Compliance

Auditing & compliance assurance

“Auditing results can be presented, managed and analyzed using JECSI’s web-based [Cloud]® EHS platform.”

JECSI offers a comprehensive array of services designed to help companies in the United States and Canada evaluate and implement regulatory compliance requirements at the local, state, national, and regional levels. Compliance assistance can come in the form of periodic compliance evaluations, day-to-day onsite compliance services, wide-breadth external auditing, and environmental management assistance. We help a wide range of industrial clients from the permitting process through ongoing facility operations and their impact on the environment, assistance with enforcement actions and other matters that may require regulatory responses.

We can address any or all of the following compliance categories: air emissions; water quality, wastewater, and stormwater; solid, hazardous, and radioactive material and waste; hazardous material; and occupational safety and health requirements.
Auditing results can be presented, managed and analyzed using JECSI’s web-based [Cloud]® EHS platform.

Our professionals understand not only the specific requirements of applicable regulations, but perhaps more importantly, the intent behind them and the real-world implementation by regulatory agencies.

 

Chemical and emission reporting

“We bring the experience of assisting more than 1,000 industrial facilities with chemical reporting services.”

JECSI compiles and reports inventory and release information under a number of local, regional, state or federal programs. Our expertise in knowing what to report and extensive background in emission estimation techniques from industrial sources helps clients ensure that their reports are accurate.

Public agencies and environmental groups often search unrelated emission reporting data to bring lawsuits or enforcement action for regulatory programs like the Form R Toxic Chemical Release Inventory or Proposition 65 warnings. During the process of preparing a chemical report, JECSI brings its knowledge of other regulatory programs and trigger points to ensure that a client does not unwittingly trigger additional compliance requirements and to help the client identify opportunities for emission reductions or product substitutions.

For example, under the Form R and NPRI requirements there are over 500 reportable chemicals and chemical categories. Common reportable chemicals include lead, antimony, ethyl benzene, toluene, xylene, polycyclic aromatic hydrocarbons, chromium and chromium compounds, nickel and nickel compounds, copper and copper compounds, zinc compounds, nitric acid, and nitrate compounds.

The Toxics Release Inventory is a publicly available EPA database that contains information on toxic chemical releases and other waste management activities reported annually by certain covered industry groups as well as federal facilities. This inventory was established under the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA) and expanded by the Pollution Prevention Act of 1990.

For multi-facility corporate clients, JECSI coordinates reporting with each facility contact and the corporate contact as well as synchronizes emission factors and emission estimation methods used at each facility. We bring the experience of assisting more than 1,000 industrial facilities with chemical reporting services.

  • Form R Toxic Chemical Release Inventory
  • Greenhouse gas reporting (California AB32)
  • National Pollutant Release Inventory (Canada)
  • Air district emission reports
  • Consumer product emission reports
  • NESHAP/MACT reporting
  • Tier I/II hazardous material reporting
  • EPCRA Self-Auditing/Self-Disclosure
  • TSCA reporting
 

EHS training

“On-site training courses presented by JECSI have been an industry standard for industrial and manufacturing professionals for nearly 20 years.”

Federal and state environmental and environmental health regulations contain many requirements for employee training. Failure to provide adequate training to employees results in thousands of dollars in fines and penalties each year. Training programs offered by JECSI are designed to meet regulatory requirements and to enhance compliance. Combining job-site specific training with web-based training programs provides employers with a cost effective and efficient method to comply with training requirements.

On-site training courses presented by JECSI have been an industry standard for industrial and manufacturing professionals for nearly 20 years. Our staff will work with you to identify applicable training requirements for compliance and develop and implement a customized training program. Training sessions can either be provided in the workplace or a web-based training program may better suit your needs. Web-based training is available in both English and Spanish.

Flexible scheduling is critical to minimizing interruptions to production. Our instructors will travel to your facility or the location of your choice to deliver the required training. Class sizes and the number of sessions can be adjusted to reduce production down-time. Monthly, quarterly, or annual training sessions may be presented in English, Spanish, or a combination of both and at the times and dates that are convenient for the workforce.

Additionally, EHS training be presented, managed and analyzed using JECSI’s web-based [Cloud]® EHS platform.

