EPA/OSHA Hazardous Chemical Safety Management

40 CFR 68/29 CFR 1910.119

USEPA issued Risk Management Plan (RMP) regulations in 1994; OSHA issued the Prevention Program portion of the EPA rule as the Process Safety Management (PSM) regs in 1992. Our engineers developed compliance programs in the petroleum refining and petrochemical industries when these regulatory mandates were first implemented, and have guided industrial and warehouse facilities through the RMP/PSM regulatory compliance maze since that time. Beginning with applicability considerations, and following through to compliance program development and auditing, we have developed compliant and efficient RMP/PSM solutions in a wide range of industries. We provide unsurpassed assistance with the core RMP/PSM compliance functions starting with: Process Safety Information (PSI) development and Process Hazard Analysis (PHA) implementation.

Waste Engineering

Ecogene capitalizes on our experience in a wide range of industries to bring our clients innovative solutions to waste management* issues. Whether gases, solids or liquids, industrial waste streams represent potential process inefficiencies. “Potential” because some waste streams have been minimized to the point of diminishing returns. However, many waste streams are amenable to more sustainable and economically advantageous approaches. In many instances, the magnitude and environmental impact of waste streams can be reduced, at lower operating, maintenance and compliance costs. This is often due to waste management technologies that did not exist or were not commercialized when the waste producing process was deployed.

While waste minimization has been a legal requirement for large quantity hazardous waste generators since the 1980s, recent emphasis on eliminating GHG emissions has resulted in hydrocarbon fuel combustion becoming by far the greatest target of waste minimization efforts. Hydrocarbon fuel combustion for process heating contributes approximately the same amount of GHG in the US as the entire transportation sector combined. There are tremendous opportunities for industrial deployment of green energy generation and storage. This will allow deployment of technologies using this stored green energy to power alternative process heating and other waste management solutions.

EHS Permitting & Compliance

EHS regulatory compliance constitutes a framework within which processing/manufacturing activities must operate.  Typically, the services we initially provide to clients are permitting/compliance in nature.  Ecogene’s extensive expertise includes the following compliance program components:

Clean Water Act Compliance

Stormwater Permitting & Management, Industrial Process Water Pretreatment & Permitting, SPCC Planning & Certification

Clean Air Act Compliance

Chemical Accident Prevention Provisions (Off-Site Consequence Analysis, RMP Submittal, Construction & Operating Permits, Air Pollution Control & Minimization (Criteria Pollutants, HAPs, GHG, ODS), Monitoring, NSPS & NESHAP Compliance, Chemical Accident Prevention Provisions (Off-Site Consequence Analysis, RMP Submittal, Prevention Program), Emission Inventories

Resource Conservation & Recovery Act Compliance

Solid & Hazardous Waste Assessment, Management* & Engineering

EPCRA, CERCLA, SARA Reporting

Tier II & TRI Reporting, Extremely Hazardous Substances

OSHA

PSM Compliance, 29 CFR 1910 Audits & Compliance Program Development

Property Assessment

Understanding today’s regulatory landscape and environmental risks is a challenge regarding real estate portfolios and transactions.  Ecogene supports municipal, commercial and industrial property owners through due diligence, site assessments and risk management:

  • Environmental Impact Assessments
  • Phase 1 & 2 Environmental Assessments (ASTM E1527 & E1903)
  • Remedial Investigation & Feasibility Studies

Ecogene personnel have performed site assessments and designed/managed remediation projects at a broad variety of properties.  We work with the leading certified contract laboratories to provide QA/QC meeting any recognized standard.  Our personnel keep up to date on emerging contaminants such as the developing focus on per and polyfluorinated alkyl substances (PFAS).  Our team has performed process source identification/elimination and environmental assessment (soils and groundwater) for this chemically complex group of contaminants. Ecogene field personnel have all completed 40-hour Hazardous Waste Operations (OSHA 1910.120) training & maintain 8-hour annual refresher status.