我们遇到很多问题，当涉及空气时：在他们说空气时可能意味着什么？您的空气是您员工的潜在关注吗？您的空气是对环境的关注吗？您的设施是否发出污染物进入空气的过程或日常活动？你在空中发出太多污染吗？
Air means many things to many people – it surrounds us all; we need it to survive but it can also make us sick. From an environmental perspective, “air help” can mean vapor encroachment or fence line monitoring. From a permitting and compliance perspective, air help can mean something as minor as a claimed permit by rule (PBR – a permit not requiring registration here in Texas), to a registration-required PBR, to a New Source Review (NSR) permit, to a full-blown Title V permit. From a safety or industrial hygiene perspective, air help revolves around employee exposures to contaminants or hazards in the form of indoor air quality, personal monitoring, confined space atmosphere monitoring, or a handful of other services.
Much of the time, the assistance required depends on the goal of the project: what you are trying to address such as meeting a regulation’s requirements or developing a safety program, or what you are prevent from happening such as an air emissions accidental release to the environment or an employee death from hazardous vapors. Further, if you have a new piece of equipment or a new process, you might need to determine if you need air permitting to document and control emissions into the environment and legally operate the equipment and then you might also need see if a the new activities are exposing your employees to harmful levels of contaminants. The issue is that there is not one decision tree or pathway to determine the type of air permitting required or assessment that is needed. However, air permitting and industrial hygiene assessments often overlap.
工业卫生评估
From an industrial hygiene (IH) perspective, the need for an assessment often stems from an employee complaint or observation but there are also standards that require periodic monitoring or providing proof that your activities meet certain employee protective levels of contaminants. An example may be an employee who smells an odd odor. This odor may be from a chemical they or using or it could be something that was brought into the work area, such as new carpet or furniture. This issue may either be addressed my industrial hygiene personal exposure monitoring or an indoor air quality assessment.
We complete many indoor air quality assessments that derive from employee observations. Most of the time, these complaints do not make it to OSHA but are informal observations. Indoor air quality assessments typically address an uncomfortable environment (temperature, excess humidity, odor, ventilation, etc.) or complaints of headaches, problems breathing, or other “minor” symptoms (we completed an assessment several years ago prompted by client employees raising a concern about cooling tower chemicals and mist causing them hair loss).
我们最近由一名客户联系，员工抱怨他的设施造成呼吸问题的灰尘。我们的顾问与客户密切合作，以确保我们完全理解情况和最终的项目目标。我们收集了确定适当的测试和分析所需的所有信息，以满足客户的需求，并确定我们顾问需要将结果进行比较的内容或行动水平。该项目的方向在我们可以钉住范围之前改变了几次并与TCEQ和OSHA代表进行了磋商。
IH评估可以建立在众多OSHA标准，投诉（以及某些情况下，保险要求）之一内建立，并且通常可以根据快速谈话设计，但需要考虑多个因素，包括员工人数，包括员工人数完成的活动以及对控件到位，以及对适用的安全数据表（SDSS）的审查。
空气允许
On the air permitting side, owners and operators of emission sources (present at most industrial facilities) must comply with all applicable air quality regulations. Between NSR, Title V, PTE, registration, permits, de minimis, PSD, non-attainment, major, synthetic minor, true minor, state rules, federal rules, and more, each authorization mechanism, governed by a variety of regulatory statues, has specific compliance, technical, operational, emission and/or control requirements. Also, as is the case with chemical facilities and coating operations, for example, more than one regulatory statute can apply in addition to authorization.
As dizzying as all this sounds, the root of all air quality programs is who, what, where, and how much. Whether you are looking to modify operations by increasing production, adding new equipment, or are in the early stages of discussing construction of a new facility, an air permitting authorization is likely needed before any construction begins. The ultimate question, “how much?” will determine which authorization mechanism is right for your specific situation.
This is the point where finding the right environmental consultant can be of great assistance. In addition to helping you understand regulatory applicability, Braun Intertec has a reputable track record of assisting clients with their permitting needs and tailoring them to match their business goals. Are you looking for maximum flexibility? Maybe you are willing to sacrifice flexibility for an authorization with less reporting and compliance requirements? Whatever your goals are, our consultants can take goals into account and provide you with options that not only meet the regulatory requirements and provide you with the required authorization, but position you in an optimal place for sustainable compliance.
Before you reach out to an environmental consultant, or if you’re feeling confident and decide to DIY it, some fundamental information is needed to help facilitate the initial conversation and information is needed to make a decision on the right air pathway for your facility and operations.
加入我们的几位内部专家，莎莉佩里，柯南读和5月27日的尼克迈人为一个现场网络研讨会，导航不可见的空气世界：允许的曝光评估。我们将讨论可能适用于您的设施的各种类型的环境允许和合规和工业卫生相关空中项目，以及您将在您所在的情况下使用什么类型的信息。