If someone has ever asked you “Are we in compliance with environmental regulations?”, there’s a good chance your role involves managing environmental compliance programs at your operating facility. Or maybe your role is at the corporate level where you focus on strategic development of environmental, health, and safety programs and how that aligns with the operational and growth goals of the company. Either way, you know the challenges associated with maintaining environmental compliance and how the question can sometimes be hard to answer.
So what kind of environmental management system (EMS) do you need to answer the question? Odds are you don’t need an ISO certified management system, but you probably need to know the key metrics that ensure that the environmental and sustainability commitments that your company have established are on track. The basis of this usually stems from an evaluation and identification of risks, review of culture and corporate objectives, and then implementing a program to monitor and achieve those objectives.
A good advisor that has experienced these challenges and built successful environmental programs can often help tweak an existing program or develop a new management system. Working with the operations group to maintain compliance, providing strategy and support to multiple facilities, and coordinating with senior leadership on strategic direction, alignment of goals, and growth initiatives can all help to build a strong culture of environmental compliance and stewardship across the company. Components of a successful environmental compliance program include:
- Communication and training is key to a successful program. This not only includes communicating the priorities and basic principles of the program, but training people on response actions and communications prior to an upset event, spill, or incident.
- Developing a team that understands who is responsible for day to day compliance, how long-term permitting is coordinated and understood, and who is ultimately accountable for the success of the environmental program.
- A comprehensive environmental management program defines regulatory applicability at the federal, state and local level. This is the process of reviewing what regulations apply (or don’t apply) to your business and why. Determining how a facility meets these environmental rules – and under what conditions – is the crux of this. Knowing why a facility may not be subject to a rule today vs. when it may trigger a rule is an important planning and growth consideration. Nobody likes surprises, especially when that new expanded facility can’t start production because the new air permit isn’t approved yet.
- Developing procedures and best practices is the key to ongoing compliance. Consistent documentation of common occurrences are handled. A uniform approach in how a particular waste is managed, how a safe work place is maintained in each area, or documenting procedures on how to handle less common events are worth the time spent. Training on these procedures and practices not only helps to ensure day-to-day compliance but gives others confidence there’s a comprehensive program in place to manage risk.
- Set goals and track key metrics. If a facility generates waste, at a minimum monthly generation is tracked, but can a goal on waste minimization be implemented? These goals not only often have a positive budgetary impact but can help to reinforce the desireable corporate culture your organization may be working towards.
The final piece to the puzzle for achieving and tracking compliance is the dashboard. An informative EHS management dashboard, no matter how basic, can provide insight into a company’s objectives and priorities. It’s often used as an internal tracking and reporting tool, providing high level detail on the compliance pulse of a business. But most importantly, it helps answer the question, “Are we in compliance with environmental regulations?”