Sasha: Hi everyone and welcome to today's Webinar on EH & S Program Gap Analysis. My name is Sasha and I will be your moderator for today. Before we get started, I want to give you a brief overview on what today's webinar is going to entail as well as a short introduction for our speaker.
Today's webinar will start with a slide show presentation by our in-house expert Mike Albert. This webinar will teach EH & S professionals how to perform a gap analysis on their existing programs as well as determine the best practices for improvement.
Specific topics addressed during this webinar will include how to determine what resources your organization needs and how they should be used to drive the most improvement; best practices for getting those resources on a limited budget or with skeptical management and tactics for designing and implementing new plans and programs.
At the end of this webinar, there will be an open Q & A. You can ask questions by typing them into your chat pane on the right where to ask questions.
So just to kind of reiterate that, nobody needs to raise their hand. No one's mic will be turned on or anything like that. You can just type the questions in and I'll ask them to Mike and he will give you an answer. All unanswered questions will be answered and sent out in an email after the presentation. So, if we don't have time to get to your question, don't worry about that. We will send you an email and answer you then. In addition to the questions, all attendees will receive the recording of the presentation and a copy of the docus today.
Today's speaker Mike Albert has worked at Triumvirate Environmental for over 6 years and currently holds the title of On-site Services Operations Manager. One of his specialties is managing the on-site support program, a program that focuses on finding and filling in EH & S program gaps for our clients. And with that I’m going to turn over you Mike.
Mike: Sasha, thank you very much. I appreciate the introduction to going forward. Today with our vast experience of understanding gap analysis and really potential improvement tactics that can be used directly today, a lot of programs out there are good. They passed inspection.
Everybody feels really good about it but even some perfect programs do have some small gaps that we found over time that can definitely be adjusted. It's very few cases that an inspector will be able to walk in or agency will be able to walk in and walk out with actually no problems going through it. There's always some good constructive feedback or criticism moving forward.
There's some definitely good take home advice in here and some quick examples of exactly what you can do when you walk out of here to go perform your own miniature gap analysis and figure out what you could need or what you could want moving forward.
I want to stress that this is an overview. This is not an in-depth gap analysis that dives in every little nook and cranium of your program. I want to be able to hit on some of the more common and more recent errors and issues that have been found through inspections and through what we found out through our local state and federal agencies as well.
Our biggest point is that it is really great to know your strengths but it's better to know your weaknesses and ultimately fix them. Without fixing them, you're leaving your program open for a compliance issue, a compliance fine or write up in the newspaper which is probably the worst that anybody could actually think of because then that causes damage to your actual business.
No matter if you're biotech, a life science place, a health care institution or even a university located almost anywhere in the US, you got to find a couple little problems, a couple little gaps and you're going to want to be able to fix them quickly and easily.
Today we're going to aim to really focus on what you can do and what you can offer your company moving forward. A lot of different agencies, a lot of different programs are out there that I'm going to touch on just a few of them.
Some you can see up in the little cloud up there between the biological, best management practices, world born pathogens, stop going down that route, the radiation safety between knowing what your radiation safety officer should know if you have radiation on your site, if you do not; and then over-all efficiency of the environmental protection agency, the EPA and that at a federal level. Always remember that when you go down the state level, rules are going to be probably more stringent.
And today it covers everything. You can use this whether you're a start-up, a brand new company right off the market, someone who's been in business anywhere from a year, couple of months, couple of hours, depending on what's going on.
If you're small EH & S program, if you have only a couple of people within your program, if you yourself are the only person actually working with your program which is very common, not something uncommon by any means. Or if you're a very large program, you have upwards of 5, 10. I've heard some programs going upwards 20, 25 people which is for some people, "Oh my gosh, this is wonderful. I have so much resources. I have so much to do. We can really dive into it as team which is really good to have.”
Strictly here, we're looking at just the overview. So something as a large EH & S program, we might not go in too in depth about everything you're going to want to look at. But this covers a lot of the basics that you should look for.
Understanding that a lot of top talents will give you the top results. You're not going to go out there and pick up your friend that wants the job and say, "Hey, let's do this environmental thing together."
No, you want to know what's going on and what's going out there. And you want to make sure that you put the right people in place if it's a consultant, if it's inside, if it's outside. If you want to hire someone inside, it's great.
Also, a lot of people out there, which I think is wonderful, is you have a great background, great experience, great knowledge, go to school, you get all these extra little webinars. You get a little white paper here and there and you're thinking, “This is great. This is just my little brush up or why do I need something like this?”
Like what I said, it's knowing what you need and ultimately when you need to do it. There are a lot of little things that change, process change; I'm going to talk about that going to depth about what's really going on.
Is there something that you're missing? Is it hard to fix? Is it easy to fix? Let's really start diving into that and understanding what's going on out there.
