Vanguard Environmental

Mark Frazier

Mark Frazier graduated with a B.A. degree in Business Administration and a Minor in Education from Oklahoma State University & Langston University (Tulsa). Mark received an athletic scholarship in football playing center for the Oklahoma State Cowboys. After his athletic career, Mark started his career in sales with the following Corporations: U.S. Tobacco, Nabisco, & Liggett Group. At Liggett, Mark served in several positions in the Corporate Office such as Training & Development Manager, Key Accounts Manager and Division Manager for Oklahoma & Kansas. Mark joined Vanguard in 2005 and serves as the Regional Manager for the Western US and was promoted to Chief Operating Officer for Vanguard in 2008.

Carlos Carrera

Carlos Carrera holds an Associates degree in Liberal Arts from Tulsa Community College with a specialized focus in AutoCAD and Drafting. His technical skills, as well as, leadership skills direct Vanguard’s Environmental Science Technology Department, whose focus is primarily Sara Title III, Section 301-312 compliance. Raised in Lima, Peru, he is fluent in Spanish and also serves as Vanguard’s translator for Safety training and various Vanguard documents. Carlos is also well-versed in the subject of Hazardous Materials Business Plans (HMBP) and Hazardous Materials Inventory Statements (HMIS) for the states of CA, AZ and TX.

Ernie Barnes

Ernie Barnes holds an Associates degree in Engineering Technology, from Rose St. College in Midwest City, OK, a B.S. in Business Administration and a M.S. in Industrial Management from Northeastern State University based in Tahlequah, OK. Throughout his career, Ernie has developed and implemented EHS programs, conducted numerous site inspections, and obtained his CHMM & HAZWOPER certification. Ernie is also ISO 14001 Lead Auditor certified. He has led one major corporation as an operations manager for over 15 years prior to his employment with Vanguard.

Tim Denhof

Tim Denhof holds a B.S. in Chemical Engineering from Michigan Technological University, Houghton, Michigan. He has been in the environmental consulting field for 20 years with a broad range of experience across air, water, waste, DOT and OSHA compliance. He has experience with ISO registration as well. Tim has over 10 years of project and management experience in environmental consulting, laboratory management, and in the manufacturing sector.

Bob Breslin

Robert N. Breslin comes from a varied background of 23 years in the health and safety compliance field. In developing his initial credentials in the U.S. Air Force & Department of Defense, Bob utilizes his skills, expertise, and infectious personality to head up Vanguard’s OSHA compliance programs. With a rare talent of bringing “dry material to life,” Bob holds practically every designation and certification within the OSHA Compliance Field, and also serves as an instructor with Vanguard’s own “Amer. EHS Training Institute.”

Environmental Management System (EMS)

Our Environmental Management System encompasses processing and documentation to be in compliance with 20 key EPA, OSHA, and DOT regulations at the federal, state, and local levels at the completion of your Environmental Management System service. Contained within the Environmental Management System service there is a five-step process: 1.We begin by compiling a detailed inventory of chemicals, hazards, and dangerous goods at your facility. 2.Next, our state-of-the-art technology will screen these items against all pertinent regulations and identify potential reporting requirements based on the types and quantities of these products that you have on-site over the course of each year. 3.We conduct a meticulous review of the documentation and training programs that you already have in place, and ensure that emergency preparedness procedures meet or exceed the expectations set forth by governmental agencies. 4.We follow this up with an on-site visit to your facility by one of our compliance specialists, who will conduct a detailed walk-through and assess for potential concerns that would be raised by an EPA or OSHA inspector. 5.Finally, we review the compliance gap analysis with you to pinpoint areas of risk and recommended remediation. We also deliver extensive, site specific documentation which captures all of the regulatory compliance findings, to help you with the next steps, and to serve as defensible documentation in the event of an actual EPA or OSHA inspection. In summation, the Environmental Management System (EMS) serves as a reference document and outlines our client’s environmental, health & safety requirements. This document satisfies the 20 EPA, OSHA & DOT Compliance Laws including the SARA Title III Sec. 301-312 reporting. The Environmental Science / Technology Department with the assistance through proprietary technology performs a site specific analysis of a facility’s chemical inventory. Each chemical in each product is tracked against the EPA’s chemical lists which are connected to regulatory guidelines.

Link: Environmental Management System (EMS)

OSHA Compliance Module

A large number of occupational health documents can be required by law, depending on the hazards that are present in your facility. As a part of our review, we ensure that your HazCom Workplace Safety List is in order and analyze the potential risks. Annual OSHA Compliance & Training Program consisting of…(Time Durations Below Are Approximate): Annual Hazard Communication Training for all employees (29 CFR 1910.1200); Training done on HazCom performed in Groups of 30 [Time Duration: 2 hrs. per group.] Personal Protective Equipment (PPE) to eliminate workplace exposure to hazardous chemicals; [Time Duration: 30 minutes] Annual Lockout/Tagout (Site-specific/General) Procedure & Training for selected employees relative to hazardous energy sources. (29 CFR 1910.147); [If “machine-specific” desired, ask Reg. Specialist for stand-alone agreement.] [Time Duration: 1 hr.] Annual Bloodborne Pathogens Exposure Control Plan & Employee Training (29 CFR 1910.1030); [Time Duration: 1 hr.] Emergency Response / Spill Prevention Training; [Time Duration: 30 minutes] NOTE: TOTAL DURATION TIME FOR BASELINE MODULE IS APPROXIMATELY 2.5 HOURS, BASED ON GROUP OF 30 EMPLOYEES (Not all of whom will need to participate in everything)

Link: OSHA Compliance Module

Electronic Hazardous Material Management

Emergency Planning and Community Right-to-Know Act (EPCRA Sections 301-312) establishes reporting requirements which provide the public with important information on the hazardous chemicals in their communities. The purpose is to increase community awareness of chemical hazards and to facilitate emergency response planning. Under Section 312, we prepare and submit the SARA reports annually by March 1st of the following year for the most current reporting year. Extremely Hazardous Substances (EHS) Section 302 must be reported on this form if a facility has an EHS on hand greater than 500 lbs. of aggregated weight or greater than the Threshold Planning Quantity (TPQ), whichever is lower. Extremely Hazardous Substances (EHS) cannot be accounted for even by a keen eye. Data calculations must be performed to determine if actual EHS reporting is needed.

Link: Electronic Hazardous Material Management

Facility Compliance Assessment (FCA)

