Author: Sarah Campbell

The Importance of Working With an Experienced Firm for Your Facility’s Environmental Compliance Audit

Identifying and correcting regulatory noncompliances can prevent harmful releases to the environment and reduce potential violations. They can also be used as tool to minimize risk and identify environmental management priorities. Having an experienced firm on your side to assist with the auditing process is incredibly valuable and can help your organization ensure compliance and avoid costly fines.

What Is an Environmental Compliance Audit?

An environmental compliance audit is a tool used by facility managers to evaluate a facility’s compliance with federal, state, and local environmental regulations. Environmental compliance audits provide organizational leaders and facility managers with necessary information regarding their environmental program’s performance, challenges, and risks.

An environmental compliance audit will typically evaluate, as applicable, the following:

  • Waste streams
  • Business operations
  • Discharges
  • Hazardous and chemical material handling and usage
  • Permitting required compliance
  • Recordkeeping
  • Reporting

The audit is comprised of pre-audit, onsite, and post-audit activities. The pre-audit activities are just as important as the onsite inspection; however, they are often overlooked and undervalued by potential clients. The audit team typically submits a pre-site visit questionnaire that the audited facility completes in advance of the onsite inspection. The PSVQ paints a picture of the environmental activities at the facility that allows the audit team to better prepare for the onsite inspection. Additionally, the audit team will request all environmental records, plans, and permits so they can evaluate them in advance and be well-prepared to ask questions while onsite and be very thorough during the inspection process.

The onsite audit generally involves an inbrief, where the audit team kicks off the audit with facility personnel to explain the audit process and review the agenda for the term of the audit. The audit team will inspect the facility, interview key personnel, and review any remaining records that are only available onsite. The success of the audit depends on the availability of key personnel during the onsite inspection.

The environmental compliance audit will result in a report that an organization or facility can use to inform its decision making to determine what program areas need  improvement. The report typically identifies regulatory compliance status across the scoped regulations, often referred to as “findings” or “noncompliances”. These findings are often assigned a priority rank based on type of noncompliance (i.e., regulatory noncompliance vs. policy noncompliance). In some cases, facilities will also request that auditors note findings that are considered “best management practices”, which are issues that are not yet a noncompliance but eventually could become one. The audit report most often includes corrective actions that can be implemented at the facility to resolve the findings.

The Importance of Working With an Experienced Firm 

Hiring an experienced environmental consulting firm provides the audited organization access to decades of experience and knowledge. The firm has already established an audit process and has resources available to ensure the audit’s success. One of the most important aspects of the audit is identifying corrective actions that provide long term solutions, rather than quick fixes. An experience environmental consulting firm will have auditors on staff who have conducted many audits in all types of facilities. These auditors complete a root-cause analysis on each finding and can identify why the noncompliance occurs, or re-occurs, and can assist the facility with identifying the long term corrective actions.

Finally, a consulting firm can provide compliance assistance, risk evaluation, planning, and support for obtaining the company’s sustainability goals.

When seeking an environmental and safety consulting firm, search no further than Aarcher Consulting. For more than 25 years, we have provided our clients with expert assistance in mitigating their environmental and safety risks while meeting their goals.

Aarcher Consulting only employs the top industry talent, ensuring that every client receives a customized, comprehensive assessment. We have proudly served 5,000+ facilities and companies in virtually every industry, including more than 25 state and federal government agencies and several Fortune 500 companies. Aarcher Consulting’s commitment to excellence sets us apart from the rest, and we provide expert consulting services for commercial, government, and industrial clients nationwide.

Wherever your company is located, Aarcher Consulting will be there to provide trustworthy environmental and safety consulting that ensures the safety of your employees and the environment.


Environmental Compliance Audits and Facilities Management, FMLINK,

How are Environmental Compliance Audits Conducted?, SafetyStratus Research Advisory Group,

How to Properly Dispose of Oil Absorbents

How to Properly Dispose of Oil Absorbents

Oil-soaked absorbent material is a common waste stream in nearly all industrial settings, and proper disposal depends on several factors, including whether it constitutes a hazardous waste, whether it will be recycled or discarded, and in which state you’re located.

Follow these general federal guidelines to dispose of oil absorbents:

1. Prior to disposal of any waste stream, you must determine if it constitutes a hazardous waste. Used absorbents may be a hazardous waste based on the absorbed liquid or other contaminants. Any absorbents that may be contaminated with a hazardous waste MUST be characterized by the generator prior to disposal. Details on the waste characterization process are outlined by EPA. Once you are certain the absorbents only contain used oil, you must then determine if they contain free liquid.

2. If the absorbent contains free liquid oil, it must be handled following the used oil management standards. Free liquids cannot be disposed to a solid waste landfill, unless specifically exempted. To determine whether the free liquids are present, the “paint filter” test (USEPA test method 9095B) is used. This test involves placing 100 ml of the absorbent in a conical paint filter (fine mesh #60 +/- 5%) for 5 minutes. Absorbent materials may need to be cut up or crumbled to fit well in the filter. If any liquid seeps through the filter and drips, free liquids are deemed to be present. Do you need to perform this test for all oil absorbent you generate? No, but you do have to ensure waste sent to the landfill would not fail this test somehow. For absorbents, that often involves a degree of estimation. Absorbents that are dripping or that drip when squeezed by hand, likely will fail the paint filter test.

3. If you intend to reuse the absorbent, you can simply store it for future use or remove oil from the absorbent (for example, wringing or squeezing) before storage. Reusing absorbents when possible is both a cost-saving and pollution prevention measure.

Generally, materials containing or otherwise contaminated with used oil are regulated as used oil. Many states have promulgated regulations for disposing oil absorbents, so you must check your state’s regulations when determining a management strategy for your oil absorbents. In every state, you must first complete a hazardous waste determination on used absorbents; hazardous waste-contaminated absorbents must be handled as hazardous waste.

Following are examples of selected state requirements for non-hazardous used oil absorbents:

Arizona: Landfills will typically not accept used absorbent. Oil-soaked absorbents are managed in the same manner as used oil. Both on-spec and off-spec used oil must be recycled. If not recycled, it is considered hazardous waste. While in storage, you must follow the federal used oil regulations.

California: Oil-soaked absorbents are managed in the same manner as used oil. Used oil is a state-designated hazardous waste, meaning it has a state-only waste code for manifests. Businesses generating used oil are required to meet most of the hazardous waste generator requirements (Health and Safety Code section 25250.11). Containers of used oil must be labeled as both used oil and hazardous waste, as well as have the initial date of accumulation.

New York: Oily absorbents should be treated as hazardous waste unless they are recycled. Store absorbents in separate metal containers with lids, according to the New York State Department of Environmental Conservation Pollution Prevention Unit. Label them “Oily Waste Absorbents Only.”

Pennsylvania: Store oily absorbent in a leak-proof container, ensuring no free-standing liquid is present, and dispose of it as a municipal waste. Absorbents that have any sign of free-flowing oil are managed as used oil. If the absorbent is a rag, recycle it through an approved laundry or vendor service.

Texas: Absorbents that have any sign of free-flowing oil are managed as used oil, according to the Texas Commission on Environmental Quality (TCEQ). When there is no free-flowing oil on absorbents, they aren’t regulated as used oil unless they are burned for energy recovery.

Wisconsin: Oil absorbents can be disposed of in a landfill when waste oil has been drained, so there are no visible signs of free-flowing oil remaining on the absorbent materials, and the oil absorbent materials are non-hazardous waste as defined in 289.01(12), Wis. Stats, according to the Department of Natural Resources (DNR). The DNR’s preferred method for handling absorbents is through recycling or reuse.

Establishing a compliant oil absorbent management strategy will provide clarity for this very common waste stream. Please be sure to check your state regulations and consider contacting your landfill to discuss any special restrictions or procedures.



This post is for information and educational purposes only and does not constitute legal advice. Aarcher, Inc. makes no warranties, expressed or implied, concerning the accuracy, completeness, reliability, or suitability of the date, information, and guidance contained herein, and assumes no liability associated with the use of such data. Any use of this information by a party shall be at their sole risk.

SPCC Training: Who are Oil-handling Personnel?

Your engineer finally delivered the Spill Prevention, Control, and Countermeasure Plan (SPCC Plan) for your facility, and it requires that you train Oil-handling employees. Oil-handling employees? How do you determine which of your employees meet the definition of that term?


