Gen Blog | Community

By Kim Allman | Head of Corporate Responsibility and Government Affairs

This month, the Gen™ family of brands, including Norton, Avast and more, joins millions around the world recognizing Pride month. This is a time to memorialize the anniversary of the Stonewall Riots and those who have lost their lives due to hate crimes, commemorate the impact that LGBTQ+ individuals have had on our collective history, celebrate the progress made in the fight for equality and reaffirm our commitment to support LGBTQ+ rights.

Gen + The Trevor Project 

We are excited to announce our new partnership with The Trevor Project, the leading organization working to end suicide among LGBTQ+ young people in the U.S. and beyond. The nonprofit operates several programs to help prevent and respond to the public health crisis of suicide among LGBTQ+ young people, who are particularly vulnerable to cyberbullying.

According to the most recent data from the Cyberbullying Research Center, more than half of LGBTQ+-identifying students have experienced cyberbullying at some point during their lifetimes. In addition, the CDC’s annual Youth Risk Behavior survey has consistently found that queer students, including transgender and non-binary students, are more than twice as likely than their heterosexual peers to be bullied online.

To combat these trends, Gen is teaming up with The Trevor Project to bolster the organization’s TrevorSpace platform, an affirming online community for 400,000 LGBTQ+ young people to safely share interests and make connections. Gen is also supporting the creation of an educational resource that speaks to how LGBTQ+ young people can stay safe online and how we can all promote more inclusive and welcoming digital spaces. We look forward to providing more details on this initiative over the next year.

Gen Team Pride Month Activations 

During Pride month, Gen will co-host an employee Lunch & Learn with our PROUD employee resource group (ERG) and The Trevor Project. Gen teams will learn more about the urgency of The Trevor Project’s mission, get access to the latest data and insights on LGBTQ+ mental health and hear more about how support and affirmation for the LGBTQ+ community is crucial year-round.

Gen and PROUD will also host our third annual all-employee virtual Pride Parade, featuring a guest speaker from The Trevor Project.

Additionally, PROUD plans to offer a TED Talk discussion while WONDER, our women-focused ERG, is running an #IamRemarkable workshop on intersectionality.

The Social Impact team has set up an #AllInThisTogether Pride Challenge in our Giving Hub, hosted by Benevity, so that employees can learn, share and participate by taking actions each week to support LGBTQ+ people at Gen and in our community during Pride Month. Employees that complete the challenge will receive a reward to donate to their favorite cause. Employees will also get the chance to learn more about our corporate nonprofit partners – The Trevor Project, Out & Equal, and The Pride Forum in Czechia – and give to these and other causes supporting LGBTQ+ communities and vetted by our PROUD ERG.

These June activations are complemented by two recent employee training co-hosted with Out & Equal. The organization is renowned for its work to make the world’s workplaces as inclusive as possible for LGBTQ+ professionals. Out & Equal provided resources at the Nonbinary & Beyond training focused on pronoun usage and other nonbinary allyship topics. An additional training, on Intersectional Allyship at Work, took place to help employees develop a greater understanding of their own dimensions of diversity, learn what “intersectionality” is and expand their own capacity for allyship, through interactive and dynamic group exercises.

While we are happy to be celebrating Pride this June, we focus on equality year-round at Gen. We will continue to partner with high-impact nonprofits and will work within our own company walls to promote LGBTQ+ equity and inclusion.

Facilities that possess aboveground oil storage capacities exceeding specified thresholds, along with the potential for oil discharge to navigable waters or shorelines, are required by federal regulations to develop and implement a Spill Prevention, Control, and Countermeasure (SPCC) Plan.

While most facilities are aware of the need to include bulk oil storage containers in their SPCC plans, the inclusion of oil-filled equipment is often overlooked.

In this blog post, we will explore the importance of considering oil-filled equipment in your SPCC plan and shed light on its applicability.

What is Oil-Filled Equipment? 

Oil-filled equipment is defined under 40 CFR 112.2 as equipment that includes an oil storage container (or multiple containers) in which the oil is present solely to support the function of the apparatus or the device. If the equipment has containers/reservoirs which contain oil and have a capacity of 55 gallons or greater, that equipment must be included in the SPCC plan.

Containment

According to the SPCC Guidance for Regional Inspectors, the definition of bulk storage container in §112.2 specifically excludes oil-filled electrical, operating, and manufacturing equipment (“oil-filled equipment”). Therefore, oil-filled equipment is not subject to the bulk storage container requirements in §§112.8(c), 112.9(c), and 112.12(c). However, oil-filled equipment must meet the general requirements of §112.7.

