How often do you walk through your facility and spot an unlabeled or open waste container? As you walk through your plant and waste storage areas, do you see problems with waste and product management, such as missing signage or products stored outside of secondary containment. You think, “These problems weren’t here last week!”, and “What am I going to do, we have an internal audit is next month!!”
As an ESH professional, it’s easy to “see” these items are not in compliance with the regulations. However, do the workers and supervisors understand the requirements AND the results if an outside agency finds them? For better or worse, most ESH professionals are responsible for all three areas of compliance – environmental, health and safety. Environmental compliance is a big responsibility, and one person can’t be in the entire facility every moment of every day. You need help!
You could ask your boss to hire several ESH staff to “police the facility”; but, they’d probably say, “No”, or my favorite response, “That’s why we hired you!” So, what can you do?
Regardless of the situation, management and supervisors must understand the risk/consequence of failure to comply with the regulations and their role in maintaining compliance. Generally, once the management team understands the risks (NOVs, fines, injuries) they will support compliance activities and enforce the processes implemented.
I believe that most employees want to “do the right thing”; but, sometimes they just don’t know what to do. In some cases, management hasn’t made it easy to comply.
A process where employees routinely inspect and take ownership of their work areas can greatly reduce the number and frequency of non-compliant issues. You may want to generate a document that establishes what’s to be inspected, the frequency of inspections, who performs the activity, and the how to initiate corrective actions. The documentation would aid in discussions with the management team and provide a basis for worker training.
To help employees, identify what items would be easy to verify using a simple checklist and prepare one or more. Remember to make it easy or it won’t be used. I recommend checklists for items such as: unlabeled/mislabeled containers; open waste containers; spills/releases into secondary containment; and improperly segregated wastes. The checklists could be established for each area in the facility, by product, type of work or by supervisor.
Once the checklists are ready, train the employees on the frequency of the inspection, what to look for, how to complete the checklists, where to submit the completed forms and how to initiate corrective actions. The supervisors will need to have a general overview of the process to ensure they can “audit” their areas on a periodic basis.
I have found that having pre-printed labels, or at least label making supplies local to the area, aids in getting employee involvement. Another good practice is to have a “roster” or matrix of approved waste streams, associated waste codes, and contact information should there be questions located in the area that your employees can reference.
Everyone in the facility should be trained on proper waste segregation appropriate for their work, i.e., what waste goes where. Should you be fortunate enough to have staff dedicated to waste collection and storage; those employees need additional training to maintain proper waste management and storage area requirements.
Although implementation of an inspection process won’t eliminate your job or all the problems you find, it can greatly diminish the items you, as the ESH professional, are required to identify and initiate corrective action and enable you to feel more confident when you’re told, “We’re going to have an audit.”