Field Reports: New twist on environmental compliance for snack maker
Early on, environmental management fell in the lap of the company’s project manager. Then it was handed off to another manager, then to the corporate attorney, and then brought back internally to yet another department. Ultimately, environmental management and compliance found its way back to the initial project manager, Dennis Tavares, who by this time had become the plant engineer.
When the responsibility landed back in Tavares’ lap, Snyder’s was expanding production capacity yet again. This meant calculating the air emissions at the state-of-the-art pretzel bakery to determine permit status. As plant engineer, Tavares oversees all of Snyder’s engineering and maintenance functions and supervises a large maintenance department. Tossing environmental management responsibility into that mix meant his plate was full and usually overflowing.
Tavares was uncertain of the new air permit requirements and exactly how to verify Snyder’s permit status. Around this time, he heard about eCAP™, a new compliance assurance program from August Mack Environmental, Inc. “Due to the ever changing regulatory requirements and the complexities of maintaining compliance, not to mention the seriousness of failing to be in compliance, I knew I had to have a partner, ” Tavares said.
eCAP is an outsourcing program that guarantees your facility will be operating in compliance for less than the cost of hiring an additional employee. According to Tavares, August Mack worked side by side with him digging through records at the Pennsylvania Department of Environmental Resources, uncovering the information needed to file for the air permit and updating other environmental compliance programs.
After the air permit application was submitted and August Mack had performed an initial audit of Snyder’s, it was apparent that environmental as well as health and safety compliance requirements created a significant and complex training challenge. Updated employee training was needed in many areas including lockout/tagout, confined space entry, pollution prevention contingency planning, and hazard communication. Complex regulations as well as the logistics of scheduling employees made training a challenge.
Snyder’s operates 24/7 on many different employee work schedules. “Keeping track of employee schedules is cumbersome,” says Tavares. “Scheduling our people before or after their shift so they didn’t have to come back to the plant for training can be a logistical nightmare.”
Another obstacle Snyder’s faced was the fact that production uses automated equipment coupled with some manual tasks. This meant that employees could not be trained during normal production hours without shutting down production lines. At a facility the size of Snyder’s pretzel bakery, training is required at least 10 times per year.
Snyder’s decided to use the eCAP Training Module, outsourcing some of the required training. Now Tavares lets August Mack organize the required training and training is available when employees need it.
Environmental, health & safety compliance for pretzel and potato chip manufacturing required several eCAP modules in order to monitor and maintain compliance at the plant. Snyder’s used a Base Service Module, Minor Source Air Permit Module, Waste Generator’s Module, Wastewater Discharge Module, Hazardous Communication Module, Lockout/Tagout Module and Confined Space Entry Module.
The eCAP Waste Generator’s Module ensures that Snyder’s is treating, storing and disposing of its hazardous and non-hazardous waste properly and in accordance with all environmental regulations. Snyder’s also has a pretreatment plant that carries with it some of its own regulatory issues that fall under the eCAP Wastewater Discharge Module. The Base Service Module includes routine inspections of environmental and health & safety compliance issues associated with any industrial or manufacturing plant.
According to Tavares, “It takes your environmental program and runs with it, without a lot of our intervention. eCAP has taken a lot of work off my plate.”