Spring permit cleaning
April 29, 2014
by Anne Giesecke
A hard winter will be followed by spring flooding and then heavy rain storms and winds. Winter damage is being repaired and preparations are being made for the coming atmospheric challenges. Now is the time to check the permits and record-keeping that ensure the operation is ready and in compliance with federal and state regulations. As an aid to your checking, this article is a list of some of the major requirements.
One newer element for most companies responding to agencies and the public is the social media contact. When checking that the personnel listed in the paperwork is current, think to add the social media contact. The contact currently may appear on emergency response plans.
Incorporating spill plans
The purpose of a Spill Prevention, Control, and Countermeasures (S.P.C.C.) Plan is to address all oil spill possibilities to, broadly defined, water and preventive actions at a specific facility. Above ground tanks for vegetable oils and petroleum oils are covered.
The change from trans fat, also called partially hydrogenated oil (PHO), to other ingredients may have required alternative use of some tanks. Verify that the S.P.C.C. has been updated since new tanks were added and personnel have changed. Check floor drains.
As a prudent management practice, many companies have built secondary containment or other protections for other liquid ingredients such as sweeteners and cream yeast. Some companies have moved away from high-fructose corn syrup (HFCS) to cane and beet sugar.
Tanks may be inside or outside a building. All tanks should have physical and procedural security measures to prevent adulteration; this is required by the Food and Drug Administration (F.D.A.), the Environmental Protection Agency (E.P.A.) and Homeland Security. Many customers have additional requirements.
Storm water plans
The National Pollutant Discharge Elimination System (NPDES) Stormwater Program regulates storm water discharges from buildings and land. Yes, a permit is needed because it might rain. Only storm water should flow into a storm drain, rivers, lakes or other waters.
Storm water running off roofs, loading docks, waste storage areas and parking lots should not pick up any substances such as flour, trash or petroleum oils. New landscaping for retention ponds and rain gardens should be in permits.
Review the storm water plan for any recent physical plant or personnel changes.
Analyzing water supply and discharge
Annual conversations with the local public drinking water supplier and the sewage treatment plant manager will help anticipate rate increases. The sewer discharge permit limits should be reviewed. Recent ingredient color changes from petroleum-based colors to plant-based colors and caramel in chocolate may have precipitated treatment changes.
Ask about gluten-free products and possible changes in the quality laboratory that may affect water treatment. Sanitation procedures may have changed or be planned to change the use of water and chemicals.
Ask about azodicarbonamide (ADA) alternatives and yeast level changes, which may have changed ethanol air emission calculations for the air permit.
Check air flow and pressure on the floor. Check vents and reverse the ceiling fans for warm weather. Check for flour dust concentrations and resolve any issues. Fix air compressor leaks, again.
Refrigeration critical to compliance
Record-keeping and certification requirements for the use of refrigerants are critical to compliance. Fines for leaks are in the tens of thousands of dollars. Freon is a common reference to various fluorocarbon refrigerants.
The E.P.A. is phasing out many refrigerants. Chlorofluorocarbon (CFC) R-12 is out of production. Hydrochlorofluorocarbon (HCFC) R-22 is being phased out. The cost of R-22 will increase and companies should plan to have transitioned out by 2020. E.P.A. decisions mean that alternatives and substitutes are constantly changing as are requirements for use.
Ammonia refrigeration systems require E.P.A. Risk Management Programs and Occupational Safety Administration Process Management Plans. Local fire department requirements also apply.
Hazardous waste and other trash
According to the E.P.A., hazardous waste is waste that is dangerous or potentially harmful to health or the environment. Hazardous wastes may be liquids, solids, gases, or sludges.
Wastes may be discarded commercial products, like cleaning fluids or pesticides, or the byproducts of manufacturing processes.
Truck maintenance operations may require a waste permit. Although the waste may be carried off-site by a contractor, the operator is still responsible for the deposition of the hazardous waste and the record-keeping to show compliance.
More changes are coming; the F.D.A. has a proposed rule out for comment for truck refrigeration systems and the cleaning of transport trucks. Oven and machine lubricants may be hazardous and serious consideration should be given to alternatives. Truck washing probably should not be done on site.
Energy reliability and training
Check with the power supplier for possible brown outs or power breaks. Energy generators for emergency use or power factoring require permits unless there is a letter in the file stating otherwise.
Management initiatives abound and may include sustainability, Lean, Six-Sigma, Kaizen, new computer programs and new customer audits. Some permits may have training requirements. Check training requirements for all personnel.
Enjoy the spring flowers.