Manufacturing Facilities

Manufacturing facilities face a variety of environmental, safety and business exposures when conducting operations in today’s business environment. The United States Environmental Protection Agency (USEPA) and the Occupational Safety & Health Administration (OSHA) regulations challenge businesses to maintain clean and safe operations. The regulations require businesses to maintain certain engineering controls and mitigation plans to reduce the potential for employee injury and pollution releases. To minimize workplace exposures and pollution risks, facilities should implement best management practices as follows.

Material Storage

• Review storage locations for stormwater exposure and potential contamination sources
• Provide secondary containment for material unloading and aboveground bulk storage areas
• Provide coated containment and floors to minimize concrete degradation from chemical spillage
• Implement a storage tank preventive maintenance program for above and underground storage tanks
• Assess and mitigate the potential for vandalism of equipment and materials stored outdoors
• Provide impact protection for tanks, buildings and associated supports
• Review and assess your compliance with National Fire Protection Association requirements for material storage and fire protection

Production

• Perform a Process Safety Management/Risk Management Program evaluation to identify existing and potential process hazards
• Monitor air quality controls during material use and waste generation
• Track employee training for safety and environmental topics including hazard communication, job safety assessments, equipment use, personal protective equipment and waste minimization

Waste Management

• Use and maintain adequate wastewater treatment and discharge facilities to prevent wastewater discharge exceedances
• Perform proper waste stream identification
• Use designated satellite accumulation locations for waste accumulation
• Train personnel to properly complete shipping manifests
• Use a point person to maintain waste manifest documentation
• Inventory and audit your waste transporters
• Complete a disposal facility inventory and implement an auditing program for hazardous, non-hazardous, special and municipal waste streams

Maintenance

• Perform periodic housekeeping and facility inspections with department managers to evaluate facility pollution controls and safety equipment
• Track repairs to ensure key equipment is maintained
• Provide safety training for maintenance employees on such topics as lockout/tagout, hazard communication, asbestos recognition, and personal protective equipment
• Develop, implement and maintain a contractor training/awareness program

Risk Management

• Assess indoor air quality for office and production areas
• Maintain and test fire extinguishers and fire protection systems
• Assess the presence of asbestos, PCBs, lead-based paint and radon
• Complete a security vulnerability analysis
• Maintain spill contingency plans and conduct emergency response drills
• Maintain and implement stormwater pollution prevention plans
• Conduct material storage area inspections
• Develop, test and maintain business contingency plans
• Assess surrounding property and sensitive receptor exposures to fire and environmental impacts from your facility
• Assess surrounding property for fire and environmental impacts that could affect your facility

Pollution Prevention

• Evaluate material types and uses in operations to possibly substitute a less hazardous product and reduce waste disposal costs
• Review usage rates, cleaning and rinsing techniques/rates to possibly minimize waste
• Evaluate alternatives for waste disposal such as regeneration, recycling or proper reclassification
• Perform spill/leak detection inspections as noted elsewhere on this sheet
• Develop, use and train employees on a pollution prevention program

Facility Expansion/Acquisition

• Review facility history for past operations, material storage and waste disposal activities
• Perform environmental due diligence prior to purchasing a facility or property
• Ensure that construction and environmental contractors have satisfactory safety records and environmental insurance coverages

XL Environmental • Risk Control Division • 520 Eagleview Boulevard, PO Box 636, Exton, PA 19341 • Phone: 800-327-1414 • Fax: 610-458-7285 • xlenvironmental.com

XL Environmental is a division of XL Specialty Insurance Company.