Common Texas Environmental Compliance Requirements

Many small Texas manufacturers don’t necessarily understand which EPA and TCEQ environmental and hazardous materials compliance regulations apply to their operations, let alone how to manage them.

Here’s a very quick summary of some of the basic environmental and hazardous materials rules that apply to a typical Texas manufacturer.

Environmental Compliance Requirements Include:

Hazardous Waste Management:
- Virtually all manufacturers generate some type of hazardous wastes, including spent chemicals, paints, batteries and more.
- Manufacturers must first complete Waste Determinations for all of their wastes and then determine their Generator Status (CESQ, SQG and LQG). Generator status will then determine which other RCRA regulations apply.
- Common hazardous waste regulations include manifesting, employee training, submitting annual waste summaries, P2 plans, and more.
- Learn more about the Top 10 Hazardous Waste Violations in Texas here

Storm Water Permit:
- Triggered by SIC code, and virtually all manufacturing SIC codes apply
- Impacted companies must either qualify for “No Exposure” (essentially meaning that all potential exposures including things like raw materials, chemical drums, manufacturing processes are either indoors or covered and protected from stormwater exposure) or apply for a permit and develop a plan.
- Companies who don’t qualify for No Exposure must develop and manage a customized Storm Water Pollution Prevention Plan (SWPPP). Plan requirements also include employee training, conducting routine inspections, and testing stormwater samples.

Air Emissions:
- Virtually all manufacturing air emissions in Texas must be authorized. This includes everything from space heaters to welding, to paint booth operations and more.
- If your process air emissions exceed certain thresholds, your company may need to apply for a New Source Review (NSR) Air Permit or Title V if you have multiple emission sources
- The majority of air emissions can be managed using Permits By Rule (PBRs). Texas has approximately 300 PBRs that cover the majority of air emissions.

Hazardous Materials Requirements:

Spill Prevention Control & Countermeasure Plan (SPCC):
- Triggered by the quantity of stored hydrocarbons on site, including oils, gasoline and diesel.
Tier II & TRI Reporting:
- These EPA regulations are triggered by the quantity of certain stored hazardous chemicals. If your company has any of these listed chemicals and exceed threshold quantities, then reporting may be required.

Click here to learn more about our Texas Environmental Compliance Consulting Services.

Most small businesses lack the expertise and time needed to navigate the complicated mess of OSHA & EPA regulations, leaving them vulnerable to costly injuries, fines, and lawsuits.

Berg Compliance Solutions offers turnkey programs to help businesses get peace of mind knowing they are fully compliant and positioned for success.

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By Russell Carr|2021-10-26T12:36:21-05:00August 9th, 2016|Hazardous Waste Management, OSHA Health & Safety, Texas Environmental Regulations, Texas Hazardous Materials Regulations|Comments Off

About the Author: Russell Carr

How A Sales Guy Transformed Into An Environmental, Health & Safety Expert & Advocate For Small Businesses I've spent my entire 30+ year career working within the manufacturing and “industrial services” sectors. The first 15 years of my career focused on sales of hazardous materials related products and services to the manufacturing sector, then for the last 16+ years transitioned into entrepreneurship, founding 3 small industrial services related contracting businesses. As you’ll see below, running these companies eventually lead me to found yet a 4th business, but more on that in a minute…. Here’s a brief description of the first 3 companies: Berg Environmental Services, Inc.: hazardous waste disposal & transportation services, founded in August of 2003 3rd party wind energy operations & maintenance services provider to utility scale wind farms throughout the US, founded in September 2007 3rd party oil & gas exploration & production services provider, founded in August of 2011 Each of these companies operated in extremely dangerous working conditions and exposed my employees to a wide range of serious health & safety hazards on a daily basis. To complicate matters, 2 of the companies also exposed the environment to significant potential harm. In other words, I learned very early the critical importance of managing environmental, health and safety issues so as to ensure the safety of our employees and the environment, as well as minimizing related risks. But I also learned how incredibly difficult and challenging this endeavor can be due to the wide range of complicated and continually changing environmental, health and safety rules and regulations that impacted the companies. To summarize the challenges: First I had to determine which regulations applied to each company, then I had to build compliance programs to meet those regulations, and finally I had to ensure that the programs were being managed and followed by our staff on a daily basis. All while trying to run and grow 3 profitable businesses…. It was overwhelming and I always struggled to keep up. To make matters worse, throughout this time I also witnessed the devastating price that companies, management and ownership can pay for failing to manage EHS compliance. This included seeing one of my hazardous waste management clients get sent to jail over environmental issues, another client’s management team threatened with jail time, a direct competitor get fined $378,000 by OSHA fine after an employee was nearly killed, and many others face major fines and penalties. Full disclosure, one of my companies got fined by OSHA at one point, & another was cited by TCEQ, so I know how it feels. In summary, I learned first hand how incredibly difficult it is for small companies to manage EHS compliance due to a common lack of the critical expertise, time and resources that are needed to keep up, and how this situation then ends up exposing them to these potentially catastrophic risks that can literally destroy lives and businesses. This later inspired me to found my 4th company, Berg Compliance Solutions in 2012, which is dedicated to helping other small businesses, and business owners, to manage EHS compliance and risk. Education BA, Philosophy, University of Colorado, Boulder, December, 1990. Summary of Professional Experience & Qualifications: 30+ years serving the manufacturing & industrial services sectors 30+ years of sales and marketing experience 16+ years as small business owner & entrepreneur: Founded and operated 4 small businesses since 2003. Environmental, Health & Safety Compliance & Program Related: 19 plus years of hazardous waste management including EPA, TCEQ & RCRA regulations 8 years of DOT/FMCSA compliance experience, including hazardous materials transportation 8 years of combined experience implementing and managing OSHA health and safety compliance programs for 2 high risk energy services businesses Successfully implemented and gained ISO 9001 Quality Management Certification and OHSAS 18001 (Occupational Health & Safety Advisory Service) Certification for wind energy maintenance business. Regulatory Enforcement Related Experience: Served as expert witness in criminal environmental compliance enforcement cases Superfund-CERCLA OSHA enforcement inspections, investigations and resolution in following industries: industrial services, manufacturing & construction. TCEQ enforcement inspections, investigations and resolution in manufacturing.

Common Texas Environmental Compliance Requirements