Oil-filled equipment must be provided with general secondary containment for the most likely spill scenario (§112.7) which can be defined as drips or leaks that can occur from equipment under normal operation. This could be a pint to a few gallons depending upon the rate and duration of the leak. General containment is not intended to contain the entire capacity of the reservoir.

Inspections

While the integrity testing requirements of §§112.8(c)(6) and 112.12(c)(6) are only applicable to bulk storage containers, EPA believes it is good engineering practice to have some form of visual inspection or monitoring for this oil-filled equipment to prevent discharges as described in §112.1(b) – see SPCC GUIDANCE FOR REGIONAL INSPECTORS, August 28, 2013.

Typically, it is recommended to inspect and maintain oil-filled equipment according to manufacturer recommendations. Oil-filled equipment should be included as part of a routine walk-around inspection of the facility.

The EPA has grouped oil-filled equipment into three categories:

OperationalElectricalManufacturing

The following provides descriptions and examples of these types of oil-filled equipment which you might find at your facility.

Operational/Mechanical 

Oil-filled operational equipment means equipment that includes an oil storage container (or multiple containers) in which the oil is present solely to support the function of the apparatus or the device – see 40 CFR 112.2

THINK RESERVOIR! Does the equipment have an oil reservoir? Is the reservoir 55 gallons or greater in capacity?

Examples of Oil-Filled Operational Equipment include:

Elevators – These reservoirs are usually located in equipment rooms which provide sufficient general secondary containment by concrete floor and walls.

Compressors – Oil lubrication and oil coolant reservoirs for large compressors.

Compactors – Large trash, box, or used automotive filter crushers can have hydraulic oil reservoirs.

Machining Equipment – Metal fabrication, manufacturing, and repair facilities can have equipment such as shears, brake presses, drills, or benders with oil reservoirs for operation or lubrication.

Generator – Working Oil Capacity – Typically, there are two oil containers associated with a generator:

Fuel tank (bulk container)Oil reservoir to lubricate the engineThe oil reservoir/crankcase on some very large generators can exceed 55 gallons in capacity and be subject to SPCC requirements for OFE.

Wind Turbines – can have gearbox oil volumes that exceed 55 gallons in capacity and be subject to SPCC requirements for oil-filled operational equipment. Containment is typically addressed with a contingency plan or equipment maintenance program for qualifying equipment.

Electrical

Electrical equipment such as transformers, circuit breakers, and switches can contain oil (mineral or dielectric) for cooling and electrical insulation. If the electrical equipment is large enough, the oil capacity can reach 55 gallons or more causing the equipment to be regulated as oil-filled operational equipment in your SPCC plan.

Transformers – are the most common electrical oil-filled equipment and can be either facility-owned or public utility owned. If they are facility owned, then the transformers must be included in the SPCC plan as oil-filled operational equipment and general containment must be provided.

Manufacturing/Process 

Oil-filled manufacturing equipment stores oil only as an ancillary element of performing a mechanical or chemical operation to create or modify an intermediate or finished product. – see SPCC GUIDANCE FOR REGIONAL INSPECTORS, August 28, 2013. 

THINK PROCESS OR CHANGE! The oil product flows through the equipment or is changed within the equipment.

Examples of Oil-Filled Operational Equipment include:

Mixing Tanks,Reaction Vessels,Phase Separators,Oil Heaters,Dryers,Knockouts, andVapor Recovery vessels.

By understanding the significance of oil-filled equipment and its inclusion in your SPCC plan, you can ensure compliance with federal regulations and effectively mitigate the risk of oil spills. Remember to consider operational, electrical, and mechanical equipment at your facility.

Also, remember to conduct regular inspections and maintenance according to manufacturer recommendations. By doing so, you can enhance the overall safety and environmental stewardship of your facility.

Do you have questions about oil-filled equipment and your SPCC plan? Antea Group is here to help.

To get answers to all your questions and for guidance in building your SPCC plan, reach out to our SPCC Plan Experts today!

About Antea Group

Antea®Group is an environment, health, safety, and sustainability consulting firm. By combining strategic thinking with technical expertise, we do more than effectively solve client challenges; we deliver sustainable results for a better future. We work in partnership with and advise many of the world’s most sustainable companies to address ESG-business challenges in a way that fits their pace and unique objectives. Our consultants equip organizations to better understand threats, capture opportunities and find their position of strength. Lastly, we maintain a global perspective on ESG issues through not only our work with multinational clients, but also through our sister organizations in Europe, Asia, and Latin America and as a founding member of the Inogen Alliance. Learn more at us.anteagroup.com. 

