Are you in compliance? A beginner's environmental compliance list

by Editorial Staff
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Ah, the sweet smell of summer and a new crop of local, state and federal environmental interns hit the food plants. Evaluation of a plant’s compliance status may save money and prevent jail time. This article will list rules that most commonly apply to food facilities but will not include all possible rules that might apply to any specific plant (including office, kitchen and restroom area), warehouse, depot or thrift store.

Be hopeful, remember that you know your business better than the government and 95% of the time if you run your business cleanly and efficiently, you will meet the regulations. One such guide to prioritizing the work is the "AIB International Consolidated Standards for Inspection." The goals of environmental compliance and a food-safe processing facility are complementary.

Permits, plans and associated paper work may be managed simply using a loose-leaf notebook with a scanned copy on and off-site. A plant manager may quickly respond when visited by an inspector. When an activity is referred to as permitted in this article, it means that a piece of paper that is a permit is needed; not that a plant manager has permission to carry out the task.

Many of the regulations referred to require annual reporting. If the necessary paper work for the activities is not present, compliance was never met and fines begin at $25,000 a day per violation with variable jail times. Take a deep breath, this is dense material.

Air quality compliance

In regards to air quality compliance, here are some of the requirements that may be necessary:

• Air permits to construct, modify and operate a facility using yeast fermentation are usually issued for 5 or 10 years but must be renewed 6 to 9 months before they expire.

• Air control devices for ovens such as catalytic oxidizers and dry ingredient silo baghouses used for flour are permitted.

• Permits also may be required for odor and outside visual emissions such as the "smoke" that may be part of a diesel startup.

• Boilers, steam generating units and emergency generators are permitted.

• Refrigeration systems maintenance, refrigerant disposal and documentation are regulated. In addition, ammonia systems require emergency response plans as well as an Environmental Protection Agency Risk Management Plan and an Occupational Safety and Health Administration Process Safety Management Plan.

• Hazardous chemicals such as code and date stamp inks and oven lubricants probably need to be reported for air permits, the Toxic Release Inventory Reporting and the E.P.A. Hazardous Chemical Inventory.

• Dust and noise limits inside the building are regulated by local fire codes, the E.P.A. and OSHA.

• Flour and air compressors are critical checks for particulate concentrations.

• Asbestos is regulated. Radon testing is required in certain areas.

• Mold is bad; think food contamination and worker safety.

• Pesticides are regulated.

 Requirements for water

The permits for drinking water and discharge water also are wide ranging. They include:

• Permits are required for the discharge of water from food processing, sanitary wastewater, boiler blow down and storm water. A spill plan is required to prevent any ingredient such as vegetable oil and flour, oil from the parking lot, material stored on-site or any other delivery from reaching a storm drain. Flour on the roof is bad; think cost of flour, bugs, birds and a storm water violation.

• The testing of drinking/processing water and discharge water often is required. Reuse of gray water is becoming more common and the rules are variable.

• Truck washing on-site is a regulated or an illegal activity.

• Above ground and underground storage tanks are permitted and the management of leaks is regulated. • Locks, berms and security fencing may be required.

Waste documentation is critical

Likewise, keeping up with documentation of waste management practices is critical. These requirements may include:

• Hazardous substances require special storage and disposal. Documentation is critical.

• Disposal of electronics, including lighting, air conditioners, cell phones, computers and just about anything with a chip is regulated and often permitted. Fluorescent lights often are returned to the manufacturer. PCBs are a particular concern.

• Disposal of cleaning solvents, used oils, paints, and other hazardous substances must be documented. Disposal of materials that go to landfills, incinerators or for animal feed must not be exposed to storm water and the disposition of the materials should be documented.

Requirements are wide ranging

Local, state and federal requirements not only vary but may be contradictory.

For more information on how to comply with this burdensome list check out for several guidance documents, including "Multimedia Environmental Compliance Guide for Food Processors" and other documents available at

Rules for OSHA worker safety, Department of Transportation fleet management, U.S. Department of Agriculture for meats, Food and Drug Administration food safety, Homeland Security and others may be researched on their respective web sites.

This article can also be found in the digital edition of Milling and Baking News, June 30, 2009, starting on Page 26. Click here to search that archive.

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