So with this, I would like to ask a poll question to everything is how many times do you run into a roadblock and need external sources to help you out? The poll is open. You can go in and answer any questions from 1 through 5. This is strictly just where you stand. Let's just be honest with ourselves. How often do you come up with a situation, in a problem with a person, a chemical, with anything, emergency response out there that you might not know what to do right away? These are very common things that you can run into and situations you can run into that you need extra help for.
So we're looking for just quick google answer, see what's going on out there. And also, are there any other constraints that come into play when you need more information and we're going to go in today a little bit about budget and money and talking about a little money everybody has as we understand because of the constraints over the past 67 years about trying to lower budgets as well.
Sasha: Great. Thanks everybody for answering the poll. Looks like the most common answer by far is 2 times a month or less so thank you guys. Turn it back over to Mike.
Mike: Thank you Sasha. Definitely moving forward, benefits of this gap analysis is knowing where you are strong. You got to know where you're strong and what's going on.
You feel very confident in your waste disposal and your clean air act admissions and half reporting. You feel really really good about that. That's excellent; you should feel good about large parts of your program.
On the other side, understand where you're vulnerable, these cases where State inspectors will come in and find these little cracks and crevices within your program and just go "Huh. What about this? Am I going to find you for it? Am I going to site you for it? I don't know about this." And then, can you provide the actual answer that could help support why you're doing it and what's going on?
Understanding new regulations. Regulations are constantly updated anywhere from monthly, yearly. There were some recent webinar that we did that it took 3 to 4 years to actually go through and get a regulation passed. And there's a lot of public comment.
You should definitely look at being able to publicly comment on things federally and through the state. There's open comment periods that you can go through. But actually understanding new regulations and how it would apply to your process within your own site and in your institution.
Of course, everybody wants to talk about money. The budgetary restraints are huge and in a lot of cases it almost doesn't matter what you're doing. There's always a money cap. Usually, it's lower than what you want and a lot of places out there can help you work with that, understand it and not just walk in and walk out without doing just the bare minimum but doing as much as possible.
And then also, what and who are out there to help. There's a lot of different resources out there including the via internet, in the web, and all this basis on who you trust, when you trust them, what's going on out there. Classic example is Wikipedia. That we all should just got to Wikipedia and just look at that but ultimately that’s not a good answer.
A lot of cases you got to consult the regency websites, the federal websites and the state websites to actually look and find out what's going on and then to interpret what you're reading is an entirely different level. We're going to cover all these throughout this process.
So what we're going to look at is finding the gaps, how to complete a basic gap analysis to identify some of the issues and what you can see in your program. Secondarily, we're going to look at budget. Where do you stand to do this type of work? What can you do? What you don't want to do and so on and so forth.
And then also, what you can do right now, the immediate tactics that are going to help you either identify one or two things or four, five, six, seven things depending on what's going on in the education experience as well.
First, we're going to go through looking at these gaps, finding them. So let's start with the basics. Let's really look into why you should be asking yourself probably every other month, every other week depending on what's going on.
What do you do currently staying compliance? How are your people? Are they trained properly? What are you doing routinely? Routine is a very good word because it means things are being done on a specific time frame and in a range.
However, as we all know when routines get a little boring, you might miss something once in a while. So, how do you stay in compliance and what can you do? And then, touching on the training point, who does it? Is it an employee, at a completely different level that you tasked to swift and you need to just guide them, check upon them, and follow up with what they’re doing?
There are a lot of different projects going on where you might be over your head with what's going on. You might be under water, I should probably say. And these trainings that these people have to go through you fall out of date. You can go through updating them and knowing what's going on.
And then documentation, documentation is probably 99% of the game at proving something is done and how it is done. Writing up SOPs, procedures, best managers practices are huge on what's going on.
And then, how often? Like I’ve mentioned before, follow up, checking in, making sure it's there. So when inspector comes in, do you know who to go to and when to go to them to actually get information that they need.
Then, is there a reminder? We have so many things to do all the time and I get it. You get it, it’s all there. Is there a reminder? Is the outlook calendar, these sources that you always use up?
I got to update this permit it's coming up. What if Outlook changes? What if something was in the background that you weren't sure of? What if you can’t find a document? What reminder can be used when everything is located?
And then ultimately, does it need to be done? Are you overdoing it in some cases or you are underdoing it in some cases? These are some little things that you should definitely ask yourself to see where you are and see what you're at.
So common program gaps that we see.
A nice little pyramid here of a lot of things that can go good, that can go bad. But ultimately, on the bottom you have all your emergency response and emergency planning contingency planning depending on how big your size is. This is stuff that you got to make sure you keep updated. You have the right trained personnel on there.
Is there an updated plan? Are these plans constantly updated yearly, biannually, every 5 years? You got to make sure that everything is up to date.
