Managing the Environmental Regulations and Safety
3
right-to-know regulations are not violated, and assesses the rate at which
a waste is generated to minimize spill potential and storage and disposal
difficulties.
Disposal issues are increasingly important because federal regulations
are dynamic, or changing. Waste minimization requirements and the
land disposal ban are making waste production
more expensive. RCRA
requires that storage locations be specific. There must be spill
containment, supplies for cleanup, controlled access, and segregation of
incompatible materials. In addition, RCRA holds that a hazardous waste
storage data area cannot be subject to a 100-year flood. Both on-the-job
training and a written training program are necessary. Fines may result
if the training is not properly documented and employees are not tested
for competency.
The OSP must also be concerned with problems of acquisition and
divestiture. A company cannot control pollution or its hazardous wastes
by selling contaminated properties or assets, however, it can certainly
add to its liabilities by purchasing contaminated property. Unfortunately,
many companies already own contaminated property with projected
remedial actions that may cost millions of dollars. The OSP may be
called upon to plan, negotiate, and manage these expensive, and
complicated hazardous waste cleanups. Too often, remedial action
contracts permit a consultant to design and build with little or no
oversight. If such contracts are not managed properly cost overruns and
disputes can be expected. Bidders must be prequalified. Contract
documents must be precise and accurate. There must be a management
plan that includes numerous inspections and thorough documentation.
There must also be emergency plans in the event that something goes
wrong such as a spill, a fire, or explosion.
MANAGING FEDERAL REGULATIONS AND
TOXIC SUBSTANCES
Toxic substances can create pervasive environmental and public health
problems. The sheer volume of toxic materials manufactured and the
many avenues of exposure (occupational, consumer use, and
environmental residues), greatly increase the unacceptable health and
environmental risks from many of these substances. Public policy has
traditionally been aimed at protecting the public from toxic substances.
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