The Language of EHS: Part 1

Every discipline creates its own nomenclature, develops its own acronyms, and specializes its own communication until it creates a language all its own. I have a friend who always asks me how my work is going and what I’ve been up to. I have to laugh, because I know she really wants to know, but her eyes glaze over as soon as I start talking.

I’ve seen quite a few lexicons for the EHS field, but thought I’d compile some of the terminology I hear most frequently, along with my own personal spin on their definition. Maybe this is something that will help those newbies, and not-so-newbies in the field that need an interpreter for the lingo!

These aren’t in any particular order, though I have tried to group Environmental terms together, and Safety & Health terms together.

EHS (alternatively, HSE, SHE, ES&H, etc.): All acronyms for the wonderful world of Environmental, Health and Safety. Every company comes up with their own acronym, depending on what they want to emphasize. Personally, I’m rather fond of the ‘SHE’ order, but that’s a personal thing. Some companies add Quality into the mix, some Security, so there are additional variations even in the letters included. Is it any wonder we have an identity crisis as a profession – I think not!

EPA (or USEPA, also known as the Feds – no, not the FBI, but close enough in our world): the United States Environmental Protection Agency. These folks set the directions for everyone. Regulations adopted by the states, can NOT be less stringent then the Federal regulations. And the Feds watch the states very closely. Trust me. I know. I live in Ohio, and OEPA (Ohio EPA) and the Feds have had some minor skirmishes. It’s interesting to watch the dynamics – forget about trying to truly understand them, because they’ll change again.

It’s also worth noting that each state adopts there own acronym for their environmental regulatory entity, and they aren’t all ‘EPA’. Ones I’ve seen include ‘DEP’ (Department of Environmental Protection, as in Pennsylvania); ‘DEM’ (Department of Environmental Management, as in Indiana), and ‘DEQ’ (Department of Environmental Quality, as in Michigan) – can you tell I’m a portal to the Midwest kind of girl?

RCRA: Resource Conservation and Recovery Act. This regulatory framework covers the disposal of solid and hazardous waste. The acronym ‘RCRA’ is often used synonymously with ‘hazardous’ when discussing waste, but the solid/non-hazardous wastes are addressed under this general framework as well. The primary federal hazardous waste regulations are found in 40 CFR 260-265. Note that 40 CFR is where most of the environmental regs are found, but in this business it isn’t the only CFR title you’ll need to be familiar with, so don’t put on blinders.

CFR: Huh, see how easily those acronyms creep in, and then you realize that not everyone knows what a CFR is. The CFR is the Code of Federal Regulations. If you don’t have the eCFR bookmarked, and you’re going to work in this field, do it now. No one, I repeat, no one, can keep all this in their head, and it changes periodically anyway. Even if you think you know it, check it. Also know your state regs. In Ohio, we’re governed by the OAC (Ohio Administrative Code) and the ORC (Ohio Regulatory Code). Know the code, check the code, love the code!

Back to RCRA . . . it’s worth exploring this realm a bit. Here are some of the (very) basics:

Solid Waste: A waste cannot be a hazardous waste unless it is first a solid waste. Now a solid waste is not to be confused with an actual ‘solid’ in the scientific sense. This is a lesson in READING THE DEFINITIONS because the definition of a solid waste is NOT intuitively obvious (in fact, it’s pretty convoluted and confusing). You will find that there are many things in the environmental arena that are not intuitively obvious. Always, always, always read the definitions for the title, chapter and part of the code you are reading!

Characteristic Hazardous Waste (also known as D-coded waste): These are wastes that exhibit, based on a standard test methodology, one of the four characteristics of a hazardous waste: Ignitability, Reactivity, Corrosivity and/or Toxicity. Each characteristic carries its own D-code (hence the term, D-coded waste). A waste can carry several different D-codes, and it is up to the Generator (the person who generated the waste) to ensure that it is properly tested and all applicable waste codes applied.

Listed Hazardous Waste (F-coded, K-coded, P-coded, or U-coded): This is where the haz waste regs get fun. F-coded wastes are wastes from non-specific sources. Generally speaking, F-coded waste likely also carry a D-code, but not always. K-coded waste are from specific sources (i.e., specific industrial processes), like a steel pickling line. Again, these can also, and often do carry a D-code. P- and U-coded wastes are for specific chemicals that are being discarded, and I’ve encountered them mostly when doing lab packs. The important thing to know about listed wastes is that once a waste is listed, it’s always hazardous, including any residue resulting from the treatment of it, unless it has gone through a delisting process. This is an ugly truth about listed hazardous wastes.

Mixture and Derived From Rule: Less a ‘rule’ and more part of a definition, this is often how I’ve heard it referenced. It relates to listed hazardous wastes, and it’s part of what makes them so difficult to deal with. Basically, if you mix a listed waste with another waste the whole mess carries the listed hazardous waste code, regardless of the resulting mixture characteristics. If you treat a listed hazardous waste, any residue that is left over from the treatment carries the listed hazardous waste code, regardless of the residue’s characteristics. See the definition of a hazardous waste for specifics.

Cradle to Grave: this is the extent of a Generator’s liability where hazardous waste is concerned. Basically, the concept is that once you generate a hazardous waste it is yours forever and ever – your liability for that waste never terminates. If it is buried in a landfill somewhere, and dug up 30 years in the future because it’s contaminating groundwater, you will still be footing the bill for dealing with it. This leads us into another, closely-related regulatory realm, CERCLA (see the next definition.

CERCLA (commonly know as Superfund): The acronym stands for the congressional act: Comprehensive Environmental Response, Compensation, and Liability Act. Superfund, as CERCLA is better known, is a huge, political morass of legalese that I hate to even get into. Suffice it to say that it earned its nickname ‘Superfund.’ If you’ve ever worked for a company that has been named as a PRP (Potentially Responsible Party) in a Superfund suit, you know what I’m talking about. It’s a behemoth, it’s ugly, and you don’t want to go there if you can help it. Really. Of all the lists out there the NPL (National Prioritites List) is not one any company wants to end up on.

The mantra of every environmental person worth their salt should be to MINIMIZE FUTURE LIABILITY. It’s the name of the game, because if you don’t, sometime, 20, 30 or more years down the road, it will come back to bite your employer right in the pocket book. Regardless of whether the bigwigs are interested in short-term goals, your view, as an environmental specialist, absolutely must be focused on the long-term liability of your actions.

CYA: Yeah, I know, everybody knows what that acronym means. Take it to heart. Document, document, document, if for no one else but yourself. I’ve been part of a discussion on LinkedIn recently discussing the documentation and investigation of incidents. “Our lawyer says not to do it.” Stupid, in every sense of the word in my opinion, whether you’re talking about issues related to employee safety, or environmental impact, or any other EHS issue that may come up.

Nobody is perfect – I’d argue that 100% compliance is an impossibility in the regulatory reality of the US. Just peruse the reams of regulations that are out there and tell me you can comply with the letter of the law at all times. But, that doesn’t mean that you don’t try to. Continuous improvement is the name of the game, and I think that’s why EHS ends up partnered with Quality so often. The goal should always to be to get a little bit better every day.

Alright, I know, I didn’t even scratch the surface of the environmental lingo, let alone OSHA. But this article is quite long enough. I’ll post another round of definitions in my next article. And probably another round after that. There is a LOT of ground to cover in EHS. If you are looking for a career that challenges you, this is the place to be.

If you have an area of particular interest that you would like me to address, please, leave a comment and let me know.