I had an apostrophe today. It wasn’t nearly profound enough to be called an epiphany, but for me it was pretty clarifying. I’ve been thinking a lot about various ‘global’ environmental issues and environmental regulation in general, and wondering in this era of companies ‘going green’ and spouting about ‘corporate responsibility’ why do we still have to go down the path of behemoth regulatory messes in order to get anyone to do anything about environmental issues?
I’m sure I’m oversimplifying, but I wonder if part of the issue isn’t that in economics, as currently practiced, it’s very common to discount the social and environmental costs of the business decisions we make. From an economic standpoint, we really haven’t learned the lessons of the last 50 years, or even the last 5. Just look at the continuing debacle that is Wall Street. Is the environmental industry any better?
Minimizing future liability is a nice idea, but it’s a difficult thing to justify in a real time way. Sure, the bigwigs understand that they don’t want to contribute to a Love Canal (Superfund was a great teacher, folks) – but do they understand how their actions contribute to say the acidification of the ocean, or global warming? Do we have a clue what the social and economic impact of these types of potentially huge ecosystem shifts could have in the future? How much ‘human impact’ are we willing to tolerate as ok and how much are we going to pay a price for?
These are fundamental questions that I would challenge anyone to tackle. These are the issues that behemoth regulatory bureaucracies are built around in this country. Gone are the days when a single point source of pollution could be pointed at as ‘the bad guy.’ Now, we’re all bad guys. Individually, each and every human, like it or not, has a carbon footprint, and contributes in a real, bottom-line way to the changes occurring in our environment.
I went to a technical conference yesterday. It was a very good program, and had a lot of great topics on ‘going green.’ But I had to laugh when the guy from the ‘solutions’ arm of the electric utility conglomerate got up to speak. He spoke of the work being done to implement alternative renewable energy sources, many of which, particularly in Ohio, are just not very ‘economical.’
He spoke proudly of an old coal-fired plant where one of the burners is being converted over to biomass fuel, and said that even that wasn’t really ‘economical’ but was being done under consent decree. But what I’m really curious about, now that I think about it, is what does ‘economical’ mean in this context? Compared to coal? Compared to how the plant was historically run, which apparently caused problems if it’s under consent decree? Compared to the cost of continuing to run coal into the future until the fuel source dries up? Compared to the cost of relocating coastal communities in 50 years when the oceans rise, and millions of homes are underwater? Economical is a tricky word to be throwing around when you look at the big picture.
I personally will think about that the next time I'm considering the need to limit future liability. Corporate responsibility, like personal responsibility, only goes so far as the bottom line. Until the economics of future impact are truly integrated into our economic decisions on a routine basis in this country, we’re going to continue to have regulatory elephants entering the room.
What do you think?
Wednesday, May 19, 2010
Thursday, April 22, 2010
Environmental Lexicon Part III: More on Air
I have been mired in PAL permitting work for one of my clients. I can see the benefit of the permit, but at times it just seems the path to the final product is too long and convoluted to traverse safely and efficiently. This is a fairly new permitting realm in the EPA world. In fact there are currently no permits of this kind in Ohio, which complicates matters.
So, I thought today I would share what I'm learned about the Plantwide Applicability Limit, or PAL permit option. We talked about the NAAQS last time and the PAL is a direct result of the existence of the NAAQS. Below are some related definitions.
New Source Review or NSR is a pre-construction permit program for significant new or modified source of air emissions at major stationary sources. The basic idea is to ensure that any new or modified air emission source construction does not adversely impact the air quality (specifically NAAQS) in a non-attainment area. NSR permitting is a notoriously long and arduous process, taking up to and sometimes over a year to complete. It is also not uncommon, under project aggregation, to inadvertently miss the need for NSR permitting, particularly if you are sometimes major and sometimes not (I'll discuss this a bit more below).
Prevention of Significant Deterioration or PSD is kind of the counterpart to NSR but for sources located in an attainment area. The requirements are not as strict, but the general intent is similar to NSR. I mention this just because even in NAAQS attainment areas there are requirements that must be met regarding maintenance of air quality. So just because you're in an attainment area doesn't mean you are home free.
Major Stationary Source is a source, or group of sources that has a 'potential to emit' (see definition below) a regulated pollutant in excess of the major stationary source threshold. In an attainment area, unless the source is one of a group of 26 industries for which the threshold is set at 100 TPY, the threshold is 250 TPY. In a non-attainment area, the threshold is 100 TPY, regardless of industry. Note that a source that is major for VOC (volatile organic compounds) is considered major for ozone.
Potential to Emit or PTE is the maximum emission of pollutants from an emission unit or stationary source usually based on 365 days per year, 24 hours per day operation, UNLESS there are federally enforceable limits that place legally-binding operational limits on the unit/source. Developing the PTE calculations for a new/modified source is the first step that must be taken in order to determine the applicability of the various air permitting requirements. Often voluntary restrictions can be written into a permit to install (they must be in the federally-enforceable portion of the permit) to avoid major source issues, if they are operationally feasible.
That brings us, in a round-about way to the PAL or Plantwide Applicability Limit. Plant-wide limits are not a new concept. When Title V permits were born, along with them came a plant-wide limit that would allow a source that was a major facility based on PTE to take voluntary, federally-enforceable limits to reduce allowable emission below the major-source threshold, allowing the facility to be a synthetic minor, thus avoiding Title V permitting. (Side note - 'major' in Title V has a different definition then 'major' in NSR/PSD).
The PAL is a similar idea, only instead of avoiding Title V permitting, with a PAL the facility is avoiding NSR pre-construction permitting issues. Another neat thing about the PAL is that it can provide some flexibility, depending on how the permit terms and conditions are written. For a facility which is looking at possible expansions that are likely to be over the 'significant' level for a regulated pollutant, but is also working on improving their existing processes to reduce emissions of the regulated pollutant, the PAL can offer a nice unbrella under which to make changes without triggering NSR.
I am still reading and learning about the PAL, and permit flexibility. It's a huge issue, especially given the economic pressures that industry is facing. The ability to make changes rapidly in response to business opportunities is something that my clients are always interested in. It is worthwhile to review your permit structure and take advantage of whatever flexibility you can get written into the permits themselves.
Any tips for building flexibility into air permits? Just curious what others are doing or have seen done.
So, I thought today I would share what I'm learned about the Plantwide Applicability Limit, or PAL permit option. We talked about the NAAQS last time and the PAL is a direct result of the existence of the NAAQS. Below are some related definitions.
New Source Review or NSR is a pre-construction permit program for significant new or modified source of air emissions at major stationary sources. The basic idea is to ensure that any new or modified air emission source construction does not adversely impact the air quality (specifically NAAQS) in a non-attainment area. NSR permitting is a notoriously long and arduous process, taking up to and sometimes over a year to complete. It is also not uncommon, under project aggregation, to inadvertently miss the need for NSR permitting, particularly if you are sometimes major and sometimes not (I'll discuss this a bit more below).
Prevention of Significant Deterioration or PSD is kind of the counterpart to NSR but for sources located in an attainment area. The requirements are not as strict, but the general intent is similar to NSR. I mention this just because even in NAAQS attainment areas there are requirements that must be met regarding maintenance of air quality. So just because you're in an attainment area doesn't mean you are home free.
Major Stationary Source is a source, or group of sources that has a 'potential to emit' (see definition below) a regulated pollutant in excess of the major stationary source threshold. In an attainment area, unless the source is one of a group of 26 industries for which the threshold is set at 100 TPY, the threshold is 250 TPY. In a non-attainment area, the threshold is 100 TPY, regardless of industry. Note that a source that is major for VOC (volatile organic compounds) is considered major for ozone.
Potential to Emit or PTE is the maximum emission of pollutants from an emission unit or stationary source usually based on 365 days per year, 24 hours per day operation, UNLESS there are federally enforceable limits that place legally-binding operational limits on the unit/source. Developing the PTE calculations for a new/modified source is the first step that must be taken in order to determine the applicability of the various air permitting requirements. Often voluntary restrictions can be written into a permit to install (they must be in the federally-enforceable portion of the permit) to avoid major source issues, if they are operationally feasible.
That brings us, in a round-about way to the PAL or Plantwide Applicability Limit. Plant-wide limits are not a new concept. When Title V permits were born, along with them came a plant-wide limit that would allow a source that was a major facility based on PTE to take voluntary, federally-enforceable limits to reduce allowable emission below the major-source threshold, allowing the facility to be a synthetic minor, thus avoiding Title V permitting. (Side note - 'major' in Title V has a different definition then 'major' in NSR/PSD).
The PAL is a similar idea, only instead of avoiding Title V permitting, with a PAL the facility is avoiding NSR pre-construction permitting issues. Another neat thing about the PAL is that it can provide some flexibility, depending on how the permit terms and conditions are written. For a facility which is looking at possible expansions that are likely to be over the 'significant' level for a regulated pollutant, but is also working on improving their existing processes to reduce emissions of the regulated pollutant, the PAL can offer a nice unbrella under which to make changes without triggering NSR.
I am still reading and learning about the PAL, and permit flexibility. It's a huge issue, especially given the economic pressures that industry is facing. The ability to make changes rapidly in response to business opportunities is something that my clients are always interested in. It is worthwhile to review your permit structure and take advantage of whatever flexibility you can get written into the permits themselves.
Any tips for building flexibility into air permits? Just curious what others are doing or have seen done.
Monday, April 5, 2010
The Language of EHS Part II: Air
Continuing with my take on the EHS lexicon, let's talk about one of the more ubiquitous and unwieldy parts of the EHS regulatory arena: Air. Whether you're talking about environmental or safety, air quality is an issue that is going to come up, and it can get sticky. How are the contaminant emissions from the facility stacks impacting the local community? And 'closer to home' how is air quality within the facility impacting worker safety and productivity?
These are the kinds of questions that are at the heart of the air arena. Of course, the regulations that have been constructed around these two questions sometimes get just a wee bit off course, but that's part and parcel to our command and control regulatory structure here in the US. But I digress.
Let's explore some of the language of air in the EHS world.
CAA: Clean Air Act. This was the legislation that would forever create the regulatory structure for air quality under which US companies currently struggle. The enacting regulations are lengthy and convoluted (like many environmental regs) and for any company that employs contaminant-emitting processes, this likely represent the biggest time-eater for their environmental staff.
Title V: refers to Title V of the CAA as amended in 1990. This resulted in the creation of a new operating permit structure for 'major sources' of air emissions. Under this structure, a source is major if it emits more than the threshold of any of the criteria pollutants. If a facility is a major source, it is required to obtain a Title V operating permit.
Ok, I just re-read that definition, and it spouts lingo left and right, here are some of the related definitions, to help clarify.
Let's start with the NAAQS: National Ambient Air Quality Standards. Ambient Air Quality standards, or criteria, are set for six common, or 'criteria pollutants:' Ozone, Particulate Matter, Carbon Monoxide, Nitrogen Oxides, Sulfur Dioxide, and Lead. The criteria are not stagnant, and change periodically. When they do, it throws everyone into a tizzy because it impacts what areas of the country are designated 'attainment' versus 'non-attainment' for the pollutant in question.
Attainment/Non-attainment is basically an evaluation of the air quality of an area (in Ohio, areas are designated attainment/non-attainment on a county by county basis, for the most part, other states may vary) against the criteria for the pollutant in question. If an area is 'attainment' for a pollutant it means that the area, on average, meets the NAAQS criteria for that pollutant. The states had to set up a huge network of monitoring stations in order to monitor for the criteria pollutants, and it is based on this data that designations are made.
When a new NAAQS standard is released, USEPA includes a deadline for each state to recommend designations within its boundaries. The state environmental regulatory agency evaluates all available monitoring data, and makes recommendations to the USEPA, with supporting evidence, for the designation of each area as either attainment or non-attainment for the new criteria. USEPA then reviews the information provided, and either agrees (making the designation 'official') or disagrees, and counters. This process is lengthy, and can lead to some back and forth between the state agency and the Feds.
It makes a BIG difference how an area is designated, because it impacts the definition of 'major source' as well as what type of permit a major source must pursue when installing a new emitting unit (or a new facility, for that matter). Companies have been known to locate plants based on the existing designation of an area, and this can be a huge consideration for new installations. As a result, NAAQS designation can have a profound impact on the economy of an area, particularly in heavily industrialized regions. I'm from Ohio. I know from whence I speak here. Economic impact has become a huge issue between OEPA and the Feds for precisely this reason.
Alright, again, I barely scratched the surface of the environmental regulations realted to air quality, but I really want to get into the safety regulations, because it's an important topic. indoor air quality (IAQ) in a facility is essential to worker health and safety, and is something that can generally be managed through installation and maintenance of appropriate ventilation equipment.
OSHA has published data on what they consider 'adequate' air quality for various chemicals and pollutants. There is a whole bunch of acronyms that go along with understanding this regulatory realm, and what 'limits' an employer should evaluate against is something I've heard debated more than once. Let's start with the OSHA 'official' limits, and then we'll discuss other sources that you should review.
PEL: Permissible Exposure Limits - OSHA has established over 500 PELs, mostly within 29 CFR 1910.1000 Table Z-1. These are regulatorily-required limits related to air quality within workers' breathing zones (also referred to as BZ). PELs are set mostly as 8-hour TWA or time-weighted average, limits. For evaluating this limit, air quality is measured continuously over a typical 8-hour shift, and the average exposure must be below the TWA limit. There are also PEL-STELs or short-term exposure limits, usually 15-minutes. For evaluation purposes, the continuous measurements are averaged in 15-minute increments, and for no 15-minute period may the STEL go above the limit, even if the TWA is below the limit. Some chemicals may even have a PEL-C, or ceiling limit established, which is an exposure limit over which a worker should NEVER be exposed.
NIOSH: the National Institute of Occupational Safety and Health is part of the Center for Disease Control & Prevention (CDC). This agency is responsible for conducting research and making recommendations on the prevention of workplace injuries and illnesses, and as part of that directive publishes the NIOSH Pocket Guide to Chemical Hazards (NPG). The NPG is updated far more frequently then the OSHA PELs. The 2005 NPG contains general industrial occupational exposure limits for 677 chemicals. The NIOSH limits, referred to as RELs (Recommended Exposure Limit), follow terminology analogous to that used by OSHA, with TWA, ST and C limits. The NPG is particularly useful, because it also provide a lot of other data on the chemical, such as its chemical properties, exposure routes, symptoms of exposure, etc. As a bonus, the entire guide is available on line, or in a downloadable format from the CDC. However, NIOSH is NOT a regulatory body, and can only make recommendations regarding exposure limits. These limits do not carry the force of law, though OSHA has been known to enforce them under the General Duty Clause.
ACGIH: American Conference of Governmental Industrial Hygienists (though I notice on their web page that they have dropped the 'governmental' part of the acronym, which I find curious). ACGIH also publishes their own set of occupational exposure limits. ACGIH is an entirely independent body, not related to the government. Their exposure limits, called TLVs or Threshold Limit Values, are developed by a body of independent IHs (Industrial Hygienists). There have been instances where the science behind thier limits has been questioned, and I am, by no means suggesting that you blindly accept the limits ACGIH publishes. However, though OSHA does not generally enforce these limits, it is always good to be aware of them. ACGIH is often at the leading edge of limit setting for occupational exposures, and if they choose to make a stink about a particular chemical, NIOSH and OSHA usually at least lend an ear, if not a hammer.
General Duty Clause: I realized, looking over the above, that I threw out a term that you hear bandied around in the OSHA realm a lot, and there's a good reason for it. The General Duty Clause is a catchall in the OSH Act of 1970, and states in part that "Each employer shall furnish . . . a place of employment which [is] free from recognized hazards that are causing or are likely to cause death or serious physical harm . . ." As an employer, therefore, it is not enough to comply with the OSHA standards, but you must take action to abate any and all recognized hazards. That is why it is important to be aware of what NIOSH and ACGIH have published as limits. Though fairly recent court rulings have put the brakes on OSHA issuing citations against NIOSH or ACGIH limits, note that states can, and often do adopt more stringent limits then OSHA (Particularly California, where CalOSH has been known to adopt ACGIH limits as law).
It is in every company's best interest to periodically test the air quality within their facility. Developing a routine Air Quality Evaluation protocol. Physical testing should be conducted at least once every couple years, or when there is a change in the facility operations. If your company is a small business, the state BWC (Bureau of Workers Compansation) will often offer help. I know in Ohio, at least at one point in time, BWC would actually come in and perform the testing for a small company, and provide the results with a preliminary evaluation. There are also consulting firms that offer this sort of testing, and can also provide aid for taking corrective measures where problems are found.
The key when designing any new industrial process is to ensure that proper ventilation and other safety measures are included in the design requirements up front to avoid the development of problems once the process goes into operation. However, as with any new process, it is important to test to ensure that everything is working as designed.
In addition, tracking results over time, and under different operating scenarios (summer versus winter, for example) can also help reveal conditions under which worker safety and health may be compromised, even with appropriate controls in place. Air quality is influenced by so many factors, that a one-time testing under controlled conditions is not enough to provide a clear picutre of the exposures a worker may experience.
I got a bit off-topic there toward the end. I will be back next week with the next installment of my take on the EHS lexicon. Again, if you have any particular areas you'd like covered, leave a comment and let me know.
These are the kinds of questions that are at the heart of the air arena. Of course, the regulations that have been constructed around these two questions sometimes get just a wee bit off course, but that's part and parcel to our command and control regulatory structure here in the US. But I digress.
Let's explore some of the language of air in the EHS world.
CAA: Clean Air Act. This was the legislation that would forever create the regulatory structure for air quality under which US companies currently struggle. The enacting regulations are lengthy and convoluted (like many environmental regs) and for any company that employs contaminant-emitting processes, this likely represent the biggest time-eater for their environmental staff.
Title V: refers to Title V of the CAA as amended in 1990. This resulted in the creation of a new operating permit structure for 'major sources' of air emissions. Under this structure, a source is major if it emits more than the threshold of any of the criteria pollutants. If a facility is a major source, it is required to obtain a Title V operating permit.
Ok, I just re-read that definition, and it spouts lingo left and right, here are some of the related definitions, to help clarify.
Let's start with the NAAQS: National Ambient Air Quality Standards. Ambient Air Quality standards, or criteria, are set for six common, or 'criteria pollutants:' Ozone, Particulate Matter, Carbon Monoxide, Nitrogen Oxides, Sulfur Dioxide, and Lead. The criteria are not stagnant, and change periodically. When they do, it throws everyone into a tizzy because it impacts what areas of the country are designated 'attainment' versus 'non-attainment' for the pollutant in question.
Attainment/Non-attainment is basically an evaluation of the air quality of an area (in Ohio, areas are designated attainment/non-attainment on a county by county basis, for the most part, other states may vary) against the criteria for the pollutant in question. If an area is 'attainment' for a pollutant it means that the area, on average, meets the NAAQS criteria for that pollutant. The states had to set up a huge network of monitoring stations in order to monitor for the criteria pollutants, and it is based on this data that designations are made.
When a new NAAQS standard is released, USEPA includes a deadline for each state to recommend designations within its boundaries. The state environmental regulatory agency evaluates all available monitoring data, and makes recommendations to the USEPA, with supporting evidence, for the designation of each area as either attainment or non-attainment for the new criteria. USEPA then reviews the information provided, and either agrees (making the designation 'official') or disagrees, and counters. This process is lengthy, and can lead to some back and forth between the state agency and the Feds.
It makes a BIG difference how an area is designated, because it impacts the definition of 'major source' as well as what type of permit a major source must pursue when installing a new emitting unit (or a new facility, for that matter). Companies have been known to locate plants based on the existing designation of an area, and this can be a huge consideration for new installations. As a result, NAAQS designation can have a profound impact on the economy of an area, particularly in heavily industrialized regions. I'm from Ohio. I know from whence I speak here. Economic impact has become a huge issue between OEPA and the Feds for precisely this reason.
Alright, again, I barely scratched the surface of the environmental regulations realted to air quality, but I really want to get into the safety regulations, because it's an important topic. indoor air quality (IAQ) in a facility is essential to worker health and safety, and is something that can generally be managed through installation and maintenance of appropriate ventilation equipment.
OSHA has published data on what they consider 'adequate' air quality for various chemicals and pollutants. There is a whole bunch of acronyms that go along with understanding this regulatory realm, and what 'limits' an employer should evaluate against is something I've heard debated more than once. Let's start with the OSHA 'official' limits, and then we'll discuss other sources that you should review.
PEL: Permissible Exposure Limits - OSHA has established over 500 PELs, mostly within 29 CFR 1910.1000 Table Z-1. These are regulatorily-required limits related to air quality within workers' breathing zones (also referred to as BZ). PELs are set mostly as 8-hour TWA or time-weighted average, limits. For evaluating this limit, air quality is measured continuously over a typical 8-hour shift, and the average exposure must be below the TWA limit. There are also PEL-STELs or short-term exposure limits, usually 15-minutes. For evaluation purposes, the continuous measurements are averaged in 15-minute increments, and for no 15-minute period may the STEL go above the limit, even if the TWA is below the limit. Some chemicals may even have a PEL-C, or ceiling limit established, which is an exposure limit over which a worker should NEVER be exposed.
NIOSH: the National Institute of Occupational Safety and Health is part of the Center for Disease Control & Prevention (CDC). This agency is responsible for conducting research and making recommendations on the prevention of workplace injuries and illnesses, and as part of that directive publishes the NIOSH Pocket Guide to Chemical Hazards (NPG). The NPG is updated far more frequently then the OSHA PELs. The 2005 NPG contains general industrial occupational exposure limits for 677 chemicals. The NIOSH limits, referred to as RELs (Recommended Exposure Limit), follow terminology analogous to that used by OSHA, with TWA, ST and C limits. The NPG is particularly useful, because it also provide a lot of other data on the chemical, such as its chemical properties, exposure routes, symptoms of exposure, etc. As a bonus, the entire guide is available on line, or in a downloadable format from the CDC. However, NIOSH is NOT a regulatory body, and can only make recommendations regarding exposure limits. These limits do not carry the force of law, though OSHA has been known to enforce them under the General Duty Clause.
ACGIH: American Conference of Governmental Industrial Hygienists (though I notice on their web page that they have dropped the 'governmental' part of the acronym, which I find curious). ACGIH also publishes their own set of occupational exposure limits. ACGIH is an entirely independent body, not related to the government. Their exposure limits, called TLVs or Threshold Limit Values, are developed by a body of independent IHs (Industrial Hygienists). There have been instances where the science behind thier limits has been questioned, and I am, by no means suggesting that you blindly accept the limits ACGIH publishes. However, though OSHA does not generally enforce these limits, it is always good to be aware of them. ACGIH is often at the leading edge of limit setting for occupational exposures, and if they choose to make a stink about a particular chemical, NIOSH and OSHA usually at least lend an ear, if not a hammer.
General Duty Clause: I realized, looking over the above, that I threw out a term that you hear bandied around in the OSHA realm a lot, and there's a good reason for it. The General Duty Clause is a catchall in the OSH Act of 1970, and states in part that "Each employer shall furnish . . . a place of employment which [is] free from recognized hazards that are causing or are likely to cause death or serious physical harm . . ." As an employer, therefore, it is not enough to comply with the OSHA standards, but you must take action to abate any and all recognized hazards. That is why it is important to be aware of what NIOSH and ACGIH have published as limits. Though fairly recent court rulings have put the brakes on OSHA issuing citations against NIOSH or ACGIH limits, note that states can, and often do adopt more stringent limits then OSHA (Particularly California, where CalOSH has been known to adopt ACGIH limits as law).
It is in every company's best interest to periodically test the air quality within their facility. Developing a routine Air Quality Evaluation protocol. Physical testing should be conducted at least once every couple years, or when there is a change in the facility operations. If your company is a small business, the state BWC (Bureau of Workers Compansation) will often offer help. I know in Ohio, at least at one point in time, BWC would actually come in and perform the testing for a small company, and provide the results with a preliminary evaluation. There are also consulting firms that offer this sort of testing, and can also provide aid for taking corrective measures where problems are found.
The key when designing any new industrial process is to ensure that proper ventilation and other safety measures are included in the design requirements up front to avoid the development of problems once the process goes into operation. However, as with any new process, it is important to test to ensure that everything is working as designed.
In addition, tracking results over time, and under different operating scenarios (summer versus winter, for example) can also help reveal conditions under which worker safety and health may be compromised, even with appropriate controls in place. Air quality is influenced by so many factors, that a one-time testing under controlled conditions is not enough to provide a clear picutre of the exposures a worker may experience.
I got a bit off-topic there toward the end. I will be back next week with the next installment of my take on the EHS lexicon. Again, if you have any particular areas you'd like covered, leave a comment and let me know.
Tuesday, March 30, 2010
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.
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.
Monday, November 9, 2009
OSHA's Hot Topic: Combustible Dust
I was reading an article relating OSHA's Top 10 Safety Violations for 2009 and it struck me that there was no mention of an issue that I am certain ranks pretty high on OSHA's list of problems: Combustible Dust.
Who hasn't heard about the Chemical Safety Board's investigations regarding combustible dust? Since then, there have been numerous additional incidents contributed to combustible dust. OSHA reissued its Combustible Dust NEP in 2008 and Congress got into the act with the Combustible Dust Explosions and Fires Act of 2008. I'd definitely say that combustible dust is a hot topic for OSHA. So why isn't it in OSHA's Top 10 list?
Well, until OSHA develops it's own standard for combustible dust, it is citing employers on combustible dust issues under the General Duty Clause. As a result, combustible dust is invisible to a top ten list. However, in their Combustible Dust NEP Status Report OSHA found over 4900 violations during inspections conducted pursuant to the NEP. If you are a safety professional, and you have not yet read this report - DO SO NOW.
I have a client that has spent the last year addressing the violations with which they were cited under this NEP. We had discussed the issue previous to the inspection, but they were confident that their dust was non-combustible. Wrong. If you don't know, have your dust(s) tested to find out if it is combustible. If it is, you better start evaluating the hazards in your workplace and taking appropriate corrective actions. Itis going to take time, so get started now, and do your homework. Costs are high for corrective measures, but the costs of an incident are higher.
So, if you checked over OSHA's top 10 list and decided you were in good shape, think again. Combustible dust is a hot topic, and one you need to seriously evaluate in your workplace. OSHA has a decent resource page on combustible dust. NFPA 654 is the primary standard for general industry, and until OSHA develops their own standard, is likely the place to go for guidance. To keep up with the latest on combustible dust, visit the Combustible Dust Policy Institute blog.
Have you reviewed your workplace for combustible dust hazards?
Who hasn't heard about the Chemical Safety Board's investigations regarding combustible dust? Since then, there have been numerous additional incidents contributed to combustible dust. OSHA reissued its Combustible Dust NEP in 2008 and Congress got into the act with the Combustible Dust Explosions and Fires Act of 2008. I'd definitely say that combustible dust is a hot topic for OSHA. So why isn't it in OSHA's Top 10 list?
Well, until OSHA develops it's own standard for combustible dust, it is citing employers on combustible dust issues under the General Duty Clause. As a result, combustible dust is invisible to a top ten list. However, in their Combustible Dust NEP Status Report OSHA found over 4900 violations during inspections conducted pursuant to the NEP. If you are a safety professional, and you have not yet read this report - DO SO NOW.
I have a client that has spent the last year addressing the violations with which they were cited under this NEP. We had discussed the issue previous to the inspection, but they were confident that their dust was non-combustible. Wrong. If you don't know, have your dust(s) tested to find out if it is combustible. If it is, you better start evaluating the hazards in your workplace and taking appropriate corrective actions. Itis going to take time, so get started now, and do your homework. Costs are high for corrective measures, but the costs of an incident are higher.
So, if you checked over OSHA's top 10 list and decided you were in good shape, think again. Combustible dust is a hot topic, and one you need to seriously evaluate in your workplace. OSHA has a decent resource page on combustible dust. NFPA 654 is the primary standard for general industry, and until OSHA develops their own standard, is likely the place to go for guidance. To keep up with the latest on combustible dust, visit the Combustible Dust Policy Institute blog.
Have you reviewed your workplace for combustible dust hazards?
Saturday, September 12, 2009
An Environmental Engineer's Journey
I apologize (to anyone who is listening) for the lengthy hiatus from this blog. Alas, life intrudes and I just haven't had anything interesting to blog about. That got me thinking: is there really anything about environmental work that is truly 'interesting?' Hmmm, why did I get into this field again?
I suppose it was vague ideas about making the world a better place to live . . . oh, that and it was definitely a leading edge career choice when I was in college. There wasn't even an 'environmental' engineering degree in those days. Sure you could get an 'environmental' subdiscipline with a Civil Engineering degree - which meant that basically you could design and run wastewater treatment plants - but that really didn't trip my trigger.
At the time, I was far more interested in environmental contamination and remediation. That could have something to do with growing up next door to the Chemical Corridor of Ashtabula, Ohio (once a booming part of the US war infrastructure), and having an NPL site almost in my back yard (Fields Brook). I suppose, too that the idea of carving out what I thought, in my young idealism, I needed in order to do 'real' environmental work held a certain appeal to my non-conformist side. I guess that's why I ended up in Agricultural Engineering at Ohio State (now called the Department of Food, Agricultural and Biological Engineering). At least there, they let me carve out my own path towards an engineering degree. I ended up in the soil and water engineering subdiscipline. For my MS, I did my thesis work on groundwater contaminant transport.
Of course, I was better off than my predecessors in the environmental field, who learned their job entirely on the fly (not to say that I didn't learn most of the real environmental work on the fly, mind you). Now there are degrees in Environmental Engineering. I've actually taken several courses toward a MS in Environmental Engineering through Findlay University. What I wouldn't have given to have some of these courses at the beginning of my career!