June 27, 2023 /3BL/ – The Healthcare Plastics Recycling Council (HPRC) is excited to welcome Casella Waste Systems, Inc. as its newest member. Casella is the largest recycler and most experienced fully integrated resource management company in the Northeastern United States, providing solid waste collection and disposal, transfer, recycling, and organics services to more than 900,000 residential, commercial, municipal, institutional, and industrial customers.

“HPRC is pleased to welcome Casella as our newest member,” shared Peylina Chu, Executive Director of HPRC. “Casella’s mission to create value by renewing and sustaining our resources and environment complements HPRC’s goals and values. We’re looking forward to learning from their experience and collaborating on projects to advance the recyclability of healthcare plastics.”

Casella also provides professional resource management and consulting services to over 10,000 customer locations in over 40 states nationwide, including hospitals, medical manufacturers, medical packaging companies, life sciences, and pharmaceutical companies to customize resource management programs unique to the healthcare industry and their individual sustainability goals.

“Investments in infrastructure and creative resource management solutions allow us to help make the world a safer and more environmentally friendly place for current and future generations,” says Casella Chairman and CEO, John W. Casella. “Today, for every metric ton of greenhouse gas we emit through our operations, we prevent 4.8 metric tons of greenhouse gas emissions throughout the economy, through the recycling, energy, and carbon sequestration services we provide, which enables us to help advance HPRC’s mission and goals.”

HPRC is currently engaged in multiple initiatives aimed at enabling the recycling and circularity of healthcare plastics, including research into advanced recycling technologies to recycle mixed-stream healthcare plastics; a study of reverse logistics processes for collecting, segregating, and preparing healthcare plastic waste for transport; and design guidance to improve the recyclability of medical packaging and products.

About HPRC 

HPRC is a private technical coalition of industry peers across healthcare, recycling, and waste management industries seeking to improve the recyclability of plastic products within healthcare. Made up of brand-leading and globally recognized members, HPRC explores ways to enhance the economics, efficiency, and ultimately the quality and quantity of healthcare plastics collected for recycling. HPRC is active across the United States and Europe working with key stakeholders, identifying opportunities for collaboration, and participating in industry events and forums. For more information, visit www.hprc.org and follow HPRC on LinkedIn.

About Casella 

Casella Waste Systems, Inc., headquartered in Rutland, Vermont, is the Northeast’s largest recycler and most experienced fully integrated resource management company. Founded in 1975 as a single truck collection service, Casella has grown its operations to provide solid waste collection and disposal, transfer, recycling, and organics services to more than 900,000 residential, commercial, municipal, institutional, and industrial customers throughout the Northeast, and professional resource management services to over 10,000 customer locations in more than 40 states.

Quest proudly fosters an inclusive workplace where all of our colleagues feel supported to bring their whole selves to work. Leaders and employees at many of our lab facilities have worked together to develop initiatives to celebrate inclusion and diversity through sharing their diverse backgrounds, nationalities, traditions, and observances. Following are some examples of how personnel in our labs—one in New Jersey and another across the country in California—created initiatives together, showing inclusion in action.

Quest’s newest lab reflects many cultures and heritages

Our new 250,000-square-foot flagship lab in Clifton, NJ, one of the largest globally, is equipped with a mother’s room, nondenominational prayer room, and all-gendered bathrooms. On a suggestion by VP Santiago Galvez, Clifton employees rallied to make the space their own with a display of national flags depicting the 20+ countries represented by the colleagues who work on-site.

“The flags represent the diversity we have in the East Region and the important commitment we have made to building an inclusive environment for everyone.”

Miguel A. Aldana

Director, Lab Operations, East Region

West Hills lab creates a tapestry of welcome

Colleagues at Quest Diagnostics in West Hills, CA also developed initiatives based on their unique perspectives to celebrate one another’s diversity of cultures and ideas.

Each employee customized artistic handprints to represent themselves and their lives, helping colleagues get to know one another on a more personal level. Of 120 employees on-site, 100 have participated—with new employees continuing to contribute.

The West Hills Specimen Management department proudly displays a mural entitled, “Diversity: Accomplishment has no color.” The mural shows a world map with photos of employees’ faces posted on their countries of origin, as well as characters around the map wearing traditional cultural attire.

“There’s always common ground… We all strive to feel needed, wanted, and welcomed… When I was presented with this opportunity to celebrate inclusion and diversity, I accepted the challenge…to show respect and celebrate all my coworkers.”

Grace Dominguez

Specimen Processing Trainer

Read more

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