Today we’re exploring the components of an A+ environmental air quality program for those impacted by the U.S. Environmental Protection Agency, Florida Department of Environmental Protection, and/or local air quality regulations. If your air compliance program was “tested”, what letter grade would it receive? The following components will assist in answering that question.
Do Your Homework
The first consideration when evaluating an existing environmental air quality program, or developing a new program, is understanding what constitutes an A+. Think of what a successful compliance program means for your organization and work backward from there. By first defining expectations, you can work toward building insightful measurements that will help you analyze the performance of your program.
If not setting up a new program, gain a command of the information available in site historical documents (e.g., past air emission inventories with calculations, permits, inspections, violations, monitoring data, records, regulatory agency reports, regulatory agency correspondence, test reports, work practice records, emission limitation records, etc.). This will allow you to feel confident in understanding your program’s foundation.
Assess the Current Operational Status
Next, you’ll want to define the site’s current state of operations and inventory the facility’s regulatory and permitting compliance obligations.
- Identify the site’s current indoor and outdoor air emission sources
- Quantify actual and potential regulated air pollutant emission estimations from each source and the site as a whole
- Perform negative and positive declarations for applicable federal, state and local regulations
- Understand and document regulatory trigger points for multiple functions to understand
- Confirm that applicable permits are up to date, and do not contain extraneous/overburdening requirements
- Perform permit hygiene as necessary to match current operations and change overburdening requirements, within legal bounds
After assessing current operations, create an internal accountability process to ensure compliance with applicable regulatory and permitting requirements. It can be helpful to sit down with key team members and physically map this process. You will benefit from building compliance review checkpoints and identifying potential process failure areas for each applicable requirement. Of course, any process is only as good as the people executing it. Therefore, investing time in training employees on the importance of air quality compliance and instilling ownership over the process will foster a living program geared toward meeting your goals.
- Create an internal ‘operationalized’ process of recurring compliance checks (e.g., reasonable inquiry for those affected by the Title V Operating Permit Program)
- Brainstorm potential compliance process failure modes for each applicable regulation and permit requirement
- Establish a plan to eliminate failure modes over a reasonable period of time
- Train team members on ‘why you are doing what you are doing’ to instill ownership and understanding of the importance of air quality compliance
- Measure defects and compliance wins and make these visible to key personnel
- Establish a file system to prevent future personnel from having to go back to the foundation and recreate what led to current state
Now that you’ve established ownership, you can explore dashboards or establish communication processes to make both “wins” and “losses” visible. This will perpetuate the importance of air quality compliance and team members’ engagement.
Embrace Change Management and Continuous Improvement
After fostering measurable accountability with the current operational state, it is important to have a change management process. A process that assesses the regulatory and permitting impacts of a potential change and evaluates necessary actions to take prior to execution will ensure continuous compliance before, during, and after the change. Categories of a change management process will include people, facility, equipment, materials, processes, regulations, and leadership expectations.
Once you have established an effective change management process, you can focus on continuous improvement. Revisiting the ins and outs of your air quality compliance program and benchmarking against similar programs will foster best practice sharing, which is a key component of continuous improvement.
Examples of best practices include digitizing your efforts to minimize manual processing or streamlining the number of personnel touching the same data. Another key tool to continuous improvement is soliciting internal and/or external resources to audit your air quality compliance program on some frequency and suggest program alternatives that save time and money. Requesting proactive reviews will help avoid situations where corporate entities or government inspectors/auditors identify a defect before you. Air quality compliance programs are “living” processes that should be routinely visited for effectiveness and improvement opportunities to minimize non-compliances and potential regulatory fines.
Trihydro is an engineering and multi-media environmental consulting firm with air and process services expertise spanning 35 years to share the above program insights. We maintain 21 offices across the US, including Jacksonville FL. If you have any questions, please contact Bill Kelly at 904.513.9742 or via email at email@example.com.