Safety of people's environment is almost as big, or even potentially bigger, than talking about your emergency response. Documenting incidents, there's a lot of cases where each EH & S personnel has to document cases that have to be filed with OSHA and have to have major incidents, root cause analysis, theories and thoughts and actually dating the investigation behind it to make sure that it won't happen again. Being preventative in the future, I am making sure that the employee is okay moving forward.
You have your permits. All the little pieces of paper that say you can do what you said you're going to do. Are they up to date? Are they accurate? Do they need revising? It just goes anywhere all the way up in the air to down below in the water, to the wastes going out the door to the chemicals coming in the door.
And speaking of chemicals in the door, the inventories. Per OSHA, in a hazard communication and compliance standard, is it active? Do you have an active inventory that you store chemicals and you have your medication, if you're at hospital location? All that kind of stuff need to be inventory. Is it active? Is it not active?
Is it in an excel sheet from back when Excel was first written back in the 80s? Is it on a piece of scratch paper just in the back closet saying inventory? Here it is and it hasn't been done in over 20 years. Stop to think about.
And then also a small portion of it but it's a big portion when you really dive into it is waste. Your municipal trash, your recyclables, your chemicals, your biologicals, so on and so forth. There are always different programs. There are always different regulations guarding it. So who's doing it? How you're training them? And what's actually going on?
Some of the common compliance gaps that we see out of it is that with your emergency response and contingency planning is the training and the correct equipment all up to date.
Training has been a huge thing that we're run into where employees run out of date with their training whether it's every year, every other year, every 3 years, people and their names on this list need to be trained and know what to do. We've seen a lot of cases where there's a lot of acting, a lot of preparation, a lot of, “Hey we're going to run drills. We're going to make sure everybody knows what's going on.” These are required for certain commissions.
I know for instance like in the joint commission, they require a lot of drill running and making sure that things are up and running accurate between fire alarms. Who's doing what? How to evacuate buildings? And this applies to almost any industry out there. Fire is one of the biggest root causes of having issues within your facilities and how safe you are.
And then also with the safety and people's environments, can you look to prevent something before it happens? We've seen a lot of cases that when there’s an incident, a chemical spill per se, that happens in a lab. You can think of anything that happened way out in UCLA where there’s an explosion. Recently they've been some other bio tech research explosions where they've been working through chemicals and it just explodes and there's an issue.
So how your SOPs are updated? What chemicals are you using? And what are the hazards you're putting your employees at risk of actually doing?
And not only thinking of the employees, what about the public? A lot of institutions and sites out there you have public interaction. Everybody thinks that hospitals are the only ones but it's not. Between bio techs and universities and industrial manufacturers, public can get in and out pretty easily sometimes. How's your safety and security? Little things like that, to definitely start thinking of.
Permits, is there a renewing schedule? Did the process change? Did you have – one of the most common problems is either mercury or high organics in your waste water. Did the process change where you tested and found something out and found some high levels of mercury and something has to change or you're going to get cited for it?
Or these permits are out of date. You're producing more, another building went up, all these things that go into it as well.
Your inventory, like I've mentioned before does it exist in a piece of paper or it's something really up to date? There are some really a lot of good programs out there. We just recently did inventory webinar where it goes over some of the most common inventory programs that are out there to help you meet the standard and meet the challenge of collecting this inventory through your site.
And then also, your waste. Did the process change? Are there more sustainability and recycling going? Are you trying to recycle paper more often and cardboards and plastics in one way? And are you training the people well enough to do it?
Anybody have an instant where potentially the wrong waste stream ends up in the wrong end disposal? For instance, a lot of cases where either biologicals or radiation ends up in the regular trash, not always on purpose but by an untrained employee. Someone mis-throwing into a trash receptacle, unfortunately, ending up in the wrong place.
A lot of different cases end up where it ends up in a trash compactor, goes up to a transfer station and then actually gets caught there and then brought back and you can handle it moving forward. So a lot of cases it gets handled and caught before it actually happen but still it's something to be wary of.
A tip that I'd like to give a lot of people is actually look at your documents that you need. Don't assume they exist because you think or were told. If you walk into a new program and they say here's the binder. Here's all the stuff you need. Here’s the inventory.
If you just go based of that inventory or the table of contents and not actually look through all your documents, you might have some trouble when the state inspector actually walks in.
We all know that when we assume, we make an ass out of you and me. You don't want to do it. I don't want to do it. Look at them. Make sure they're accurate. Make sure if you're missing something, inquire about it.
A lot of times we see missing documents that were misplaced, were partially damaged, and were just completely out of date. They were put in there way back in the early 2000s, late 90s. And suddenly it’s like, “Hey it's 2015, you might want to update your discharge permit for your waste water going through facility right now. This is something that needs to be updated pretty often. Let's get talking about that.” So, definitely look at it.
Some other issues that we've seen that I like to talk about a lot is, are you reactive or proactive? Are you someone who always constantly is reacting to a situation? You're not ahead of the game. You are not thinking about if I introduce these chemicals or introduce this process, it will be alright. Ultimately, you want to think that through before you even say yes to the entire process.
