Environmental Engineering Reference
In-Depth Information
requirements, depending on the size and nature of your operation.
Safety programs that deal with safe forklift driving, material handling,
and first aid procedures, for example, are important. If you are not sure
of your requirements in this area, then you should contact your local
branch of OSHA for guidance.
1.14 reCordKeePing
Personnel employed in the wastewater industry quickly learn about
recordkeeping requirements. For example, wastewater treatment facili-
ties that discharge to state waters must have a discharge permit issued
by the state water control board or other official agency. This permit is
known as the National Pollutant Discharge Elimination System (NPDES)
permit. The NPDES permit has very specific and detailed recordkeeping
requirements, such as recording monitoring information, instrument
calibration and maintenance, reports required by the permit, and data
used to complete the permit application. All records must be kept at
least three years (longer if requested).
Because of the NPDES permit recordkeeping requirements, waste-
water treatment plant operators soon learn that recordkeeping is an
important part of their job. How important is this recordkeeping? The
best way to answer this question is to consider the average routine within
a wastewater treatment plant. You might actually be able to measure the
pulse of the treatment operation by observing the strict attention that
is given to keeping the plant operating log current. Among managers,
operators, and assistants, a normal daily (indeed, hourly) topic of dis-
cussion seems to relate to the plant's need to “make permit” for the
month. In other words, plant personnel are geared to constantly control-
ling the plant process to stay within specific permit guidelines or limits.
An integral and critical part of “making permit” is data recording in the
plant's operating log.
The plant's ongoing effort to “make permit” and the never-ending
recordkeeping requirement bring up another point—that is, if the plant
does as good a job in maintaining its safety and health records as it does
with its permit records, then the plant would be “making permit” on a
big-time scale. Safety and health records? Yes, absolutely. The OSH Act
mandates certain recordkeeping requirements; moreover, the DOT and
EPA also have certain recordkeeping requirements.
Safety and health records are vital for several reasons. First, as pre-
viously stated, they are kept because they are required. Second, without
records, plant management has no way of knowing how the plant is per-
forming. Without safety and health records on accidents and injuries,
management may be unable to remedy hazards and develop prevention
methods. Moreover, without the legally required records on safety and
health, management may find itself subject to civil penalties; for exam-
ple, if plant management fails to maintain employee health records (e.g.,
audiometric test results), then the result may be a liability suit for a for-
mer employee's hearing problem, even years after the alleged exposure
took place.
