What are the regulatory implications associated with shutdown of processes?
Although many communities are implementing Shelter-In-Place orders, environment, health and safety (EHS) compliance is expected to be maintained by applicable regulatory agencies.
We’re answering questions for clients planning a plant closure, curtailment, or shortening of hours due to the COVID-19 pandemic. Navigating the shut-down process is especially difficult when certain EHS-related processes may be represented in permits and can’t arbitrarily be shut down.
As we’re reviewing our clients’ proposed shutdown procedures, we’re identifying a few gaps. For example:
- Are security guards being notified of anticipated atypical actions associated with shutdown, and do they know who to contact in the event of an unusual situation?
- How will wastewater from drains, sinks, and other areas that go to pH adjust systems be handled if the pH adjust systems are shut down?
- Is a procedure in place to perform, after shutdown, weekly inspections of all 90-day hazardous waste storage areas by trained personnel?
In compiling customized checklists for clients, we’re seeing broader applications. That’s why we’ve developed a more comprehensive checklist that includes a range of EHS requirements.
Plant Closure/Plant Curtailment EHS Checklist
Our Plant Closure/Plant Curtailment EHS Checklist will guide you through tasks and topics to be addressed when planning shutdown activities.
Our checklist can serve as a resource to guide your company through this challenging process, when typical EHS compliance tasks and risk reduction measures may become difficult to sustain or impossible to implement.
Contact us today to get our Plant Closure/Plant Curtailment EHS Checklist and our help in navigating these unusual circumstances to safeguard ongoing EHS compliance.