But back to my initial question, what is interesting in the Environmental field? Well, actually, looking back on my career, I've done some pretty neat stuff. My first job out of college was with a consulting firm. I got to do investigative drilling, and evaluate the results to determine the remediation path forward. When I moved back to Ashtabula County, Ohio, I got to be involved in some of the early work of the Ashtabula River Project, an innovative approach to cleanup coordination for the Ashtabula River Area of Concern (downstream of the Fields Brook NPL site) that has now been modeled in other places.
I worked at another facility where they treated hazardous waste (my introduction to a RCRA facility), and worked for several years on the program monitoring the contamination at old inactive units, and helping to develop the remedial action plans. Now, years later, as a consultant, I am actually witnessing those plans comes to fruition.
I also worked at a DOE decommissioning project. While I learned A LOT about environmental regulations while working on that project, I also vowed that I would NEVER work for the government again. Long story, probably mostly politically-incorrect, so I won't relate it here. While there, I did get to do some actual remediation project management work on one of the operable units associated with Fields Brook (not related to the DOE project, mind you). Completing the PCB cleanup, and certifying closure of the unit was probably one of my proudest achievements as an Environmental Engineer.
My foray into industrial environmental management was also frought with excitement, especially working for a reinforced plastic composites manufacturer (right around the time the Quad W MACT came out). There was a huge learning curve there, and the work was never really boring, but it was extremely demanding. If you've ever worked in industry, you know that in general it is always about efficiency. Unfortunately, I was doing the work of two people, with no end in site, and a sh**-load of 'new' work coming down the pike.
It definitely takes a dedicated person to become a career industrial environmental manager. I have since struck out on my own, and offer support services to those poor, over-worked, and generally over-looked environmental managers, many of whom are also tasked with managing the safety program. It is a career choice filled with challenges, and in the challenges are significant opportunities.
In fact, there are always new rules and regulations coming out, presenting new challenges, and new opportunities to demonstrate the rewards that environmental stewardship can have for a company. It is in facing these challenges head-on, and making the case for the business oppotunities present in the challenges that the excitement of an environemtnal management career reside.
Yes, the environemntal field is interesting - endlessly so!
So, does anyone else care to share their journey in the environemental field? I'd love to hear YOUR story!
I suppose it was vague ideas about making the world a better place to live . . . oh, that and it was definitely a leading edge career choice when I was in college. There wasn't even an 'environmental' engineering degree in those days. Sure you could get an 'environmental' subdiscipline with a Civil Engineering degree - which meant that basically you could design and run wastewater treatment plants - but that really didn't trip my trigger.
At the time, I was far more interested in environmental contamination and remediation. That could have something to do with growing up next door to the Chemical Corridor of Ashtabula, Ohio (once a booming part of the US war infrastructure), and having an NPL site almost in my back yard (Fields Brook). I suppose, too that the idea of carving out what I thought, in my young idealism, I needed in order to do 'real' environmental work held a certain appeal to my non-conformist side. I guess that's why I ended up in Agricultural Engineering at Ohio State (now called the Department of Food, Agricultural and Biological Engineering). At least there, they let me carve out my own path towards an engineering degree. I ended up in the soil and water engineering subdiscipline. For my MS, I did my thesis work on groundwater contaminant transport.
Of course, I was better off than my predecessors in the environmental field, who learned their job entirely on the fly (not to say that I didn't learn most of the real environmental work on the fly, mind you). Now there are degrees in Environmental Engineering. I've actually taken several courses toward a MS in Environmental Engineering through Findlay University. What I wouldn't have given to have some of these courses at the beginning of my career!
But back to my initial question, what is interesting in the Environmental field? Well, actually, looking back on my career, I've done some pretty neat stuff. My first job out of college was with a consulting firm. I got to do investigative drilling, and evaluate the results to determine the remediation path forward. When I moved back to Ashtabula County, Ohio, I got to be involved in some of the early work of the Ashtabula River Project, an innovative approach to cleanup coordination for the Ashtabula River Area of Concern (downstream of the Fields Brook NPL site) that has now been modeled in other places.
I worked at another facility where they treated hazardous waste (my introduction to a RCRA facility), and worked for several years on the program monitoring the contamination at old inactive units, and helping to develop the remedial action plans. Now, years later, as a consultant, I am actually witnessing those plans comes to fruition.
I also worked at a DOE decommissioning project. While I learned A LOT about environmental regulations while working on that project, I also vowed that I would NEVER work for the government again. Long story, probably mostly politically-incorrect, so I won't relate it here. While there, I did get to do some actual remediation project management work on one of the operable units associated with Fields Brook (not related to the DOE project, mind you). Completing the PCB cleanup, and certifying closure of the unit was probably one of my proudest achievements as an Environmental Engineer.
My foray into industrial environmental management was also frought with excitement, especially working for a reinforced plastic composites manufacturer (right around the time the Quad W MACT came out). There was a huge learning curve there, and the work was never really boring, but it was extremely demanding. If you've ever worked in industry, you know that in general it is always about efficiency. Unfortunately, I was doing the work of two people, with no end in site, and a sh**-load of 'new' work coming down the pike.
It definitely takes a dedicated person to become a career industrial environmental manager. I have since struck out on my own, and offer support services to those poor, over-worked, and generally over-looked environmental managers, many of whom are also tasked with managing the safety program. It is a career choice filled with challenges, and in the challenges are significant opportunities.
In fact, there are always new rules and regulations coming out, presenting new challenges, and new opportunities to demonstrate the rewards that environmental stewardship can have for a company. It is in facing these challenges head-on, and making the case for the business oppotunities present in the challenges that the excitement of an environemtnal management career reside.
Yes, the environemntal field is interesting - endlessly so!
So, does anyone else care to share their journey in the environemental field? I'd love to hear YOUR story!
Monday, July 20, 2009
Accounting and the Environment
“If all the accountants in the world were laid end to end – it would be a good thing.”
I used to tease my husband while we were in grad school with this quote. He was working toward a masters in economics, and at the time he was taking a series of honors accounting classes. His usual comeback was “I don’t want to be an accountant. I want to be the accounting boss. You have to understand what you manage.”
OK, entirely off-topic, right? Not really. There is a corollary to my husband’s philosophy: You cannot manage what you do not understand. Perhaps it is because I was in the throes of TRI (Toxic Release Inventory) report preparation that the topics of accounting and regulating came to mind. The vagaries of my interests tend to lead to some odd philosophical thoughts. This one caught my attention when it flitted through, and I decided that it was worth at least a brief essay attempt.
For those of you who do not know, TRI reporting is required every year for any industrial facility that ‘processes’ or ‘otherwise uses’ any of a list of 581 chemicals or 30 chemical categories above the reporting thresholds. If the threshold is exceeded, the facility must then account for what happened to that chemical through the facility processes that resulted in releases to each of the three environmental media:
• How much was emitted to the air?
• How much was released into surface water?
• How much was released to the land (i.e., managed in onsite waste management units or was sent off site for disposal)?
And my favorite: how much is projected to be released into the various environmental media in each of the next two years? Talk about polishing your crystal ball. After this past year, clients are quite uncertain about their production projections for the next month, let alone the next year!
Anyway, the data gathered is now submitted through the USEPA’s Central Data Exchange where it is compiled, validated, confirmed, and finally put out on TOXNET for perusal by the public. The TOXMAP feature is really quite interesting, and contains a phenomenal amount of data. You can, literally, see what is released in your back yard.
From an industry perspective, I know I anticipate the TRI reporting cycle with a dread akin to my annual visits to the OB/GYN (apologies to any male readers - you can insert dentist, if you prefer, but trust me, this analogy is more apt). It doesn’t matter how conscientious I am about my accounting practices, I always find something I’ve missed before. I spend so much time worrying about whether I’ve accounted for everything, I have little time, or energy, left over to actually make any headway on managing what I’ve measured, let alone understanding exactly why changes may have occurred.
Also, who selected the 581 chemicals and 30 chemical categories? Are these the worst, most toxic chemicals? Are there other chemicals that I should worry about? I always start with what I reported on the SERC (State Emergency Response Commission) report for the year, since its reporting requirements are much broader. But there isn’t always a lot of correlation, since the SERC reporting is based on the product, while the TRI reporting is based on specific chemicals, which may be in the products, some at low percentages. I also look at the air reporting, but it is done in even broader terms like volatiles and particulates (an exception being hazardous air pollutants, which generally do require individual emission tracking). In short, the TRI reporting really does end up being a process onto itself.
And while I applaud the collection and dissemination of data, I wonder, does it help to make our environment any cleaner? I fully adhere to the idea that you cannot manage what you do not understand (read as ‘measure’) but when has the measurement gone so far that we lose sight of the need to manage?
I finished the TRI reports for two clients on time (due July 1) – woot! For one client, I found a chemical that I missed last year. It’s a small percentage of a product, but they use enough of the product that the threshold was exceeded. We’ve made strides in reducing use of the nastier products at the facility. This particular one is really a fairly innocuous material, overall. It just happens to have a small percentage of a TRI chemical in it. Turned out that there was very little ‘released to the environment,’ but it was processed over the threshold so it has to be reported. Feels like the time I spent on this was a colossal waste.
I shouldn’t complain. This is what keeps me in business. But it irks me when it just seems like a bunch of busy work with no real benefit to the environment. Maybe that’s my general problems with the regulatory framework in the U.S. as a whole; a lot of busy work with little benefit; a self-sustaining bureaucracy that has lost touch with its intended purpose.
It is disheartening to me that picking up trash with my 4-year-old along the road feels more environmentally-relevant than performing my work as an environmental manager.
Go figure – literally.
I used to tease my husband while we were in grad school with this quote. He was working toward a masters in economics, and at the time he was taking a series of honors accounting classes. His usual comeback was “I don’t want to be an accountant. I want to be the accounting boss. You have to understand what you manage.”
