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Potential Environmental & Regulatory Liabilities for Chemical Manufacturing & Distributors

Monday, January 16, 2017

Running a chemical manufacturing or chemical distribution company is certainly filled with challenges. Unfortunately, many the employees quickly find out the environmental and regulatory liabilities associate with having inqadequate chemical manufacturing insurance – putting a dent in their wallet.

We’ve outlined the most common environmental and regulatory exposures encountered at breweries and similar alcoholic beverage plants below.  Many of these exposures can easily be prevented or mitigated through a solid chemical manufacturing insurance program:

  • Inadequate pretreatment of process wastewaters discharged to municipal treatment plants and surface water.
  • Uncontained floor drains around the plant site, both inside and outside buildings, which make spill control difficult.
  • Information unavailable on where ALL floor drains discharge.
  • Extensive liquid chemical inventories without secondary containment.
  • Storing and staging 55-gallon drums of chemicals at multiple locations around the site in uncontained areas.
  • Complicated piping networks without color coding or containment.
  • Storm water contaminated by chemical drip, leaks and spills.
  • Inadequate controls and containment for fire fighting water.
  • Failure of high pressure and high temperature processes resulting in chemical releases to the environment.
  • Inadequate containment of the chemical loading and unloading areas.
  • Poor underground tank management programs.
  • Improperly maintained PCB-containing electrical equipment.
  • Aboveground tanks, which are not tested or inspected for leaks through the bottoms, placed over soil.
  • Underground tanks that were removed/abandoned for unknown reasons.
  • Uncertainties about the historical use and conditions of closed on-site lagoons and landfills.
  • Insufficient groundwater monitoring around wastewater lagoons and impoundments, especially in clay-lined basins.
  • Inadequate assessment of potential impacts to groundwater from past spills and releases to on-site soils.
  • Use of hazardous gases which might be released to the environment if tanks, valves, pipes, connections, etc. fail.
  • Nuisance odors and noises.
  • Chemical plants located on heavily industrialized areas might be falsely blamed for environmental problems of other companies.
  • Poor housekeeping practices.
  • No information on past waste management practices and environmental releases.
  • Inadequate employee safety and medical surveillance programs.
  • Absent, inadequate or out-of-date emergency and spill control plans, many of which are extensive and complex.
  • Use of unusual or even exotic chemical compounds which could hinder emergency response personnel in chemical identification.
  • Poor information on the possible adverse reactions and interactions of chemical compounds that accidentally commingle during a fire.
  • Inadequate auditing of hazardous and non-hazardous waste handling and disposal contractors.
  • Obsolete and remote equipment storage (bone) yards where oils and other residual liquids percolate into the soils.
  • Inadequate backflow prevention devices to prevent harmful chemicals from siphoning back into the municipal water supply.
  • Large inventories of bulk hazardous gases stored near areas frequented by vehicular traffic.
  • Infrequent or undocumented preventive maintenance.

This is not an exhaustive list of environmental exposures. It represents the most common environmental exposures for this industry.

© 2017 Zywave, Inc. All rights reserved.

Material posted on this website is for informational purposes only and does not constitute a legal opinion or medical advice. Contact your legal representative or medical professional for information specific to your legal or medical needs.

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