Echelon Solution Matrix

Preliminary Assessment

I. Quick Compliance Assessment & Report. A short, proprietary on-line questionnaire for gathering some basic information about a facility’s operations. Upon completion, a report is automatically generated and returned by email.

II. Full Compliance Assessment. Another unique product, the Full Assessment is by invitation only and covers every EPA, DOT and OSHA standard. Upon completion of this extensive assessment, a report is generated that becomes the basis for further discussion of EHS needs.

III. Verbal Overview. The initial overview is comprised of:

• Objectives. Those stated by client as well as initiatives suggested by the Echelon Certified Advisor™
• Business Units Requiring Compliance. We define the business units impacted by regulations
• Regulatory Obligations. Obligations with respect to the above are elucidated.
• Recommendation of Program. A proposal is sent, discussed, refined if necessary and acceptance.

Primary Initiatives

I. Overview. Regulatory initiatives addressed include:

1. EPA Regulations. Initiatives for regulatory compliance are developed with an eye to:

• RCRA Hazardous Waste Rules. These are common and wide-ranging mandates.
• Clean Water Act. This primarily involves regulating wastewater discharges.
• Clean Air Act. One of the most heavily regulated and complex pollutant discharge methods.
• Emergency Planning and Community Right to Know Act. Concerns reporting of chemicals to the EPA.

2. OSHA Regulations: We review the extensive rules for all workplace hazards: chemical, electrical, heavy equipment and many more.

3. DOT Regulations. A review of applicable regulations of the Federal Department of Transportation

• FMCSA: Rules for drivers, equipment, drug testing and other requirements many more.
• PHMSA: Regulations specific to transport of hazardous materials.

4. State and Local Regulations. The applicable state and local regulations are identified and reviewed.

II. Preliminary Scope and Review. A document outlining of the agenda for the advisor’s next call.

1. Review of Existing EHS Programs. This includes a thorough examination of existing EHS initiatives:

• Program Review. A checklist sent to indicate requirements and existing plans to review.
• Employee Training Documentation. This is critical and often neglected.
• Written Plans & Documentation. These are reviewed and the regulatory requirements are detailed.

2. Business Systems and Processes Review. Analysis and review of the following, with phone support available:

• Business Units, Systems & Operations. Any of these that are affected by regulations are discussed, as well as the relationships between them.
• Organizational Chart. We review the client’s organizational chart.
• Policies and Procedures. Important in maintaining the EHS already in place and any that will be developed.

3. Company History. The company’s history of incidents and issues of:

• Compliance Issues. Internal near-miss and other incident reports are valuable reference points.
• Other Incidents. These may be unapparent yet related to and affect compliance.

4. Employees. We identify the people primarily involved in EHS and participants in this project.

III. Facility and Company Review. Multi-facility corporations will be analyzed at the corporate headquarters level and at the facilities level to identify gaps or deficiencies. Each facility will have an Echelon Certified Advisor and is treated as an autonomous business unit. The components include:

• Program Review. We perform a thorough review of all company EHS programs.
• Physical Conditions. The advisor will utilize summaries in the assessments and will look for unidentified potential compliance issues. A walk-through of the facility ensues and the processes seen in II. 2 above are evaluated. We identify every area and operations that may be subject to regulatory compliance
• Other Facility Areas. We will be looking for those hidden compliance liabilities such as insufficient lighting, poor housekeeping, dusts and more.
• Employee Activities. We review practices and rules which are not necessarily related to compliance but impact employee safety and corporate liability.
• Risk Identification: The hazards are compiled and numerically ranked by severity of exposure and risk.
• Training Records. All training records are reviewed again to identify gaps or deficiencies.
• Relevant Regulations. The relevant regulatory citations are identified, listed and explained.

IV. Needs Analysis & Written Plan. A written 30/60/90-day plan with actionable components delineates a timeframe for the analysis, development and implementation of the tasks needed to build a foundation for regulatory compliance. This may also include developing new programs, reinforcing existing programs or both. Key areas include, but are not limited to:

• Regulatory Synopsis. This summarizes every federal, state and local regulatory obligation.
• Hazards. A detailed report of the workplace hazards and the applicable compliance remedy.
• Recommendations: A list of improvements prioritized by potential risk and seriousness.

Program Development and Implementation

• EPA. We cover compliance with every aspect of EPA mandates, including hazardous and non-hazardous waste, chemical management (EPCRA), wastewater treatment (NPDES), and air emissions (CAA), and others as identified.
• OSHA. OSHA safety requirements are addressed, including hazard communications, respiratory protection, forklifts, protective equipment, confined space and process safety management.
• DOT. We design a program for DOT compliance for hazardous material classification and shipping, HazMat employee training, HazMat security plans, and FMSCA for land, sea or air transportation.
• Employee Education. We will meet specific training needs via regularly scheduled drip training.

• Regulatory Oversight. We monitor all agencies for new rules and changes to the existing rules.
• Monthly Phone Consultation. The client will have a seat on our monthly “Open Office” group phone calls where recent developments are reviewed and questions are answered.
• Quarterly Review. Every 90 days a review will be conducted to audit and assess progress.
• Initial Training. This is employee-specific with an emphasis on their roles and relationships.
• Ongoing Drip-training. This utilizes quizzes, videos, and audio recordings as well as live workshops.
• Case Studies. News stories and case studies for managers and employees are discussed.
• Ongoing Behavioral Encouragement. This assures continued employee engagement and development.
• Employee Surveys. These help us to track initiatives to make sure they are met.
• Corporate Compliance Committee. This may be established at the option of the client.
• White Hat Inspection. With the client’s permission, the regulatory agencies are invited to inspect the facilities. When invited, they cannot fine, no matter what they find (if anything).

• Regulatory Mentoring Program. A private forum via APEX to discuss a variety of issues, held weekly for 2 hours. Panel discussions provide real insights from people that have been in the business for decades.
• EHS Compliance Advisory. This is a leading-edge advisory for C-level / Enterprise-level managers in companies which already have well developed EHS programs.

Comprehensive OSHA, EPA and DOT Training

This includes both initial training as well as drip training by Ron Harvey and seasoned Echelon advisors. Our capabilities include and are not limited to: