At the recent MFSA and NAMF 1998 Joint Industry Convention, Larry R. Troxel of Verdict Re: Sources, Camarillo, California, spoke about environmental investigations he has participated in. He also offered those in attendance 10 suggestions for minimizing their risks during environmental investigations.
- Keep a personal file. Keep records of everything in a place where you, the owner or manager, can personally access it at any time.
- Develop a corporate environmental policy. Give a copy to all present and new employees. Have all employees sign a statement saying they have read and understood the policy.
- Conduct random, unannounced inspections to enforce the environmental policy.
- Know your waste streams and their destination. Know the penalties and fines you could be assessed if there is a leak. Make sure your suppliers and transporters have the necessary permits.
- Conduct independent annual environmental audits using an outside auditor.
- Establish a direct hotline to the CEO or plant manager's office. The line can be used by disgruntled employees to vent their concerns and complaints.
- Conduct training sessions for all employees. Instruct them as to how to behave during an environmental investigation.
- Know your agencies. Train specific personnel as regulatory escorts.
- Determine in advance what documents in the company are privileged, such as under attorney/client privilege.
- Remain active in your associations. Maintain a strong lobby for your industry.
For additional information, contact Larry Troxel at 805-445-1997; fax 805-445-1427.