Headquartered in Westborough, MA, BJ’s Wholesale Club, Inc. is a leading operator of membership warehouse club stores in the Eastern United States. The Company currently operates over 200 clubs in 15 states from Maine to Florida and employs more than 25,000 team members.
As a large retailer, BJ’s faces many unique safety and environmental compliance challenges. Regulations are constantly changing, and for retailers with multiple facilities, such as BJ’s, managing chemical and regulatory data can be a complex maze to maneuver. BJ’s Asset Protection Team is tasked with managing several critical business initiatives, all of which are key components of a comprehensive environmental regulatory compliance program. These issues include:
- Ensuring proper, compliant shipping documentation
- Managing hazardous material storage requirements to ensure that fire code obligations are met
- Preparing store specific disclosures to comply with local government and/or fire department requirements
- Ensuring club Team Members have proper disposal information
- Responding to emergencies, such as spills, inhalations or exposures
- Providing store employees with access to Material Safety Data Sheets (MSDSs)
Ensuring accurate regulatory reporting is of particular importance as BJ’s has diversified compliance programs where multiple departments (e.g. licensing, photo, stores) manage different aspects of the reporting puzzle, making it difficult to ensure that all obligations are identified and fulfilled.
“With so many club locations along the east coast, it is quite difficult to respond to regulator requests, and not responding can result in fines, project delays, inability to sell product, or increased regulatory scrutiny,” said William Peters, Assistant Vice President, Safety & Regulatory Compliance, BJ's Wholesale Club.
With so many requirements on so many different fronts, BJ’s turned to a solution provider that could ease the burden of achieving compliance and augment their in-house efforts.
BJ’s chose to partner with 3E Company, which has an extensive history of leadership in serving the needs of the retail market. BJ’s Asset Protection Team worked with 3E’s team of regulatory compliance experts to create a customized suite of services to address BJ’s compliance requirements.
BJ’s relies on 3E’s Emergency Response Hotline for Workplace to provide 24-7-365 information and professional guidance for chemical spill management, as well as access to professionals for concerns related to a chemical or product exposure at any of BJ’s 201 locations.
“Our Team Members use the hotline on daily basis. Knowing that 3E is available around-the-clock is a tremendous relief,” said Mr. Peters. “Having near immediate access to 3E’s vast expertise and know-how in the event of an incident is critical to our employees’ ability to respond quickly and properly, in a manner that reduces risk to members, Team Members and the surrounding community.”
The 3E team fields thousands of calls from BJ’s annually, ensuring that incidents were handled safely and in accordance with local, state and federal regulations.
BJ’s also uses 3E’s Emergency Response Hotline for Products. As part of this service, BJ’s can display 3E’s toll free telephone number on shipping documents to ensure transportation compliance.
“Having 3E’s number on shipping documents provides us with an added level of security,” said Mr. Peters. “We know that if something goes wrong during transport, reliable information is just a phone call away.”
With over 200 sites generating their own waste, classification can be a challenge. BJ’s relies on 3E's Waste Classification Service to provide expert assistance with the identification and classification of items that may be regulated as hazardous waste at the Federal and State levels.
“Outsourcing this task to 3E streamlines and takes the guesswork out of the process of identifying and classifying hazardous waste,” said Mr. Peters. “And should we have any questions about how an item is classified, 3E offers 24-7-365 access to waste specialists.”
To ensure that BJ’s hazardous waste items are properly classified, 3E’s waste experts regularly conduct an exhaustive review of manufacturer Safety Data Sheets (SDSs). Those SDSs are then analyzed to determine the appropriate Federal and State-specific waste codes and descriptions for their products should they become hazardous waste.
BJ’s waste classification data is delivered via the 3E OnData service platform, meaning the data can be supplied in the form of customer report, data file or data feed of classification information directly into BJ’s corporate system. This enables the Asset Protection Team to reduce data management costs by providing a centralized repository for classification data to be shared with the entire enterprise. 3E maintains data provided by monitoring for changes to hazardous waste regulations or manufacturer supplied MSDSs and providing updates on an on-going basis.
Waste Classification data can also be used to evaluate disposal costs as well as the impact of using the chemical at a company’s facility and also to identify alternative or less harmful products. This data can also be used to help ensure that hazardous wastes are being properly disposed and that BJ’s is acting in the most environmentally responsible and compliant manner possible.
3E Regulatory Reporting services also play an important role in BJ’s Asset Protection Team initiatives. BJ’s relies on 3E to facilitate the development and submission of its hazardous materials disclosures, which are associated with emergency planning and community right-to-know requirements related to the storage and handling of hazardous materials.
In particular, BJ’s relies on 3E’s expertise to power its Tier II reporting program.
“3E has been managing our Tier II disclosures for years, and we have been very pleased with the results,” said Mr. Peters. “We were previously managing these disclosures in house, and we have realized a tremendous increase in efficiency and productivity since we outsourced this time-intensive task.”
3E's Regulatory Specialists annually complete and submit nearly 8,000 disclosures and permits, maintain active relationships with thousands of regulatory agencies and jurisdictional authorities, and track tens of thousands of individual compliance reporting tasks. 3E’s breadth of experience, regulatory expertise and relationships help provide accurate and timely completion of required disclosures, permits and fees specific to all of BJ’s facilities.
“Using 3E’s regulatory reporting services helps BJ’s streamline and simplify the regulatory reporting compliance process,” said Mr. Peters. “These services – especially when combined with additional, complementary 3E services that we are utilizing – really help us centralize our regulatory reporting and permitting initiatives.”
BJ’s also relies on 3E MSDS On Demand, which offers live assistance 24-7-365 for all SDS requests, and provides access to the entire 3E database of millions of SDSs, which are sent via fax directly to BJ’s, their Team Members or other related callers.
“We have deployed 3E MSDS on Demand at all of our sites, and it has been a very valuable resource for us. All of our Team Members know how to use it, so if they come into contact with a hazardous material, they know to call 3E and request the appropriate SDS,” said Mr. Peters. “3E responds very quickly to all of our requests, and we typically have a response within a few short minutes.”
To ensure compliance with the Department of Transportation’s regulations, BJ’s utilizes 3E’s Transportation Shipping Papers services. As part of this service, 3E prepares and provides the required shipping papers and documentation for any mode of transportation on behalf of BJ’s, including tailoring information to internal shipping acceptance requirements. 3E’s team of Transportation Specialists is highly scalable and flexible, and these papers can be prepared on an as-needed basis and provided for inclusion with the shipment.
“I appreciate 3E’s ability to quickly scale up or down based on our needs,” said Mr. Peters. “The 3E team is always extremely responsive, often acting like an extension of our internal team.”
“With so many locations, and with regulations constantly changing, achieving compliance can be difficult,” said Mr. Peters. “Outsourcing some of the more complex EH&S regulatory compliance initiatives to 3E has allowed BJ’s to meet their compliance needs 3E has been instrumental in providing us with the data or information we need to achieve compliance on a local, state and federal level. Knowledge is power, and 3E provides us with the knowledge we need to empower our business decisions, and achieve the objectives of our compliance initiatives.”