 

Environmental management

“We act as indispensable advisors to corporate business managers and environmental managers…”

JECSI has a long history of providing environmental, health and safety management solutions for clients in many different industries. Our services include developing and writing environmental and health & safety standard operating procedures that provide the backbone of an integrated management program, training environmental and support staff, and auditing and evaluating compliance on an ongoing basis.

Within this practice area, JECSI assists clients with creating and managing ISO 14001 programs and other corporate management approaches. We act as indispensable advisors to corporate business managers and environmental managers as well as factory level employees to ensure that the programs we help establish are organized, directed, and carried out. We integrate the consulting and procedure-writing, onsite auditing and compliance assurance with our renowned [Cloud]® EHS web-based portal that gathers, organizes and delivers EHS data and information.

  • Environmental master plans
  • ISO 14001 procedures and policy development
  • RIOS environmental standard consulting
  • Work instruction and procedure development
  • Compliance plan preparation
  • Environmental training
  • [Cloud]® EHS web-based portals
 

EPCRA/Form R reporting

“Our results are accurate, precise, and take into account information being reported on other emission reports.”

JECSI completes the EPCRA/Form R reports for more than 500 facilities each year. We provide services to small companies with a single location and to multi-facility enterprises. We offer a turn-key service during which we acquire the raw data from the client, evaluate SDSs, technical data sheets and chemical engineering information, calculate releases and then prepare the reports.

Our results are accurate, precise, and take into account information being reported on other emission reports. Remember, the information provided to USEPA under EPCRA/Form R is made public.

For single facility companies and multi-facility corporate clients, JECSI leverages reported releases across the company or corporation to compare against other companies, competitors and on an intra-company basis.

For multi-facility corporate clients, we coordinates reporting with each facility contact and the corporate contact as well as synchronize emission factors and emission estimation methods used at each facility.

Clients that use our [Cloud]® EHS portal are provided with easy to use on-screen tools allowing users to manipulate data, fields and queries to compare, chart, and trend chemical usage and emissions by chemical, facility, type of release (e.g. stack, fugitive, wastewater, etc.), and over different periods of time.

Form R reports must be filed by 1 July for chemical usage in the prior calendar year. The usage and emissions of more than 400 chemicals and dozens of chemical categories, ensnaring commonly used chemcials and metals. Reporting thresholds are typically 10,000 lbs or 25,000 lbs, though the threshold for lead is 100 lbs. Lead is prevalent in plastics, metals and many raw materials, e.g. calcium carbonate. The Form R requirement is contained in 40 CFR part 372.

 

Hazardous waste facility permits

“With more than 600 active clients throughout the world and more than 100 permitted facilities as part of JECSI’s active client base, there is no wonder that JECSI is an industry leader in hazardous waste facility permitting.”

JECSI’s hazardous waste facility permitting services are extensive, including new facility permits, permit renewals, permit modifications, tiered permitting, Universal Waste handling permits, and generator notices. The overall permitting process can take months and even years if not completed properly. JECSI staff members maintain professional working relationships with the regulators to ensure that the permitting process is managed effectively and efficiently; typically resulting in significant time reductions in the overall permitting process.

Regulations promulgated by USEPA under 40 CFR parts 264 and 270 establish performance and permitting requirements for hazardous waste treatment, storage, and disposal facilities in the United States. In order to obtain a new permit, or to renew an expiring permit, facility owners must submit an application package containing detailed process and engineering information.

Careful consideration must be given to the operational needs of the facility when preparing the permit application package to ensure that permit conditions do not unnecessarily restrict the facility and its operations. A well developed and sophisticated understanding of industrial processes and regulatory requirements that only comes with many years of experience is needed to develop an effective permit application. With more than 600 active clients throughout the world and more than 100 permitted facilities as part of JECSI’s active client base, there is no wonder that JECSI is an industry leader in hazardous waste facility permitting.

  • RCRA Part B facility permits
  • Corrective action investigations
  • California tiered hazardous waste facility permits
  • Canada operational plans and permitting
 

Onsite services

“This service allows a client to fully leverage the JECSI professional as well as the support structure and resources afforded by all of JECSI.”