OK, entirely off-topic, right? Not really. There is a corollary to my husband’s philosophy: You cannot manage what you do not understand. Perhaps it is because I was in the throes of TRI (Toxic Release Inventory) report preparation that the topics of accounting and regulating came to mind. The vagaries of my interests tend to lead to some odd philosophical thoughts. This one caught my attention when it flitted through, and I decided that it was worth at least a brief essay attempt.
For those of you who do not know, TRI reporting is required every year for any industrial facility that ‘processes’ or ‘otherwise uses’ any of a list of 581 chemicals or 30 chemical categories above the reporting thresholds. If the threshold is exceeded, the facility must then account for what happened to that chemical through the facility processes that resulted in releases to each of the three environmental media:
• How much was emitted to the air?
• How much was released into surface water?
• How much was released to the land (i.e., managed in onsite waste management units or was sent off site for disposal)?
And my favorite: how much is projected to be released into the various environmental media in each of the next two years? Talk about polishing your crystal ball. After this past year, clients are quite uncertain about their production projections for the next month, let alone the next year!
Anyway, the data gathered is now submitted through the USEPA’s Central Data Exchange where it is compiled, validated, confirmed, and finally put out on TOXNET for perusal by the public. The TOXMAP feature is really quite interesting, and contains a phenomenal amount of data. You can, literally, see what is released in your back yard.
From an industry perspective, I know I anticipate the TRI reporting cycle with a dread akin to my annual visits to the OB/GYN (apologies to any male readers - you can insert dentist, if you prefer, but trust me, this analogy is more apt). It doesn’t matter how conscientious I am about my accounting practices, I always find something I’ve missed before. I spend so much time worrying about whether I’ve accounted for everything, I have little time, or energy, left over to actually make any headway on managing what I’ve measured, let alone understanding exactly why changes may have occurred.
Also, who selected the 581 chemicals and 30 chemical categories? Are these the worst, most toxic chemicals? Are there other chemicals that I should worry about? I always start with what I reported on the SERC (State Emergency Response Commission) report for the year, since its reporting requirements are much broader. But there isn’t always a lot of correlation, since the SERC reporting is based on the product, while the TRI reporting is based on specific chemicals, which may be in the products, some at low percentages. I also look at the air reporting, but it is done in even broader terms like volatiles and particulates (an exception being hazardous air pollutants, which generally do require individual emission tracking). In short, the TRI reporting really does end up being a process onto itself.
And while I applaud the collection and dissemination of data, I wonder, does it help to make our environment any cleaner? I fully adhere to the idea that you cannot manage what you do not understand (read as ‘measure’) but when has the measurement gone so far that we lose sight of the need to manage?
I finished the TRI reports for two clients on time (due July 1) – woot! For one client, I found a chemical that I missed last year. It’s a small percentage of a product, but they use enough of the product that the threshold was exceeded. We’ve made strides in reducing use of the nastier products at the facility. This particular one is really a fairly innocuous material, overall. It just happens to have a small percentage of a TRI chemical in it. Turned out that there was very little ‘released to the environment,’ but it was processed over the threshold so it has to be reported. Feels like the time I spent on this was a colossal waste.
I shouldn’t complain. This is what keeps me in business. But it irks me when it just seems like a bunch of busy work with no real benefit to the environment. Maybe that’s my general problems with the regulatory framework in the U.S. as a whole; a lot of busy work with little benefit; a self-sustaining bureaucracy that has lost touch with its intended purpose.
It is disheartening to me that picking up trash with my 4-year-old along the road feels more environmentally-relevant than performing my work as an environmental manager.
Go figure – literally.
Tuesday, July 14, 2009
Nature Always Rebuilds
It's been awhile since I updated. Life intrudes periodically, and the beginning of summer is usually when that happens. Once school is out, all five kids are underfoot, and it makes it hard to get work done, let alone anything extra. We took a wonderful vacation up to the family cabin on Tilden Lake in Ontario, Canada, and I was just looking at some of the pictures, and a topic came to mind that I decided to run with: nature rebuilds.
You see, this is my general problem with us humans; we're less interested in preserving the environment than we are in preserving the status quo. The honest to God truth is, the environment will do fine without us. It can rebuild, readjust, and recover from just about anything we humans can throw at it. It might look a little different, it might be less hospitable to us, and perhaps to other species, but it will go on.
As a testament to the tenacity and resilience of nature, consider the accompanying pictures, taken by my children during a canoe ride on Tilden Lake.
The second photo shows another strategy: rebuilding on the skeleton of the past. Here a dead,
felled tree actually creates the start of a new island in the lake, providing a platform for new life. Honestly, how can you not be impressed by the ingenuity of nature itself.
So, admit it you measley human beings, what you're really interested in is preserving YOUR EXISTING ENVIRONMENT, not in preserving the environment itself. I mean, let's be honest with ourselves here, who doesn't believe that nature will come up with another species to take our place if we screw this up?
You see, this is my general problem with us humans; we're less interested in preserving the environment than we are in preserving the status quo. The honest to God truth is, the environment will do fine without us. It can rebuild, readjust, and recover from just about anything we humans can throw at it. It might look a little different, it might be less hospitable to us, and perhaps to other species, but it will go on.
As a testament to the tenacity and resilience of nature, consider the accompanying pictures, taken by my children during a canoe ride on Tilden Lake.
The first
photo shows the rocky terrain of the area we visit. Tilden Lake is located in mid-Ontario province, where there is precious little soil. Highways have to be blasted through the landscape (a true wonder of human tanacity and ingenuity - really, I don't totally disdain my own kind). You can see in this first picture that the trees literally cling to the sides on the rocks, their roots reaching deep into the rock, and breaking it up to create their own 'environment' for life. It is truly amazing to see where things grow in this beautiful wilderness.
photo shows the rocky terrain of the area we visit. Tilden Lake is located in mid-Ontario province, where there is precious little soil. Highways have to be blasted through the landscape (a true wonder of human tanacity and ingenuity - really, I don't totally disdain my own kind). You can see in this first picture that the trees literally cling to the sides on the rocks, their roots reaching deep into the rock, and breaking it up to create their own 'environment' for life. It is truly amazing to see where things grow in this beautiful wilderness.The second photo shows another strategy: rebuilding on the skeleton of the past. Here a dead,
felled tree actually creates the start of a new island in the lake, providing a platform for new life. Honestly, how can you not be impressed by the ingenuity of nature itself.So, admit it you measley human beings, what you're really interested in is preserving YOUR EXISTING ENVIRONMENT, not in preserving the environment itself. I mean, let's be honest with ourselves here, who doesn't believe that nature will come up with another species to take our place if we screw this up?
Tuesday, June 2, 2009
Web of Life and the Human Bias
I found the following explanation on an educational web site developed by the University of Illinois Extension:
Web of Life: An ecosystem is made up of all the living animals and plants and the non-living matter in a particular place, like a forest or lake. All the living things in an ecosystem depend on all the other things - living and non-living for continued survival - for food supplies and other needs. In some ways, the actions and reaction that take place within an ecosystem are like a spider web - when one strand is broken, the web starts to unravel. What affects one part of an ecosystem, affects the whole in some way.
I have always been fascinated by this analogy for an ecosystem. In fact, no defined ecosystem exists independent of another, so the analogy can be extended to encompass all life on the planet. NASA has even extended this concept beyond our planet to encompass space.
The one part of the description above that I take issue with is the broken strand analogy. A spider web, our apt web of life analogy, does not unravel if one strand is broken, or even if two strands are broken. Spider webs, and life, are much stronger, and more resilient than that.
The final statement, that what affects one part of an ecosystem affects the whole in some way, is very true. If something changes, the entire system must adjust, or adapt, to that change. Sometimes the adjustments are catastrophic for other parts of the system, sometimes beneficial, but the change itself is unavoidable.
This brings us to what I call the human bias in the web of life: avoidance of change. Change is an inevitable part of life. Ecosystems, like all living organisms, rise and fall, but life goes on. Perhaps not as we currently know it, but life does go on.
I look at it this way, if change did not occur, we humans, as a species, would never have come into existence. And try as we might, there is no way we can exist on this planet and not have an impact on the system of life in which we live. It is a fallacy to think we can.
Change is inevitable. Adapt or die - as a species this is our 'choice.' Trying to maintain the status quo is an impractical strategy. Instead we need to explore ways to bring our way of living into harmony with the ever-changing world around us.
So what's my point. Let's take the greehouse gas (GHG) regulatory-behemoth-in-the-making that is the current hot environmental topic. Is counting GHGs and creating a cap-and-trade system going to help us to live in harmony within our ecosystem? I have my doubts. It seems more about accounting than anything else (see the GHG calculators available everywhere online). I am pleasently surprised at the increasing focus on developing renewable energy sources - wave generators, wind farms, current turbines - these are all examples of human ingenuity tapping into the living energy available all around us. Maybe GHG regulation will accomplish something in moving us closer to the ideal.
I truly hope so.
Web of Life: An ecosystem is made up of all the living animals and plants and the non-living matter in a particular place, like a forest or lake. All the living things in an ecosystem depend on all the other things - living and non-living for continued survival - for food supplies and other needs. In some ways, the actions and reaction that take place within an ecosystem are like a spider web - when one strand is broken, the web starts to unravel. What affects one part of an ecosystem, affects the whole in some way.
I have always been fascinated by this analogy for an ecosystem. In fact, no defined ecosystem exists independent of another, so the analogy can be extended to encompass all life on the planet. NASA has even extended this concept beyond our planet to encompass space.
The one part of the description above that I take issue with is the broken strand analogy. A spider web, our apt web of life analogy, does not unravel if one strand is broken, or even if two strands are broken. Spider webs, and life, are much stronger, and more resilient than that.
The final statement, that what affects one part of an ecosystem affects the whole in some way, is very true. If something changes, the entire system must adjust, or adapt, to that change. Sometimes the adjustments are catastrophic for other parts of the system, sometimes beneficial, but the change itself is unavoidable.
This brings us to what I call the human bias in the web of life: avoidance of change. Change is an inevitable part of life. Ecosystems, like all living organisms, rise and fall, but life goes on. Perhaps not as we currently know it, but life does go on.
