Comprehensive Industrial Compliance Services

MFA provides a wide range of air, stormwater, and health and safety compliance services to this industrial client based in Oregon. MFA conducted an assessment that informed the development of a company-wide health and safety program, developed reports required to comply with state and federal environmental regulations, including for Oregon air toxics inventories, toxics release inventories, stormwater pollution control plan and discharge monitoring and discharge monitoring reporting, and toxic use and hazardous waste reduction planning. Taking a big picture approach to health and safety programs helps this client maintain a compliant workplace.

MFA’s Health and Safety, Air, and Stormwater services teams provided Malarkey with the following key project solutions: 

Company-Wide Industrial Hygiene Assessment

MFA helped Malarkey assess chemical and occupational noise exposures in its workplaces. The scope of the chemical exposure assessment included asphalt, silica, dust, fiberglass, and formaldehyde. Data from the assessment was evaluated by a large industry trade group that prepared comments in response to proposed OSHA standards. 

Oregon Air Toxics Inventory Reporting

MFA’s Air Services team assisted the client with the development of emissions inventories for toxic air contaminants, compiling their findings in a report required by the Oregon air toxics regulations. Drawing on our deep expertise in developing emissions inventories, MFA kicked off the project with the identification of emission sources, taking a look at nonexempt sources of air toxics (both permitted and unpermitted) and included our results in the client’s response to the Oregon DEQ. We then developed an emissions inventory that included current and projected maximum annual emissions for each emission source.

Toxics Release Inventory Reporting

To assist Malarkey with the preparation of Toxics Release Inventory reporting forms, we worked with the client to compile records of reportable hazardous substance use, stormwater and wastewater discharges, air emissions, and other reportable release information. MFA entered the resulting data in the USEPA’s TRI-MEweb online reporting program on behalf of the client.

Toxic-Use and Hazardous-Waste Reduction Plan

A Toxic-Use and Hazardous-Waste Reduction Plan was developed by our health and safety team to comply with Oregon Administrative Rules and reduce the client’s chemical use and hazardous waste generation. In the plan, we recommended annual goals such as evaluating current and new technologies that can achieve further reductions of toxic chemicals and hazardous waste; reviewing and updating relevant processes and personnel procedures; and training employees on ways to help the facility reach its reduction goals.

Stormwater Pollution Control Plan and Discharge Monitoring Report

MFA’s Stormwater Services team prepared a SWPCP consistent with the National Pollutant Discharge Elimination System Stormwater Discharge Permit No. 1200-Z issued to the client by the Oregon DEQ. The SWPCP addressed the requirements of the NPDES No. 1200-Z Permit and served as a guidance document for the client to manage the quality of stormwater discharged from the site to the receiving waters, and included helpful checklists, site descriptions and controls, and guidance for recordkeeping and internal reporting to streamline future SWPCP submittals.

We also developed discharge monitoring reports summarizing data from stormwater sampling at the client’s industrial facilities in Oregon. The reports submitted were consistent with the requirements of the NPDES Stormwater Discharge Permit No. 1200-Permit.

Lasting Compliance Solutions

We provided Malarkey  with an industrial hygiene program handbook, meant to be a living document that they can use as a tool to guide their daily health and safety practices. The company maintains contact with MFA for major regulatory updates and has established a designated in-house health and safety advisor who can update the program on an as-needed basis.