cap, resulting in a cap and trade program.
Q: What is the Carbon Tax?
A: The Carbon Tax Center (www.carbontaxcenter) defines it well. A carbon tax is a tax on the carbon content of fuels effectively a tax on the carbon dioxide emissions from burning fossil fuels. Thus, carbon tax is shorthand for carbon dioxide tax or CO2 tax. So, for every chemical processing company, if a carbon tax was instituted, they would be paying for every pound of CO2 emitted. If analysts are correct, CO2 could cost industry between $13 to $40 per ton of carbon dioxide (or its equivalents) emitted.
Q: What are its potential effects on the chemical processing companies?
A: Regardless of whether there will be a cap and trade program or a carbon tax, the effect on chemical processing companies is clear what used to be free (CO2 emissions) will eventually cost the company money. Overall estimates of either approach are in the $50 billion range in the U.S. alone. This makes it even more imperative to have a system in place that can track environmental regulations including impending greenhouse gas emissions. The fundamental prerequisite to any meaningful effort to manage greenhouse gas at any level is the implementation of a system that produces auditable, verifiable, standardized greenhouse gas emissions data. Chemical processing companies need this information to: 1) understand their footprint within the fence line, 2) assess, address, and audit the greenhouse gas footprint of its supply chain, 3) provide competent calculations that can be used to disclose the costs and future financial risk greenhouse gas poses to the company and its investors, and 4) create and access the success of greenhouse gas reduction strategies. Fortunately, there is both a platform and commercialized technology to provide the solution required here. An Internet-based application, like Enviance, is ideal because these applications are designed from inception to be deployed quickly, and require no hardware or software on the user’s end. In most cases, these Internet-based solutions combine subject matter domain with technology and are offered on a subscription basis as a service.
Enviance provides an Internet-based environmental, health, and safety compliance solution. More information is available at www.enviance.com.