The Facility Compliance Assessment (FCA) is available from Vanguard Environmental, Inc. to meet the client's concerns for an accurate regulatory compliance assessment and written status report by qualified and objective third-party professionals. The results from the FCA are provided in the form of documentation, becoming a matter of record for the eventual purpose of resolving those compliance gaps discovered as a result of the regulatory data retrieval and site-investigation. Upon completion, an Executive Briefing is scheduled between Vanguard Environmental, Inc.'s Regulatory Specialist and the client's management team to engage in an open dialogue regarding the findings of the project. Of course, the objective of local, county, state, and federal agencies is to protect the safety and health of employees, the environment: air, land, and water, the community-at-large, and the region downwind from the facility. The FCA encompasses the review and evaluation of environmental permits, reports, and documentation as required by the Environmental Protection Agency (EPA), the Occupational Safety & Health Administration (OSHA) from the Department of Labor, the Department of Transportation (DOT), and the Department of Homeland Security (DHS), as well as state, county, and local regulations. Vanguard Environmental, Inc.'s work encompasses a Compliance Gap Analysis in order to screen the facility's chemical inventory against all the laws, thereby developing the client's Regulatory Compliance Agenda - a veritable strategic plan for achieving compliance. The site-investigation to be performed by the Engineer of Record emphasizes EPA, OSHA, DOT, & DHS regulations (unless otherwise specified by the client), including exhaustive compliance checklists screening all aspects of major and minor issues from the respective regulatory agencies, including state, county, and local regulatory agencies. In general, the FCA establishes the client's regulatory compliance agenda thru a two-fold approach: 1. Compliance Gap Analysis; 2. Engineer's Site-Investigation. The FCA reviews and evaluates the following elements of the client's Environmental, Health, & Safety Management Program: Management's written commitment to fulfilling all major and minor requirements thru environmental, health, safety policy; Evidence of required permits, reports, and documentation stemming from requirements of regulatory agencies; Current practices in pollution prevention, remediation and source reduction; Physical, documentary, and analytical evidence of EHS program and its practices; Testimonial information via interview and discussion with client contacts &/or employees Specifically, the FCA tests the company's accountability toward local, county, state, and federal mandates, which include: PERMITS; REPORTS; EMPLOYEE TRAINING; HAZARDOUS MATERIALS MGT; PERFORMANCE PACKAGING; LABELING; RECORD KEEPING; SHIPPING / TRANSPORTATION METHODS; DEFENSIBLE DOCUMENTATION OF COMPLIANCE PROJECTS; MSDS MGT; POLLUTION PREVENTION; EMPLOYEE HEALTH & SAFETY; RECYCLING & RECOVERY; WASTE MINIMIZATION; SOURCE REDUCTION; HAZARDOUS WASTE MGT; AIR QUALITY; SOIL QUALITY; WATER QUALITY; STORM WATER MGT; ERGONOMICS; EMERGENCY RESPONSE TRAINING

Link: Facility Compliance Assessment (FCA)

Site Security Plans (SSP & C-FAT)

1. Vanguard Environmental, Inc.'s Engineer of Record will proceed in behalf of the client to secure Chemical Security Assessment Tool (CSAT) Top-Screen RegistrationSecuring Chemical Security Assessment Tool (CSAT) Top-Screen Registration with the of Homeland Security (DHS), including but not limited to... Name of Facility; Street Address; City, State, and Zip Code; Country Latitude (in decimal degrees) -- this is a positive number Longitude (in decimal degrees) -- this is a negative number and must have a "-" sign prior to the numeric designation 2. After completion and submittal of the Chemical Security Assessment Tool (CSAT) Top-Screen Registration, the Department will issue unique usernames and passwords for access to the CSAT data collection tool to protect the client company’s sensitive data. Usernames and passwords will be granted after registration has been verified and will be e-mailed to users. 3. The CSAT user evaluation and password assignment process is summarized as follows: Identify the chemical facility, including facility identifier, parent company, facility address, and location information. Designate Preparer(s), Submitter(s), and Authorizer(s) for your facility. For companies with multiple facilities the person creating the registration should complete the Submitter section once and then repeat the facility section for all facilities. Submitters may be responsible for one or more facilities. If all of their facilities are entered on one registration form they will be granted one username and password. If their information is entered for only one facility at a time and then the Submit button is pressed, they will receive one username and password for each separate registration form they submit. This is not the preferred method. Collect the signatures of Preparer(s), Submitter(s), and Authorizer(s) named on the user registration form. Please retain a copy of this form for your records. Vanguard Environmental, Inc. will submit the printed and signed user registration form(s) to Office of Infrastructure Protection - Chemical Security Compliance Division Department of Homeland Security - Oak Ridge, TN 4. Once the signed user registration form is received, Vanguard Environmental, Inc. will work with DHS to create the client’s user access account. All Preparers and Submitters will receive usernames and passwords in separate emails. 5. After the username and password has been received by the Vanguard Environmental, Inc. and the client, it will be possible to access the CSAT data collection tool through DHS to submit the clients chemical facility data (“Top Screen”) as required by the Interim Final Regulation. 6. Vanguard Environmental, Inc.’s Engineer of Record will develop a document book for the purpose of Defensible Documentation as an Inspection Showpiece.

Link: Site Security Plans (SSP & C-FAT)

Stormwater Pollution Prevention Plan

There are many operations that may drive the need for Storm Water Runoff Permitting. These can include the unloading of semi-trucks in an uncovered dock or unloading by forklift in the yard, as well as carrying out vehicle maintenance in the yard. If you store raw materials in uncovered containers in the yard, or if your waste containers do not have lids or are otherwise not covered at all times, then again your facility could require a permit. Maintaining an active railroad spur on your premises also creates storm water compliance requirements. As a part of our review, we verify the applicability of storm water pollution prevention programs to your operations, including the National Pollutant Discharge Elimination System, the Multi-Sector General Permit, and provisions for Endangered Species Protection.The Federal Water Pollution Control Act, its follow-on legislation leading to the Clean Water Act, and other amendments also drive requirements for which we will assess compliance. For example, your location may be near specific bodies of water that appear on a list of impaired waters and for which a Total Maximum Daily Load has been established by pollutant type, such as chemical types, sediments, or even temperature. If your location is in proximity to wetlands and discharges dredged or fill material into the waters, then a determination must be made as to whether a general or an individual permit will apply. Finally, we will ascertain whether California’s Safe Drinking Water Act could have implications for your facility’s discharge, based on the type and quantity of chemicals in your runoff, as well as its location. 1. SITE-INVESTIGATION, PRELIMINARY EVALUATION & CONFIRMATION OF PERMIT REQUIREMENTS. A member of Vanguard Environmental, Inc.'s technical/engineering staff shall perform a site-investigation at the client's facility, and then further evaluate and confirm permitting requirements for the client. The site-investigation (inside & outside) will include an interview with client contact, gathering of data pertinent to project, and photograph on-site evidence of processes, pollution sources, outfalls, inlets, natural water conveyances nearby, adjacent facilities, and other potential pollution sources. Among the findings of the site-investigation, a determination will be made on sampling / monitoring requirements. The Notice of Intent (NOI) and/or Disclosure Statement (as required in some states) is submitted to the EPA and/or State of Record, thus securing the client's SWR Permitting I.D.# from the granting body. Further research is conducted on those storm water pollutants targeted by Vanguard Environmental, Inc.'s Chemical Inventory Analysis performed as a part of the client's EPA Environmental Compliance Reporting under SARA Title III, Sec. 301-312. 2. SAMPLING / MONITORING OF STORM WATER (AS REQUIRED) Upon verifying that incremental sampling / monitoring is required, the technician will coordinate...

