White Paper: Connecting the Dots for Compliance at Ports

December 2, 2016
By Brian Schefke

Check out our latest White Paper, “Connecting the Dots for Compliance at Ports, by Freer analyst Nick Lowe-Hale and featured in BC Shipping News!

Freer Town Halls in October

October 20, 2016
By Brian Schefke

Join Freer Consulting, Hal Calbom, and Sustainable Media Partners for our Town Halls on Best Practices and Integrated Compliance Systems on October 26 and 27.

The October 26 Town Hall will be held at the Port of Morrow Riverfront Center in Boardman, OR. The October 27 Town Hall will be held at the Courtyard Richland Columbia Point in Richland, WA. Both Town Halls will feature a complimentary buffet with bar service. We hope to see you there!

White Paper: Mitigating Excel Risk via an Enterprise Risk Management Solution

August 31, 2016
By Brian Schefke

If your business uses Microsoft Excel to manage and process data, you could be incurring risks such as inaccurate financial statements, client overcharges, and nonconformance to standards. These risks often go undetected and can ultimately harm your business. To find out how Freer Consulting can help you improve your risk management, download our White Paper, “Mitigating Excel Risk via an Enterprise Risk Management Solution”.

If you are interested in learning more about Freer’s risk management consulting services, contact us at (206) 285-9044 or info@freerconsulting.com.

Phase I Municipal Stormwater Permit Revised

July 29, 2016
By Brian Schefke

The Washington State Department of Ecology has issued a revised Phase I Municipal Stormwater Permit that will go into effect on August 19, 2016. Developed as part of the National Pollutant Discharge Elimination System (NPDES), the Phase I permit regulates stormwater discharges from municipal separate storm sewer systems (MS4s) in incorporated cities with populations of over 100,000 and in unincorporated counties with populations greater than 250,000.

The main changes in the permit include:

  • Incorporation of municipal stormwater programs that provide equivalent or better protection of receiving waters as compared with the minimum technical requirements as stipulated in Appendix 1 of the permit.
  •  A description of the City of Seattle’s management plan for stormwater pollutants that discharge to the Lower Duwamish Waterway.

Further discussion of the changes to the Phase I permit can be found on the Department of Ecology’s website here.

If you would like to know more about stormwater management and how it applies to your community or business, contact Freer Consulting at (206) 285-9044 or info@freerconsulting.com.


June 30, 2016
By Brian Schefke

Increasingly, businesses are implementing a quality management system (QMS) that meets the requirements of the ISO 9001 standard, since potential customers often require certification in ISO 9001. If your business has a QMS, it’s worth considering a shift in focus from maintaining a QMS to developing a business management system (BMS). Doing so doesn’t require you to change your business practices; rather, a BMS can enhance your current practices by providing for accountability and continual improvement.

The BMS concept entails focusing on your current business processes while conforming to standards like ISO 9001. For example, your business processes may include:

· managing contracts
· purchasing
· employee training
· product inspection

Instead of using the ISO 9001 standards as the starting point , the BMS approach starts with your business processes and then modifies them so that they conform to the ISO 9001 standard.

The BMS approach has the additional benefit of enabling your business to incorporate other standards into your businesses processes, so that you can conform to multiple standards in a unified matter. For example, a business may have management systems that deal with aspects of the business’s operations and that are governed by other standards, such as an environmental management system (EMS) that complies with ISO 14001. Processes in an EMS include:

· identifying interactions between a business’s operations and the environment
· monitoring and measuring environmental impacts
· training to mitigate or eliminate environmental risks, e.g., spill cleanup
· compliance with applicable regulations

A BMS approach integrates these management systems, and any others, that the business has implemented. This allows for greater accountability and consistency across all aspects of a business’s operations, which in turn enables the business to identify opportunities for improving its products, services, customer relations and other key areas.

Freer Consulting has extensive experience assisting businesses with creating and implementing a BMS and achieving ISO certification. If you would like to know more about how Freer can help you, contact us at (206) 285-9044 or info@freerconsulting.com.

EPA Issues Draft Construction General Permit

April 21, 2016
By Brian Schefke

Construction activities can have a significant impact on stormwater discharges. Stormwater flows through construction zones pick up sediment, oil and grease, heavy metals and other pollutants, which are ultimately deposited into receiving waters. In order to limit pollutants in stormwater, construction that disturbs one or more acres of land requires permit coverage, either under the Construction General Permit (CGP) administered by the Environmental Protection Agency (EPA) or by a state regulatory agency.

