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Setting Priorities, Developing Strategies
Safety and environmental regulations and standards that apply to institutional and commercial facilities can easily overwhelm managers. These mandates require maintenance and engineering managers to set up a system that properly identifies, implements and ensures compliance with the many requirements associated with these standards. Complicating matters are new and updated regulations, codes and standards that continue to emerge.
Beyond these challenges, unregulated issues, such as indoor air quality (IAQ), require knowledge of best practices, as well as access to resources that help establish or update programs to occupants, visitors and buildings.
Successful compliance with this range of challenges first requires that managers understand common safety and environmental regulatory issues, as well as emerging issues that might affect facilities.
Break it Down
Managers must be fully aware of regulations, codes and standards that impact on building operations and the daily tasks of front-line technicians. One place to start is to break down compliance issues into four categories:
- Worker Protection. These regulations usually are found under standards from the Occupational Safety and Health Administration (OSHA) or from states. Common compliance topics include: exposure to environmental hazards; working at heights; equipment safety; and the use of personal protective equipment (PPE).
- Environmental Protection. These regulations address pollution of air, land and water and usually are found in state or federal environmental protection laws. Compliance topics include asbestos, lead paint, wastewater discharge, air emissions, and chemical-waste disposal.
- Public-health protection. Some issues in this area are regulated, while others are not. Regulations and guidance of public-health issues are usually arise from city, county, or state public health agencies or from the national Centers for Disease Control (CDC). Common issues include hand washing and hygiene, sanitation, pest control, and preparation for and response to emergencies.
- Building Protection. This issue encompasses codes and consensus standards in such areas as fire safety, scaffolding, aerial lifts, electrical systems, and HVAC system design and operation. A number of agencies reference these codes and consensus standards for regulatory compliance.
Mistakes and Lessons
It is next to impossible for managers to focus on all compliance issues affecting maintenance and engineering activities while still overseeing their departments, so managers must prioritize the issues.
In many cases with regulations and standards, the squeaky wheel gets the grease. Building occupants complaining about odors might prompt managers to make IAQ a high-priority issue, whether or not regulations apply or greater compliance is necessary. But identifying employees working at heights during routine maintenance activities without proper fall protection actually might be a higher priority.
How can a manager identify issues that deserve more attention or are a higher priority? One way is to learn from the mistakes of others. For instance, OSHA publishes an annual list of regulatory violations, which can help managers identify the most common worker safety violations.
OSHA recently released its top safety violations related to worker protection between October 2005 and September 2006.
Managers can focus on the top 10 topics to see if their programs are currently in compliance:
- fall protection
- hazard communication
- respiratory protection
- control of hazardous energy
- powered industrial trucks
- electrical wiring methods
- machine guarding, ladders
- electrical system design.
OSHA also provides a different version of the list that prioritizes violations by the largest proposed fines. The administration’s web site — www.osha.gov — allows managers to query its citation database based on the type of industry or regulatory topic.
New worker-protection rules on the horizon include a revision to OSHA and EPA’s lead standards, which will specifically address lead-paint disturbance in buildings.
OSHA also has released its hexavalent chromium standard, which can apply to carpentry shops and landscaping operations where staff handle, cut, saw, sand and paint treated lumber. Carpenters and carpenter helpers are the primary groups exposed during woodworking with treated lumber.
Exposure also can occur to those involved in waste incineration from the thermal destruction of chromium-containing products discarded by consumers and businesses. Employees with potential exposures include laborers, shredder and heavy-equipment operators, maintenance workers and helpers, boiler operators and assistant operators, maintenance electricians, and truck operators. A compliance guide is available at www.osha.gov/Publications/OSHA_small_entity_comp.pdf.
Finally, communicating worker protection information to non-English speaking employees can be a difficult hurdle to overcome. To assist with compliance issues, state and federal agencies are producing safety and environmental guidance documents in a variety of languages.
Regulatory agencies and industry associations have targeted mercury for reduction and eventual removal from facilities. Managers can seek out potential mercury-containing equipment in their facilities with a compliance guide provided by the EPA at its web site, www.epa.gov/seahome/mercbuild.html. Helpful mercury resources also include documents on reducing its use in the healthcare setting and documents on its proper handling, recycling and disposal.
Local, state and federal environmental agencies are encouraging the reduction or elimination of waste at the source by modifying operating processes, promoting the use of non- or less-toxic substances, implementing conservation techniques, and re-using materials rather than putting them into the waste stream.
EPA has a number programs designed to educate managers on processes that prevent pollution by saving energy, encouraging environmentally preferable purchasing, and providing technical assistance to state agencies and businesses at www.epa.gov/ebtpages/pollutionprevention.html.
Finally, the EPA provides environmental audit checklists available to assist managers in evaluating their compliance with federal EPA regulations. The audit protocols, available at www.epa.gov/compliance/incentives/auditing/protocol.html, cover these regulations:
- Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)
- Clean Water Act (CWA)
- Emergency Planning and Community Right-to-Know Act (EPCRA)
- Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)
- Resource Conservation and Recovery Act (RCRA)
- Safe Drinking Water Act (SDWA)
- Toxic Substance Control Act (TSCA).
Codes and Standards
Managers trying to ensure the compliance of their organizations’ safety and environmental programs with workplace health and safety requirements need to understand the requirements. That is not as simple as it might appear. Merely reading applicable OSHA or EPA regulations and standards and state laws isn’t enough.
To determine an organization’s legal obligations, managers also need to review technical safety and environmental standards published by organizations such as the American National Standards Institute (ANSI), the American Society for Testing and Materials (ASTM), and the National Fire Protection Association (NFPA).
These organizations are involved in quite a great deal of activity on consensus standards about which managers need to be aware. Consensus standards already incorporated into regulations include NFPA’s fire and electrical codes, ASHRAE’s ventilation standards, and ANSI’s aerial-lift standards.
Managers can stay abreast of new regulatory issues, standards, codes and compliance developments more easily by subscribing to free list-serves from numerous associations and agencies.
These services typically provide free e-mail updates and timely resources to aid managers in complying with existing regulations. They also provide best practices and guidance on non-regulated issues. For more resources, see the accompanying article.
Managers can also benefit from joining industry specific associations and local chamber of commerce that have services to keep members abreast of safety and environmental compliance issues affecting facilities.
Jeffery C. Camplin, CSP, CPEA, is president of Camplin Environmental Services Inc., a safety and environmental consulting firm in Rosemont, Ill. He also is administrator of the American Society of Safety Engineers (ASSE) Environmental Practice Specialty.
Focus: Compliance Resources
Managers seeking the latest information on regulatory compliance issues have an array of resources at their disposal via the internet.