Are You Catching All Your EHS Requirements?
By Cory Sander
You’re pretty well versed in EHS regulations, but how do you know if you’re really catching all the right program requirements? It’s a good question to ask and worth investigating to make sure you achieve EHS compliance. Try these five proven strategies:
Conduct an internal audit/review
Think of this as the opposite of an external regulatory audit. Instead of giving limited information, you want to openly share and find anything you might be missing in your EHS compliance requirements.
You’re too close to your facility to conduct an effective internal audit yourself, so we recommend tapping an outside consultant to give you a different perspective and fresh set of eyes. Be open and honest about what’s happening at your facility and involve a wide range of staff in the process. This gives your external partner an in-depth look at your facility and allows him or her to capture all your EHS compliance requirements.
Create a management of change procedure
Even if you conduct a perfect audit, you’ll still have things changing at your facility all the time. And many of these changes may be connected to EHS regulations. If you’re bringing in new equipment, the engineer heading up the project is probably concerned with successfully completing the project. He or she may not think about the potential environmental, health, safety, and quality impacts. It’s critical this information surfaces to the right people.
How? Create a process for communicating change. It might be a simple form that’s filled out and sent to the EHS manager, but you need everyone across the organization on board. Then you’ll be able to ask crucial questions related to the change. Does the equipment require an air permit? Do you need new personal protective equipment? Proper communication around change allows you to catch potential regulatory applicability.
Pay attention to new materials
Ideally, a new material—or a change in material—would trigger a management of change procedure. But often people don’t consider these changes a big enough deal to engage in that formal process. Even though they may impact your regulatory requirements.
Switching to a new paint, for instance, may push you past your permit limit of 5 lbs of VOCs per gallon. Your new paint may have 5.2 lbs of VOCs per gallon, and you can’t do that without a permit modification. All these changes require planning, so it’s important to educate all staff about why it’s key to alert the EHS team.
Keep up with new and changing regulations
EHS regulations don’t stand still. It’s crucial to keep up with a changing regulatory environment, especially as it relates to your specific industry. Join trade groups, read industry publications, and network with your peers. Check official government sources, too. Make it part of your job to keep up with changes, so your program keeps pace—and achieves compliance.
Document and track requirements
Even if you are doing all the above, EHS requirements can be overlooked if they are not well documented and communicated. It is critical to have a well-organized system for recording, communicating, and tracking your requirements. This can be accomplished by using excel spreadsheets, document management systems, internal software systems, and/or an externally provided web-based solution.
Keep in mind, the more scattered and disorganized your documentation, the harder it will be to verify you are in compliance, and the harder it will be to communicate requirements during staff transition. Organizing and tracking EHS requirements in one system makes it significantly easier to delegate requirements, track compliance, implement changes, and maintain compliance through transition.