Link: Stormwater Pollution Prevention Plan

Toxic Chemical Release Inventory Form "R" (TRI - Section 313)

Depending on your facility’s SIC code, you may be required to report on releases that result from your use of certain toxic chemicals. By accounting for the quantity of these chemicals that are used over the course of the year, a calculation is made of the emission level that occurred, into the air, water, or land, or otherwise transferred off-site. This report, known as the Form R report, enables the EPA to track Toxic Release Inventory (TRI) as required by SARA Section 313. Vanguard Environmental will identify whether the chemicals used in your facility create the need for Form R reporting and, if so, we can assist you by performing the emissions calculations and also in creating all of the appropriate documentation. FACILITIES & CRITERIA FOR FORM R CHEMICAL REPORTING There are three primary criteria that trigger Form R Reporting: 1. The requirements apply to facilities with 10 or more full-time employees (or 20,000 hrs/yr.); plus, 2. A facility must operate within the SIC Code range of 2000 - 3999 (since 1987); or beginning with the 1998 reporting year, 7 additional industry groups further designated for Form R compliance effective January 1, 1998, and filed by July 1, 1999. The 7 industry segments for the "TRI Industry Expansion" initiative are: 1. SIC code 10 - Metal Mining (except 1011 & 1094); 2. SIC code 12 - Coal Mining; 3. SIC codes 4911, 4931, 4939 - Electric Utilities; 4. SIC code 4953 - Commercial Hazardous Waste Treatment; 5. SIC code 5169 - Chemicals & Allied Products-Wholesale; 6. SIC code 5171 - Petroleum Bulk Terminals & Plants; 7. SIC code 7389 - Solvent Recovery Services. Note: As it regards SIC code 4953 above, the definition of "otherwise use" has been amended to include treatment, stabilization, and disposal of toxic chemicals received from off-site for waste management purposes or generated during the waste management of materials received from off-site. It should be noted that many states have other specific requirements. Such as, the State of Minnesota requires Form R Reporting at the state level (in addition to that which is required at the federal level) for 14 additional SIC codes - interestingly including medical operations - to those SICs stated above. Both the states of Minnesota and Arizona require that a “Pollution Prevention Plan” (plus a Progress Report in MN) be submitted at the state level to accompany a facility’s Form R Reports; plus; 3. A facility must process, manufacture, import, or "otherwise use" a listed toxic chemical or chemical category at or above specified threshold quantities. As a historical readback, the “otherwise used” has been 10,000 lbs. used annually ever since the inception of the TRI law in its first reporting year, 1987. However, the “process or manufacture” threshold started out in 1987 at 75,000 lbs. annual usage, was moved down to 50,000 lbs. annual usage in the 1988 reporting year, and stayed at 25,000 lbs annual usage from 1989 through the 2000 reporting year...

Link: Toxic Chemical Release Inventory Form "R" (TRI - Section 313)

Emissions Inventory Reporting (EIR)

Vanguard's engineering department performs emissions inventory reporting for its clientele by tailoring the entire procedure to the company’s site-specific issues relative to that legislation invoking jurisdiction over the client’s facility. 1. COMPLIANCE GAP ANALYSIS / SCREENING FOR STATE-SPECIFIC CHEMICAL CANDIDATES. Many states require the tracking of more than 600 air toxics, sometimes more commonly known as Hazardous Air Pollutants (HAPs). Vanguard Environmental, Inc.’s copyrighted technology screens for all listed chemicals as they may be manufactured, processed, or otherwise used at the client’s facility. This mandate is one of nine laws requiring adherence to the “aggregate total ruling” in which chemical constituents of like kind pervading a facility’s product inventory must be accounted for, tracked, analyzed for annual throughput, and eventually reported/filed pertinent to the annual emissions calculated as an end result of the owner/operator’s responsibilities. Through Vanguard Environmental, Inc.’s technology, these due diligence and reporting matters are executed with precision. Without such a technology, the facility’s compliance remains inaccurate and suspect. 2. PROJECT SETUP / TRACKING OF MONTHLY THROUGHPUT, LOGIN & ANALYSIS. Vanguard Environmental, Inc.’s engineering department will evaluate the client facility’s air emissions to set up the proper product information to be tracked and submitted to Vanguard Environmental, Inc. on a monthly basis. Product information is to be submitted at the first of each month for the previous calendar month on those products containing the chemical constituents designated as a part of the overall due diligence effort throughout the course of each compliance year. Vanguard Environmental, Inc. will work with the client’s purchasing department contact (or data retrieval contact) to accommodate the client’s data submittal issues in the most convenient manner possible. The fact that data retrieval/submittals are executed on a monthly basis allows the purchasing department contact to utilize Vanguard Environmental, Inc.’s unique Data Retrieval System (DRS) to avoid being burdened by the imposition of having to research and submit product data for an entire calendar year which, with the increased requirements and changes in state-specific threshold determinations, has become virtually impossible to perform in the course of just 30-45 days prior to the annual emissions reporting deadline. Vanguard Environmental, Inc. will actually implement two data retrieval systems for efficiently gathering correct information: FACILITY INFORMATION (an annual gathering) and the aforementioned Data Retrieval System, to be submitted by the client’s purchasing department contact on a monthly basis. Both systems will be introduced, discussed, and implemented by the engineering specialist as a follow-up to the Evaluation. This encompasses... A. an understanding of what product information is to be gathered and tracked, with a computerized format provided by Vanguard Environmental, Inc.; B. how the information is to be submitted to Vanguard Environmental, Inc.; C. how to implement the ongoing MONTHLY data retrieval system; D. contact and technical as

Link: Emissions Inventory Reporting (EIR)

Air Permit

A Compliance Gap Analysis will be conducted via chemical data retrieval through all liquid, solid, and gaseous products being used, stored, processed, or manufactured at the facility. 1. COMPLIANCE GAP ANALYSIS, FACILITY DATA RETRIEVAL A Compliance Gap Analysis will be conducted via chemical data retrieval through all liquid, solid, and gaseous products being used, stored, processed, or manufactured at the facility. This will organize, codify and quantify the chemicals and their aggregate totals under the CAAA's various chemical categories, the four critical Title Programs, and specific State Programs. Upon completion of this step of the project, a final chemical count will be known, replacing the "projected price" with a final price. An MSDS/chemical updating program will then be implemented for maintaining current records and updating the facility's emissions documentation, and Title V Operating Permit, as necessary, in preparation for the semi-annual reporting, annual certification requirements, and/or state-specific regulations. 3. APPLICABILITY, AGENCY APPEAL & APPROVAL PROCESS WITH STATE OF RECORD Throughout the project, the engineer(s) assigned to the project shall communicate and correspond with the State of Record having authority, along with the U.S. EPA, in granting and regulating the permitting process over the years. It is Vanguard Environmental, Inc.'s approach to make early contact with State 2. EVALUATION AND SCOPE OF PERMIT REQUIREMENTS Whenever a relationship is begun between Vanguard Environmental, Inc. and a client, Vanguard Environmental, Inc. will treat the initial air permitting project as if the client does not or never has had a permit (even though the client possesses an active, effective air permit). This methodology is to ensure that nothing has been neglected, thus negating the possibility that compliance work prior to Vanguard Environmental, Inc.’s involvement will be assumed to be accurate without making the appropriate effort to verify its precision relative to current legislation. A site-investigation will be conducted by one of Vanguard Environmental, Inc.'s Engineering Staff to evaluate all internal sources and their "potential to emit" hazardous air pollutants. A comparison of the site-specific findings against the statutory components of the CAAA will be conducted as follows: a. Volatile Organic Compounds, Title I; b. 187 Air Toxics – Hazardous Air Pollutants (HAPs), Title III; c. Acid Rain Deposition, Title IV. Sulfur Dioxide (SO2) and Nitrogen Oxide (NOx) under National Ambient Air Quality Standards (NAAQS); d. Class I & II Ozone Depleting Chemicals (ODCs), Title VI; e. Attainment and Nonattainment Provisions specific to metropolitan and non-metropolitan locations; f. Construction Permits; g. Incinerator(s) and Paint Booth(s) as Emission Sources; h. Accidental Release Contingency Programs; i. Implications for subsequent requirements for Maximum Achievable Control Technology (MACT); j. Operating Permit rules and regulations for State of Record, and/or Federal Title V; k. Emissions Inventory Questionnaire (EIQs), and the like, as required in selected states.

