Risk Management Audits Developing a Comprehensive Audit Approach

Transcription

1 www. chwmeg. org Risk Management Audits Developing a Comprehensive Audit Approach Environmental, Health & Safety International Communications Symposium September 14, 2016 Pittsburgh, PA USA Brian Bosilovich CHWMEG, Inc tech@chwmeg.org tel: (412)

2 Contents Just a little background Why audit? Who to audit? Why accept or reject a facility? Auditing E-Waste facilities

3 CHWMEG Background CHWMEG not an acronym Trade association with 280 members Conduct shared-cost audits of TSDFs around the world Originated in the mid-80s Incorporated in Members 29 Audits in 15 US States 2016 Program 280 Members 304 Audits in 44 US States & 18 Countries

4 Membership Diversity Industry Members Oil/Pipeline/Coal/Gas 49 Chemical 36 Electric/Gas Utilities 31 Pharmaceutical 27 Materials/Advanced Materials 22 Consumer Goods 18 Automotive/Aerospace 17 Medical/Health Equipment 15 Electronics OEM 12 Other 11 Equipment/Heavy Equipment 10 Semiconductor 10 Universities 8 Agricultural Chemicals 7 Communications 4 Media 3

5 Audit Program Analysis Benchmarking Surveys: 2004 (103 responses) 2007 (79 responses) 2012 (108 responses) Surveys contained the same questions Formal vs. Informal Policy Corporate vs. Business Unit Global vs. US-only Motivation for Audits/Reviews Facility Types to Audit Criteria for acceptance/rejection And much more

6 Motivation 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% What are the motivations for conducting facility audits (check all that apply)?

7 Motivation Reason Delta Superfund Avoidance 92.4% 91.8% 96.0% -3.6% Corporate Social Responsibility 68.8% 73.8% 55.0% +13.8% Corporate EMS Requirement 62.4% 59.0% 62.4% 0.0% Corporate "Responsible Care" 52.9% 46.7% 44.3% +8.6% Informal Voluntary Program 29.3% 30.3% 23.5% +5.8% Supplier Driven Requirement 22.9% 12.3% 14.8% +8.2% Customer Driven Requirement 13.4% 13.9% 11.4% +2.0%

8 Motivation - Other Past exposure has been an expense to the Company Provide consistency - ensure wastes are sent to "approved" companies Reduce footprint by controlling the program at corporate Business continuity planning - to prevent business interruption. Insurance recommendation Reduce potential for negative public relations

9 Who to Audit and When? Hazardous Waste Facilities Incinerators, Fuel Blenders, Sub C Landfills, etc. Average Frequency: 3.3 years Non-hazardous Waste Facilities RCRA Exempt, Sub D Landfills, Metal Recycling, etc. Average Frequency: 3.7 years Municipal-like Waste Facilities C&D Landfills, Towel Laundries, Salt Wells, etc. Average Frequency: 4.0 years

10 Facility Types - Specific Incinerators: 94% Drum/Tote Reclaimers: 44% Glass Recyclers: 18% Landfills: 87% Radioactive Material: 40% Acid Regenerators: 17% Fuels Blenders: 81% Other Metal Recyclers: 39% Tire Processors: 15% Fluorescent Lamps: 79% Transfer Only Facilities: 36% Petroleum Landfarms: 14% Industrial Wastewater: 71% Spent Carbon Regen: 35% Tank Car Washout: 12% Solvent Recyclers: 71% Plastic Recyclers: 31% Shop Towel Laundries: 11% Battery Processors: 69% Paper/Cardboard Recyclers: 31% Uniform Laundries: 11% Ballasts: 69% Thermal Desorbers: 29% PPE Recyclers: 7% Electronics/E-scrap: 68% Catalyst Regenerators: 26% Salt Water Injectors: 6% PCB Facilities: 56% Gas Cylinder Reclaimers: 25% Tank Wagon Washout: 4% Scrap Metal Sites: 49% Aluminum Recyclers: 23% Barge Washout: 3% Mercury Processors: 47% Deep-well Injectors: 21%

11 Why Accept/Reject? 100% 95% 90% 85% 80% 75% 70% 65% 60% 55% 50% What specific criteria are used in the decision to accept/reject facilities?

12 Why Accept/Reject? Criterion Delta Financial 97.2% 97.5% 98.1% -0.9% Compliance 94.4% 96.2% 98.1% -3.7% Potential for Future Incidents 92.6% 92.4% 90.3% +2.3% Existing Contamination 91.7% 93.7% 93.2% -1.5% Waste Handling Programs 88.0% 86.1% 87.4% +0.6% Facility Design and Operation 81.5% 84.8% 88.3% -6.8% Facility Appearance 80.6% 88.6% 88.3% -7.7% History of Use 79.6% 82.3% 86.4% -6.8% Safety 78.7% 74.7% 65.0% +13.7% Management 77.8% 86.1% 86.4% -8.6% Residue Management 74.1% 83.5% 73.8% +0.3% Site Security 70.4% 82.3% 70.9% -0.5% Potential Receptors 67.6% 75.9% 73.8% -6.2% Public Relations 57.4% 69.6% 62.1% -4.7%

13 Develop an Approach to Meet Your Needs Make a list of reasons for auditing Examine your entire list of disposal facilities, and prioritize audit type need Comprehensive Simple site visit Desktop review None needed How often to audit those facilities When to re-audit outside that cycle Prioritize acceptance and rejection criteria

14 Develop a Protocol to Meet Your Needs A: GENERAL INFORMATION B: FACILITY OPERATIONS C: FACILITY DESIGN C.1 FACILITY DESIGN GENERAL C.2 UNIT DESIGN STORAGE/TRANSFER C.3 UNIT DESIGN RECYCLING/TREATMENT C.4 UNIT DESIGN THERMAL TREATMENT C.5 UNIT DESIGN LANDFILLS C.6 UNIT DESIGN IMPOUNDMENTS C.7 UNIT DESIGN LAND TREATMENT C.8 UNIT DESIGN INJECTION WELLS C.9 UNIT DESIGN RADIOACTIVE PROCESSORS C.10 UNIT DESIGN DRUM RECONDITIONING D: REGULATORY COMPLIANCE E: SITE GEOLOGY/GROUNDWATER F: LOCATION G: INCIDENTS AND REMEDIAL ACTIONS H: MANAGEMENT PERSONNEL I: FINANCIAL STRENGTH J: INSURANCE K: COMMUNITY RELATIONS L: SECURITY

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16 E-Waste Facilities Reuse/Recover/Dispose Hierarchy type Policy Data security policies and procedures Quality Assurance Plans for testing of reusable or resalable equipment Verify upstream sources Selection of downstream vendors Policies for compliance with transit, import, and export laws Import/Export notification and consent documents

17 Always Consider Other Factors Are other deep pockets using the facility? Regulatory opinions of management Up to date news items They know you are coming Satellite images of the property Facility photographs

18 PICTURE SHOW

19 Thank You! CHWMEG, Inc: Globally Promoting Responsible Waste Stewardship