This area covers administrative issues related to maintaining environmental compliance at retail stores. Regulations frequently have administrative requirements such as recordkeeping, permits, reporting, training, and notification. Facilities that may otherwise be in compliance with environmental laws can be cited and even face penalties for not keeping the appropriate records. To be in compliance with these many requirements, a facility and/or company needs to have strong management and tracking programs.
It is a challenge for stores to consistently manage paperwork and records for activities outside of their core functions. For that reason, many retailers centralize recordkeeping. Two common examples are 1) having waste haulers submit records to the corporate compliance office, and 2) maintaining training records in an online training management system. Store managers need to know how to access records when inspectors ask for them. The more readily the store can provide what the inspector requests, the less likely the inspector is to expect and dig deeper for problems.
This section covers some of the common types of administrative requirements that may apply in a retail setting. The CRC regulatory area pages provide more detail on the specific requirements.
Having an organized approach to managing environmental requirements is key to staying in compliance and reducing costs associated with environmental management. An Environmental Management System (EMS) is a widely used approach for maintaining compliance and improving environmental performance over time. An EMS is a set of processes and practices that enable an organization to reduce its environmental impacts and increase its operating efficiency.
A valuable aspect of an EMS is the flexibility. A small facility that has to comply with few regulations can implement a simple, limited EMS that works for their situation, while a much larger organization that must comply with numerous regulations across many facilities will likely need a more detailed and comprehensive EMS.
For more information, visit the CRC Retail EMS Guidance page.
The table below is a summary of some of the administrative requirements that may apply to retail facilities, including stores and distribution centers.
Often environmental regulations require businesses to keep relevant records for a number of years. Specific examples of records maintained for an environmental program include training certificates, hazardous waste manifests, HVAC refrigerant records, emission testing, etc. Inspectors will expect easy access to the records; making an efficient filing system, whether digital, hard copy, or both, important.
Agency inspectors often request required records such as mandatory employee training, waste disposal records, logbooks, and weekly inspection checklists at the store. While most retail chains centralize as many administrative tasks as possible to help store operations focus on their core purpose, store management will need to manage or have access to this environmental "paperwork" at the store level. Stores should be provided with the tools they need for all aspects of compliance, including consistent and standard procedures for what records must be kept and for how long, where records are to be stored and by whom, how to access online records off the company's intranet, and who to call for assistance in obtaining copies of missing records.
One approach used by many companies is for each store to have an "Environmental Binder" with standard tabs and folders for records management, along with environmental program descriptions and procedures. Others rely on online storage and management of records and procedures. Under many regulations, the records are required to be kept on site at the store. If your company maintains records centrally in an online systems, you must ensure that store management knows how to access those records during an inspection. Store management should be able explain how your company manages the required records to agency inspectors and provide them the records they request in a timely way.
Many regulations also require periodic reporting and permit renewals. Compliance often breaks down when reporting responsibility resides with the stores. Managing reporting at the corporate level can be a daunting challenge. To effectively comply with federal, state, and local reporting requirements, a retailer must build business process and systems that meets a great majority of obligations, and minimizes the need to actively manage exceptions. Many retailers use a software-based Environmental Management Information System (EMIS) customized for retail to help manage compliance obligations with permit and renewal tracking, task assignment and accountability functions, routine reporting, regulated asset records (for example, tanks, generators, and grease traps), company audit results, and compliance analytics and dashboards.
Environmental departments often develop corporate environmental policies and promote environmental stewardship throughout the business. An environmental policy for the company is a good way to promote environmental or "green" initiatives in different parts of the business. These policies can lead to specific procedures that can improve environmental performance.
An example of a procedure would be a set of steps for how to handle an expired or spilled chemical. Another policy could be related to buying products with a smaller environmental footprint or that are less hazardous than similar products.
There are a number of voluntary environmental programs managed by regulatory agencies and non-profits that businesses can participate in. Some of these programs may be as simple as setting and achieving recycling and waste reduction goals. Others may involve inviting a regulatory agency to your facility for a voluntary inspection. Typically these types of inspections have incentives such as no documented negative findings and being skipped on the next round of actual inspections. Voluntary programs from regulatory agencies often include a requirement for an EMS.
Specific training is required by a number of regulations, such as the required training for staff who fill out hazardous waste manifests. Even if not required, general awareness training on environmental and regulatory issues as well as company policies is important for a well-functioning environmental program. The CRC Training Page has a list of training courses that may be relevant in retail. Training, especially required training, should be documented with both the content and staff who have taken the training.
Tools used for compliance can also be used to implement sustainability initiatives. An EMS can help reduce environmental impacts and implement sustainable solutions. For example, sustainability initiatives such as waste reduction can be incorporated as an objective into an EMS to ensure that it is implemented. Environmental policies can include sustainability to help make sustainability part of operational thinking.