1.0 PURPOSE
Nitro Construction Services is committed to protecting, preserving, and enhancing the environment. The purpose of this Environmental Compliance Program is to ensure compliance with environmental regulations, reduce environmental risks, and continuously improve environmental performance for a Project Construction Site managed by Nitro Construction Services.
2.0 RESPONSIBILITIES
All project personnel shall participate in the environmental compliance program. The key individuals involved in the development and implementation of the project environmental program are:
2.1 Project Manager – shall facilitate the environmental program and provide the necessary resources to effectively implement the program. Key activities include:
2.1.1 Ensuring a site environmental plan is developed and implemented before starting work if required by the customer.
2.1.2 Monitoring compliance with plan requirements;
2.1.3 Implementing corrective action as required to maintain compliance;
2.1.4 Verifying that all subcontractors have submitted their site environmental plan, as applicable, before the commencement of on-site work.
2.2 Environmental Coordinator – shall designate one member of its project management team as the Environmental Coordinator. Duties of the Environmental Coordinator shall include:
2.2.1 Coordinating with the project managers and customers to ensure potential environmental risks and compliance issues are addressed;
2.2.2 Assisting project team with development and implementation of the Site Environmental Plan, if required by the customer.
2.2.3 Reviewing Nitro Construction Services and subcontractor work plans for environmental compliance, and
2.2.4 Evaluating project opportunities to continuously improve the environmental program.
2.3 Field Personnel/Supervision – shall perform their work in compliance with the requirements stated in the Site Environmental Plan. Supervisors responsible for employees performing work covered by the Site Environmental Plan must:
2.3.1 Confirm that each job has been properly evaluated for hazards and that these hazards have been eliminated or controlled;
2.3.2 Ensure that employees are aware of hazards associated with their work;
2.3.3 Continuously monitor the work to assure compliance with the Site Environmental Plan.
3.0 REFERENCES
3.1 US 40 CFR – Protecting the Environment
3.2 US State and Local Environmental Quality-Related Regulations
3.3 International Country and Local Specific Regulatory Agencies
4.0 DEFINITIONS
4.1 Environmental Coordinator – Competent individual assigned to manage or conduct environmentally-related functions, such as hazardous waste management, etc.: single point of contact for company employees, subcontractors, and regulatory agencies regarding project environmental issues.
4.2 Environmental Management System (EMS) – a work process that provides a framework and a systematic approach to managing environmental responsibilities and regulatory compliance.
4.3 Environmental Plan – a plan prepared to implement tasks identified in the project’s environmental checklist.
5.0 PROCEDURE
5.1 Nitro project managers and subcontractors are responsible for assessing potential environmental risk and managing, inspecting, and documenting environmental compliance.
5.2 This Program provides tools to identify potential environmental concerns, evaluate risk, and manage environmental performance responsibilities under regulatory compliance and best practices.
5.3 The Nitro project managers and subcontractors are responsible for regulatory compliance, assessing potential environmental risk, managing, inspecting, and documenting environmental compliance. Nitro and their subcontractor(s) will designate a person responsible for their on-site environmental compliance. All work will be conducted per applicable regulatory standards, operating permits, customer requirements, and best practices.
6.0 PROJECT ENVIRONMENTAL PLAN
6.1 Based on the requirements of the customer and/or project, a Site Environmental Plan shall be developed to eliminate, reduce, and control environmental risks. This must be completed before starting work.
6.2 The Project Manager will develop the Site Environmental Plan, which will:
6.2.1 Identify the work activities that pose a potential environmental risk,
6.2.2 Describe control measures to prevent environmental incidents,
6.2.3 Assign responsibilities to designated personnel or groups,
6.2.4 Designate completion dates to critical actions, and
6.2.5 Describe reporting procedures in the case of environmental incidents.
6.3 Segregation and proper disposal of wastes shall be included in the Site Environmental Plan and shall follow each facility’s requirements. Opportunities for recycling shall also be evaluated.
7.0 IMPLEMENTATION
7.1 The project managers will secure resources (budget, trained personnel, schedule, equipment, etc.) to facilitate and implement the Site Environmental Plan.
8.0 MEASUREMENT AND EVALUATION
8.1 Each project will track performance, compliance, and effectiveness of corrective actions.
8.2 Self-assessments or audits and corrective actions related to environmental performance will be reported as needed to the Project Manager and Environmental Coordinator (i.e., daily, weekly, or monthly).
9.0 AUDIT AND CONTINUOUS IMPROVEMENT
9.1 Nitro and subcontractor supervisors shall conduct periodic environmental self-inspections to verify and document that work procedures are being followed as required to maintain compliance with all applicable regulations.
9.2 The Nitro Corporate Safety Director will conduct periodic, formal environmental inspections to assess environmental performance and compliance.
9.3 Results of these inspections will be sent to the Project Manager and Environmental Coordinator.
10.0 RECORDKEEPING
10.1 Each subcontractor shall maintain environmental records related to their project work activities. These records will be available for review by Nitro or customer representatives and may be the subject of audits by regulatory agencies.
10.2 The project managers and subcontractor(s) shall be responsible for maintaining and tracking project environmental compliance program records.
10.3 Specific record and document requirements should be listed in the Site Environmental Plan.
11.0 TRAINING
11.1 A training program shall be established to ensure that each employee is trained in the information and skills needed to complete all tasks in an environmentally responsible way.
11.2 Training requirements will be dependent on the job(s) being performed and/or customer requirements.
11.3 Records of this training shall be available for an audit.
11.4 Records retention shall be compliant with the customer’s requirements.
11.5 Nitro Construction Services shall ensure that each subcontractor has provided training to the Subcontractor’s employees to enable them to do their work in an environmentally responsible way.
12.0 APPENDICES
12.1 NCS Form 037 – Project Environmental Assessment Checklist