Step 1: Understand Your Facility Operations
I give a talk regularly at industry conferences and educational seminars about how facilities can beef up their environmental, health and safety (EH&S) policies and protocols.
As I’ve written about previously, when it comes to EH&S, simply complying with permits and regulations isn’t enough. That course of action, while necessary, is limited and doesn’t do enough to keep your facility safe from risks and threats. Think of basic compliance as looking at a rear-view mirror, while ignoring the windshield and what lies ahead.
My audiences generally get that. But a related question pops up quite often.
“We just need to get into compliance in the first place – how do you do that?”
I understand where they’re coming from.
Typical manufacturing plants – even warehouses, office parks, and other seemingly simple sites – can be quite complex as far as all the permits and procedures that must be followed to stay in the good graces of regulators, not to mention make it a safe work place and lessen the chances of impacting the surrounding environment.
Some folks just don’t know where to start. They feel overwhelmed.
But that’s only because they’re looking at compliance from the big picture angle. It’s daunting to look at ALL those different regulations in front of you – in addition to all the different tasks you, as a facility or plant manager, face throughout the day.
On top of that, requirements and regulations are dynamic – always changing. You also have documentation and reporting deadlines to keep track of.
And if you don’t follow everything to the letter… you face potential violations and monetary fines.
Like a high school student facing a big term paper, the tendency for some folks is to put it all off… procrastinate… promising themselves they’ll get to it as soon as they get a bit more time.
But this isn’t something you can ignore, because it won’t go away. And you need to get started addressing this issue now.
What I tell people, is that this is like many problems in life. Rather than look at this big mountain in front of you and wonder how you’ll ever get to the top, just get on the trail. Take a few steps… then a few more… and so on.
Consistent incremental action is what will help you get into compliance.
Getting Into Compliance Step-by-Step
There are four main steps in this process of breaking down the big problem of compliance into manageable chunks.
Step 1: Understand Your Facility Operations
Step 2: Get It Together and Become a Well Organized and Efficient Manager
Step 3: The Dreaded Regulations and How to Deal With Them
Step 4: Keep Moving Forward and Maintain Progress
In this article, we’ll be tackling Step 1.
Ask yourself how well you really know your facility.
I’ll share that from my experience working with clients, many people think they understand their facility, but they actually don’t really know the real workings and important details of the day-to-day operations, and how they all inter-relate.
Here’s an important point that is hard for some to admit. It’s okay to say, “I don’t know” and to admit you don’t know everything.
It’s okay to seek help from internal staff or a sister facility, or even an external source like an industry association, to help you fully understand your facility.
The bottom-line is that you must know:
- Raw materials used in your processes
- The finished goods that are produced
- Waste materials generated
- The actual processes involved
- Existing permits – their requirements and what they cover (which may change)
- Existing systems like procurement, inventory, manufacturing – even systems that don’t seem to have anything to do with environmental, health and safety.
Everything is based upon what you do and how you do it. And only when you understand that, will you know what regulations apply to you, what permits are required, and what EH&S policies you need in place to create a safe workplace and eliminate unnecessary impact on the surrounding environment.
Here’s where you get all this information:
- Look at your facility’s own records, including documents, plans and schematics, historic photos, aerial photos, and more.
- Check past regulatory records for your facility.
- Talk to the personnel on the line and maintenance folks, who deal with your processes intimately every day.
- Check in with veteran employees who have seen significant changes over the years.
Can’t I Just Hire a Consultant?
Many managers think they’ve figured out a shortcut to this whole process: they’ll just hire a consultant to help them get into compliance.
I always recommend you don’t do this until you have at least completed this Step 1 of understanding your facility inside and out.
When we’re called into a facility for any reason, the first thing we do is try to understand what the facility does and how they do it. That’s the foundation upon which you build any work on the site.
If the facility manager we meet with doesn’t know this important information … we have to figure it out. That costs time and money. If somebody already knows, that eliminates a lot of costs, makes our job easier in figuring out what regulations and permits apply, and reduces our time on-site.
A good incentive to truly understanding your facility.
Understanding your facility is an important – and admittedly big – first step in bringing your site into compliance.
Take it bit by bit and tackle each element like raw materials, existing permits, and the rest, one issue at a time. That reduces the feeling of being overwhelmed and keeps you moving forward.
In the next article in this series, we’ll give you some tips on how to organize your environmental, health and safety efforts and make sure everyone at your facility understands their role… and gets on board with changes.
In the meantime, download and review this free checklist, 4 Questions You Must Be Able to Answer About Your Facility, to help ensure you don’t miss anything as you conduct a thorough review.