Link: Air Permit

Phase I Environmental Site Assessment (ESA)

The basic purpose of a Phase I Environmental Assessment, as related to real estate transactions, is to determine and document what environmental impairment, degradation, or hazards (known as Recognized Environmental Conditions), if any, are associated with the property or site in question. A report documenting a thorough investigation of the site and its historical use alerts all parties involved (buyer, seller, financial institution) in the transaction for any potential for remediation / cleanup prior to the consummation of the final agreement. Phase I especially informs the buyer and financial institution of any environmental liabilities at the time of the transaction that could substantially reduce the value of the investment in the future. If the Phase I Environmental Assessment documents evidence that environmental hazards do exist, then there may be cause for the site to undergo Phase II (Sampling, Testing & Evaluation) and Phase III (Cleanup & Abatement) projects. An outline description of Phase I, II, & III projects is offered below to avoid confusion about the scope of each project's requirements. The Phase I outline serves as Vanguard Environmental, Inc.'s Schedule of Work in this case. Also known as Superfund, this law was created to provide the authority and a source of funding for cleaning up environmentally abused property. Courts have upheld CERCLA's provisions of strict liability for contamination and joint and several liability among potentially responsible parties (PRPs). Congress recognized the plight of "innocent" buyers by incorporating the "innocent landowner" defense into CERCLA. To claim innocence, however, the landowner must first demonstrate that at the time of property transaction there was "no reason to know" that the property was contaminated and that "all good commercial or customary practice" was undertaken to detect the potential for property contamination. In order to qualify for the "innocent landowner" defense, a buyer must establish that, immediately prior to or at the time of acquisition, a Phase I Environmental Assessment was conducted and documented on the real property by an environmental professional.

Link: Phase I Environmental Site Assessment (ESA)

Globally Harmonized System (GHS) Hazard

Vanguard Environmental OSHA's compliance requirements for an effective 365-day-a-year GHS Hazard Communication Program are founded in five major components which serve as essential ingredients for Vanguard Environmental's Schedule of Work in providing the client Turn-Key Compliance with OSHA's GHS HazCom Standard. 1. OSHA-MANDATED "GHS HAZARD DETERMINATION" A complete GHS Hazard Determination (Chemical Inventory Analysis) must be performed with regard to physical and health risks on every chemical in the facility and organized by department in order to satisfy OSHA's GHS Hazard Determination Mandate, thereby also fulfilling OSHA's requirement that a company's GHS HazCom Program be Site-Specific. The Chemical Inventory Analysis screens each chemically-oriented product for all hazards to employee health and safety, considering physical state, container types, and location in the facility. Finally, the Chemical Inventory Analysis segments the hazards according to compliance laws and regulations: NFPA rating, Extremely Hazardous Substances, CERCLA substances for Spill Containment, Toxic Chemicals, Regulated Hazardous Waste, Carcinogens, Mutagens, Teratogens, Ozone Depleters, Air Toxics, Storm Water Pollutants, and DOT Regulated Chemicals. 2. WRITTEN HAZARD COMMUNICATION PROGRAM. The WRITTEN PROGRAM is the CORNERSTONE of the employer's entire GHS HazCom Program and serves as the key to the client's compliance. As a working document, the Written Program must provide evidence that the client's GHS HazCom Program is performance-oriented for employees in the workplace. This Written Program is developed on behalf of the client (site-specific to the client's facility) by Vanguard Environmental's OSHA Compliance Educator, utilizing the Hazard Determination as its driving force. 3. SAFETY DATA SHEETS (SDSs). SDSs must be obtained for every hazardous chemical in the workplace. Inactive SDSs must be maintained as a part of the company's records for 30 years. Active SDSs must be accessible to all employees at all times. SDS training for employees is vital. Proper SDS Management (also Labeling Mgt. in #4 below) is a part of the instruction and is implemented daily through the Vanguard Environmental "SDS/Labeling Manager's Manual" as taught to the safety coordinator/facility designee. 4. CONTAINER LABELING. Inadequate container labeling is one of the most common violations under the OSHA GHS HazCom Standard. Labeling must contain the identity of the chemical, immediate hazards, severity of hazards, acute and chronic health hazards, and any personal protective equipment to be used by employees when exposed to a chemical hazard. The purpose of labeling is to serve as an employee's immediate warning of chemical hazards in the workplace. Titled the "Chemical Hazard Identification Program" (CHIP), labels are provided with the initial training service and are available in the future. 5. EMPLOYEE INFORMATION & TRAINING (ON-SITE).

Link: Globally Harmonized System (GHS) Hazard

Greenhouse Gas Emissions Report

1. Compliance Gap Analysis (Prerequisite for GHGER) As a part of the client's GHGER compliance responsibilities, Vanguard shall execute precision due diligence by screening the client's GHGER issues via Vanguard Environmental's proprietary Compliance Gap Analysis, essentially the government's benchmark for compliance. The CGA executes the screening process of the facility against the four title programs (Titles I, III, IV & VI) of the Clean Air Act Amendments. Title I covers VOCs most prominently found in products like paints, solvents and degreasers. Title III covers the 187 air toxics, also called Hazardous Air Pollutants (HAPs). Title IV covers those chemicals related to acid rain, which truly comes into play for GHGER when concerned with Nitrous Oxide, Suphur Dioxide and other particulate matter. Title VI covers ozone depleters of which there are 34 Class I Ozone Depleting Chemicals (ODCs) and 22 Class II ODCs. Important Note: GHGER is one of the 13 laws requiring the execution of the Aggregate Total Ruling (ATR) which must be computed in order to test all GHGs against the threshold required by the State of Record. 2. Process and Instrumentation Analysis By GHG Point Source, a site visit shall be made by the client's Engineer of Record (EOR) as necessary. If one of Vanguard Environmental 's Engineers has executed a site visit in the previous year for the purpose of satisfying compliance on Air Permitting, Emissions Inventory Reporting (EIR), or Toxic Release Inventory (TRI, aka Form R Reporting), it's quite conceivable that a site visit is unnecessary, provided the client is willing to assist in gathering pertinent data covering process emissions, site-specific to the client's facility. Emissions Reporting will require an analysis and tracking of process emissions from DIRECT, STATIONARY COMBUSTION, AND PROCESS EMISSION SOURCES. 3. Process and Instrumentation Diagram (P&ID) Vanguard Environmental will produce a site-specific P&ID by AutoCad as a means identifying and indicating all GHG point sources. 4. Quarterly Tracking As done by Vanguard Environmental on other Emissions and Release Tracking Programs, the GHGER service is galvanized by quarterly throughput/emissions tracking in Best Management Practices (BMPs) relative to the U.S. EPA's so-called GHG Protocol. 5. Reporting and Defensible Documentation Site-Specific reporting is transmitted to the State of Record by the mandated deadline, provided the client's annualized data has been retrieved and/or submitted, and is current to the most current reporting year, at least 30 days in advance of the reporting deadline. Upon project completion, the client's Defensible Documentation, reflective of the entirety of the client's GHGER compliance program, is sent to be kept on site as an Inspection Showpiece. 6. Regulatory Review Within a few days after receiving his Defensible Documentation, the client is contacted by the Engineer of Record for a Reg...