I look at it this way, if change did not occur, we humans, as a species, would never have come into existence. And try as we might, there is no way we can exist on this planet and not have an impact on the system of life in which we live. It is a fallacy to think we can.
Change is inevitable. Adapt or die - as a species this is our 'choice.' Trying to maintain the status quo is an impractical strategy. Instead we need to explore ways to bring our way of living into harmony with the ever-changing world around us.
So what's my point. Let's take the greehouse gas (GHG) regulatory-behemoth-in-the-making that is the current hot environmental topic. Is counting GHGs and creating a cap-and-trade system going to help us to live in harmony within our ecosystem? I have my doubts. It seems more about accounting than anything else (see the GHG calculators available everywhere online). I am pleasently surprised at the increasing focus on developing renewable energy sources - wave generators, wind farms, current turbines - these are all examples of human ingenuity tapping into the living energy available all around us. Maybe GHG regulation will accomplish something in moving us closer to the ideal.
I truly hope so.
Sunday, May 17, 2009
CALEB'S CARNIVAL - May 23, 11am-5pm, by CCGM
This post isn't really environmentally related
, but it is on a subject near and dear to my heart, so I hope you'll indulge me!
, but it is on a subject near and dear to my heart, so I hope you'll indulge me!It’s spring at the Market, and besides veggies, flowers, and hanging baskets, it is time for our annual fund raiser for the Leukemia & Lymphoma Society: Caleb’s Carnival.
First, I thought it might be good to provide an abbreviated history of Caleb’s Carnival. It is named for a remarkable little boy from Conneaut, Ohio who has a disease called Chronic Myelogenous Leukemia or CML for short. He was diagnosed two years ago, in July 2007. He spent 5 days in the Pediatric ICU, followed by 10 days in the Immunodeficiency Ward, and during that entire time, he was unflagging in his cheerfulness, even given the poking, prodding and general discomfort of what he was going through.
Now, two years later, Caleb is in remission. All he has to do is take three little pills a day, and the leukemia that had distended his spleen to the point that it took up nearly his entire abdomen, is held at bay. It is a miracle; and would not have been possible without the hard work and dedication of the researchers at Novartis, and the funding from the Leukemia & Lymphoma Society (LLS).
So when Aunt Babe decided to become a very active participant in the LLS Light the Night Walk, we joined her whole-heartedly in forming Caleb’s Walkers. Brainstorming ways to raise money for this worthwhile and now very personal cause, Caleb’s Carnival was born. We held the first annual Carnival on Caleb’s birthday in 2008, and the event was a wonderful success. We think this year will be even better.
Heather Lindberg and Carnival’s for a Cause have put together a wonderful lineup of family fun for the day, including tug of war, egg toss and a sack race, as well as other games for the kids, with some great door prizes generously donated by local businesses and friends (I’ll get a list posted soon, thanking everyone – I’m constantly blown away by everyone’s generosity).
In addition, there will be food provided by Sav-a-Lot and the Conneaut High School Music Boosters, as well as barbecue from Smokin’ T’s. Brad’s Bouncy House in Erie will be providing a space for kids to work out some of their energy. There will be musical entertainment provided by the Erie Traveler’s and friends. And we are very excited to have two of the Cleveland Cavaliers’ Cheerleaders coming to sign autographs and join in some of the fun activities.
We hope you’ll be able to join us on May 23, 2009 between 11am and 5pm in Chapin’s lot, next to the City Center Garden Market. The Market will be donating 5% of the sales from that day to the LLS in honor of Caleb, and is accepting cash donations ahead of the Carnival as well. Or, you can donate online at our donations page.
But we really hope you’ll be there to wish Caleb a happy birthday and join in the festivities!
First, I thought it might be good to provide an abbreviated history of Caleb’s Carnival. It is named for a remarkable little boy from Conneaut, Ohio who has a disease called Chronic Myelogenous Leukemia or CML for short. He was diagnosed two years ago, in July 2007. He spent 5 days in the Pediatric ICU, followed by 10 days in the Immunodeficiency Ward, and during that entire time, he was unflagging in his cheerfulness, even given the poking, prodding and general discomfort of what he was going through.
Now, two years later, Caleb is in remission. All he has to do is take three little pills a day, and the leukemia that had distended his spleen to the point that it took up nearly his entire abdomen, is held at bay. It is a miracle; and would not have been possible without the hard work and dedication of the researchers at Novartis, and the funding from the Leukemia & Lymphoma Society (LLS).
So when Aunt Babe decided to become a very active participant in the LLS Light the Night Walk, we joined her whole-heartedly in forming Caleb’s Walkers. Brainstorming ways to raise money for this worthwhile and now very personal cause, Caleb’s Carnival was born. We held the first annual Carnival on Caleb’s birthday in 2008, and the event was a wonderful success. We think this year will be even better.
Heather Lindberg and Carnival’s for a Cause have put together a wonderful lineup of family fun for the day, including tug of war, egg toss and a sack race, as well as other games for the kids, with some great door prizes generously donated by local businesses and friends (I’ll get a list posted soon, thanking everyone – I’m constantly blown away by everyone’s generosity).In addition, there will be food provided by Sav-a-Lot and the Conneaut High School Music Boosters, as well as barbecue from Smokin’ T’s. Brad’s Bouncy House in Erie will be providing a space for kids to work out some of their energy. There will be musical entertainment provided by the Erie Traveler’s and friends. And we are very excited to have two of the Cleveland Cavaliers’ Cheerleaders coming to sign autographs and join in some of the fun activities.
We hope you’ll be able to join us on May 23, 2009 between 11am and 5pm in Chapin’s lot, next to the City Center Garden Market. The Market will be donating 5% of the sales from that day to the LLS in honor of Caleb, and is accepting cash donations ahead of the Carnival as well. Or, you can donate online at our donations page.
But we really hope you’ll be there to wish Caleb a happy birthday and join in the festivities!
Monday, April 13, 2009
Nature Walk Photo Essay
Quin the explorer heading down the hill leading to Bluebell in Conneaut, Ohio.This past spring has been hard on the road. The erosion channel cut into the road bed is up to a couple feet deep in some places.
Quin thinks it’s a great waterfall. 
Quin and I walked up the old road approach to the bridge. The wooden decking is long gone, and the grapevines are taking over. In the upper left hand corner of the photo (left) you can see where the bridge frame is propping up a large old sycamore – shown from below in this photo (below)
At the top of the bow of the Creek, the far bank is eroded by the faster-moving water, while on the side Quin and I were on, large deposits of alluvial material (in this case, sand) occur.
Around the bend, we found our old friend, Mr. Canadian Goose. He didn’t puff and preen at us today, though – he just took off!
Weathered shale is deposited all along Conneaut Creek, as it forms the Creek bed. Deposits like this are prime placed to find fossils!
We found some cool stones, like this weathered coral fossil (I think?)
I call these ‘lake bottom’ fossils – not sure the appropriate term – it’s like the bottom a some long-ago lake was frozen in time in the shale.
In this particular section of the Creek, several layered oxbow ‘lakes’ (more like ponds) have been created. During high water, these oxbow may still carry water, but for the most part they are stagnant ponds, that may even dry up during the summer.
Quin the environmentalist helps with litter pickup. We have gotten into the habit of carrying a bag for garbage when we walk down here. It was full by the time we got back home.
Deer track, in addition to other wildlife, are fun to find.
This time of year, the signs of spring are just beginning to emerge, but the skeletal trees along the Creek are beautiful in their own right. The water in the Creek was muddy today. Rain and snowmelt carry sediment via overland flow, creating the muddy condition. When the Creek is at base flow the water is crystal clear, and COLD. The groundwater that contributes the base flow of the Creek stays right around 56 degrees F year round.
Quin took a little rest in this tree by the Creek – 
but not for long. He was up and adventuring again, in short order! 
Views of the Creek looking downstream, the way we’d come (left) and upstream towards home (above). Our home is only about 1500 feet upstream of here, but lies approximately 60 feet above the flood plain.
Quin the conqueror on a concretion weathered out of the shale at the edge of the water. We find small concretions, as well as quite a bit of flint, Ohio’s official gemstone.
Views of the Creek looking downstream, the way we’d come (left) and upstream towards home (above). Our home is only about 1500 feet upstream of here, but lies approximately 60 feet above the flood plain.
Quin the conqueror on a concretion weathered out of the shale at the edge of the water. We find small concretions, as well as quite a bit of flint, Ohio’s official gemstone.
The road home. Quin and I really enjoy our walks together. We’ll begin expanding our wanderings, and I will try to remember the camera so we can document our adventures!
Saturday, April 4, 2009
Nature Walk
Today, I thought I would take a step back from the technical aspects of environmental issues and talk about the aesthetics. I took a walk with my 4-year-old this past weekend. It was a picture-perfect day: sunny, blue sky with wispy clouds, about 55 degrees F. Quin decided he wanted to go down ‘the short end of Parrish.’ To orient you, we live in Conneaut, Ohio, and we walked from Daniels Avenue north on south Parrish Road to where it dead ends at Conneaut Creek.
There is now a campground down in the flood plain of the creek here (locally known as Bluebell), which is private property, but the public road still leads to the frame of the old metal bridge that used to carry vehicles across the creek to Route 20 (warning to those of you who rely on on-line mapping – many still show Parrish going through, but it hasn’t done so in a long time).
The bridge is located at a large bow in the creek, where shallow riffles are interspersed with deeper pools. The bridge deck is gone, but the metal skeleton remains, and is currently supporting a huge old sycamore that was partially uprooted during a wind storm. If the bridge hadn’t been there, the tree would likely have gone all the way over, its stretching branches reaching across the creek, creating a change in the course of the waterway over time. But, since the bridge is there, this didn’t happen. Quin was fascinated by the partially-exposed roots of the sycamore, which will likely cling to life for a few more decades with the help of that old bridge.
