Environmental, Health, & Safety Regulatory Compliance Services

Regulatory Rulemaking Tracking & Comment Letters

 

Tracking regulatory rulemaking initiatives can be time consuming for both small and large businesses.  AssenTerra can relieve that burden using tracking systems that match the complexity and volume of your issues. Additionally, AssenTerra can prepare rulemaking comment letters that address your business concerns.

Impact Assessment for Regulatory Rulemaking Initiatives

Along with regulatory rulemaking tracking and comment letters, AssenTerra has the ability to assess operational and financial impacts associated with proposed rule language changes.

Strategic Planning for Regulatory Initiatives

When the rulemaking is moving through the final promulgation process, AssenTerra can assist you and your operations team with a strategic plan and schedule for compliance with the new or revised regulation. Having a holistic strategic plan will prepare you for your post-promulgation conversation with regulators and minimize the cost of implementation using a holistic approach.

Auditing Services

 

Conducting internal audits doesn’t have to take internal resource time. AssenTerra has 20 years of experience in preparing facilities for audits, reducing audit deficiencies, and responding to audit findings.

Environmental Permitting – Air, Water, & Waste

With over 11 years of industry experience, AssenTerra is uniquely equipped to assist you with obtaining, renewing, and implementing your permits and compliance management programs including:

  • Minor source air permits
  • Title V air permits
  • Muli-sector general permits
  • NPDES permits
  • Solid waste management permits

Outreach to non-government organizations

 

Outreach and participation with community organizations is an effective tool for communicating your business message and purpose. We can help you maintain your presence and provide community outreach support to these organizations by preparing content for meeting presentations, addressing issues discussed at the meeting, and summarizing key decisions from each meeting.

EHS EMIS Implementation Projects

Many companies are moving toward EMIS database toolsets to collect, store, and report their EHS data. Whether you are embarking on an EMIS implementation or endeavor to change your existing platform, AssenTerra can be your EHS SME.

Recent Projects

  • Led an interdisciplinary (internal/external) team to prepare technical documents with suggested regulatory language changes. Nearly 50% of the proposed changes were incorporated into a State regulation resulting in a 10% reduction in implementation liability for the client.
  • Developed a holistic implementation solution for 17 locations to address compliance with a new regulation that resulted in a projected 30% reduction in liability for the company.
  • Cultivated collaborative partnerships with 10+ regulatory agencies, stakeholders, and NGOs to focus on a science-based approach to new compliance and regulatory initiatives.
  • Identified creative solutions to resolve process gaps realized during an SAP EMIS implementation.  These solutions were used to facilitate standardization across 24 facilities in 3 states and Canada for nearly 375 air, water, and waste permits.

Case Study: Regulatory Rulemaking – Water Initiative in Florida

Problem

As part of a company’s regulatory compliance team, we were asked to lead an interdisciplinary team on a regulatory rulemaking initiative that could significantly impact the company’s operations in Florida. The company’s request was to influence the rulemaking language, determine the scope and extent of the rulemaking impacts to the company operations, and propose alternatives to address compliance with the new rule.

Action

The AssenTerra team lead assembled the key internal and external interdisciplinary team members that worked together to develop one pre-rulemaking comment letter and two comment letters responding to requests for comment to proposed rulemaking language.  The combined three comment letters provided suggested language revisions grounded in technical documentation and otherwise supported by existing agency policy.

Further, the AssenTerra team leader worked directly with engineering to assess impacts to the business operations based on the anticipated rule language. Once the impacts were understood, three alternative solutions to address compliance were provided:

  1. an administrative solution leveraging the regulatory language;
  2. site-by-site physical treatment solutions for the more than 40 discharge locations; and
  3. a holistic solution that used a combination of administrative relief coupled with physical treatment solutions.

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Result

AssenTerra successfully influenced the regulation with 50% of the AssenTerra team’s proposed changes being incorporated into a State regulation resulting in a 10% reduction in implementation liability for the company. Upon evaluation by the company, it was decided that the holistic implementation solution on a watershed basis would be the most protective of the environment while allowing the company to continue operating successfully.