I know a lot of institutions that go through a really big review from step 1 to step 300 of the different process it goes through and get many many different people involved. It doesn't mean you need to have every person sitting around the table. That could be 20, 30, 100 people sitting around the table and actually talking about it at once. But making sure you vet it out and make sure you vet out the process to the right people and who it's going to affect.
Do you work as a team or are you the white knight? We've seen a lot of cases where the white knight, "Hey, I'm running the program. I know what's going on. Quiz me. I'll tell you what's going on." And I've been delightfully surprised with a lot of answers in the great conversation that we can have about brand new updated reg. “This is how I'm applying it. What do you think?”
That is actually a great way to start the conversation. Whether that man or that woman is leading the charge in what's going on in their institution or in their site and feeling very comfortable about it. It's wonderful.
And the team aspect might be from 1, 2, 3. I've seen operates of 20, 25 different people on a team doing a lot of different things to help each other out and really improve the program which is wonderful.
When you first got there, were you given sinking ship or were you given this aircraft carrier? Were you given this ultimate site that everything is perfect, everything is good, and you were wondering what to do next?
That's exciting. That's the stuff you’re like, “Oh, I can be innovative. I can do this. I can do that.” Awesome.
However, when you first show up it's like, “I don't have disposal documents from the past 10 years.” Did they do anything? Did my biologicals go out with my biologicals? Did my chemical waste go out where it's supposed to go at chemical waste? Is there a back hole in the backyard somewhere where everybody just knows they just throw stuff? This is stuff that is scary but true and it's up to you to make that change, make it turn into something so much better. And there are a lot of places that we can help as well.
And then ultimately, who do you call? Really, everybody thinks, who do you call? Let’s call the Ghost Busters. Honestly, that's what it is.
However, in this case, you want to call the environmental guys, consultancies, people that you know that can refer you to a bigger programs or something else that can help you work with your program and really make it better. You can do a lot in your own and that's why you got the job and that's why everything is going in there and that's wonderful. But taking it to the next step is definitely the hardest thing you can do. However, it's something that can get you promoted really easily, impress your boss, and really help out the environment as a whole and the institution.
Speaking of people who to call and what's going and what resources you have, let's talk about the money, the budget situation. It does really cost money to be in compliance but it really doesn't have to break the bank. There are a lot of cases out there where you can get a little bit of consulting, a little bit of resourcing in there for a lower dollar amount and really suffice your needs for what you're looking at.
You don't need the entire 5, 10 person crew to come in overhaul your site when you're looking at small biotech or you're looking at a smaller university, community college of some sort. And you're looking at and going, “I don't need $20,000-30,000 worth of work. I only need a little bit of work to help me going and figure out what's going on out there.” So ultimately, it's really finding what you need at that right point in time.
Don’t over hire. Don't over commit. Don't go all in. See what you can get for a little freebies. See what you can get for a little bit here and there just to help you with what you need.
Is it just a permit? Is it simply just, “Hey help me out. I don't know what I can do with it? Can I send it off site? Should I accept this drug, this chemical coming in to the actual institution? What's going on?”
Safety of people's environment is probably one of the things that everybody looks at because the time and effort to assess all potentially dangerous environments takes time and takes money. A lot of times when the "normal process" comes true, you're not as worried about. They've been tried, tested, trued up for a very long time which is great. The exposure is low. People know what they're dealing. They understand it.
But potentially, when you walk in and say, “Hey I want to use this [00:26:20] which is made up of sodium hydroxide or an acid and a mixture of a lot of different things.” You really start wondering, “What's going to happen or you're going to heat it up. Let's think about this for a minute. Let's take a step back and make sure that you know what's going on.”
And for those safety portions, you got to have those safety talks. You got to think about it because the cost of putting a person in the a hospital or somewhere is going to be monumentally worse than actually just having a very small incident or even preventing that incident completely and spending some money upfront to make sure that you're doing the proper safety protocol, air monitor, equipment change out, the right engineering controls, the right PPE controls when you can’t engineer it out and moving forward and so on and so forth.
Fume hoods are constantly looked at for the safety of people's environment and research labs and clinical spaces and many, many different areas that you use any type of chemicals in any type of process. Fume hoods need to be inspected. They need to be brought in to compliance almost at yearly rate sometimes. And depending on the process, they might work very, very well or the people who are using them are using them improperly and they’re not actually doing their job and they're actually going to have bare issue.
Reviewing, walking around, talking to people, understanding what they're doing and how they're doing it in a more hazardous situations are something that’s going to save you money over the time with the decrease amount of lost time or anything like that you're looking at.
Compliance and permits, yes, time and effort equals money. Or, does it equal a lot of money? It depends on how educated and how resourceful you are on the permits work and what's going on. I have a lot of people that understand the clean air act completely and that's wonderful. I've met some people that school me in the Clean Air Act all the time.