While we were walking the bow, Quin made friends with several stream fishers. Conneaut Creek is a ‘hot spot’ for steelhead fishing, making it a popular destination for anglers. It is a beautiful waterway, heavily wooded along much of its length, with the bed cut into shale bedrock. As a result, it is a great place to go fossil hunting; Quin and I found several fossils, though they didn’t interest him any more than finding a neat erratic rock, or a big slab to throw in the water to make an impressive ‘kerplunk!’ The thinner pieces of shale are great for skipping across the deep pools, too. The anglers probably didn’t appreciate the noise we made, but there is no containing the energy of a 4-year-old!
We even met a mating pair of Canadian geese. The male was a spitfire, and puffed out his chest and flapped his wings at us when we got too close. Quin thought that was hilarious, so I guess the intimidation bit just doesn’t work on an energetic pre-schooler. I felt kind of sorry for the poor preening goose, but in the end we moved on, so hopefully he felt he had successfully defended his territory - even if Quin did laugh at his show!
In general, in this section of the creek, the water is crystal clear, so you can almost always see the bottom (except after a heavy rain, when sediment loading is high). In warmer weather, the creek is teeming with insects, crawdads, tadpoles, etc. and we looked, but I think it was too cold yet to find those creatures. We’ll be back when it gets a bit warmer. We hoped to see a few fish, given the number of anglers we met, but though we thought we heard one or two jump we never did catch site of the elusive fish. We did scare up a few spiders when picking up rocks, though.
Our walk along with Creek was a grand adventure for Quin and I. It reminded me of Winnie the Pooh and his adventures in the 100-acre wood. It was fun to watch Quin discover all the things I take for granted. Taking a nature walk with a young child is a real eye-opening experience – I highly recommend it. It will reawake your wonder in the natural world around you. Next time, I must remember to take the camera, so we can share our adventure in pictures!
One down-note: Quin and I did decide that the next time we take a walk down to the Creek, we would need to bring a trash bag. It’s amazing the detritus of human existence that finds its way into nature. You want my honest opinion, I think we should spend less time worrying about how much carbon dioxide we respirate as a species, and start taking care of our trash.
And when I say taking care of it, I don’t mean just bagging it up and burying it in a landfill, but really taking care of it: mandate community recycling programs; demand reduced packaging in our food supply; and for heaven’s sake, when you visit a natural area, carry your trash out with you and dispose of it properly!
Sorry, couldn’t avoid a mini-rant about the trash, but I ended up with both hands full – couldn’t carry any more out, and had to leave quite a bit behind. Seems sad that a trash bag is a necessary accessory on a nature walk, don’t you think?
Note of interest regarding Conneaut Creek:
In 2005, a 21-mile stretch of Conneaut Creek (including where Quin and I visited) from the Ohio-Pennsylvania border to the former Penn Central Railroad bridge in the City of Conneaut was named a State Scenic River, and the portion of that section that is upstream of the Creek Road Bridge crossing, also carries the ‘Wild’ designation. To learn more about Conneaut Creek’s designation and special features that resulted in this designation see the Ohio Department of Natural Resources web page on Ohio’s Scenic River Program . For information about Conneaut Creek clean up activities, visit the Friends of Conneaut Creek - there's also additional information and links regarding the wild and scenic designation here, and some great photos taken along the length of the creek.
There is now a campground down in the flood plain of the creek here (locally known as Bluebell), which is private property, but the public road still leads to the frame of the old metal bridge that used to carry vehicles across the creek to Route 20 (warning to those of you who rely on on-line mapping – many still show Parrish going through, but it hasn’t done so in a long time).
The bridge is located at a large bow in the creek, where shallow riffles are interspersed with deeper pools. The bridge deck is gone, but the metal skeleton remains, and is currently supporting a huge old sycamore that was partially uprooted during a wind storm. If the bridge hadn’t been there, the tree would likely have gone all the way over, its stretching branches reaching across the creek, creating a change in the course of the waterway over time. But, since the bridge is there, this didn’t happen. Quin was fascinated by the partially-exposed roots of the sycamore, which will likely cling to life for a few more decades with the help of that old bridge.
While we were walking the bow, Quin made friends with several stream fishers. Conneaut Creek is a ‘hot spot’ for steelhead fishing, making it a popular destination for anglers. It is a beautiful waterway, heavily wooded along much of its length, with the bed cut into shale bedrock. As a result, it is a great place to go fossil hunting; Quin and I found several fossils, though they didn’t interest him any more than finding a neat erratic rock, or a big slab to throw in the water to make an impressive ‘kerplunk!’ The thinner pieces of shale are great for skipping across the deep pools, too. The anglers probably didn’t appreciate the noise we made, but there is no containing the energy of a 4-year-old!
We even met a mating pair of Canadian geese. The male was a spitfire, and puffed out his chest and flapped his wings at us when we got too close. Quin thought that was hilarious, so I guess the intimidation bit just doesn’t work on an energetic pre-schooler. I felt kind of sorry for the poor preening goose, but in the end we moved on, so hopefully he felt he had successfully defended his territory - even if Quin did laugh at his show!
In general, in this section of the creek, the water is crystal clear, so you can almost always see the bottom (except after a heavy rain, when sediment loading is high). In warmer weather, the creek is teeming with insects, crawdads, tadpoles, etc. and we looked, but I think it was too cold yet to find those creatures. We’ll be back when it gets a bit warmer. We hoped to see a few fish, given the number of anglers we met, but though we thought we heard one or two jump we never did catch site of the elusive fish. We did scare up a few spiders when picking up rocks, though.
Our walk along with Creek was a grand adventure for Quin and I. It reminded me of Winnie the Pooh and his adventures in the 100-acre wood. It was fun to watch Quin discover all the things I take for granted. Taking a nature walk with a young child is a real eye-opening experience – I highly recommend it. It will reawake your wonder in the natural world around you. Next time, I must remember to take the camera, so we can share our adventure in pictures!
One down-note: Quin and I did decide that the next time we take a walk down to the Creek, we would need to bring a trash bag. It’s amazing the detritus of human existence that finds its way into nature. You want my honest opinion, I think we should spend less time worrying about how much carbon dioxide we respirate as a species, and start taking care of our trash.
And when I say taking care of it, I don’t mean just bagging it up and burying it in a landfill, but really taking care of it: mandate community recycling programs; demand reduced packaging in our food supply; and for heaven’s sake, when you visit a natural area, carry your trash out with you and dispose of it properly!
Sorry, couldn’t avoid a mini-rant about the trash, but I ended up with both hands full – couldn’t carry any more out, and had to leave quite a bit behind. Seems sad that a trash bag is a necessary accessory on a nature walk, don’t you think?
Note of interest regarding Conneaut Creek:
In 2005, a 21-mile stretch of Conneaut Creek (including where Quin and I visited) from the Ohio-Pennsylvania border to the former Penn Central Railroad bridge in the City of Conneaut was named a State Scenic River, and the portion of that section that is upstream of the Creek Road Bridge crossing, also carries the ‘Wild’ designation. To learn more about Conneaut Creek’s designation and special features that resulted in this designation see the Ohio Department of Natural Resources web page on Ohio’s Scenic River Program . For information about Conneaut Creek clean up activities, visit the Friends of Conneaut Creek - there's also additional information and links regarding the wild and scenic designation here, and some great photos taken along the length of the creek.
Friday, March 6, 2009
Carbon Dioxide: The New Pollutant?
What’s your carbon footprint? This is the latest, hot topic in the environmental arena, and everyone seems to be jumping on the band wagon. There are even calculators out on the web to help you determine you personal footprint, and provide tips for reducing it. Here’s just a couple that I found when I Googled:
http://www.carbonfootprint.com/calculator.aspx
http://www.nature.org/initiatives/climatechange/calculator/
http://www.climatecrisis.net/takeaction/carboncalculator/
And these were just the first three to pop up in a web search!
So, what’s my carbon footprint? One site calculated it at 3.9 tons per year; another estimated it at 12.32 tons per year, but they included ‘secondary’ carbon emissions based on my lifestyle; still another estimated my footprint at 100 tons per year (which is still, according to the calculator, below the US national average).
The disparities in the calculations are a result of differences in what is counted (primary versus secondary carbon emissions) and what assumptions are used in the calculations. Luckily, most do compare your footprint to the US National average (based on their calculations), so you can at least get a relative idea.
So what? In the end, all of these sites were going for the same thing – we all need to ‘reduce our carbon footprint’ – or in common vernacular, we should all try to PROTECT OUR ENVIRONMENT. What a novel concept!
In my mind, all this talk is less about carbon dioxide as a pollutant, and more about putting a new spin on a continuing struggle to protect this wonderful, amazing, living, breathing planet we live on.
In keeping with the green message – here are some tips on reducing your carbon footprint:
· Buy ENERGYSTAR appliances and products (http://www.energystar.gov/),
· Walk or ride a bike instead of driving (not only is it good for the environment – it’s good for YOU),
· Reduce, reuse, recycle (remember this tag line?)
· Use recycled products,
· Buy food with little/no packaging (this means giving up some of the convenience food, folks!),
· Buy/drive fuel-efficient vehicles (anyone else out there disgusted with the SUV commercials that tout 20 MPG as wonderful?)
· Turn the lights off, turn the heat down, and don’t waste water (OK, perhaps that last one isn’t so much about your carbon footprint;),
· Buy local foods whenever possible – not only is the quality generally better, but the food wasn’t trucked half way around the globe. And beware organic labels – check where they were PRODUCED!
So, what do you do to reduce your carbon footprint? Please share!
Thursday, February 12, 2009
Darwin and God
Charles Darwin was born on this day in 1809 . . . can you hear the majestic music in the background? No one can deny that Darwin was a great man, and apparently a pretty nice guy. His work, revolutionary for its sweeping general theories developed from studying minutiae, is the basis for modern-day biology. Evolutionist or creationist – no one can deny Darwin’s indelible mark on our belief systems.
So, in honor of Darwin’s 200 year anniversary, let’s take up the subject of evolution and creation. Personally, I subscribe to what would be termed Theistic evolution. There is actually an organization that delves into the interpretation of the biblical writings in light of scientific findings: http://www.theisticevolution.org/ . The articles available on this site provide excellent food for thought in the evolution versus creation debate.
