C1. Environmental Permits and Reporting

Code 8.0

All required environmental permits (e.g. discharge monitoring), approvals, and registrations shall be obtained, maintained, and kept current, and their operational and reporting requirements shall be followed.

Elements to Demonstrate Compliance to RBA Code

1. Policy

Ensure the facility's environmental policy includes environmental permits and reporting elements including:

• a. Applying for and maintaining all necessary permits, approvals, and registrations.
• b. Accurate tracking necessary data to report and show level of conformance.

2. Procedures & Practices

Procedures & Practices are in place such that:

• a. The facility maintains a registry/inventory of environmental permits, licenses and certifications including their monitoring and reporting requirements, expiration dates, etc.
• b. The facility has an implemented process to ensure that permits, licenses, and certifications are kept current and updated as necessary as operations changes occur.
• c. All environmental violations have been remediated and are considered closed by the appropriate authorities.

3. Controls & Monitoring

Controls & Monitoring should include:

• a. Tools, systems, and processes are properly tested, calibrated, and otherwise maintained to demonstrate accuracy in measurement, indication, and recording.
• b. Site operations are in compliance with all monitoring, reporting and other permit requirements based on:
  • i. Internal monitoring and assessments
  • ii. Independent third-party assessments
  • iii. Regulatory agency reviews/inspections

4. Records

Records are maintained including:

• a. All the environmental permits required by law are current such as but not limited to:
  • i. Operating permit
  • ii. Air emissions
  • iii. Wastewater discharge
  • iv. Stormwater exposure
  • v. Hazardous materials storage and use
  • vi. Generation of waste (solid and hazardous)
  • vii. Boundary noise limits
  • viii. Other equipment
• b. Certifications as required by law are current such as but not limited to:
  • i. Professional certificates
  • ii. Environment ERT members have the required qualifications/certifications.

NOTE: All permits, licenses, certifications, and reporting data are posted as required by law

5. Serious conditions that will result in a severe finding

• Not properly reporting environmental accidents or incidents to the governing agency as required by law.
• Delay in mandatory government reporting in excess of 3 months from the due date.

1.0.0 (2024-01-01)

Changed

• Initial release for RBA Code of Conduct 8.0: Comprehensive criterion covering environmental permits, approvals, registrations, and regulatory reporting requirements aligned with ISO 14001 and GRI 307.