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Chapter 11
Appendix
11.11. Mass Highway Compliance Tracking Methods

Example 24 : Mass Highway Compliance Tracking Procedure for Facilities

Facility Inspections
Facility inspections are performed by Mass Highway personnel on a quarterly, bi-monthly or monthly schedule based upon the operations conducted at each facility. Facility personnel perform weekly inspections of facilities equipped with Hazardous Waste accumulation areas.

A facility designated for vehicle or heavy equipment repair will be inspected monthly whereas a seasonal snow and ice facility is inspected quarterly. These regular inspections permit Mass Highway to gather compliance information on a more frequent basis as compared to the self-audits. The results of these inspections are transmitted to the District Maintenance Engineer who facilitates the correction of any out-of-compliance issues. Corrections are coordinated between the DME the CS III, Facility Foreman and the DHC. The results of these inspections and the documented corrections are maintained at the District headquarters. The respective District HazMat Coordinator reports compliance matters that cannot be corrected within 14 days of identification to the Supervisor of the HazMat/HazWaste Unit. The Supervisor instructs the Mass Highway Clean State Database Coordinator to enter the matter into the database with a schedule for correction. Progress made on correcting the compliance matter is reported to the Clean State Database on a quarterly basis.

Routine Facility Observations
Mass Highway personnel are expected to keep facilities neat and generally adhere to good housekeeping practices. Furthermore, facility personnel are expected to report issues that may pose a potential compliance issue to their supervisor. Examples of potential issues that should be reported include but are not limited to the identification of dumping of materials in non-designated areas, missing spill equipment, spills and/or dripping fluids from containers and/or equipment.

Correcting Out-of Compliance Issues
Out-of Compliance situations that have been identified by way of Inspection, Self-Audit and/or Due Diligence must be corrected as soon as possible. Simple corrections such as replacing a label or closing a container should be made upon discovery. Corrections such as replacing broken or missing equipment, equipment repairs, and waste disposal should be made in a matter of days. Efforts should be made to resolve corrections requiring the use of outside contractors within 14 days of identification.

Tracking Compliance Matters
The Supervisor of HazMat\HazWaste Unit receives regular updates from the District HazMat Coordinators that identify any needed compliance corrections at the Facilities. This information is gathered from the regular facility inspections. The District HazMat Coordinators also maintain a log of compliance issues that require Environmental Section intervention. All issues that cannot be corrected within the 14 calendar period will be entered into the Clean State Database. Out-of-compliance issues from self-audits are tracked with the Audit Program Coordinator using the Corrective Action Report and the Clean State Matter Report. All issues that have not been corrected are entered into the clean state database.

Compliance Tracking Roles and Responsibilities
A summary of the roles and responsibilities for the Compliance Tracking Component is provided below.

 
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Table of Contents
 
Chapter 11
Appendix
11.1 Florida DOT Environmental Policy 11-1
11.2 Kentucky Transportation Cabinet Environmental Policy 11-1
11.3 Maine Dot Environmental Policy 11-2
11.4 North Carolina DOT Environmental Stewardship Policy 11-3
11.5 PennDOT’s Green Plan Policy Statement 11-3
11.6 Washington State Dot Environmental Policy 11-4
11.7 New South Wales Roads and Traffic Authority Environmental Policy 11-4
11.8 Texas Environmental Commitment Checklist 11-5
11.9 Maine DOT Environmental and Safety Auditing Policy and Procedure 11-11
11.10 Maine DOT Corrective Action Request Form 11-14
11.11 Mass Highway Compliance Tracking Methods 11-15
11.12 Mass Highway Compliance Tracking Roles and Responsibilities 11-16
11.13 Mass Highway Self-Audit Procedure 11-17
11.14 Mass Highway Facility Self-Audit Checklist 11-18
11.15 Mass Highway Environmental Roles & Responsibilities 11-20
11.16 Mass Highway Environmental Section EMS Roles and Responsibilities 11-20
11.17 Mass Highway Operations Division EMS Roles and Responsibilities 11-22
11.18 Mass Highway District EMS Roles and Responsibilities 11-23
11.19 Mass Highway Training Expectations By Role 11-24
11.20 Mass Highway Environmental Training Program Roles and Responsibilities 11-25
11.21 PennDOT District 10 SEMP Responsibility Table 11-26
11.22 PennDOT District 10 SEMP Training Table 11-28
11.23 NYSDOT Construction/Environmental Training Schedule 11-29
11.24 Environmental Checklist for MoDOT Facilities 11-30
11.25 PennDOT Stockpile Quality Assurance Responsibilities 11-33
11.26 PennDOT 15-Minute Stockpile Walkaround 11-34
11.27 PennDOT Stockpile Snapshot 11-34
11.28 PennDOT Maintenance Stockpile Activity Protocol 11-35
11.29 PennDOT Post-Storm Salt Management Tracking Responsibilities 11-41
11.30 Risk, Compliance Issues, and Management Examples for Highway-Generated Waste - Oregon DOT 11-42
11.31 NYSDOT-DEC Deer Carcass Composting – Practice Guidelines 11-43
11.32 NYSDOT’s Draft Metric for Assessing Performance of Integrated Vegetation Management on ROW 11-47
11.33 NCDOT Roadside Vegetation Management Guidelines in Marked Areas 11-50
11.34 Invasive Species Coordination and Control DOT Resources
   
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