And I'm like, wow, you knew that a little bit more than I did or a lot more than I did. Alright, I can help with this, I can help with this but it's not going to be that much so it's definitely good to just do a little outside checking on what's going on.
Between your knowledge and experience, it's huge. Knowledge and experience comes in many different forms, in many different aspects where you're going through and actually understanding what's going on. Ask your friends. Ask other people that are in similar roles, network a little bit. Definitely, know what's going on.
And if you're in a hospital situation or in a community hospital, workforce or larger research community and the city and the suburbs that are just bigger places that you can actually work with and gain experience, great stuff to do.
If you're at a university, I can think of the research triangle mostly because the NCAA tournaments are on it right now. I know most people would really want to get home and watch that today. But thinking of research triangle, you have three humongous schools down at North Carolina between Duke, NC State and UNC that I am sure there's a lot of talk going on between each one of those schools talking about, “Hey what about this plan, what about this, what about this?” And actually come together and communicating with each other and knowing what's going on. But if that doesn't happen as often there's always an outside source to go through and know what's going on.
Proving by experience and knowledge and by fellow experience will help you get smaller numbers pass through the budget.
Taking on a humongous task like bringing in a brand new process, a brand new principal investigator, a research project that could possibly cause some high hazard situations and really hit the budget big time.
Talk to other people, there's so many things out there between research and actually doing the work that you can lower the numbers and understand that. Your budget doesn't have to get full force hit on this and you can understand what's going on.
And ultimately, lastly with this one understands of your site. Know where everything is. Take a walk around. Know where high hazards are. Know where the low hazards are.
Know where the public is and so on and so forth. It can definitely save you a lot of time in the long run understanding what you can and can't do to help.
Cost of inventory waste in compliance. Simple as that is inventory can cost money to complete, definitely does. But you're meeting OSHA standard. You're meeting HAZ COM, you know what's going on. And if you keep it up to date, it will cost less over time. There are a lot of programs out there that are used – a lot of times that we see in biotech industry that controls how much chemicals are actually coming into a facility.
They can rash them out. They can buy them bough quantities and store in other places and create less hazards up in the lab and create less hazards for the environment of the people up in the lab and helps save money over time because all these coming from one spot. People can share. People can work together. A lot of different concepts of inventory that can go really sky high.
Also, think about what comes in, must go out. So as you're doing an inventory, you got to understand that ultimately, when everything comes in, you got to report everything going out.
For example, I mentioned the HAP report which goes into the hazardous air pollutant and you need to understand who needs to submit this and why they submit. Within the documents that we're going to send out after this webinar, we're going to include some websites that are definitely really good at understanding what happens, what you got to do, what you don't have to do. Some people just don't have to actually fill out these reports but they go the extra mile and do it.
Sometimes it looks good; sometimes the inspector is just like, “It's good.” It doesn't matter that much. You got to be careful. But ultimately, the cost of the inventory outweighs the effects of an issue.
We had a recent incident over two summers ago where we had not only an ETO spill, ethylene oxide, but it is only on an area where there are a lot of other chemicals and a lot of people that could be in. Ultimately, it turned out to be not that much ETO spill but the ETO still set an alarm off. Everybody was still evacuated. The fire department showed up. The news crew showed up and everybody showed up to see what was going on.
And then, as we were standing outside, looking in, debating, “Alright, this is what we're going to do. This is the plan of attack. We know what we're going to do. We know what we’re going to do for the spill response. We got it. We’re going to send these people in,” and so on and so forth.
You suddenly see a person walking in the hallway right near the actual spill and they're not affected by it but the fire department suddenly was like, "Safety and security, can you get that person out of there?”
Just one of those things that there was some bad communication, a little more coordination would definitely work and help out but it also goes back to also knowing the inventory of what’s in there. They said, “Hey! Do you also know what’s in there?"
And with a couple clicks of a button boom! Boom! Boom! Hey! They did know what other chemicals are in there. They know what they're going to put their guys into and know, “Hey! It’s not that actually bad it’s in this hood. All these other chemicals are underneath. There's no reactions but this is also there so be careful of the [00:34:21] that's sitting below it. Watch out for this watch out for that.” It definitely helps out saves money and saves time in the long run.
Other cost factors that we really like to look out at and understand is the size, the size of your institution and/or sites or just one small site coming to affect big time.
When you’re looking at small community based college or hospital or small start-up bio tech, you're looking at smaller cost at running these institutions and running everything that you need. A place with only a thousand employees or even a 500 employees is much different than running a place and understanding a place that has over 10,000 different employees running around and causing issues as they always do. We all know this.
But what is in place already what is has been already done? And then what do you really need to know more about? There are some things that everybody feels confident. Like I was talking about before with the clean air act permit or waste water discharge, what are you really comfortable with public safety and understanding, “Hey! I have a little bit of an impact here. I know we have a security guard here we have this we have that.”
