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SITUATION
A large national and international oilfield services and waste disposal company operates shore-based terminal stations, oil and gas E&P waste processing and disposal facilities, and drilling mud plants. As part of its compliance assurance program, as directed by its Board of Directors, the company solicits the assistance of third-party consultants to evaluate the company’s compliance with applicable environmental and safety regulations.
SOLUTIONS
Premier staff has conducted environmental and health and safety compliance audits of the company’s facilities located along the Gulf Coast and in other states. As part of the annual compliance audits, environmental and health and safety compliance issues are evaluated and corrective actions proposed, where necessary, so that the company can assure its customers, investors, insurers, and Board of Directors that the company is operating in compliance with applicable environmental and health and safety laws and regulations. Typical laws/regulations against which compliance is evaluated include elements of: Occupational Safety and Health Act (OSHA), Federal Clean Water Act, Federal Clean Air Act, Federal Resource Conservation and Recovery Act (RCRA), Oil Pollution Act of 1990 (OPA), Texas Solid Waste Disposal Regulations, and State of Texas equivalents of the aforementioned federal laws. Upon completion of the audits, a findings report is prepared per facility and presented to the company’s executive management. Based on the findings, the company’s executive management initiates corrective actions where necessary and closes out the findings by documenting the results of the corrective actions.
RESULTS
The environmental and health and safety compliance audit program typically identifies several process-related and facility-specific findings that need to be corrected as part of compliance assurance. The company receives such findings without prejudice and strives to correct issues of non-compliance diligently. Results of such audits are made available to prospective customers and investors. Premier staff’s involvement in the audit program assists the company in a consistent, objective review of its compliance status.