Link: Greenhouse Gas Emissions Report

Hazmat Training

As of October 1, 1993, the U.S. Department of Transportation (DOT) required that detailed training be given to all "Hazmat Employees" associated with transporting hazardous materials - by air, roadway, rail, or water - in the workplace. (The original deadline was April 1, 1993.) DOT defines a "Hazmat Employee" as..."a person, who in the course of employment, DIRECTLY AFFECTS HAZARDOUS MATERIALS TRANSPORTATION SAFETY." The definition mandates Hazmat Training of the following employees to include anyone who: - is involved with packaging; - marks or labels packages, - prepares shipping papers; - manages or supervises shipping; - loads a vehicle; - operates a vehicle; - manages records; - any other employees involved in transporting hazardous materials. DOT defines a "Hazmat Employer" as... "any person who uses one or more employees in connection with any of the above functions." DOT requires that "it is the responsibility of the Hazmat Employer to assure that every hazmat employee receives certification training, as mandated." SCHEDULE OF WORK AND TRI-ENNIALTRAINING REQUIRED: 1. DOT's Hazardous Materials Analysis will be conducted so as to determine the inherent hazards of each product which, in turn, will make the HazMat Training "site-specific" as required to satisfy compliance by DOT. 2.. All Hazmat Employees must receive GENERAL TRAINING, on: Requirements of DOT regulations; Recognition and identification of hazardous materials consistent with DOT hazardous materials communication rules. 3. All Hazmat Employees who handle or transport hazmat packages and anyone else who might be exposed to the materials as a result of an accident must receive SAFETY TRAINING on: DOT emergency response communications (49 CFR 172 (g); How to protect themselves and others from the hazards of hazardous materials to which they may be exposed; Methods and procedures for avoiding accidents involving hazardous materials. 4. Each type of Hazmat Employee must receive SPECIFIC TRAINING, such as: Classification and naming of Hazardous Materials; Packaging (Including new "Performance Packaging"); Marking and Labeling; Shipping Papers and Emergency Response Information Provision; Placards; Loading and unloading of transport vehicles; and other hazmat transportation information applicable to their job. 5. Site-specific written plan, documentation (inclusive of employee record-keeping), and participant manuals are prepared by trained and qualified instructors and support personnel. These materials are provided for the client, in the event of a DOT inspection under this ruling, as reflective of the training taken place. The records are also maintained at Vanguard Environmental's corporate office as a precautionary backup on behalf of the client. 6. The instruction is to last a minimum of two hours in length, preferrably at the facility of the client, for the purpose of site-specificity. A conference will be scheduled with..

Link: Hazmat Training

Process Waste Water Permitting (PWW)

Vanguard Environmental will provide comprehensive, turn-key Environmental Services as required by laws under the U.S. EPA, the State of Record and local/county regulatory agencies, to satisfy the Process Waste Water compliance responsibilities for the calendar years 2012 and 2013. Defensible documentation shall be a part of the deliverables as a complete disclosure and resolution of problems related to the project. The initial project shall be executed as a baseline from which a determination shall be made for any further compliance aspects (unless already known and/or requested) requiring additional attention to be followed at an additional cost. The 2nd and subsequent years’ work shall be better defined upon the 1st year’s project, but primarily would encompass the annual compliance review of due diligence to determine that the client is operating within the framework of its permit conditions, plus any reporting, documentation, management plans, and related issues required to be executed. Services will be performed to meet compliance objectives in six steps through the procedures listed below. However, the results of the Evaluation under Phase 1 will determined which of steps 2-6 would be subsequently necessary to be performed. Phase 1. 1. EVALUTION OF PROCESS / WASTE WATER ISSUES. Represents due-diligence required to analyze wastewater sources, water content, volumes, process, regulatory/permitting requirements, and restrictions, treatment, and options; Note: performed by a Vanguard Environmental engineer on-site at the facility. Phase 2. 2. EXECUTION OF THE PERMITTING PROCESS OR RELATED SERVICES. Should the engineer’s evaluations determine that permitting is a requirement, Vanguard Environmental will execute the steps necessary to secure the appropriate permit for the facility. 3. PROCESS WASTE WATER REPORTING ANNUAL/SEMI-ANNUAL OR RELATED SERVICES. 4. DEVELOPMENT OF A TOXIC-ORGANIC MANAGEMENT PLAN (TOMP). 5. DEVELOPMEMT OF SLUDGE MANAGEMENT PLAN (SMP). 6. PROVIDE & DISCUSS DOCUMENTATION SUPPORTIVE OF THE PROJECT.

Link: Process Waste Water Permitting (PWW)

Spill Prevention Control & Countermeasure Plan (SPCC)

The Environmental Protection Agency and state agencies oversee the enforcement of a large number of laws which are designed to prevent and minimize pollution at the source. Vanguard Environmental will work with you to ensure that your facility is following these requirements for pollution prevention, as well as produce the necessary documentation and reports that must be regularly filed with the regulatory authorities. Our experts assess the activities of your facility and identify compliance responsibilities in the areas of water, spills and release prevention, air quality, and hazardous waste. A harmful spill, in terms of quantity, is defined by the U.S. Environmental Protection Agency (EPA) as a discharge which “violates applicable water quality standards and/or one which causes a sheen, film or discoloration of the surface of the water or adjoining banks and shorelines, including discharges that may cause a sludge or emulsion deposit beneath the surface of the water or upon adjoining banks and shorelines." The SPCC Plan is required for fixed or stationary facilities which store chemicals, fuels or oil-related products under the following conditions: 1. Store the product at a capacity > 1,320 gallons in containers at a minimum size of 55 gallons and up; 2. Store the product underground at capacities in excess of 42,000 gal; 3. Could reasonably be expected to discharge the product into U.S. waters should a spill occur. The plan must cover three basic functions: 1. Practices devoted to the prevention of spills; 2. Plan of containment should a spill occur; 3. Plan for removal, cleanup, and disposal of the spilled material. [Note regarding HAZWOPER: The SPCC Plan and updates should be done concurrently with OSHA's 1910.120 requirement for HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE in which the 24 hour Hazmat Technical Training is followed each year with the annual 8 hour refresher. The company's Contingency Plan should also be done concurrently with these two functions on the annual anniversary date of the HAZWOPER TRAINING.] SCHEDULE OF WORK The SPCC Plan must be represented in document format reflective of a site investigation by a technically-qualified, certified engineering professional. It should be made available upon request for inspection by an EPA official, local & state authorities, U.S. Coast Guard, employee of the company, or citizen-at-large. Because such a plan must demonstrate a reality-based capability to respond immediately, effectively, and efficiently to a spill, a part of the implementation of the plan must also consist of at least discussion with the company's internal emergency response team, pertinent personnel, and the environmental compliance management team. Moreover, the most effective evaluation of the SPCC (short of an actual spill response) would be a "staged rehearsal of the spill contingency" to evaluate and measure the capability of the company's spill response. The...

Link: Spill Prevention Control & Countermeasure Plan (SPCC)

Personal Protective Equipment (PPE)

Vanguard Environmental provides instruction for personal protective equipment training encompassing all proper safety procedures as outlined in OSHA's training requirements under 29 CFR 1910.132. A member of Vanguard Environmental's technical / engineering staff will conduct an on-site review to identify current operational procedures, evaluate working order of current equipment, recommend further equipment as needed for compliance with OSHA's personal protective equipment standard, assist in the proper fitting personalized to each individual participant, and present a site-specific instructional program. The 1 1/2 - 2 hour program format includes a multimedia presentation of video, visual aids (overhead transparencies), student manuals, classroom instruction, plus 20 minutes "proper fit time" to be spent with each participant for groups of no more than 2-15 employees at a time. The written program, class roster, and instructional manual provides defensible documentation for compliance with this OSHA regulation in the event of an enforcement inspection.

