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Environmental Compliance Audits
ERG offers environmental compliance program development and implementation services.
Environmental compliance audits are generally performed to:
- Ensure compliance with the regulations
- Minimize the potential for creating short- and long-term environmental liabilities
- Evaluate the legitimacy of violations alleged by regulatory agencies.
Environmental auditing of facilities for property owners/managers is also performed to:
- Ensure tenants comply with operational provisions of the lease agreement
- Avoid the application of passive contribution by property owners, which can override indemnification agreements (legal theory established in case law)
- Minimize transfer of potential tenant pollution liabilities to the property owner should a tenant become financially insolvent (e.g. bankrupt)
- Support legal cost recovery actions
Our services include:
- Audit program development and implementation
- Tiered auditing system for multi-use properties and facilities
- Evaluation of leasing terms to develop an auditing approach that minimizes the liability of the property owner and manager
- Digital auditing systems (e.g. PDAs or similar and digital camera) to:
- Minimize data transcription costs and field to office QA/QC issues
- Maximize information retrireview by utilizing database operations
- Baseline environmental assessments to:
- characterize existing (background) chemicals and concentrations in the environment at the facility
- identify potential off-site sources of contaminants to the property
- establish basis for indemnification (if any) of pre-existing conditions
- establish basis for future cost recovery actions
- Baseline operations assessments to:
- document current operations
- track changes in operations
- assess potential environmental hazards and risks
- Facility inspections. In the event that operations are significantly specialized, ERG can contract with appropriately experienced persons
- Positive relationships with tenants and facility operators that promote environmental compliance. As needed, we can establish confidentiality agreements with tenants to avoid concerns associated with confidentiality, trade secrets, etc.
- Recommendations and assistance to facility operators to ensure that operations are consistent with local, state, and federal regulations
- Environmental management systems to promote continuing compliance
- Permitting efforts for allowable discharges to air and water, including storm water permitting
Elements of an Environmental Compliance Program could include:
- Hazardous Materials Management Plans (HMMPs) pursuant to Subchapter 3, Chapter 2, Title 19, California Code of Regulations (CCR), and SARA Sections 311-313.
- Process Safety Management and Risk Management Plans pursuant to 29CFR Part and Title 19
- California Proposition 65
- Hazardous Waste Management pursuant to CCR Title 22, Division 4.5
- Air Quality Permits and Emissions (EPA and California AQMD Regulation 11, Rule 8
- Storm Water Quality pursuant to SWRCB Industrial Activities Permit requirements
- Injury and Illness Prevention pursuant to CCR Title 8, Section 3203
- Emergency Action Plan pursuant to CCR Title 8 Section 3220
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