RL Macklin's Sustainability & EHS Website

Integrated Strategies for Managing Sustainability & EHS

RL Macklin's Sustainability & EHS Website

Integrated Strategies for Managing Sustainability & EHS

RL Macklin's Sustainability & EHS Website

Integrated Strategies for Managing Sustainability & EHS

RL Macklin's Sustainability & EHS Website

Integrated Strategies for Managing Sustainability & EHS

Project Highlights

Click on the project titles below to read about some of the projects I have completed
Carbon Footprint - Greenhouse Gas (GHG) Inventory
Quick Facts
*1st GHG inventory for Avery Dennison
*35 Countries
*161 Facilities
I worked with outside consultants to develop a GHG data collection and analysis protocol suited to Avery Dennison's business needs. We built and deployed a data collection system. In order for the facilities around the world to understand why they were being asked to gather data I provided training via web conferences to introduce them to what GHG was, what in their facilities contributed to GHG emissions and the data entry system.
Total Waste Management Program
Quick Facts
*Waste was independently managed by individual facilities
*Disposal records were missing
*New liability from disposal activity
Developed a policy to manage all waste (hazardous, non-hazardous and recycle material) through approved vendors and only into approved disposal facilities. Qualified a preferred vendor to provide enhanced waste management services, including disposal facility audits, electronic record keeping, and added insurance. Cost were reduced by 2% in the first year, internal customer satisfaction was improved and the number of disposal facilities were reduced by 20%.
Paxar Acquisition EHS Due Diligence
Quick Facts
*6 months to complete an acquisition related due diligence
*125 Facilities
*60 countries
Avery acquired a $1.3 billion garment label manufacturer. The EHS due diligence had to be conducted after the acquisition for regulatory reasons. Hired a consultant to perform EHS screening on facilities in order of risk based priority. Used the results from the screenings to undertake limited Phase 2 investigation at facilities most likely to be contaminated. Established remediation reserves based on the result of the limited Phase 2 investigations.
NPDES Stormwater Applicability Assessment
Quick Facts
*An multinational confidential client (based in France) needed to determine compliance with Stormwater regulations at its US facilities
I prepared informational material to help the companies local EHS staff to understand the applicability and requirements of NPDES Stormwater regulations. I visited the facilities and assessed the applicability of the NPDES Stormwater regulations for each facility. Developed documentation to review the entire matter with the companies US and French based attorneys. A plan to bring each facility into compliance either through making changes to the facilities' infrastructure or procedures to gain an exemption or filing for and complying with a permit.
Remediation Liability Reserves Management
Quick Facts
*Avery Dennison had remediation projects "stuck" with regulators
In order to continue to reduce reserves and move projects forward I identified projects that were slow movers either because of erratic data or lack of agreement with regulators. Examples include a projects in New York, Georgia, Switzerland and The Netherlands. Working with consultants we identified gaps in our data that could account for the erratic data and were able to better define the plumes of contamination and viable remedial alternatives. The improved models allowed us to approach the regulators and jointly develop remediation approaches that were fiscally responsible and within regulatory boundaries.
FASB 143/FIN 47
Quick Facts
*Avery Finance needed help with complying
*140 facilities in 3 months
I worked with a consultant to develop a protocol and provide training to Avery personnel to gather data on effected assets in all affected facilities. We also set up regional help lines so questions could be asked and answered in the local time zone and language. For the 2nd year we converted the data gathering process to an EHS IT system rather than Excel. The facilities reported that they were able to complete the work in roughly 30% of the time as it took when they had to use Excel.
PA Emergency Response
Quick Facts
*3000 lbs of adhesive released
*1/4 mile wide almost 1 mile long impact area
An over pressurization during adhesive manufacturing resulted in the unexpected airborne release of adhesive. The Avery Dennison facility, employee cars, neighboring manufacturing facility, residential, commercial and municipal properties where all impacted with adhesive that had to be removed. Working with an emergency response contractor and town officials I was able to arrange to clean all the impacted properties sufficiently to allow them to be used safely. We were successful in cleaning, and/or replacing property sufficiently to avoid any negative impact to Avery Dennison by from the community.
Subpart BB Violation Negotiation
Quick Facts
*Facility faced with fines in excess of $1 MM