Link: Personal Protective Equipment (PPE)

Machine Specific Lockout / Tagout Training (LO/TO)

Vanguard Environmental's Lockout / Tagout Service & Training exists as a turn-key program in which the employer has met his responsibilities to OSHA's Standard for Lockout / Tagout. Vanguard Environmental's Director of OSHA Education shall make a site-investigation of the employer's premises, thus designing an effective machine-specific program for Lockout / Tagout, 3-4 weeks prior to the training function. Materials and hardware will be established as a part of the program's design to isolate hazard sources. While Vanguard Environmental may procure locks and tags as a service convenience to the client, these "materials costs" will be the responsibility of the client upon invoice which will be supported by any and all receipts. Vanguard Environmental charges no surcharge for this service. 1. The site-investigation shall encompass a study of machinery, processes, energy isolation procedures currently in place, development of those to be implemented, employee skills proficiency, instructor familiarity with operations, materials and hardware to be introduced to operations, and interviews with one or more personnel to be trained. Instructor will identify which of four types of harzardous energy may become a part of the overall program: electrical, mechanical, pneumatic, and hydraulic sources of energy. The site-investigation consists of: A. Develop a Process Design Schematic for all hazard sources (Machines, etc.). - Identify each hazard source to Description, Model #, Serial #, Location; - Assign Hazard Analysis Number to each machine to correspond to theclient's written plan; B. Develop Energy Hazard Analysis for each hazard source. - Identify type of energy source, magnitude, isolating mechanisms, location, stored energy, dissipation methods, startup & shutdown procedures for each machine; C. Determine Lockout / Tagout Requirements. - Ascertain the level of lock &/or tag for each machine; D. Develop Lockout / Tagout Procedure for each machine relative to: - Authorized Employees - Affected Employees - Names, Job Titles, Ph's/Pgr's - Names, Job Titles, Ph's/Pgr's - Cross Reference to Hazards - Cross References to Hazards - Select & Place Appropriate Lockout / Tagout Devices; - Identify and document special information or action steps. 2. A written program shall be provided for the employer's ongoing use and implementation. The written program becomes a living, working document that relates the facility's Hazard Analysis from Vanguard Environmental's Machine-Specific Site Investigation to the employees' training. Proper procedures for program implementation shall be an integral part of the written program. Since a written program is mandated by OSHA's Lockout Standard, the written program, hazard analysis documentation, and supportive records become an inspection showpiece and defensible documentation upon the visitation of an OSHA inspector. 3. Training and communication shall involve three groups of employees:

Link: Machine Specific Lockout / Tagout Training (LO/TO)

Bloodborne Pathogens Exposure Control

Vanguard Environmental will provide its turn-key compliance program and employee training service in order to assist the client in the fulfillment of its compliance requirements with the Bloodborne Pathogens Standard. 1. THE EXPOSURE CONTROL PLAN. Vanguard Environmental personnel will gather all vitally important data regarding the client's facility and employee participants so as to develop the written Plan site-specific to the client's facility. The Plan is comprehensive in scope, encompassing: Purpose Establishing Program Management and Performance Criteria Exposure Determination Methods of Accomplishing Compliance HIV & HBV bloodborne pathogens Hepatitis B Vaccination and Post-exposure evaluation and followup Labels & signs - Information & training. 2. EDUCATION AND TRAINING. Vanguard Environmental's Bloodborne Pathogens instructor is degreed in Medical Technology. Training shall consist of the following; Bloodborne Pathogens Standard; Overview of epidemiology and symptoms of bloodborne diseases; Understanding how bloodborne pathogens are transmitted; Instruction on the facility's Exposure Control Plan; Recognizing how tasks and activities may involve exposure to blood and other infectious materials; Overview of epidemiology and symptoms of bloodborne diseases; Review of the methods that will prevent or reduce exposure to bloodborne pathogens such as work practices and the use of personal protective equipment; Review of proper labels, signs, and container "color coding." Contingency plans and emergency response to emergencies involving blood or other potentially infectious materials, including procedures for and "exposure incident." 3. RECORDKEEPING, DOCUMENTATION, AND QUIZZES. A part of the overall annual service is to substantiate through documentation those very objectives accomplished as a part of the program. Appropriate records, documents, and employee quizzes offering evidence of participation are all a part of the program and service. These items are packaged in an attractive 3-ring binder that becomes an excellent showpiece for defensible documentation upon the arrival of an OSHA inspector.

Link: Bloodborne Pathogens Exposure Control

Forklift Safety Training Services

Vanguard Environmental provides instruction for forklift operations encompassing all proper safety procedures as required in 29 CFR 1910.178. A member of Vanguard Environmental's technical / engineering staff will conduct an on-site review to identify current operational procedures, evaluate working order of current powered industrial truck equipment, assess potential safety concerns, and present a site-specific instructional program, inclusive of a student-friendly quiz. The 1 1/2 - 2 hour program format includes a multimedia presentation of video, visual aids (overhead transparencies), student manuals, and classroom instruction.

Link: Forklift Safety Training Services

Oil Spill Prevention & Facility Response

Vanguard Environmental provides turn-key service in satisfying those elements that comprise a facility's requirements under the "Oil Spill Prevention & Response Plan." A Vanguard Environmental engineer will conduct a site-investigation at the facility of record in an exhaustive search and collection of data pertinent to fulfilling these comprehensive requirements on a multi-jurisdictional level. The engineer will then formulate appropriate documentation for submittal to the pertinent regulatory agency to satisfy that aspect of the requirement. Two copies of the documentation will be delivered by Vanguard Environmental’s Regulatory Specialist to the client for presentation and review. Upon client project approval, one copy will be filed with the OGLO as required. Vanguard Environmental’s staff, including the engineer performing the tasks of the requirement, will remain available as technical representatives in the event an enforcement inspection would require such assistance. For further program elements & topics for Oil Spill Prevention & Facility Response Plan (OSPRA): 1. Facility Certification. The owner of a regulated facility must apply to the OGLO for a discharge prevention and response certificate. No facility may commence or continue operations after January 1, 1993, without a discharge prevention and response certificate issued by OGLO. An application fee shall be required of the client by OGLO, additional to Vanguard Environmental’s fee for this project. 2. Application for either Major Facilities, Small Commercial Facilities & Underground Storage Facilities; 3. Description of Facility. Owner/Operator Status, Products Handled, Location, Contact Person, MSDSs, Storage and Transfer Capacity, Throughput Capacity, and Average Daily Throughput, etc. 4. Facility Prevention Measures, Facility's Response Plan (Planned Discharge Prevention, Chain of Command, Lines of Communication, and Procedures for OGLO notification in the event of an Unauthorized Discharge, Response Equipment & Supplies, Plans for Sampling, Testing, & Measuring, Plans for the Recovery; 5. Plans for the Recovery, Storage, Separation, Transportation, and Disposal of Waste from an Unauthorized Discharge; 6. Probable Direction and Rate of Flow for Unauthorized Discharges; 7. Plans and Maps showing Strategy Protecting Environmentally Sensitive Area - Site Map, Topographical, Aerial, Neighborhood, Community, Shoreline, Affected Geographical Areas etc.; 8. Plans for Providing Emergency Medical Treatment, Site Safety & Security & a Site- Specific Plan for 29 CFR 1910.120 (HAZWOPER which may become an additional project if not yet developed and readily available); 9. Schedules, Methods & Procedures for Maintaining & Evaluating Response Readiness; 10. Description of Relationships with Discharge Cleanup Organization(s); 11. Estimate of Worst Case Discharge, Including Rationale used to Establish Estimate; 12. A Description of all Hazardous Substance Discharges at the Facility within the Previous Year; 13. A List of Environmental Permits and Registration / Identification Numbers (wastewater discharge,..

