From Compliance Risks to Solutions: EHS Best Practices for Warehouse Operations

Warehouses and distribution centers face unique challenges when it comes to maintaining compliance with environmental and health and safety regulations. In a recent Antea Group webinar entitled “From Compliance Risks to Solutions: EHS Best Practices for Warehouse Operation,” Kelly Sampliner, CSP, Retail Industry Lead, Kara Van Blarcum, CESCO, Senior Professional, and Al Capps, PE, CIH, CSP, Senior Professional, discussed these risks and more. Below, we'll dive into these compliance risks, covering waste management, chemical storage, and workplace safety, followed by a summary of best practices. To listen to the full webinar, click below. 

Environmental Compliance Risks 

1. Waste Management

Every warehouse generates waste, which can be classified as hazardous, non-hazardous, universal, or general solid waste. The first step you must take is to identify a waste streams classification. Some questions to consider include:  

• Are your bulbs considered universal waste? 
• Is this product hazardous once it becomes a waste and you have to discard it? 
• Can I recycle this material? 

You'll want to review the safety data sheet (SDS) or perhaps even perform a Toxicity Characteristic Leaching Procedure (TCLP) analysis to determine the proper classification. Once classified, waste must be stored and labeled correctly, particularly if it is hazardous or universal waste. Compliance requires timely disposal according to generator classification guidelines and maintaining thorough documentation. Other best practices include choosing a waste vendor that is going to comply with the regulations for that waste stream and can properly dispose of it. If you have warehouses in multiple states, know the difference for waste management in each state. What is considered universal or hazardous waste in one state may not be the same in another state.  

2. Outdoor Activities and Permits: 

• Emergency Generators: If your facility has an emergency generator, it may need an air permit, and an air permit applicability should be completed. It will also need routine maintenance, such as filter changes and inspections. Also, emergency generator regulations typically have a limit on the number of hours an emergency generator can be used for non-emergency use. As a best practice, it’s important to track this non-emergency generator usage to demonstrate you did not exceed the time limit.  
• Stormwater Permitting: Depending on the state you’re in, facilities with stormwater exposure must secure a stormwater permit and implement a pollution prevention plan. For sites without exposed activities, a no-exposure certification may be an option but could require validation through regulatory inspections. The best practice in that scenario includes completing an annual inspection to verify that nothing has changed at your facility that would require getting a storm water permit.  
• Chemical Storage: Warehouses with significant chemical storage (diesel in your emergency generator, oil stored in 55 gallon or larger containers, or more than 1,320 gallons total) may require a Spill Prevention, Control, and Countermeasure (SPCC) Plan. Annually reporting hazardous chemicals, especially if stored in large quantities, falls under Tier II reporting. Proper chemical storage and segregation are critical for safety, particularly for substances like lead-acid batteries that contain hazardous sulfuric acid. 
• Refrigerant Leak Tracking: Facilities with refrigerants may need to perform leak rate calculations and report leaks when above a certain percentage. Documentation and calculations typically require collaboration with a certified refrigerant technician or HVAC vendor. 

Health and Safety Compliance Risks 

The hierarchy of controls is a good place to start in terms of health and safety compliance risks. The goal, while not always feasible, is to remove the risk from the workplace. Where that's not possible, the next best solution is to substitute a process or product for a less hazardous one. Next, engineering controls should be considered after that. Their physical systems are barriers to prevent employees from getting near a hazard. After that, administrative controls are the next tier in the hierarchy and include policies, procedures, and training. Finally, we should consider the use of personal protective equipment or PPE when reducing risk. 

It usually takes a tiered approach by using a combination of engineering, administrative, and PPE controls to keep workers safe. Now, let’s get into health and safety risks.  

1. Chemical Hazard Management: All facilities using hazardous chemicals must develop and implement a hazard communication program, which includes a comprehensive inventory, up-to-date SDSs, and employee training. Leaking or damaged chemical containers should be isolated to prevent incompatible reactions, such as chlorine gas from bleach and ammonia mixing, and employees will need training to handle these chemicals safely.  
2. Racking Solutions: When designing racking solutions, ensure racks are deep enough to fully support pallets, preventing push-through and instability. Use fully decked racking to avoid pallets falling through. Install pass-through protection like barriers or nets to keep materials from encroaching on neighboring aisles and maintain at least 18 inches of clearance between stacked materials and sprinkler heads for fire safety. Administrative controls, such as keeping aisles clear during loading and training employees on proper stacking and material handling, help minimize risks. Secure materials with shrink wrap, stack them stably, and avoid overloading the racking system to ensure safety and efficiency. 
3. Powered Industrial Trucks (PITs): Forklifts and other PITs present risks for both operators and pedestrians. Mitigating risks include designating a space for fueling or charging, setting speed limits, designating pedestrian-only walkways, and installing mirrors or notification systems to alert both PIT operators and pedestrians of nearby traffic. High-visibility vests and pedestrian training are also essential for safe PIT operation. 
4. Robotics in Warehouses: As robotics become more common in warehousing, safety protocols should evolve to consider robot-related risks. Autonomous systems can malfunction, requiring human intervention in confined or hazardous areas. Robotics need proper guarding and integration into the facility's lockout/tagout program to protect employees. 
5. Noise Exposure: High noise levels from conveyors, compressors, and power tools can lead to hearing damage and other health issues. Facilities with noise levels exceeding 85 decibels should implement a hearing conservation program, including audiometric testing and appropriate hearing protection. Regular noise assessments help to manage exposure effectively. 
6. Heat and Electrical Safety: Warehouses can become dangerously hot, especially in areas without climate control. Heat stress protocols include regular breaks, cool water access, and airflow management. In addition, all employees are exposed to electrical hazards in every workplace. Electrical safety, lockout/tagout programs, and regular training on electrical hazards are necessary to reduce injury risks. 

Quick Review: Summary of Best Practices 

Environmental Compliance: 

• Classify and separate waste streams, label and date containers, and work with compliant waste vendors. 
• Maintain documentation for generator use, apply for air and/or stormwater permits, and verify storage regulations for chemicals and refrigerants. 
• Conduct routine leak calculations for refrigerants and keep up-to-date Tier II reports. 

Health and Safety Compliance: 

• Implement a hazard communication program with inventory management, labeling, and annual training for handling hazardous chemicals. 
• Enforce clear pedestrian paths and speed controls for PITs and integrate high-visibility protocols. 
• Ensure adequate noise control, heat management, and electrical awareness training to protect employees. 

In summary, warehouse operations have a significant responsibility to balance productivity with safety and compliance. By implementing these best practices and maintaining proactive oversight, facilities can safeguard both their teams and their operational integrity. 

Do you have questions about your warehouse risks? Reach out to our team of experts to get answers today !  

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