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How to look at Environmental Risks – a different perspective

ImageThere are many risks around us as we wake up in the morning and go to work. There is the risk of car crashes as we drive along the freeway.  We also have the risk of buildings falling down during an earthquake. When we get on the plane, there is always the risk that some terrorists may hijack our plane.

Society has taken certain actions to manage these risks. We establish speed limits and impose traffic rules by to minimize the chance of cars crashing into each other. We require buildings to meet certain codes to keep them from collapsing during an earthquake. We created the Transportation Safety Agency to screen all passengers going on planes. All of these actions are part of risk management.

Companies also manage risks at various levels.  For example, corporate risk managers work with insurance companies and fire departments to reduce the risk of their factories burning down. Safety managers set up machine guards to prevent amputations. They establish lockout/tagout procedures to reduce the risk of employees being electrocuted.

What about the environmental managers? How should we go about managing environmental risks?

The first thing we need to recognize is that environmental risks involve more than the risk of being fined by the government for permit violations. We as environmental managers need to think outside the box. Always be suspicious when somebody says “we have always done it this way” as a reason to resist change.

The old adage: I”f it ain’t broke, don’t fix it” is true only up to a certain point. If we had stuck with it during the horse and buggy days, we would still be riding to work in a horse drawn buggy because the buggy was never broken. It got us from point A to point B most of the time.

To think outside the box, we should look at chemicals that we use at the factory and ask these questions:

What are the risk to our workers when they use these chemicals?

What risks do these chemicals pose to the environment if they are spilled?

Are we storing too much of these chemicals on site at any given time?

We should look at the amount of hazardous wastes that we store onsite. What are the environmental risks associated with storing all those highly ignitable hazardous wastes on-site even though they may be within the legal limits of 90/180/270 days? Should we ship them out more frequently so as to reduce the risk of fire and spillage onsite?

These are all important environmental risk management questions we as environmental professionals need to ask ourselves.

When we do an environmental audit, we should never rely solely on a simple checklist. We should look around us and try to recognize risks. For example, if we see a deteriorating water tank right next to a transformer substation, a flashing red sign saying “HIGH RISK” should light up in our heads. We should immediately recognize that risk because when that water tank collapses, our factory will be out of commission for a long time.

Another example to consider environmental risk management concerns chemical reformulation? There is a simple reason why air regulations are constantly reducing the allowable amount of VOC in our cleaning solvents. The regulatory agencies are trying to encourage industry to switch to a more environmentally friendly solvent. Reformulation is an excellent way to reduce environmental risks. Many paint shops have escaped the clutches of Title V air permits simply by reformulating their paints. They now use paints that contain much less Hazardous Air Pollutants and VOC and that takes them below the Title V permitting threshold. So by getting out of title V permitting system, they significantly reduce the risk of citizen lawsuits and running afoul of Title V compliance certifications.

The last and very important way to reduce our environmental risks is to make sure that all our employees receive the proper training that they need so that they know what to do in case of an emergency. They also need to know why they are doing the things that they do and not just because someone told them so. A good auditor will always ask the question:  “How will they deal with it when something really bad happens?”

That is the ultimate test for environmental risk assessment and it should be on the mind of every environmental manager.

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