Compliance Programs, EMS & Auditing

Factory Workers Internal AuditThe development of cost effective programs to comply with EHS regulations is a core service provided by Caltha LLP. Caltha also provides expert professional & technical support in developing environmental management systems and safety management systems and in ISO 14001 or OHSAS 18001 registration. Caltha also supports our clients’ liability management programs by providing both systems and compliance auditing services.

Compliance Management Programs

Developing compliance management programs that are easy to implement, document & track is an important service Caltha provides to our clients. This includes integrating compliance management with other risk management, quality improvement and cost control initiatives that our clients may already have. Caltha will train your staff to successfully implement the compliance management programs in the future.

Caltha can also provide “as needed” technical support in preparing annual compliance reports such as air emission inventory reports, permit compliance certifications, toxic release inventory (TRI) reports, hazardous material storage reports required under EPCRA, and other.

Environmental Management System, EMS & ISO 14001

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?)

OSHA Hazard Communication, HazCom Compliance, & MSDS Preparation

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.

Need to create or update a Safety Data Sheet? Contact Caltha at info@www.calthacompany.com or call us to discuss.

OHSAS 18001 Safety Management System – RAB Certified OHSAS 18001 Lead Auditor

Caltha LLP offers the expertise needed to assist clients in developing and implementing a safety management system that meets the requirements set out in OHSAS 18001. This service ranges from helping the client understand the requirements to conform to and self-certify that they meet the requirements all the way to achieving certification by the international body and their registered third-party auditors that their SMS meets the Standard’s rigorous requirements.

Caltha’s full service OHSAS 18001 program includes assistance in developing, implementing, and internally auditing an SMS to assure that all elements of the Standard have been met. This activity also includes providing training packages and the training needed to accomplish the desired goals. This service is provided by people who have developed and implemented single site and multi-site programs that have achieved certification and further, are RAB certified OHSAS 18001 Lead Auditors who have the background to assist with or conduct internal audits.

EPCRA Compliance, Toxic Release Inventory & Hazardous Material Reports

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.

EHS Compliance Auditing & EMS Internal System Audits

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.

Product Registration, Product Stewardship, ROHS & REACH Compliance

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.

TSCA Compliance, Chemical Data Reporting Rule, SNUR

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 2012 CDR reporting requirement?  Give Caltha a call

SPCC Rule, 40 CFR 112 Compliance

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.

Commercial Energy Audits, Industrial Energy Audit, Certified Energy Manager (CEM)

Caltha conducts energy efficiency audits for commercial, institutional and industrial buildings. Audits are conducted by a certified energy manager (CEM). Related services include Heat Loss Imaging Camera (infrared camera) Assessments, Phase 1 Energy Audits, Equipment or Process Focused Audits, Combined Natural Gas/Electric Energy Usage Assessment, Identification of Energy Efficiency Rebate Programs & Tax Incentives, Energy Benchmarking Assessments. In 2013, the new air emission rules for boilers and process heaters (“Boiler MACT”) require energy efficiency audits be conducted for affected emission units; Caltha provides energy assessors meeting the EPA qualification requirements.

 

Example Project Summaries

Caltha posts write-ups on selected projects on our web site. You can view an archive of past project summaries for this service area by clicking on one of the general project categories listed below:

Permitting

Compliance auditing

Compliance reporting

EMS and ISO 14001

EH&S training

EHS staffing

 

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Regulatory Resources

Environmental Regulatory Compliance blog >>

Recent blog topics

Air Emissions, Antidegradation policy, Audit immunity, Audit policy, Audit privilege, ADEQ , AWAIR,  Changes to List of Section 313 chemicals, Chemical Hazard, Chemical Data Reporting, Chemical Security, Commercial energy audit, Compliance assessment, Energy use audit, Environmental compliance audit, Environmental inspection, Compliance calendar, Compliance plan, Demolition wastes, DENR, DHS, EMS manual, Environmental Management System, Environmental procedures, Environmental program, EPCRA, Energy audit, E-waste, Globally Harmonized Standard, Greenhouse Gas , Hazard Communication, Hazardous Material Transportation, Hazardous Materials, Hazardous waste, Heat loss imaging camera, Homeland Security, IDNR, Infared camera assessment, ISO 14001, ISO 14001 equivalency,  IUR, Management System Audit, MDEQ, MDNR, Mercury, MPCA, MSDS, NDDH, NDEQ, NYDEC, OSHA, Product Stewardship, ODEQ, RCRA, REACH , Recycling, RoHS, SARA 313, SDWA, Section 319(g), SPCC threshold, SPCC training requirements, SPCC inspection requirements, Spill reporting, Sustainability,  SVHC list, Tier I, TRI Reporting, TSCA, UST, Water use audit, WEEE, WDNR, Writing MSDS