You could have the most stringent environmental, health and safety program at your facility, but unless you have these four core requirements in place, it will inevitably fail at some point.The result could be…
- A workplace accident that causes injury
- Being caught out of compliance by regulators and facing fines or other actions
- A spill or other environmental issue that requires an expensive cleanup
- A slowdown in production – and reduction in profits
As the facility/plant manager, you are ultimately responsible for everything that happens, especially any negative outcomes. That means you need to increase your awareness of just about everything that goes on at your facility.
That can seem overwhelming, so we’re going to focus your efforts on four core areas:
- Facility Knowledge
- Property History
Whether you’re overseeing a major manufacturing facility, a warehouse, a hospital, a school, an office complex, or a multi-tenant building, keeping these four core requirements in mind will ensure that environmental, health and safety become a priority for planning and projects, as well as ongoing operations.
Keep in line with the best practices for each of these, as I outline below, and you’ll keep things running smoothly and reduce costly mistakes, because these practices focus your efforts on what’s most important for managing your facility.
You need to be a great communicator at your facility. A great communicator is well organized and efficient, very observant and knowledgeable, and is able to effectively increase awareness of these very important environmental, health and safety issues throughout the facility. But most importantly, you need to be seen at your facility.
There are a few facets to consider when it comes to communications. You have to communicate effectively and maintain good relationships with everyone you interact with, especially your employees and regulators.
The bottom-line is that your goal is to be the helpful go-to person who’s not seen as the pain in the butt about environmental, health and safety issues. Then, people will want to work with you.
Are the guys on the job floor afraid to talk to you about a safety issue because they don’t know how you’ll react, or are they fearful of any form of reprisal as a whistleblower? Good communicators are able to effectively change such cultures.
I’m not saying you have to become good buddies with everybody, but you must create an atmosphere of openness, where people aren’t punished for bringing environmental issues to your attention. Otherwise, even small issues can quickly spiral out of control.
One client of mine hosts an Awareness Luncheon once a month where employees can speak freely about issues they’re concerned about and figure out ways to address them. They serve free pizza to those in attendance, and it’s a no-pressure situation that has been very successful for them.
For many, the relationship with regulators is purely adversarial. The only times you talk with them are when something has gone wrong and you’re fighting their decisions.
That is counterproductive to say the least.
Instead, you want to take a proactive approach and maintain an open communications channel with your regulators. Call your local regulatory agency. Get to know the individuals there who handle your industry.
That way if you have a question about a permit or any other potential environmental, health and safety issue at your site, you have a contact you can go to “unofficially” for direction. They won’t necessarily look the other way, but they’ll likely work with you instead of sending you straight to enforcement.
Remember, the regulators want you to maintain a compliant facility. Now, isn’t that what you want also?
Say you collect samples as part of a water quality permit but one of your samples comes back with results outside of the permitted limits. Give the regulator a call and explain the situation; perhaps it was an operations issue or an upset condition that caused the issue. If you have a good rapport, and you’ve not had issues in the past, they’ll likely let you re-collect the sample to show that your results were due to an issue you immediately corrected; such an approach may help you avoid a violation or a fine.
Remember the keys to communications are to keep it simple, clear and brief. If you get to the point quickly, clearly and thoroughly – more people will pay attention and will retain the information you are conveying.
2. Facility Knowledge
You would think this would be automatic, but facility/plant managers are wearing so many hats that I’m never surprised when I’m on a site and the manager can’t answer basic questions about what they do and how they do it.
You don’t need to know all of the nitty-gritty details or how to run every machine – after all, that’s why you have supervisors and managers out on the floor.
But you do need to know your raw materials, the finished products, and the waste products generated. In other words, a good general knowledge of operations.
Here’s the hardest part: you have to be willing to say, “I don’t know” and then start asking questions.
Only then can you start to understand what environmental impact you might expect and which regulations apply. Along with that, you must also know what permits, programs, policies, licenses, etc. you already have in place, what they cover, and the requirements necessary to stay in compliance.