But how confident are you knowing that they know their job you know your job and also knowing how to run it through out there. And then, also how often do you actually scratch your head and wonder what if? What if this person walks over here talks to…? My researcher can walk right to a lab and they are in general public and walking and talk, takes something and walk out?
It’s definitely a question mark. It's something that we're not all really familiar with but you got to be careful that’s why you walk around and talk figure it out what’s going on and ultimately save a lot of money in your program.
Here are some great examples of cost savings when you have a really strong program. These are directly pulled off the USA EPA website. There are many different areas where environmental compliance is not being met and they found it and they're fining it and they're cleaning up and figure it out what’s going on out there.
The last one a fine, $205,000 for hazardous waste violations. You got to think of what your vulnerabilities so something like this doesn't walk in. For a multi-billion dollar conglomerate, $205,000 might not be that much. They understand that. However, it shouldn't matter. It shouldn't matter what the fine is. It shouldn't matter what’s going on. You just don’t want to be in the newspaper for actually doing this as well.
In this case, a little bit of background in this story that they ended up with the newspaper. They ended up losing some profits and losing some costumers over because they're not following proper practices. It took a while to actually recover from it as well.
So let’s go through some immediate tactics to help solve some of these problems. A couple of case studies we'd like to go through. Simple conversation started with the very large biotech company. Who are you? What are you doing? What kind of research are you doing? Are you doing cancer research? Are you doing specialized disease research? Are you doing animal research? What’s going on?
So when you get through all that you go, “Alright so you're doing animal research, you're doing a little clinical research and you're doing some drug [00:37:53]. You're doing some cool things with drugs that are what biotechs do. They come up with some really great drugs for all of us.
And so what are you doing with all your waste? Very common question that we ask and they kind of scratch their heads a little bit and say, "Well, we got the bottles set up. Nothing goes down the drain. That's not supposed to go out on the drain and yes, we're good. We’re good. Trash goes out of trash. We're all set.”
Alright so do you have satellite accumulation areas? Do you have storage area, central accumulation area, a main accumulation area? Do you have any of these? And they're like, "I don't even know what you're talking about.”
So some of these outcomes came from this is that they set up a satellite accumulation area program and knew what's going on. They set up storage areas to store their wastes and send it off properly. Signs and labels, everything in storage up to date, knew what was going on. “Hey here's the rag, you got to comply with. Let's move forward.”
And then ultimately, the design safety procedures for moving and handling waste around the entire place. This place is over 50 acres of land that gorgeous. And you couldn’t tell that something like this is happening but it's set up in a very nice area. You want to keep that nice area. And you don't want to be kicked out so all these procedures and SOPs were definitely set up in place that helped out.
So, some quick and easy improvements. Implement regular site walk. Walk around your site. Know what's going on. Understand what's going on.
Definitely good thing to smile and talk to people. Understand the processes people are actually complaining and doing. You don't need to understand the minute details of the R & A synthesis or synthetic gene growth. But, understand how they're putting themselves in a hazard or are they not.
Look for some unmarked containers. Look in the trash receptacles. See if they're putting the right stuff in the right areas. Look at the outside grounds. Is there something coming out of the building or around the building that you're kind of like, "What's that color and what is it doing that? Let's talk about it.”
And then the public interaction. Like I've mentioned before, universities and hospitals see this all the time. Public is in and out. Students in and out all the time. How's your safety and security?
Bio techs, a little more locked up but every once in a while you find some waste slip right in, passed security and you got to make sure everything's buttoned up really, really good.
Continue to review an update. Your permits and plans are huge. Everything from emergency procedures, standard operating procedures around everything, your discharge permits, your plans, these are important things to look at. Understand your safety protocols. Make sure that you are advising the people on the right direction but also putting people in a safe environment as well.
Agencies, everybody take a look at these. These are some of them. These are just the EPA, OSHA, "Oh I've heard of those. I get it yes."
How about the Water Resource Authority? There's one in Massachusetts that's really strict on a lot of things. And many other cases and many other states, you might not see that as often. However the closer I can tell, the closer you get to see these, the more pertinent these types of authorities actually are.
Classic example of state agency is Pennsylvania Department of Environment Protection. Get to know them. Get to know how they do, what they're working on. Are you more stringent here? You’re less stringent here? How can I help save some money, stay in compliance and also continue on and make sure my institution is good?
Another case study, you get an unexpected call from your local state agency, your local DEP, your local waste water commission. They're coming in to inspect tomorrow and want to review the previous inspection.
Well, let's go check everything. Let's go make sure everything is good. Let's go look at main accumulation area, central accumulation area, SAA, paperwork, your permits, your air permits, your generators. The list goes on and on.
The fact is with this scenario, before I go in to some actual conclusions that came out of this, is that you knew they were coming. Being prepared, knowing what's going on, knowing what you have in your share drives where it needs to be is huge in understanding that.
