A Practical Guide for Environmental Compliance
a Blueprint for Environmental Managers
This is a 340-page book written by Norman Wei and it contains 17 chapters and 10 appendices. It offers a PRACTICAL approach to environmental compliance designed for anyone who is responsible for environmental compliance in his or her organization.
The book is not a recitation of environmental regulations. The focus of this book is on the skills required of an environmental manager.
The first chapter of this book lays out how senior management views the role of an environmental manager vis-a-vis that of a safety manager. It is not that senior management views environmental protection any less than safety. It is all in how “effectiveness” and “return on investment” are often perceived by management on a daily basis.
Chapter 2 discusses how you as an environmental manager should work with your colleagues in the office as well as attorneys and plant managers. Your relationship with these folks dictates your effectiveness as an environmental manager.
The third chapter is about your working relationship with the regulatory agencies. How you or your agents (consultants) interact with them is paramount to your success. This is because people generally work with people they like. Permit writers are no exception.
Chapter 4 discusses how you should view regulations and why it is critical that you understand how the agencies enforce environmental laws. Those of you who understand the agencies’ thinking will be able to steer your organizations away from being targeted for enforcement action. The last part of this chapter talks about how to set up an early warning system to minimize your own personal liability.
The discussions of liability are carried over into Chapter 5 where environmental risks and hazards are further quantified. You have to know your risks before you can manage them.
Chapter 6 reviews the danger of letting someone else manage and control your environmental data. This chapter goes on to discuss the over-used term “environmental sustainability” and what it really means. There is also discussions on the fallacy of “environmental indices” and why they should be avoided.
Environmental audits are an essential tool for environmental managers. If done properly, a full environmental audit can identify current state of compliance and predict future performance. Chapter 7 discusses EPA’s Environmental Audit Policy of 1986 and the two different types of audits. There is a lengthy discussion of the difference between a compliance audit and management audit. It covers the art of asking the right questions and getting high quality information during an audit. An example of root cause analysis is also included in the chapter.
Chapter 8 is one of the most important areas many environmental managers face. How you choose your consultant can make or break you. If you hire the wrong consultant to get a permit from an agency, that consultant can cause irreparable harm to your relationship and reputation with the agency. This chapter shows you what to look for in a consultant and what to avoid.
Chapter 9 is all about ownership of environmental plans. If your plant personnel do not have ownership of your environmental plans, the plans will not be implemented no matter how well they are written.
Citizen lawsuits are very common under federal environment laws - especially under the Clean Water Act. Chapter 10 offers a case study on what you should do in case you are faced with a citizen lawsuit.
Chapter 11 is on how to cope with agency inspections. What you do before, during and after an inspection defines the eventual outcome. This chapter contains numerous practical tips on how to prepare for an inspection and what to do during and after the inspection.
Accidents happen all the time and they often happen in the middle of the night. Chapter 12 outlines the steps you should take to prepare for an incident such as a chemical spill. It discusses your obligations under federal spill reporting requirements. It also describes what you need to do in California which has a very different spill reporting requirement. This chapter contains a list of all 50 state agencies and their state-specific spill reporting requirements. It also discusses what you can learn from the BP oil spill of 2010 in the Gulf of Mexico.
Chapter 13 introduces a rather tricky question of an auditor’s duty to report should the auditor come across an event that could pose imminent danger to public health. The duty-to-report principle applies to auditors and environmental managers.
Chapter 14 has little to do with environmental regulations. But it touches on one of the key job skills of an environmental manager - how to communicate effectively with your managers and peers. You may have the best ideas in the world. But if your presentations put your audience in a coma, your ideas are not going to go very far. This chapter presents a much more effective and field tested way of preparing your PowerPoint slides. This is the approach the author used in all his environmental compliance seminars.
Chapter 15 describes the step-by-step approach in setting up your own environmental management systems. Having an EMS in place will help you to stay in compliance and better manage your programs.
Chapter 16 summarizes the key differences in environmental regulations in California. Included is a discussion of the state's Prop 65 requirements which are unique in the country. Anyone who has a facility in California will need to understand the far reaching arms of Prop 65 and the liability it poses.
The last chapter is a summary of all the things an effective environmental manager should have or follow. Chapter 17 is in effect a blueprint for environmental managers to stay in compliance.
There are 10 appendices in this book. One of them is an in-depth discussion of the Clean Water Act which includes the permitting process, SPCC and storm water management.
Another appendix discusses the approach you should take in obtaining air permits and how to avoid Title V permits under the Clean Air Act. There is also a brief description of what Cap-and-Trade means.
Appendix 8 discusses five bad environmental/safety decisions or actions taken by companies that led to catastrophic results. These are teachable moments. It is always good management practice to learn from other people’s mistakes.
At the end of book is a section on Additional Resources. Here you will find reading material that are used in the preparation of this book. Click here to find out the background of the author.
Click here for the Table of Contents.
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