Link: Oil Spill Prevention & Facility Response

Process Safety Management (PSM)

Vanguard Environmental, Inc. will conduct a turn-key compliance project on behalf of its client that meet OSHA's PSM requirement under 29 CFR 1910.119. The project shall be initiated under the annual compliance structure in 25% increments by each annual deadline in May, guiding the client to total project completion until the ultimate deadline of 100% compliance on May 26, 1997. A basic assumption is that Vanguard has performed a Chemical Inventory Analysis on the client's facility. If not, this step must be added to the Schedule of Work below and will require an additional cost. The owner/operator of the facility must understand and assure that PSM applies, not only to his facility's employees, but to contractor and subcontractor employees, except in the case of incidental services, such as janitorial, food and drink, laundry, delivery, or other supply services.

Link: Process Safety Management (PSM)

Risk Management Program (RMP)

Vanguard Environmental, Inc. assists its clientele in satisfying this compliance requirement in four categorical ways: 1. Register the facility with the EPA as required. The registration consists of a written program to be sent to EPA headquarters in Washington, D.C., indicating the facility is covered by the rule, identifying the regulated substances triggering the registration and the quantity of those substances in a process. Vanguard will track registration changes as new chemical products are added, dropped, or when the quantities change, so as to amend the facility's registration form and prepare amendments to Air Permits acknowledging the applicability of CAAA 112(r) as required in the regulation. 2. Develop and assist with the implementation of the RMP that includes a hazard assessment, prevention program, emergency response program, and maintain onsite documentation of the implementation. The hazard assessment will include offsite consequence analyses (using EPA-mandated models and parameters) and a five-year accident history. The prevention program will consist of a process hazard analysis, process safety information, standard operating procedures (SOPs), training, maintenance, pre-startup reviews, management of change, safety audits, accident investigations, and a management system for orchestrating the ongoing RMP strategy. Note: as is the case with PSM, the component of Mechanical Integrity pursuant to PSM & RMP comes to the client as a separate project and pricing structure. The client should strongly consider Mechanical Integrity as a vital part of PSM & RMP as it would be difficult to fulfill compliance with both laws without an ongoing Mechanical Integrity Program. The emergency response program requires emergency response plans, drills or exercises, and coordination with public emergency response plans. 3. Develop and submit to the EPA, State Emergency Response Commission, and the Local Emergency Planning Committee the facility's RMP documenting the results of the program, summarizing offsite consequence analysis, a list of major hazards, steps being taken to address those hazards, five-year accident history, a description of the emergency response program, and a description of the management system that ensures the safety of the facility and the implementation of the required elements. The plan finally must be made available to the public. 4. Establish and document source information, program level, responsible party contacts for RMP elements, emergency contact(s), employee training, applicability of air permitting, guidelines for RMP inspections by EPA, SERC, or LEPC authorities.

Link: Risk Management Program (RMP)

Refrigerant Emissions Tracking Rule

Vanguard Environmental, Inc. assists its clientele in satisfying this compliance requirement in a two-phase process with six key, categorical steps: PHASE 1. 1. Screen the client’s facility(ies) for any and all refrigerants being used among its processes against applicable regulations with emphasis to Title VI of the Clean Air Act Amendments. Within this step, an analysis of those refrigerants that would trigger compliance responsibilities shall be determined; 2. Conduct an on-site investigation into the use of all machinery, equipment, CFCs, HCFCs, and amounts of refrigerants maintained in any given piece of equipment. Conduct a study of existing practices for charging, maintaining, repairing, and accounting for leaks of each piece of equipment or refrigeration system, including an accounting of all record keeping and paper trails created in the 3 years prior to the client’s contract date, as well as an accounting of the services of third party technicians/repair services/vendors in that time frame, as available. 3. Apprise the client in the form of written documentation of the complete scope of Section 608 implications, inclusive of programs, record keeping requirements, and equipment/systems monitoring, [perhaps to even begin a replacement/retirement program for the equipment in question, although such issues fall outside the scope of this project]. Should there be no reason discovered that Section 608 would be applicable to the client’s facility(ies), the engineer of record would submit an executive summary to the client apprising him of that fact, and suspend work on the project at that current time. It may be wise for Vanguard to conduct an update visit every three years to monitor for any amendments to regulations and/or changes to the facility. PHASE 2. 4. Establish with, and in behalf of the client a complete 30 day record keeping and document control cycle that would keep the client compliant with existing regulations at all times. This shall be done in a mission control style in operating via a communications link with the client’s on-site personnel to gather the data as deemed necessary and applicable encompassing leak rates, recharging information, repair/maintenance matters, vendors used for various “technician” services, etc. A web-based system shall be provided to accomplish this continuous record keeping and data control, complete with daily, weekly, and monthly accountability checks and appropriate non-compliance triggers to alert the client and the client’s personnel that compliance is due to lapse and, therefore, decisions must be made by Sr. Mgt. to suspend operations of any and all refrigeration equipment until compliance can be reinstated. The client shall be provided with web-based, secure pass codes (user I.D., password, and security pin #) in order that he can monitor his compliance status with regard to records, refrigeration data, each piece of equipment being monitored, etc., at any time,...

Link: Refrigerant Emissions Tracking Rule

Global Automotive Declarable Substances

Vanguard will provide Threshold Benchmarking against Global Automotive Declarable Substance List (GADSL) and screening. The intent of GADSL is to become the company specific list for declaration of parts composition within the automotive industry. It provides a definitive list of substances requiring declaration with the target to minimize individual requirements and ensure cost-effective management of declaration practice along the complex supply chain. The scope is to cover declarable substances in the flow of information relevant to parts and materials supplied throughout the automotive value chain, from production to the end of life phase. The GADSL only covers substances that are expected to be present in a material or part that remains in the vehicle or part at point of sale. The total number of regulated GADSL chemical substances is 2,593. The use of certain substances in vehicle parts may be a risk factor to human health and the environment. Information exchange along with the vehicle supply chain helps manage those potential risks while also meeting customer requirements. The GADSL is used to enhance further dialogue and cooperation along the supply chain on the benefits and potential risks of certain substances or groups of substances in a specified use within vehicle parts/materials. Declaration of a substance does not mean, however, that the substance is prohibited from being used in vehicle parts or is to be de-selected from use. Any declaration process using the GADSL must respect the framework formulated by GASL. The GADSL and specific client requirements are industry-specific to the automotive field and customer requirements of Vanguard’s client. Therefore, this chemical inventory screening and threshold benchmarking is executed against the GADSL as a stand-alone step. Its process is one of the five stages that Vanguard provides for the GADSL service.

Link: Global Automotive Declarable Substances

Contingency Planning Services

The Contingency Plan must be represented in document format reflective of site visits and Plan development by a technically-qualified professional in the field of emergency response implementation procedures . The Plan must be updated annually and made available for inspection by an OSHA or EPA official, local or state emergency response officials, employee(s) of the company, or even citizens-at-large. Because such a plan must demonstrate a reality-based capability to respond immediately , effectively and efficiently to even the most catastrophic events, a part of the implementation of the plan must also consist of education with the company's internal emergency response team, pertinent personnel, and the environmental compliance management team. Moreover, the most effective implementation would be a "staged rehearsal of an emergency scenario" to evaluate and measure the performance capability of the company's response to a life-threatening / environment-threatening event.