Some of the outcomes, there's a chance to follow up over what was going on. In this case, we had small generator that inquire for some help that the local authority came in and said, "Hey, you went over your generator status with three months in a row. Can you tell me what's going on? What happened? Did you file a report? I don't see a report on my records,” so on and so forth.
One of the direct outcomes is that they came back a week later and they noticed, "Hey, you guys did everything. You guys followed the report. You guys followed up here in front of us. You’re showing us what's going on. You disposed of it properly. You did everything.” Constructive feedback is make sure you send a report and you get a confirmation that it was received, something small like that.
You updated your documents, some SAA issues, very, very common of what's going on. But over all you buttoned up and cleaned up universal waste area and you schedule where to follow up the missing discharge on your report and say, "Hey we had these reports that are missing.” Not a good thing but you followed up you know how you're going to prove it in the future. You put SOP in place. We're happy with it. Good outcomes.
Another one, when you have people on-site, extra resources out there that actually really help you out, keep you up to date with your program and you can feel confident about the inspection. There's still that initial shock “Oh, you’re here. What's going on?" Focus on what needs to be done. However, when you pass that inspection and you changed from years past, that's where the huge, huge portion of the program really is.
When we ran through, a personal connection is we got to call when many years ago, when it was a Thursday afternoon and I remember this because it was a Thursday afternoon at 1 o'clock, "Hey you know the local authorities here."
And I go, “Come on. You’re joking with me. No way. It's Thursday afternoon, we all know that it's late in the week. Everybody comes in the beginning of the week. You're joking with me. Get married this weekend. Leave me alone.”
But it was true. They showed up from site and we freaked out for a second, went out to all the places and then ultimately passed the inspection. We knew who the local representative was. We could actually have a good conversation with them. They were just as hard as not knowing them but it was better.
There was more integral process of knowing them and knowing what the previous inspection entailed and fixed. You get the chance to impress that person. Impressing state agencies and inspectors is huge. It helps out with not only future visits but with what's going on right now.
And then also, the follow ups and the follow up items. He definitely found some little errors, fixing some SAAs, adjusting some storage arrangements and make sure you communicate the hazards a little better. Signs, extra labels, extra that, huge. And then, making a plan to fix the generator because there's an emission issue, all these things that came through.
Ultimately, be honest with yourself. Know what's going on, understand, look at it. Don't put it on the rug. Understand, be honest.
Overall, documentation. Make sure you have it.
Training, make sure you train you and your people and you know it well. Is your workload too high? Do you need something else? Do you need a resource once in a while, all the time? Can you hire somebody? Can you not? What it is there and going on?
And then, your knowledge behind it. Understand that you're not going to know everything. I'm not going to know everything. No one's going to know everything but knowing where to get it, reference the book or the internet, proper internet sources, and going from there is huge, definitely helps.
Overall, we went through looking at some of the gaps, the budget, and also some of the immediate tactics you can actually go around and actually do. Remember, walking around your site and asking questions is the first thing that you should always do and inquire. Talk to people. Make sure that they're on your side and that they get buy ends so when you have to fix something, everybody is really happy about it.
Moving forward, observe. Make those changes, some immediate issues that can help improve your program. Do it now. Look at the documentation. Look at what's going on.
Look at the compliance. Look at past records. Understand everything about your site. And if it's too much, take a step back ask for some extra resource.
Secondly, take the survey. We're going to have a survey posted after this in one of the documentation that is going to be sent out. You answer about 10 questions and it helps you diagnose what a problem could be even if you think your program is really, really good which is awesome. Extra supplemental support can always help it just a little bit more.
Reach out for more resources when you hit a road block. We mentioned before that everybody is really like maybe one or two times a month, if not every other month where people are looking for resources. Just to understand who to call, know what to do or at least get a reference from something and go there and actually use it which is great.
Do you need some sort of customized onsite support program? You got to throw it all out there, just something in my boss, I had to throw in there.
This is what Triumvirate can do for you. And I'm trying really hard to just give you a little overview. There's going to be some follow ups on what's going on.
However, when you have supplemental support with fully integrated on site programs, you can really dig deeper. You can really integrate different people, different opportunities into your program to make it better, make you look better.
Understand what's efficient, what we can do and what you can do to be more innovative and look at things that are not just black and white but look at that process and say, "Hey, I can save some money. It's more efficient and it's in compliance.” “That's awesome, let's do that."
What makes our people unique and top notch? We hire the right people, we know what's going on and we put them on site. They're young. They can lift. They can move stuff. It's great and they think of all new ideas because of their schooling behind this as well.
And then also, why we make the biggest difference as a partner here in your compliance world? Because we want to help. It's not we're out there just to gain a buck. We want to help. We want to see you succeed, put you on the upper level, and see you pushed towards the next level and also use us as a resource whenever possible.