For nearly 20 years JECSI has provided value-added onsite services to clients in dozens of different industries. The value of having an environmental professional partly or completely staffing the environmental functions at your facility is enormous. This service allows a client to fully leverage the JECSI professional as well as the support structure and resources afforded by all of JECSI.

Our services range from supplying a professional to train or work with facility staff on a short-term basis to outsourcing the entire environmental and health & safety program at a facility or multiple facilities across an enterprise. Depending on the duration and frequency of the onsite support contract, significantly discounted professional rates may apply.

Clients benefit from the credibility and trust that we have earned through many years of successful interactions with regulators at local, state, provincial, regional, and national levels.

  • Periodic site inspections and followup
  • EHS training
  • Part-time EHS staffing
  • Full service outsourcing
 

Permitting

“JECSI’s ability to prepare and streamline the permitting process by approaching projects in a comprehensive manner has proven invaluable…”

New facilities, facility relocations, process and equipment changes, and related activities can trigger a myriad of permitting requirements. JECSI expertise and understanding of air quality, building code/fire code, hazardous material, stormwater, and wastewater permitting requirements throughout the United States and Canada provides for an efficient and effective permitting process.
We specialize in assisting companies with new construction and facilities and offer services to assist each client from the real estate acquisition phase, through planning and engineering, into permitting, and seamlessly into startup
and on-going compliance.
We provide services to many different types of industries and other entities including developers, engineering contractors, legal counsel, and governmental entities. Our services include:

  • New Facility and Facility Expansion
  • Integrated facility acquisition & expansion assessment
  • Environmental feasibility analysis; CEQA air quality analysis; risk assessment
  • Fire code, building code issues and technical analysis
  • Agency liaison
  • Engineering services
  • Multi-media permitting
 

Proposition 65

“JECSI’s Proposition 65 evaluation includes obtaining Material Safety Data Sheets (SDSs), technical data sheets, or similar resources for raw materials used at the facility…”

California’s Safe Drinking Water and Toxic Enforcement Act of 1986 “Proposition 65” protects drinking water sources from chemicals known to cause cancer, birth defects or other reproductive harm, and informs citizens about exposures to such chemicals. Proposition 65 requires the Governor to publish, at least annually, a list of chemicals known to the state to cause cancer or reproductive toxicity.

JECSI’s Proposition 65 evaluation includes obtaining Material Safety Data Sheets (SDSs), technical data sheets, or similar resources for raw materials used at the facility to determine whether the ingredients present in the materials are listed pursuant to Proposition 65. In addition, operations and ancillary processes such as machining operations and natural gas combustion are evaluated to determine whether Proposition 65 listed substances are emitted.

  • Occupational, environmental, and consumer exposure warning evaluations
  • Exposure assessment, air dispersion modeling
  • Health risk assessment
  • Litigation support
  • Public notification
 

Violation self-disclosure process

“JECSI has been successful in completing the self-auditing and self-disclosure process for dozens of facilities — all of which resulted in a 100% reduction of agency penalties.”

A violation of EPCRA for failing to timely file a Form R report carries a penalty of up to $32,500 per chemical per year for up to five years. USEPA created a program in which companies can voluntarily audit and self-disclose the violations. By self-auditing and self-disclosing any violations in a timely manner (following a prescribed format) a company can eliminate the penalty entirely. JECSI has been successful in completing the self-auditing and self-disclosure process for dozens of facilities — all of which resulted in a 100% reduction of agency penalties.

The self-audit and disclosure process follows guidelines contained in the USEPA Audit Policy dated 11 May 2000. The audit involves a detailed review of files, records, and documents at the facility. The report will contain threshold planning quantity calculations of each substance listed pursuant to EPCRA in 40 CFR part 372, as well as a determination for each listed substance whether: (1) a Form R or Form A report was filed for the chemical for the applicable reporting years, (2) the Form R or Form A filed was erroneously filed, and (3) whether the Form R and Form A reports that were actually filed are accurate and correct based on chemical usage information.

JECSI will prepare the necessary Form R reports for the five year period , and will correct (or redact if appropriate) previously filed Form R reports. During preparation of the Form R reports, JECSI will develop emission estimation methods to be used at the facility. JECSI will also coordinate the submission of the necessary Form R reports to USEPA and state agencies.

 

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