NWA fees are typically based upon a time and materials (T&M) basis. Under this approach, an hourly rate is provided and a not to exceed amount is stipulated. The client is only charged for the time and materials used to complete the service. NWA can also bid on a lump sum or firm fixed price, based upon client preferences.
NWA has a core area of expertise. We have established
relationships with other service providers and based upon the scope of work we may supplement our consult team. If the client’s needs are not within our core area or expertise, we will gladly refer you to another firm or provider.
It is best to be proactive and retain a consultant to help identify and address environmental compliance needs before they become a problem. Waiting until you are informed by a regulatory agency that you have a problem can be costly and increase your liability.
No. Legal advice can only be provided by an attorney. NWA can provide regulatory compliance advice and represent your technical interests; however, you need to hire an attorney to protect your legal rights.
This is particularly important if you are involved in actual or potential litigation, administrative or judicial proceedings.
Yes. NWA offers other options to clients based upon their needs. Call us and we can discuss your needs and how we can best
OSHA and EPA have general duty clauses under their respective authorities. These can be used to cite a facility for non-compliance. The OSHA general duty clause requires the employer to maintain a workplace that is free from recognized hazards. The EPA general duty clause, under Section 112r (1)of the Clean Air Act, requires facilities that produce, process, handle or store extremely hazardous substances to be maintained in a manner to prevent releases and to minimize the consequences of accidental releases which do occur.
Non-compliance can usually be caused by a breakdown in the management system. Compliance based management systems can be a good tool but they must be maintained and require a top down management commitment within the organization. Common elements include identification of all legal requirements, management and operational controls, training, inspections, process for managing change, continuous improvement metrics, and corrective actions as necessary. One of the key elements to success is to make EHS compliance everyone's responsibility.
Establish written policies and procedures that are compliance based. Assign responsibilities and train employees on your procedures. Periodically audit to ensure follow through. Establish incentives for performance and a discipline and corrective action plan for non-performance.
The historic model for compliance has been to assign a person or group the sole responsibility to ensure that the facility is in compliance with environmental health and safety (EHS) requirements. The more successful models expand the responsibilities for compliance with environmental health and safety to all employees.
Many facilities are required to maintain emergency response or action plans under various OSHA and EPA programs. Some businesses will rely upon external agencies and others will maintain an onsite emergency response capability. Consider an integrated plan that addresses multiple regulatory requirements. Keep your plan current and up-to-date, particularly if it contains employee names and telephone numbers. Consider incorporating or referencing your plan in facility operating procedures. Periodically conduct exercises and training. Remember that onsite emergency response personnel, if used, must have certain types of specialized training, medical surveillance, and equipment.
04. Determine what your organization needs to comply with the New Hazard Communication Standard.
To meet the new Globally Harmonized System CFR 29 1910.1200 requires:
-A new written Hazard Communication Program
-New Safety Data Sheets
-A list of hazardous chemicals known to be present
-New labeling elements on containers
- Employee training
Review your new Safety Data Sheets, you may need to modify your job hazard assessments and other programs based upon new information.