In my opinion, it is much more amazing to think of God having set up this self-perpetuating system of biological evolution than to imagine him plopping man in the middle of Eden. Theistic evolution views the creation story as allegory, rather than attempting a literal interpretation that doesn’t coincide with the hard evidence that supports the evolution theory.
It is important to remember that the bible was written by humans – flawed, with imperfect knowledge, they wrote what they understood. Perhaps God inspired them, but He could not explain the intricacies of the evolutionary engine He designed – that's something that we had to learn over time. Maybe that is why He gave us these big brains!
So, in honor of Darwin’s 200 year anniversary, let’s take up the subject of evolution and creation. Personally, I subscribe to what would be termed Theistic evolution. There is actually an organization that delves into the interpretation of the biblical writings in light of scientific findings: http://www.theisticevolution.org/ . The articles available on this site provide excellent food for thought in the evolution versus creation debate.
In my opinion, it is much more amazing to think of God having set up this self-perpetuating system of biological evolution than to imagine him plopping man in the middle of Eden. Theistic evolution views the creation story as allegory, rather than attempting a literal interpretation that doesn’t coincide with the hard evidence that supports the evolution theory.
It is important to remember that the bible was written by humans – flawed, with imperfect knowledge, they wrote what they understood. Perhaps God inspired them, but He could not explain the intricacies of the evolutionary engine He designed – that's something that we had to learn over time. Maybe that is why He gave us these big brains!
Saturday, February 7, 2009
A History Lesson & Change
Welcome to the maiden voyage of the Environmental Realist. I’m Kenna Coltman, and aside from being a wife and mother of five (I know, how unsustainable of me), I am an Environmental Management Consultant; have been for fifteen years. My views on the environment reflect my upbringing in the rust belt. I’m a typical midwesterner: practical and just a tad jaded.
First, let’s talk about the history of the environmental movement. I know, many credit Rachel Carson with starting the modern environmental movement, but in my opinion it began over 100 years before she wrote her novel Silent Spring. Henry David Thoreau was a well-known environmentalist, and his Walden was utopia to many. He was also one of the first to speak out for the establishment of national nature preserves, though his entreaty, in The Maine Woods wasn’t published until after his death.
However, pre-dating even Thoreau, George Perkins Marsh was one of the first prominent citizens to recognize and acknowledge the destructive effect that humans have on their environment, in a speech to the Agricultural Society of Rutland County, Virginia. His book, Man and Nature; or, Physical Geography as Modified by Human Action could be considered the first environmentalist publication, and was reprinted several times. Others followed Thoreau and Marsh: John Muir, Gifford Pinchot, Robert Sterling Yard, Aldo Leopold, Ansel Adams . . . just to name a few. All called for stewardship to halt the decline of our environment (see http://www.ecotopia.org/ehof/timeline.html ).
But it wasn’t until 1948, when an atmospheric inversion occurred in Donora, Pennsylvania, that our legislature finally recognized the debilitating effect we were having on the world we live in. Let’s talk about this event, which is rarely discussed, but was, in my view, the true beginning of the environmental regulatory era in the US.
An inversion is when the usual air temperature gradient from the earth’s surface to the atmosphere, inverts or flips. Normally, air is warm near the earth and cools as you move higher in the atmosphere. In an inversion, a layer of cool air becomes trapped at the earth’s surface (often in a valley, where it is hemmed in from moving sideways) under a layer of warmer air. In Donora, when this happened, pollutants emitted from the local Donora Zinc Works became trapped as well. The inversion lasted 4 days, and the accumulation of pollution from DZW resulted in the death of at least 20 people, and left many others severely ill. This event led to the first actual environmental legislation, the Air Pollution Control Act of 1955, a precursor to the ‘modern’ Clean Air Act (CAA) of 1970.
So Rachel Carson was really just jumping on a band wagon that started before she was born. I’m not trying to belittle her contribution. Silent Spring, as well as her other books, have provided impetus to the environmental movement – allowing the layperson to understand the problems that our actions, as a species, were having on other species that share this world with us. As a result, our environment, now, is much cleaner than it was 100, or even 50 years ago. We continue to make improvements, and are ever more aware of our impact on the world around us.
In my opinion, our biggest failure in the current environmental debates is an inability to view ourselves as a natural, yes natural, and integral part of the wonderful, living, breathing, and ever-changing world in which we live. As a glaring example, let’s take the hot topic of global warming.
I’m not going to debate whether global warming is occurring – as with all statistical evaluations, that of the earth’s median temperature can be manipulated to support whatever the person doing the manipulation wants to support. I’m a firm believer in the old adage that there are lies, darn lies, and statistics. Let’s assume, for the sake of argument, that the world is warming. The ice caps are melting. The sea levels are rising.
Hmmm, hasn’t this happened before? Perhaps not in the tiny, limited span of our existence on this planet, but it has happened. What did the species alive at the time of this terrible change do?
I'll tell you what they did - they either adapted, or they died, simple as that. I’m a true Darwinist – and please don’t drag me into a religious debate over the theory of Darwin right now (we’ll leave that to another time – as I love to debate organized religion).
My point is this – the earth has changed immensely over the course of its existence, and it will continue to change, regardless of what we puny little humans do or do not do to minimize our impact on it. I’m not saying that it’s a bad idea to curb our fossil fuel appetite, or to reduce the emissions of VOCs (though the whole carbon footprint thing has me a bit flummoxed – another topic for another time), or look for renewable energy sources. All of these are responsible activities; and should continue to be pursued.
But, we need to start thinking about the inevitability of change in our environment, and how we, as a species, are going to adapt to that change. Are we going to continue to rail against nature; rebuild our cities below current sea level; grow lush, green lawns in the middle of the desert; build homes in flood plains . . . Just because we have the brains to allow us to do something, doesn’t mean we should.
In fact, we should use these big, old brains of ours to figure out what the earth is trying to tell us: that she’s a change artist, and we had better prepare ourselves for the inevitability of that change, rather than trying to maintain the status quo.
First, let’s talk about the history of the environmental movement. I know, many credit Rachel Carson with starting the modern environmental movement, but in my opinion it began over 100 years before she wrote her novel Silent Spring. Henry David Thoreau was a well-known environmentalist, and his Walden was utopia to many. He was also one of the first to speak out for the establishment of national nature preserves, though his entreaty, in The Maine Woods wasn’t published until after his death.
However, pre-dating even Thoreau, George Perkins Marsh was one of the first prominent citizens to recognize and acknowledge the destructive effect that humans have on their environment, in a speech to the Agricultural Society of Rutland County, Virginia. His book, Man and Nature; or, Physical Geography as Modified by Human Action could be considered the first environmentalist publication, and was reprinted several times. Others followed Thoreau and Marsh: John Muir, Gifford Pinchot, Robert Sterling Yard, Aldo Leopold, Ansel Adams . . . just to name a few. All called for stewardship to halt the decline of our environment (see http://www.ecotopia.org/ehof/timeline.html ).
But it wasn’t until 1948, when an atmospheric inversion occurred in Donora, Pennsylvania, that our legislature finally recognized the debilitating effect we were having on the world we live in. Let’s talk about this event, which is rarely discussed, but was, in my view, the true beginning of the environmental regulatory era in the US.
An inversion is when the usual air temperature gradient from the earth’s surface to the atmosphere, inverts or flips. Normally, air is warm near the earth and cools as you move higher in the atmosphere. In an inversion, a layer of cool air becomes trapped at the earth’s surface (often in a valley, where it is hemmed in from moving sideways) under a layer of warmer air. In Donora, when this happened, pollutants emitted from the local Donora Zinc Works became trapped as well. The inversion lasted 4 days, and the accumulation of pollution from DZW resulted in the death of at least 20 people, and left many others severely ill. This event led to the first actual environmental legislation, the Air Pollution Control Act of 1955, a precursor to the ‘modern’ Clean Air Act (CAA) of 1970.
So Rachel Carson was really just jumping on a band wagon that started before she was born. I’m not trying to belittle her contribution. Silent Spring, as well as her other books, have provided impetus to the environmental movement – allowing the layperson to understand the problems that our actions, as a species, were having on other species that share this world with us. As a result, our environment, now, is much cleaner than it was 100, or even 50 years ago. We continue to make improvements, and are ever more aware of our impact on the world around us.
In my opinion, our biggest failure in the current environmental debates is an inability to view ourselves as a natural, yes natural, and integral part of the wonderful, living, breathing, and ever-changing world in which we live. As a glaring example, let’s take the hot topic of global warming.
I’m not going to debate whether global warming is occurring – as with all statistical evaluations, that of the earth’s median temperature can be manipulated to support whatever the person doing the manipulation wants to support. I’m a firm believer in the old adage that there are lies, darn lies, and statistics. Let’s assume, for the sake of argument, that the world is warming. The ice caps are melting. The sea levels are rising.
Hmmm, hasn’t this happened before? Perhaps not in the tiny, limited span of our existence on this planet, but it has happened. What did the species alive at the time of this terrible change do?
I'll tell you what they did - they either adapted, or they died, simple as that. I’m a true Darwinist – and please don’t drag me into a religious debate over the theory of Darwin right now (we’ll leave that to another time – as I love to debate organized religion).
My point is this – the earth has changed immensely over the course of its existence, and it will continue to change, regardless of what we puny little humans do or do not do to minimize our impact on it. I’m not saying that it’s a bad idea to curb our fossil fuel appetite, or to reduce the emissions of VOCs (though the whole carbon footprint thing has me a bit flummoxed – another topic for another time), or look for renewable energy sources. All of these are responsible activities; and should continue to be pursued.
But, we need to start thinking about the inevitability of change in our environment, and how we, as a species, are going to adapt to that change. Are we going to continue to rail against nature; rebuild our cities below current sea level; grow lush, green lawns in the middle of the desert; build homes in flood plains . . . Just because we have the brains to allow us to do something, doesn’t mean we should.
In fact, we should use these big, old brains of ours to figure out what the earth is trying to tell us: that she’s a change artist, and we had better prepare ourselves for the inevitability of that change, rather than trying to maintain the status quo.
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