EPA’s SPCC regulation (found at 40 CFR 112.7) require that the owner or operator of a facility subject to SPCC regulations train all “oil-handling” personnel (see inset). No deviation from this requirement is allowed, even if your plan is signed by a Professional Engineer. For the purposes of this requirement, who is considered oil-handling personnel?


The term “oil-handling” personnel is not defined in the regulations, but EPA has clarified that the term can be interpreted according to industry standards. Oil-handling personnel include employees involved in the operation and maintenance of oil storage containers or the operation of equipment related to storage containers and emergency response personnel. This applies to both permanent employees and contractors.

Job titles that may be responsible for “oil-handling” include garage foreman, operations and maintenance, and mechanic. Employees with responsibilities that are solely administrative in nature (secretaries, clerks) and those who are not involved in operation or maintenance activities related to oil storage or equipment, oil transfer operations, emergency response, countermeasure functions are not considered oil-handling personnel.


SPCC regulations allow for flexibility on training formats as it results in comprehension and understanding of the SPCC topics. The method of training should be specified in your SPCC Plan. Any format can be used (for example, classroom training or “tailgate” training). The regulations do not require a specific format, time length, or method, only that you get it done and include the following topics:

  • Operation and maintenance of equipment to prevent discharges
  • Discharge procedure protocols
  • Applicable pollution control laws, rules, and regulations
  • General facility operations
  • The contents of the facility SPCC Plan

(Remember, SPCC training is different than stormwater training.)


Oil-handling personnel must initially be trained when hired or assigned, when the facility changes, and when the SPCC Plan is amended. Every year thereafter, conduct annual SPCC briefings for these employees.

Determine which of your employees are oil-handling personnel and provide these employees training on the SPCC Plan.  Provide training to new employees (or when employee duties change) and require that new employees work under the supervision of trained personnel until their training is complete.


It is important to document and maintain records of SPCC training to demonstrate the extent to which training requirements are met should an EPA inspector come to your facility.

While the SPCC regulations do not require oil-handling personnel to be tested on the SPCC plan or SPCC regulations, ensure that they have a good understanding of the SPCC plan. An EPA inspector would more than likely interview oil-handling personnel during an inspection to determine how familiar they are with the SPCC plan and how well they understand it. Should trained oil-handling personnel be unable to answer questions regarding the SPCC plan, the EPA could identify them as not being trained resulting in training violations at the facility.

Sarah Campbell is an environmental compliance specialist supporting environmental programs for land management agencies, Federal facilities, and private commercial companies. She has her hands in many projects, including NEPA planning, Environmental Management Systems, stormwater protection, and landowner liability research. Sarah can be reached at [email protected].


What are the primary differences between a wireless Phase I ESA and a commercial Phase I ESA?

ESA Blog 1As opposed to a commercial ESA where the property footprint consists of a building, series of buildings, a city block, or an undeveloped acreage, a wireless Phase I ESA is typically focused on a specific site location, existing tower compound, or proposed installation path within a building.  The wireless company is concerned not only with the general environmental condition of the underlying property, but specifically with the areas that will be impacted by their planned installation.

How long should a Phase I Environmental Site Assessment (ESA) take?
For the wireless industry, once all of the information needed to define the planned installation is received, the Phase I ESA report should be completed within 2 to 3 weeks.  If additional research is needed due to concerns identified during the evaluation, such as unresolved contamination on the target property or adjoining properties, completion may be delayed.

What information is needed to initiate a wireless Phase I ESA?

  1. What type of installation is planned? Tower colocation, raw land, small cell, DAS, in-building, etc.
  2. Specifically where is the site? Physical address and geographic coordinates.
  3. Site plans or construction drawings detailing the planned installation.
  4. Name and contact information for the person that should be contacted for permission to conduct the site inspection.
  5. Recent title documents including an Environmental Lien and AUL Search.
  6. Completed User Questionnaire.

Sarah Campbell is an environmental compliance specialist supporting environmental programs for land management agencies, Federal facilities, and private commercial companies. She has her hands in many projects, including NEPA planning, Environmental Management Systems, stormwater protection, and landowner liability research. Sarah can be reached at [email protected].