I recommend you get out on the shop floor to get your education. Once your employees see somebody in management take an interest in their safety and in maintaining compliant operations, they’re happy to help. They’re motivated because that leads to a growing business, and further secures what they do for a living.
And don’t forget about tapping into your most valuable resources at your facility - maintenance personnel and long-time employees. They usually know all the secrets of how your facility operates.
3. Property History
Whether you’ve been at your current facility for a few months or 20 years, you must have a solid understanding of the history of your site. Your starting points are records, files, site maps, architectural drawings, aerial photos and any other similar documents kept over the years at your facility. Never get rid of any of these historical documents because they are like snapshots in time – they can help tell you what was done, where it was done, how it was done and when it was done.
But some of your best sources of information, especially if you’re a newcomer, are maintenance personnel and long-time employees.
They know where the underground storage tanks that everyone else has forgotten about are located and what that old piece of equipment in the corner was for. They know the secrets that lie in the dark corners of your facility.
Property history helps you to not only identify risks and liabilities; it also helps protect you from those risks and liabilities. Property history helps you avoid making past mistakes. Remember, repeating mistakes is very costly – not only from a monetary standpoint, but also due to the damage they can cause to your reputation.
Was your facility previously used for a different purpose? Say you run a warehouse, but the building used to be a manufacturing plant that used solvents in their processes. Where were those solvents used? Could these solvents have contaminated your property?
In one case we worked on, the client started a major building expansion project. When they started digging the foundation for the building, they hit some old storage tanks that nobody knew about and were probably last used in the 1980s! The tanks had to be properly decommissioned, removed from the ground and sampling performed. Unfortunately, some soil contamination was found and it took a year and a half and thousands of dollars to address the issue and obtain regulatory closure approval. During this entire time, the building expansion project was put on hold until the tank issue was properly addressed. This issue could have been avoided if the facility had maintained and reviewed records of the property history.
As you build your knowledge about the property history, your task is to write it all down, constantly update your records, and make them readily available to anybody in your organization.
It is critical that you maintain useful and compliant records. Your first step is to determine which records are required, which are valuable and useful, and which can be considered disposable – you can simply get rid of them.
Once you go through that exercise, you want to make sure you maintain control of those records by creating a central repository for them – like a filing cabinet in your office. This way, these important records will not disappear on you!
Now, the type of documentation we are talking about includes:
- Environmental, Health & Safety Reports – Make sure you keep complete copies of these reports, not just the summaries from the reports. If you completed a tank removal project, make sure you keep the text, figures, tables and all of the appendices from the final report. Granted these reports can be sizable, but information contained in these reports may be beneficial during other projects at your facility.
- Key Policies and Programs – Make sure your key policies and programs are current, especially if they contain contact hierarchies. I can’t tell you how many times we review a client’s important policies and programs, like Spill Response Programs, and find the contact hierarchy to be outdated. Now this is the section of the policy that facility personnel access to determine who they need to notify, should a spill occur at the facility. But the names listed in the policy are names of people that no longer work at the facility. We have even come across policies that have telephone numbers or e-mail addresses that are no longer active. What good is that policy if the contact hierarchy is not up to date? Don’t make this mistake!
- Training, Inspection and Permit Monitoring Records – These vital records must be complete, up-to-date and well maintained. The records are extremely important to demonstrate that you run a compliant facility.
- Maintain a Work Journal – Document any work performed at your facility – very simple documentation is all that is needed because our memory is not as good as we think it is. We can’t always remember when, why, and how we did something; but that basic information can be very beneficial in the future.
These basic forms of documentation will ensure that you maintain a safe and compliant working environment at your facility.
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There are substantial side benefits to following these four principles. Follow them, and you’ll improve your purchasing and management skills, and pretty much anything else you’re responsible for as a facility/plant manager.
The result will be a more productive, safer, and profitable facility.
I will also mention that, as an environmental consultant, when you have these four core requirements in place and can answer any question related to them, you make my job easier (and my fee much lower) if I’m called in to assist with any environmental, health and safety issue.
Be sure to download our free Four Core Requirements Checklist to help you prioritize these important tasks in your day-to-day routine. It’s a great reminder to have on your desk.