As I gaze into the crystal ball for the year 2013, I believe that there are multiple environmental and sustainability issues that will come to the forefront for the construction materials industries during the New Year. But here's five that I think that might really make a difference to you and your operation during 2013.
- TRI Reporting - TRI Form R Reporting, required at most concrete plants in the US will likely continue to emerge as perhaps the most dangerous environmental compliance issue to confront industry in a long time. This applies to all concrete producing operations, be it ready mixed, precast, pipe plants, etc. Exempt are those very small production plants or those that worked significantly less than a full year. A high enough percentage of plants that are required to report are NOT currently reporting, which will only lead to continued, or enhanced, enforcement efforts by USEPA. When combined with the USEPA's new apparent vigilance in enforcing the need to report lead in cement (which will likely trigger reporting at most concrete producing facilities), this potential for non-compliance makes this a hot button issue for 2013. Given the magnitude of the fines and other penalties associated with failure to conduct TRI Reporting, this would appear to be low-hanging fruit for the USEPA. Don't wait - if you need to be doing TRI Reporting, are unsure, or perhaps haven't been conducting TRI reporting for everything you should have, get help, fast.
- Back To The Basics - It would seem that in the year 2013 we wouldn't have to continue to identify NPDES stormwater permits as a hot topic, but it remains so due to continued lack of compliance with basic issues such as having the correct NPDES permit, understanding what types of discharges are covered by your NPDES permit, failure to have an adequate SWPPP plan, failure to conduct inspections and stormwater monitoring, etc. This is particularly applicable since a number of state's NPDES permits will be up for renewal (and modification) during 2013, possibly making things more difficult for current NPDES permit holders. Combined with continued issues with SPCC compliance, I think the basics will continue to be a real environmental issue in 2013.
- TMDLs Start to Come to The Forefront - As mentioned above, a number of state-specific NPDES permits are either up for renewal in 2013, or have just recently been renewed with compliance inspections to follow. Many of these NPDES permits now have the requirement to self-determine whether or not your facility discharges to an impaired waterway which may have a TMDL (total maximum daily load), or whether in fact your facility discharges pollutants for which a TMDL was created. For many, this somewhat confusing analysis may be a bit much, possibly resulting in a lot of NPDES permit applications mistakenly submitted, or SWPPP plans created which fail to identify the presence of TMDLs or applicable pollutants in the discharge stream. If this isn't in your state yet, it will be, soon.
- Sustainable Practices Get Increasing Attention - While it seems that the sustainability bandwagon may have lost a bit of steam during the latter part of 2012, the trend is inevitable. Sustainable practices and operations are the wave of the future. Those in the know are participating by identifying and improving key areas of sustainable practices, while a great many more are interested in finding out about sustainability and its many benefits. Those who aren't paying attention? Watch them begin to lag behind in 2013, in terms of market visibility and market share. Customers will be demanding sustainability in 2013, so look for this to become one of the hottest issues this coming year.
- Proof of Sustainability is Here - Green-washing doesn't cut it anymore, and bench-marking sustainable performance is here to stay, both on the production and on the product side. On the production side, watch for more emphasis on tangible demonstrations such as sustainable certifications, corporate sustainability reporting using standardized formats and tools, and environmental product declarations (EPDs). During the latter part of 2012, we saw the first concrete EPD developed for concrete here in the US in response to customer demand; watch for this type of trend to significantly increase in 2013. Savvy corporate participants are heeding the call, and looking for a legitimate certification of their products or operations - before customers begin demanding these proofs.
For me, those are 5 hot topics that I expect to see really take off in 2013, and we can help you with each of these topics if you're not ready to meet the challenge of the New Year on your own. To really ring in the New Year right, I'd advise you to heed the call of these issues. Being on the right side of them can help make 2013 a happy and prosperous New Year for you!
Ready to take on 2013? If you're struggling with regulations, or need help getting your sustainability program off the ground, click here to contact us or give us a call at 609-693-8301 to see how we can help today.