COMPLIANCE PROGRAMS, EMS & AUDITING

Whether they intend to pursue ISO 14001 registration or not, many of Caltha’s clients are interested in improving their environmental management systems. They may wish to improve compliance, improve efficiency, reduce wastes or reduce costs. Caltha provides expert guidance and “coaching” to identify areas for improvement, develop metrics to track progress and to prepare written programs and procedures to improve the EMS. Caltha can also prepare an “EMS Manual” for your operations, which describes how your EMS works. Caltha has successfully guided facilities from coast-to-coast through the EMS process. For many operations, the process of developing an EMS begins with a Gap Analysis (What is a Gap Analysis?).

The OSHA Hazard Communication requirements are generally considered one of the most difficult requirements to comply with. Material labeling and maintenance of the Material Safety Data Sheet control system are challenging for many facilities. OSHA also has stringent training requirement to assure that employees are aware of hazards in the work place. Caltha will prepare your written HazCom program, prepare training materials and write or update your MSDS.

Caltha also provides specialized technical support to manufacturers, importers and distributors of chemicals as they are required to update the format of their hazard labeling and Material Safety Data Sheets (now refered to a Safety Data Sheets, or SDS) to meet new OSHA standards that align with the Globally Harmonized System(GHS) for the classification & labelling of hazardous materials.

The storage and use of hazardous materials at a site is regulated under the Emergency Preparedness and Community Right-to-know Act, or EPCRA. Many States have EPCRA-equivalent State programs. Caltha provides expert EPCRA support in evaluating EPCRA reporting requirements, preparation of EPCRA Tier II reports, and tracking and preparation of EPCRA 313 Toxic Release Inventory, or TRI, reports. Caltha is a TSCA expert and provides technical support in complying with TSCA requirements, including  Chemical Data Reporting, CDR, (formerly known as Inventory Update Reporting, IUR) required of many facilities that manufacture or import chemicals.

Many EPCRA reports are submitted on-line through the US EPA CDX system. Caltha is registered in CDX and can prepare reports on your behalf. The facility simply reviews the final report and submits it. This makes getting expert technical support very cost effective for facilities regardless of location.

Caltha LLP provides Certified Professional
Environmental Auditors (CPEA) certified through
the Institute of Internal Auditors (IAA).

Caltha staff have special expertise in regulatory requirements and stay current with developing or proposed regulations. This background is required to conduct facility compliance audits, and to provide auditing under corporate third party auditing programs, and preserving audit privilege and audit immunity rights under State and EPA rules. Caltha also understands environmental management systems and the different approach that is required to conduct Environmental Management System Audits.

Caltha offers a range of options for the scope and level of effort to conduct compliance audits or EMS audits. We will discuss this options with you to determine which is best suited for your facility.

Caltha provides special expertise in product registration requirements, and product stewardship rules, including regulations on product take-back programs and product recycling requirements. Caltha also provides technical support for compliance with international product standards such as ROHS and REACH. Caltha provides technical support to US based manufacturers and exporters on EU article exemptions, restricted chemicals under REACH Section 8 and Substances of Very High Concern (SVHC) list.

The Toxic Substance Control Act (TSCA) requires tracking and reporting on certain chemicals. In addition, on a four year cycle, manufacturers and importers of chemicals must report their activities through the Chemical Data Reporting (CDR) system, formerly known as Inventory Update Reporting. Caltha provides technical support to manufacturers and importers to track chemical usage and to comply with the TSCA notification and reporting requirements. Need more information in the CDR reporting requirement?  Contact us now!

Depending on their use of oil products some facilities may also need to comply with the US EPA SPCC Rule, or 40 CFR 112. Caltha prepares SPCC Plans, including the new SPCC Template Plan used by smaller facilities that meet the Tier 1 eligibility criteria. Caltha also assists larger facilities requiring a SPCC Plan that is certified by a professional engineer, and in developing their SPCC rule compliance program, including SPCC inspections and SPCC training. Caltha provides certified SPCC plans in all States.