Link: Contingency Planning Services

Hearing Conservation

Vanguard's Hearing Conservation is established to satisfy the employer's OSHA compliance as described above. The program is implemented in two phases (the first phase - noise level monitoring - as a one-time requirement. 1. APPLICABILITY DETERMINATION FOR A HEARING CONSERVATION PROGRAM through Plant-wide Noise Level Monitoring on an 8-hour Time Weighted Average (TWA); 2. Annual Employee Testing, Training, and Hearing Protection Fitting. APPLICABILITY DETERMINATION: NOISE LEVEL MONITORING Vanguard's staff will first conduct a detailed noise survey. The purpose is to: 1. Obtain specific quantifiable information on the noise levels existing at any and all workplace area(s) of concern using precision monitoring equipment; 2. Document results of survey so as to define scope for which audiometric testing, training, hearing protection, and pertinent recordkeeping will be required; ANNUAL EMPLOYEE TESTING, TRAINING, AND HEARING PROTECTION Assuming that permissible exposure limits were exceeded in the noise level monitoring phase, Vanguard will develop the WRITTEN HEARING CONSERVATION PROGRAM under OSHA's 29 CFR 1910.95. The Program will address the following: 1. Results from the noise survey; 2. Audiometric Testing of those employees exposed to excessive noise levels; 3. Install Hearing Protection Program for all employees exposed to 85 decibels or more in the workplace; 4. Employee Training by groups of 25; 5. Record Keeping;

Link: Hearing Conservation

Indoor Air Quality

VANGUARD'S SCHEDULE OF WORK FOR INDOOR AIR QUALITY (OSHA: PERFORMANCE OUTLINE) 1.INTRODUCTION & OBJECTIVES - Select Date of Site Investigation, Time, Personnel Involved; - Perform Chemical Inventory Analysis through Material Safety Data Sheets and Emergency Response Information from Facility Layout; - Acquire notes, records, and recommendations from OSHA inspector; - Air Quality Monitoring in areas of concern (facility layout) to determine if exposure to dust, fumes and vapor warrants respirator use. Levels to be monitored: ______________________________________________________________________________________________________________________________________________________________________ - Process Machinery/Equipment as sources of concern:_______________________________________________________________________________________________________________________________________________________________________________________________ - Interview relevant personnel, such as Sr. Management, safety coordinator; - Personal Protective Equipment & Clothing being utilized by personnel: - Determine areas where Chemical Emissions and Volatile Organic Compound (VOC) monitoring is appropriate; - Check for Diisocyanate (DSI) Emissions & all other chemicals whose standards are specified under OSHA; Each sample is gathered using the specific flow rate, analytical media and methodology recommend by the American Industrial Hygiene Association. Sample intervals are determined by the individual laboratory requirements for flow rate, required sample volume, capacity of the collection device, concentration range, contaminate to be analyzed and test methodology. Each sample event can be affected by many external variables such as temperature and humidity, individual work habits, room dimensions and many other factors. A Time-Weighted Average is an acceptable measurement and is frequently used by Industrial Hygiene professionals to extrapolate an 8-hour result. However, it is Vanguard Environmental’s belief that all samples should represent a full work shift in order to gather accurate data. Variations in each individual’s work day may result in false high or low concentrations of environmental contaminates over a specific measured period of time. Since most job functions tend to consist of several steps and involve multiple processes, a “snapshot” measurement seldom yields an accurate representation of actual contaminate levels. For example; a “Welder” may actually weld 35% of the day, grind the weld 20% and cut metal to the correct shape for welding another 20% of the day. The remaining 25 % of his/her time may consist of breaks, cleaning of the work area and other non-welding activities. Any sample taken only during the part of the day when actual welding is being performed would fail to account for those periods of lower or nonexistent exposure to the measured contaminate(s).

Link: Indoor Air Quality

Source Reduction Waste Minimization (SR/WM)

Vanguard Environmental, Inc. will conduct the project with direct emphasis on rendering the 3 major components of agency's SR/WM Annual Progress Report: 1. Pollution Prevention Plan; 2. Executive Summary; 3. Annual Progress Report. Moreover, Vanguard will proceed to develop and file these mandated documents with TCEQ by the annual deadline. Finally, the client shall be provided with Defensible Documentation of the project for the purpose of implementing the plan as TCEQ requires it to be a "working" document. The project shall include the following elements: - Site-Investigation by a Vanguard engineer; - Chemical Inventory Analysis (completed by Vanguard under SARA Title III); - Survey of RCRA Hazardous Waste Manifests & pertinent RCRA Documents; - Review of Form R Reports for at least 3 previous years, if not back to 1987; - Review of SWR Pollution Prevention Plan under Storm Water Runoff Permit/NPDES; - Survey of Operational Waste Minimization, Recovery, & Recycling Methods; - Inspection of Paint Booths & their applications (filters & exhausts, too); - Consideration of Neighborhood, Community-at-Large, & Region Downwind; - Employee Training as required under RCRA & OSHA; - Personal Protective Equipment being utilized at the facility; - All items compared to 1987 as the base line year;

Link: Source Reduction Waste Minimization (SR/WM)

RCRA Hazardous Waste Management Program

Vanguard provides Annual Turn-Key RCRA Hazardous Waste Management Program as stated below: Annual Turn-Key RCRA Hazardous Waste Management Program project provides a turn-key management system to keep the client's facility in compliance with RCRA regulations at all times, but relieve the client of the burdensome, time consuming, and costly procedures to manage the program internally. The client's benefits for Vanguard's RCRA program are clearly positive and far-reaching. An end-result benefit is the reduction of waste disposal costs. For example...... A. In developing the program around only REGULATED chemical wastes, many disposal costs can be reduced or eliminated. B. By product substitution, some regulated chemicals may be eliminated, thus reducing disposal costs. C. By modifying generator status, agency fees can be reduced or eliminated. 1. COMPLIANCE GAP ANALYSIS. This analysis will be conducted to establish all the facility's chemicals regulated by RCRA, providing a foundation for regulated hazardous waste generation. 2. EVALUATION, SITE INVESTIGATION. A specialist from Vanguard's engineering staff will visit the client's facility for first-hand familiarity with the processes generating hazardous waste from the facility's product / chemical inventory. He will interview client contact(s) regarding processes, the generation of hazardous waste, and

Link: RCRA Hazardous Waste Management Program

Respirator Training

Vanguard Environmental, Inc. provides instruction for respirator training encompassing all proper safety procedures as outlined in OSHA's training requirements under 29 CFR 1910.134. A member of Vanguard's technical / engineering staff will conduct an on-site review to identify current operational procedures, evaluate working order of current equipment, recommend further equipment as needed for compliance with OSHA's respirator standard, assist in the proper fitting personalized to each individual participant, and present a site-specific instructional program. The 1 1/2 - 2 hour program format includes a multimedia presentation of video, visual aids (overhead transparencies), student manuals, classroom instruction, plus 20 minutes "proper fit time" to be spent with each participant. The written program, class roster, and instructional manual provides defensible documentation for compliance with this OSHA regulation in the event of an enforcement inspection.

Link: Respirator Training