Nearly any major industrial facility is subject to the conditions of the Clean Water Act (CWA) or the Resource Conservation and Recovery Act (RCRA).  Having a clearly defined and documented reporting system is vital to ensure compliance with NPDES and RCRA regulatory needs.

As the environmental coordinator for your facility, imagine the following scenarios:

• A new employee or Facility Manager joins your team. You are responsible for training that person to the requirements of your environmental operations. With your already busy schedule, how are you going to provide that person with an overview of your program?
• A regulatory inspector or third-party assessor arrives for your next audit. The inspector begins to ask the pertinent questions of how your program functions and how you address various issues.  Where are your reports kept?  What procedures are followed?  Who performs these activities?  Where are your training records?  And so the audit continues.

Throughout the greater environmental community, and specifically industrial facilities, it is essential to have documentation that describes your facility’s regulatory control system.  Similar to a laboratory Quality Assurance Plan, which describes the systems and procedures of all activities related to quality assurance, industrial facilities benefit from documentation that clearly describes the systems and programs utilized to maintain regulatory compliance. Such documentation supports and serves compliance efforts by facilitating training within the company, providing support for regulatory audits, and meeting the needs of internal and external quality assessment evaluations (such as ISO).  To have documentation of this nature provides you with the ability to present a complete guidance document.

I. Clean Water Act (CWA)

Many facilities that discharge water to a river, lake or stream are subject to the conditions of the CWA.  As part of the CWA, the National Pollutant Discharge Elimination System (NPDES) requires a facility to conduct routine sampling and analysis of its discharge waters.  Each permit is unique based on the type of industry, the receiving water, and location.  The NPDES Permit to discharge will specify the parameters that must be analyzed and the frequency at which samples must be procured.  Even if the activities performed to support a permit are of high quality and consistency, the lack of a documented system that describes sample handling, equipment maintenance, analytical procedures, data reviewed and data reporting may provide ample opportunities for auditors and regulators to question the product.

Microbac prepares Self-Monitoring and Data Reporting Quality Assurance Plans (SMDRQAP) to support NPDES activities for major industrial facilities.  The process of developing such a plan involves detailed audits of the current environmental regulatory compliance system, review of the permit, and interviews with associated personnel.  The resulting SMDRQAP will detail the permit requirements and how the facility adheres to these requirements.  A typical SMDRQAP includes an introduction to the facility, an overview of the compliance process, description of the field operations and equipment utilized, documentation of laboratory methods and quality assurance, as well as data reporting and record handling.

II. Resource Conservation and Recovery Act (RCRA)

Facilities producing waste materials that are subject to RCRA are well-advised to have available a Waste Analysis Plan (WAP).  Microbac produces WAP’s for a wide variety of industrial facilities.  These plans detail the production, handling, storage, sampling, analysis, transport and dispensation of each waste material produced by a manufacturing facility.  The completed WAP becomes a procedural guide for how to handle all waste materials produced by a facility.

Revisiting the example scenarios for the environmental coordinator, it becomes obvious that documents such as the SMDRQAP and WAP provide the opportunity not only to meet a facility’s immediate needs of training and internal process control, but also to succeed in ensuring regulatory compliance.

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As a member of the analytical community, Microbac Laboratories, Inc. is familiar with the need to have complete documentation of our business and analytical systems. To successfully meet and maintain our accreditations and certifications, Microbac must ensure detailed documentation for employee training, analytical methods, quality assurance programs, quality control procedures, data reporting and record archiving. Documentation such as Microbac’s Quality Assurance Plan, the associated training documents and the Standard Operating Procedures (SOPs) are key to our efforts in documenting the required activities and providing high quality and defensible testing services.

Our experience in maintaining the demanding documentation requirements of our accreditations as well as our industrial experience provides us the unique ability to assess your regulatory compliance status and generate a comprehensive document to address your needs. These documents are produced in a format(s) that is of the highest value to the user, with final documents that include hard copy, electronic and web based options to allow for full integration of lab data and references. To investigate these opportunities and the benefits that can be provided to you, please contact Microbac Laboratories, Inc.