SpecialtyBatch Chemical Sector Environmental Forum Environmental Management Challenges

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Specialty-Batch Chemical Sector Environmental
ForumEnvironmental Management Challenges

• Synthetic Organic Chemical Manufacturers
  Association

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Management Challenges

• All companies face management challenges
• Staffing
• Information
• Operating flexibility

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Management Challenges

• But the force of the impact on smaller companies
  is much more significant

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Staffing

• Resources
• As small businesses, fewer financial resources to
  dedicate to EHS activities
• Environmental personnel wear multiple hats
• Downsizing
• Turnover
• Training

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Information

• Too little
• Staff may not be familiar with resources
• Too much!
• Staff are familiar with resources
• No access to outside help
• No corporate structure or lack of support
• Afraid to dialog with regulatory agencies

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Operating Flexibility

• One-size-fits all regulations
• Batch manufacturers tend to have greater variety
  of waste streams, air emissions, water emissions,
  and wastes.
• Greater paperwork burden due to fluctuation in
  production lines (e.g. TSCA PMNs, IUR reports,
  etc.)
• Nature of the process requires different methods
  for handling wastes (e.g. cleaning vessels,
  pre-treatment)

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Operating Flexibility

• The size of the site vs. number of applicable
  regulations is NOT a linear relationship!
• Example Specialty batch manufacturer
  approximately 110 employees
• Over 150 applicable environmental regulatory
  conditions
• Over 38 reports submitted annually

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SOCMA Compliance Assistance Efforts

• SOCMA Efforts
• Conduct workshops
• Develop written guides
• Develop online training tools
• Sample topic areas
• Living with TSCA, HPV testing
• Site security, process safety, OSHA recordkeeping
• P2, wastewater rules, Risk Management Planning,
  RCRA Subpart CC Manual

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SOCMA Compliance Assistance Efforts

• http//www.socma.org/Products/index.htm

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SOCMA Compliance Assistance Efforts

• Active in joint compliance assistance efforts
  with EPA

• NJ Project
• RCRA Subpart CC Training Guide
• Global Chemical Regulations Conference
• TSCA 101 Workshops

• PTE Guidance
• Sustainable Industries Program
• ChemAlliance
• Numerous regulation-specific workshops

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Identifying Compliance Assistance Needs

• Better dialog between Federal and State agencies
• Better dialog between EPA regions HQ
• Maintain current dialog with SOCMA on existing
  issues and open up dialog on new issues

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Identifying Compliance Assistance Needs

• Take a sector-based approach
• One Size Fits All

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Identifying Compliance Assistance Needs

• Work with the industry sector to develop plain
  language guides or small business guides
• Provide enforcement discretion and advice in lieu
  of penalties for smaller companies struggling to
  comply

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Identifying Compliance Assistance Needs

• Comply with the Small Business Regulatory
  Enforcement Fairness Act (SBREFA)
• Use comments generated in panel process
• Encourage ingenuity and creativity
• Specialty batch sector very entrepreneurial let
  sector develop alternative compliance methods
  that continue to protect the environment
• Example Facility-wide air pollutant cap

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Overcoming Impediments to Compliance Assistance

• Regulatory Agencies
• Some communication occurring
• Look for additional opportunities to open dialog
• Issue EPA Compliance Assistance Manuals in a more
  timely fashion
• What can industry provide to EPA to make efforts
  more effective?

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Overcoming Impediments to Compliance Assistance

• Industry
• Industry has to learn to trust regulatory
  agencies
• Many companies only interaction with regulatory
  agencies is when they are inspected
• Many inspectors do not understand batch and
  specialty chemistry
• Many companies dont understand how to or the
  benefits of dialog with regulatory agencies

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Where do we go from here?

• Work to identify additional specific compliance
  needs
• Continue dialog on existing needs
• DSW, HPV, MON, site security, etc.
• What can industry provide to EPA to make efforts
  more effective?
• What can industry provide to improve EPAs
  understanding of small business needs?