Benjamin Holden, P.E., undertook a presentation at the Arkansas Environmental Federation Convention entitled Avoid the Deviation: The Art of Compliance (“Presentation”).

Mr. Holden is an Air Services Engineer with GMBc & Associates.

The focus of Mr. Holden’s presentation was Clean Air Act permit deviations. He addressed different types of deviations which included:

  • Unavoidable Deviations
    • Malfunctions
  • Preventable Events and Deviations
    • Deficient Records
    • Inaccurate Permitting
    • Poor Communication
    • Lack of Knowledge of Requirements

The Presentation included a “Case Study” that addressed issues at a facility such as:

  • Inaccurate permitting
  • Deviations during inspections
  • Missed reporting deadlines
  • Deficient recordkeeping
  • Inadequate communication between production and environmental staff
  • Poor relations with regulators

For each of the Case Study “issues” a potential solution was discussed. For example, in addressing “Inaccurate Permit Representation” a suggested solution included:

  • Site Visit/Internal Audit
    • Take notes of all potential sources and stacks (including non-regulated sources)
    • Take pictures
    • Update permit (if needed)
  • Document all sources and non-sources
    • Add physical signs to equipment and/or stacks with permit source number and description
    • Include all information in compliance manual

Potential solutions for the other issues included:

  • Deviations During Inspections – Permit Review/Document facility compliance methodology
  • Missed Reporting Deadlines – Compliance Calendar/Include all routine actionable items
  • Deficient Recording – Tracking Spreadsheets
  • Inadequate Communication - Involve management/Require all product changes go through environmental review/Environmental review of all capital projects/Routine review of projects between corporate and facility environmental staff, etc.
  • Poor Relations with Regulators – Compliance Manual/Keep records accessible

A copy of the slides from Mr. Holden’s presentation can be downloaded here.

A link to the GMBc & Associates website is below.