An Avery Dennison facility, unaware of applicable regulations was faced with cumulative fines of over $1,000,000 from EPA for violations of the air portion of RCRA. I went to Philadelphia to negotiate with EPA the outcome of the violation. Prior to the negotiations I worked with the facility to implement corrective actions and develop a plan to assure future compliance. As a result of these actions and negotiations the final fine was reduced to less than 10% of the original proposed fines.
Remediation Goals Negotiations
Quick Facts
*Avery Dennison had remediation projects "stuck" with regulators.
In order to continue to reduce reserves and move projects forward I identified projects that were slow movers either because of erratic data or lack of agreement with regulators. Examples include a projects in New York, Georgia, Switzerland and The Netherlands. Working with consultants we identified gaps in our data that could account for the erratic data and were able to better define the plumes of contamination and viable remedial alternatives. The improved models allowed us to approach the regulators and jointly develop remediation approaches that were fiscally responsible and within regulatory boundaries.
Two Tier EMIS System Design & Implementation
Quick Facts
*Avery had limited number of EHS professionals
*Operations in 45 countries
In order to maintain compliance, effectively share information among a distributed group of professionals and track large amounts of data Avery decided to implement an EMIS. In order to accomplish this I developed a two (2) tier EMIS system. I lead the programming and implementation of the system, as well as designed many of the applications. The first tier of the system was comprised of a number of custom built databases to manage data related to audits, EHS policies, EHS task guidelines, liability reserves, TSCA chemical reporting, acquisition and divestiture, injury and illness. The second tier utilized a configurable system to allow management of data related to permits, such as Title V and other air permits, FIN 47, GHG and other data and calculation intense activity.
Underground Storage Tank UST Removals
Quick Facts
* Avery implemented a 10 year policy to remove all underground storage tanks.
In order to facilitate implementation of the policy I directly lead the removal of over 200 USTs in 20+ facilities around the world. Staff reporting to me removed approximately another 40 USTs. To accomplish these removals it was necessary to negotiate for variances to local regulations, in multiple domestic and international jurisdictions so above ground replacement tanks could be installed. I designed numerous tank and mix room containment systems to install in place of the removed tanks. I assisted facilities with meeting the requirements from FM to be considered highly protective but have above ground storage without ways for water to exit containment rooms in the event of a fire. My staff and I implemented site investigations and remediation projects as needed to clean up chemicals released while the tanks were in operation. It was generally necessary to undertake these activities so that the facility could remain in operation during the removal and replacement.
Facility Decontamination and Decommissioning
Quick Facts
* Either through acquisitions or changes in business Avery from time to time had facilities containing contaminated equipment and building structures
* Many of the environments in these structures were highly hazardous as the conditions were not always well known
Supervising hazmat vendors I and/or my staff decontaminated and decomissioned multiple facilities. In some instances obsolete equipment was removed and the facilities were re-commissioned with a different purpose. In those instance we turned the facilities over to the building engineering group free of contaminates and broom clean. If the facility was to be used with hazardous chemicals we installed sub-slab liners, solvent resistant coatings etc. as needed to protect the environment from the consequences of accidental spills and the business unit from the costs associated with chemical releases. In other instances the facilities were decommissioned and demolished. We salvaged the valuable scrap and turned over cleared property to either the real estate group or the business unit. In the course of this work we addressed VOC solvents, metal dust, TPH, small radioactive sources, utility disconnects moves and reconnection. Most of this work was done at active facilities requiring close coordination with facility staff so production would not be interrupted.
Health and Safety Training
Quick Facts
*Unionized facilities maintenance group had a high rate of injury and wasn't retaining safety training
I assessed why participants in training were not able to retain the knowledge from training sessions by talking with the people being trained. Revamped the training program to include, train the trainer process, PowerPoint presentations, more visuals, takeaways for participants, multiple reminders throughout the facility of the current training topic, quizzes to identify any gaps in understanding. These changes resulted in not only improved retention but increased enthusiasm for attending training in both the instructors as well as the staff receiving instruction. Topics trained included Lockout Tag out, Bloodborne Pathogens, Heat Stress, Personal Protective Equipment (PPE), Hazard Communications, Confined Space Entry procedures, Ladder Safety, Hand Tool Safety.