Sorry if that's too much of a little bit of a plug but it's one of my bosses require me you got to throw it in there. You got to just try and throw that. It’s a Triumvirate webinar, just got to throw a little bit in there. We're going to have some follow-up to that as well.
Thank you very much. I appreciate it and on you Sasha.
Sasha: Great alright. I'm going to open this up to any questions you guys have about your EH & S programs gaps and things like that. Again, you can ask question in the questions pane so just type it in and I will ask it to Mike.
Alright, so first question, someone wants to know how you suggest addressing getting management buy in for investing and sustainability programs.
Mike: A lot of the times when you're addressing sustainability or management, getting them to actually say ‘yes’ is showing them a return on investments. A lot of cases we get people come in, potential clients come in and say, "Hey, I want to improve my program. However, I know it's going to cost so much money but I need help dealing it."
Well, lay out your objectives. Lay out, "Hey, I'm looking to become completely sustainable with all my waste going out the door."
“Awesome, let's see what we can do. We can go here. We can go to many different disposals. We can offer these types of cost here, here and here.” No cookie cutter will fit.
So therefore, looking at a return on investment, finding out what your objectives are, what can happen and what you can save in the end is going to be huge. And having that safety component in there is going to be even better because over a long period of time, less people get hurt, there's less ergonomic issues, all that. You're going to get the buy in from your management that it’s a good thing to do.
It's going to help you. It's going to help the people around you and help the environment around you by being sustainable as well.
Sasha: Next question, someone says the main issue in their organization is cultural. How do you convince people that safety and other priorities like that are important?
Mike: Changing the culture is probably the hardest thing that you have to do. And what we found is that in some places, there are very integrated environmental, health and safety programs that will go above and beyond for their people and they get along extremely well. When you see that, it's easier to start implementing little changes at a time.
Ultimately step one, implement small changes at first. Have some really good areas that like you and like them cast these little changes. Then have them help you promote a new culture for changing what's going on.
Two, don't bite off too much of the apple right away. If you try to take a bite of the whole thing, it's probably going to fail because culture dictates what's going on around there.
Many examples include where you're ordering your chemicals from to where you're throwing your trash to, "Hey, can you help me out by just putting your chemicals away out at night?” And teaching your research people what to do and getting them to actually do it.
It's hard in some cases. I'm not going to lie because as a system, culturally they want to do it their way. But it's how nice you are and how integrated you can be and how much you can show them that it's a benefits of your program and benefiting what they're going to do, they're going to buy in off at it as well.
Sasha: Someone wants to know how to know when it's time to make a hire from a contractor or when to make a full time hire.
Mike: It all depends on what you ultimately want to do. I'll give you two scenarios. One scenario, you start off by hiring a contractor because you need help in a very small way. You want help on your permitting. You hire specialized persons to come in. They help you with the permitting. Say, once or twice a month help you supplement what's going on.
Then, you find out that there are some routines or some other things that are outside the permitting that you need help with. Well, bring them in for a little bit more time. Maybe it's twice a week now and then you start adding it up. Depending on what you want to do, you can keep bulking it up, keep adding it up, adding more people, adding more time which is good.
However, you're looking at a cost prohibitive center more or less. So, depending on your budget, depending on when you want to make that switch, example number two is that, we are actually working with a pretty large institution and we had a person on-site five days a week, 40 hours a week. And it's not cheap for that kind of stuff, it really isn't.
But, there came a point where it's just they're here all the time, they know what's going on. They're updated with everything. They really have a good relationship with you. Can we potentially hire this person and really work with them to move forward and go on with what we need to do?
And in that case, that company actually hired our employee on after a little bit of talking, negotiating, figuring all that out obviously but there's a switch. There's definitely a switch when you feel that the cost doesn't outweigh the benefit at that point and then you can internalize all that. And not necessarily hire that person per se but work with them to find the right person to get in there.
And it's funny because a lot of times that when you decide to make that switch, decide that your workload dictate a full time hire or full time FTE, full time employee, it usually cost thing. And you look at the cost, you figure out the people and a lot of times it's ex contractor that really wants the job more consistent and here I go, I'll work here, this is great. And then you get experience, you get the connection; you get to build the faith from there as well.
Sasha: I actually think that's it for questions. So, unless anybody has other questions, I think we're going to close out the webinar. Mike, if you want to switch to the next slide.
Alright, so I just want to thank everybody for attending the webinar. We will send everyone an email with the copy of the presentation along with the recording later today.
The email also has a link to a survey asking you to rate this webinar so everybody could fill that out, that would be great. And in the upcoming week, you'll also receive an offer for an initial assessment for a gap analysis at your organization. Feel free to fill out the form for that and we'll do that for you.
If you are interested in attending any of our future webinar, you can go to www.triumvirate.com/training/events. I will also send you a link to that in the email so no need to write that down as well as the answers to the Q & As today. Alright, thanks everybody for coming. Bye!