Techniques for Environmental Investigations

At the recent MFSA and NAMF 1998 Joint Industry Convention, Larry R.

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.

  1. Keep a personal file. Keep records of everything in a place where you, the owner or manager, can personally access it at any time.
  2. 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.
  3. Conduct random, unannounced inspections to enforce the environmental policy.
  4. 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.
  5. Conduct independent annual environmental audits using an outside auditor.
  6. 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.
  7. Conduct training sessions for all employees. Instruct them as to how to behave during an environmental investigation.
  8. Know your agencies. Train specific personnel as regulatory escorts.
  9. Determine in advance what documents in the company are privileged, such as under attorney/client privilege.
  10. 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.