TABLE OF CONTENTS
3.1 Introduction………………………………………………………………………………………………………… 3-1
3.2 Environmental Compliance Calendar…………………………………………………………………….. 3-1
3.3 Routine Inspections and Updates…………………………………………………………………………… 3-3
3.4 Annual Training Requirements……………………………………………………………………………… 3-3
3.1 Introduction
An important part of maintaining compliance with environmental regulations is
knowing when to do what. It is difficult to keep up with all of the deadlines and
schedules for the many different regulations without compiling a single compliance
calendar. To assist furniture manufacturing facilities with this sometimes difficult task,
the AFMA Action Committee on the Environment (ACE Committee) developed a
generic compliance calendar, which is presented in Section 3.2 of this chapter. The ACE
committee has also developed a listing of the routine inspections and updates that are
required by the various federal regulations. These are listed in Section 3.3. Finally,
annual training requirements for all of the regulations have been compiled into a single
list that is presented in Section 3.4.
3.2 Environmental Compliance Calendar
The AFMA ACE committee compliance calendar was developed to provide
furniture manufacturing facilities with a template calendar to start developing a facilityspecific compliance calendar. This calendar is organized by month, indicating dates for
specific items to be completed on an annual basis. If the calendar includes a year in the
date, then this indicates a one-time deadline for a specific regulation.
Although this calendar provides most of the relevant dates for federal regulations
applicable to furniture manufacturing facilities, all federal and state regulations, sitespecific permits, and any agreements should be consulted for additional dates that may be
specific to your facility.
COMPLIANCE CALENDAR INTRODUCTION CHAPTER 3
AFMA/3M/AKZO NOBEL/Environmental Guide
December 21, 1998 3-2
ENVIRONMENTAL COMPLIANCE CALENDAR
by AFMA Action Committee on the Environment – ACE
Date Action
January 1 Pesticide applicator license renewal, annual requirement
January 21, 1998 Initial Compliance Certification for NESHAP facilities with greater than 50 tons of
HAP emissions.
January 31 Anaytical test taken in accordance with the facilities stormwater program are to be
sent to the state regulatory agency, annual requirement.
January 31 NESHAP Continuous Compliance Certification for facilities with less than 50 tons
of HAPs emissions, annual requirement.
February 1 Employers must post previous year’s Log and Summary (OSHA), annual
requirement
February 7, 1999 Initial Compliance Certification for NESHAP facilities with less than 50 tons of
HAPs emissions.
February 15 Emission of VOC & HAP information due to NC Div. of Air Quality for Prohibitory
Small Sources, annual requirement
March 1 Tier II Reports are due to State EMC, LPC, and Fire Department annual requirement
March 1 Hazardous wate report to be files with State (due annually or biennially depending
on state requirements), annual requirement
April
May 21, 1998 NESHAP Training must be done for existing employees’ for facilities with more
than 50 tons of HAPs emissions
June 7, 1999 Existing employees must be trained under NESHAP regulations for facilities with
less than 50 tons of HAPs emissions
June 21, 1999 Compliance with Accidental Release Prevention Rule
June 30 Annual Emissions Inventory report due to State Environmental Management.
Annual renewal of registration to transport certain highly hazardous materials.
Structural pest control: licenses, ID cards expire.
June 30 NESHAP Continuous Compliance Certification Report due for NESHAP facilities
with emissions of greater than 50 tons, report certifies complaince for months of
December – May, annual requirement
July 1 SARA 313 Toxic Release Inventory report due to Federal, EPCRA reporting Center,
annualy requirement.
Annual Used Oil notification and fee due.
PCB Annual Document due to EPA9TSCA0, annual requirement.
July 31 NESHAP Continuous Compliance Certification for months of January – June, for
facilities with less than 50 tons of HAPs emission, annual requirement
August
September
October
November
December 7, 1998 Must comply with NESHAP for facilities with less that 50 tons of HAPs emissions,
including the training of new employees
December 22, 1998 All UST owners must have leak detection, corrosion protection, spill/overfill
prevention
December 31, 1998 NESHAP Compliance Certification reports due for facilities for facilities with
greater than 50 tons of HAPs Emissions for months of May- November
COMPLIANCE CALENDAR INTRODUCTION CHAPTER 3
AFMA/3M/AKZO NOBEL/Environmental Guide
December 21, 1998 3-3
3.3 Routine Inspections and Updates
In addition to the compliance items identified in Section 3.2, furniture
manufacturing facilities are also responsible for performing specific action on a routine
schedule, but the regulations do not specify a date for performing these actions. The
frequency and these actions are listed below.
As with the compliance calendar this list provides most of the relevant actions for
federal regulations applicable to furniture manufacturing facilities, all federal and state
regulations, site-specific permits, and any agreements should be consulted for additional
dates that may be specific to your facility.
Frequency Action
Weekly Inspection required for all generators of Hazardous Waste for storage and
accumulation areas
Monthly Inspection required as part of Wood Furniture Finishing MACT
Semi-Annual Storm Water Facility Inspection along with qualitative visuals samples
Annual Storm Water – Analytical monitoring as required by Storm Water Permit
Inspect and update all written plans including (but not limited to):
· Emergency Response or Contingency Plans,
· Hazardous Waste Contingency Plan,
· Storm Water Pollution Prevention Plan,
· SPCC Plan, and
· NESHAP Work Implementation Plan.
3.4 Annual Training Requirements
In addition to the routine inspections and actions identified in Section 3.3, there
are numerous training requirements for environmental regulations. These are identified
below for federal regulations applicable to furniture manufacturing facilities.
As with the compliance calendar this list provides most of the relevant actions for
federal regulations applicable to furniture manufacturing facilities, all federal and state
regulations, site-specific permits, and any agreements should be consulted for additional
dates that may be specific to your facility.
COMPLIANCE CALENDAR INTRODUCTION CHAPTER 3
AFMA/3M/AKZO NOBEL/Environmental Guide
December 21, 1998 3-4
Annual Training Requirements
· RCRA Training required for employees handling hazardous waste
· SPCC training
· Storm water training required for employees that work with materials that are stored that come in
contact with storm water runoff
· Formaldehyde exposure training
· Hazardous Materials Responders training- awareness, operations, & technician level
· Forklift Operator training/Power Hand Jack Operator training
· Respirator training
· Confined Space Entry Training
· Hot Work Permit Training
· Lockout/Tagout Training
· CPR Training
· Infection Control/Bloodborne Pathogens/TB
· Hearing Conservation/audiometer exam
· Audiometer Technician Training
· Fire Extinguisher Training
· Fire Hose Training
· Fire Hazard Training
· First Aid training (conducted every three years)