The EPA has issued a draft CGP that is available for public comment through May 26, 2016. Once the draft CGP is made final, it will replace the current CGP when it expires in February 2017. To check if the EPA or the state is the CGP permitting authority for your area, visit the EPA’s authorization status page.

Freer Consulting has the experience and the expertise to assist you with stormwater regulatory compliance. If you would like to know more about how Freer can help, contact us at (206) 285-9044 or or info@freerconsulting.com.

The SPCC Rule

March 11, 2016
By Brian Schefke

If your business stores oil on site, you may be subject to the EPA’s Spill Prevention, Control, and Countermeasure (SPCC) Rule. The intent of this rule, established in 1973, is to prevent oil spills from reaching navigable waters and nearby shorelines, as well as to mitigate any direct spills in water and shoreline areas.

A facility is subject to the SPCC Rule if:

• The total aggregate aboveground capacity of the facility’s oil containers is greater than 1,320 gallons, and/or;
• The total aggregate capacity of the facility’s buried oil storage containers is greater than 42,000 gallons.

To comply with the SPCC Rule, a facility must:

• Take preventive action against spills (for example, proper containers, secondary containment for aboveground oil tanks, etc).
• Create and implement an SPCC plan.

Some important elements of an SPCC plan include:

• A diagram and description of the facility.
• A list of on-site containers and their capacities.
• Transfer and handling procedures.
• A description of secondary containment measures.
• Procedures for reporting spills.
• Certification by a Professional Engineer (PE), as applicable.

A facility subject to the SPCC Rule, but whose total aboveground storage capacity is 10,000 gallons or less, may comply with the Rule as either a Tier 1 or Tier 2 Qualified Facility. In addition to the storage requirement, a facility cannot have a single discharge of oil greater than 1,000 gallons to waters or shorelines or two discharges of oil greater than 42 gallons to waters or shorelines within any 12-month period. Tier 1 and 2 Qualified Facilities can self-certify their SPCC plans, and do not require certification by a PE.

Bear in mind that the SPCC Rule is a federal regulation—oil spill prevention regulations at the state level may also impact your facility, even if the SPCC Rule does not apply.

If you would like to know more about the SPCC Rule, or would like assistance in complying with the Rule, contact Freer Consulting at (206) 285-9044 or info@freerconsulting.com.

Internal Audits – Objective and Competent

February 9, 2016
By Carrie Salters

Internal audits, while necessary, are often dreaded by companies that conduct or receive them for a few reasons:

• The auditor’s responsibilities are time consuming—they schedule, conduct, and provide a detailed report of each audit to management.
• The auditees often feel interrogated by the auditor.
• It can be difficult to find a qualified and objective auditor.

Internal audits may be conducted by a delegation of employees or by a third party auditor. In either case, the auditor must be objective when conducting audits. Depending on the size of the company, it can be difficult to find a group of objective employees. In smaller companies, where everyone knows one another, employees often find it difficult to write-up their co-workers for a nonconformance to the process or standard. In larger companies, employees may not understand a process well enough to competently determine what is acceptable and what requires corrective action. Additionally, an employee’s knowledge of the standard is often limited, which impacts their ability to recognize a deviation from requirements.

At Freer Consulting Company, we can help as follows:

• Provide a one to two day training session to employees. This session provides important tools and reference documents to promote objectivity, impartiality, and an overall less stressful audit experience.
• Train internal auditors on the highlights of the standard, including what questions to ask and what types of records to look for in order to meet the requirements.
• Provide certified auditors to conduct internal audits on your behalf.

If you have questions about ISO 9001, ISO 14001, API, BRC, HACCP, or other international and industry standards and would like to learn more about how certification enhances marketability, contact Freer Consulting at (206) 285-9044 or info@freerconsulting.com

ISO 9001:2015 – Leadership Commitment

January 23, 2016
By Brian Schefke

Many companies struggle with implementing ISO 9001 without upper management’s leadership. Businesses seeking certification in the latest revision of the ISO 9001 standard should understand the importance of top management being committed to the standard and maintaining compliance with it. Section 5.1 of ISO 9001:2015 stipulates the ways in which management should exhibit leadership with respect to their company’s quality management system. Among the requirements are:

• taking accountability for the effectiveness of the system;
• ensuring the integration of the system into the company’s processes;
• communicating the importance of the quality management system and conforming to its requirements;
• promoting improvement; and
• supporting others whose role is to ensure the effectiveness of the system.

If you need assistance with any stage of the ISO certification process, Freer has the knowledge and experience to help you achieve certification and grow your business. For more information, contact us at (206) 285-9044 or info@freerconsulting.com