How to write a perfect Best Management Plan

iStock_000003319956XSmallThere are many environmental programs that require best management practices (BMP). These are actions that you must develop on your own to address certain environmental conditions at your facility. While the agencies provide guidelines, they do not prescribe specific details on how you must write your plans.

Here are three examples of BMPs that are required under US environmental regulations.

BMP for storm water management

BMP for hazardous waste

BMP for spill control

In all three examples, you are required to evaluate your particular situation and come up with a specific plan of your own to mitigate any environmental damages that might arise.

In the case of storm water BMP, you must identify how you store your chemicals and how you operate your facility and develop a plan to minimize the impact on storm water. There are two basic types of BMP: structural and procedural. Your structural BMP would describe how you physically control the movement of storm water to avoid coming into contact with your industrial activities.  For example, if you build a roof over your chemical storage area and install secondary containment, you are physically and structurally preventing the storm water from coming into contact with your chemicals.

A procedural storm water BMP would consist of good housekeeping practices that require your staff to clean up any spilled chemicals and not wash them down the storm drain. You achieve that through a training program and implementing of procedures to mitigate potential damages.

In the case of hazardous waste BMP, you are required to have a contingency plan or emergency response plan in place to manage any incidents involving your hazardous waste storage areas.  In this case, you must identify an emergency coordinator who has been given the prior authority to shut down operation in the event of an emergency. As part of the plan, you will have to develop a weekly checklist to inspect your waste storage area.  The regulations do not prescribe how you should write your contingency plan. The details of the weekly inspection checklist is left up to you. But the agencies do require you to develop the plan AND implement it.

If you store more than certain amount of oil onsite and have the potential to impact navigable waters of the United States, you are required by law to develop a BMP known as Spill Prevention and Control Countermeasures (SPCC). in this plan, you must identify specific steps that you will take to prevent any spilled oil from reaching the navigable waters of the United States. The specific details of how you do it is based on where and how you store your oil. Every facility is different.

One common thread among these BMPs is that you control the contents of these plans and it is your responsibility to demonstrate to the agency that your plans will do the job and that you will implement the plans as written by you.

Is your BMP overly simplistic that it cannot possible mitigate any damages? Or is your BMP so complicated and involved that you cannot possibly implement it? There is a happy medium and that’s what the agencies look for during an inspection. They look for evidence of implementation as written in the plan.

Many facilities make the mistake of hiring outside consultants to prepare these BMPs for them without any regards to how the plans will be implemented. For example, if the consultant puts down in the BMP that you will inspect your oil storage facilities every day, will you have the manpower to carry it out? The agencies will be looking for a COMPLETED daily inspection checklist as evidence that you have carried out your BMP.

The best way to avoid such situation is to make sure you and your staff are involved with the consultant in developing the plan. Make sure the consultant does not promise anything in your BMP that you cannot deliver. Also make sure the people who will be implementing the plan are involved. Ownership is the key to implementing any environmental plans.

Bottom line: always write a plan that has sufficient meat in it to do the job but not so complicated that it never gets implemented.

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