It happens all the time: you hear about an audit (internal or external), and your brain starts racing and your “to do” list quickly doubles or triples in length and your blood pressure shoots through the roof. It doesn’t have to be that way. While touring facilities and conducting environmental, health and safety (EHS) audits over several years, I’ve identified several items that routinely appear as non-compliant findings that are things that you can tackle every day. These items, some minor and some major, have either been missed, overlooked, or abandoned due to lack of time. A sample of these observations include:
- Mislabeled/unlabeled waste and product containers
- Open waste containers
- Releases into secondary containment not removed promptly
- Missing/incomplete signage at waste storage areas
- Missing/illegible labels on power tools
- Improperly stored flammable products
- Damaged slings/lifting devices
- Missing/incomplete markings on cranes
- Improper storage of respiratory protection
- Prompt access to inspection documentation – forklift, safety equipment, waste containers, SPCC, SWPPP, cranes, fire equipment
- Exposed/damaged electrical circuits
- Missing/incomplete hazard assessments
While the minor issues may only result in fines and/or Notice of Violations (NOVs) from State, EPA and/or OSHA agencies, the major items can result in severe injuries and/or significant liabilities. These are all what are considered “low hanging fruit,” meaning they are areas that every auditor will check but maintaining compliance with the regulations is relatively easy. Generally, correcting problems in these areas are quick and require minimal capital expenditures. If you are in compliance with these items, it sends a positive message to the auditor.
Through the implementation of a comprehensive inspection process, training, routine internal assessments, and periodic external reviews, facilities can significantly reduce these common findings. A comprehensive inspection process generally contains the following elements:
- Identification of regulations/requirements applicable to your operations;
- Generation of processes/checklists;
- Establishing frequency of verification; and,
- Periodic internal audit/review of process/documentation.
Employees need to be trained to understand the requirements for each inspection process and required documentation. The applicable regulation usually determines the frequency of each inspection process. Internal assessments by qualified supervisors, ESH staff, or management should be performed at a frequency (monthly, quarterly, semi-annually) sufficient to ensure the inspection process functions properly. External reviews/audits are recommended to ensure regulatory changes are added to the process and to verify the proficiency of the overall inspection program.
Many times, a checklist can be used to document the level of compliance. A facility we work with on a routine basis was up for sale a couple of years ago. Knowing that suitors would be in and out of the facility, they wanted to present well, so they had us come up with a program by program checklist and each week a team of employees completed the checklist and documented when areas were out of compliance. Now, weekly might be a little ambitious for some facilities, but I will say that it worked out well because the managers and the employees observed what the team was looking for and picked up on what needed to be done to make sure their areas were in compliance. The business was purchased, and they modified that checklist to include items as they arise, but now the facility only conducts the “audit” monthly and is seeing fewer and fewer items noted as not in compliance. Repetition and frequent follow up is a great place to start. It was also helpful to put up diagrams and signs that specifically identified what needed to be done in the various areas.
Preparing for an audit is stressful by nature. You work harder, and even longer hours, and after an audit, you tend to feel like somebody just picked at every imperfection and flaw in your baby and can start to question your ability to perform even the most mundane of projects effectively. But it doesn’t have to be overly stressful. If you build a process to cover the “low-hanging fruit” for good, then you will free up time to tackle the longer, more onerous issues at your facility. Over the next few months, we’ll be taking these common non-compliances and telling you how to manage them so that you don’t have to double up on the Lisinopril when you hear the A-word.
Should you have any questions, please contact Nick Foreman or Victor Cason.