With so many regulations and required permits, many facility managers struggle to stay in compliance – and in the good graces of regulators. It’s a task made more difficult by the fact that regulations and related requirements are always changing.
It can seem like a monumental task. But if you break it down into steps, you can efficiently get into compliance – and relatively quickly, too. Those four steps are:
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
If you haven’t done so already, please read Step 1: Understand Your Facility Operations, first.
That article covers what information you need to know about your facility to start the compliance process and how to get that information. In general, you need to understand what you do at your facility and how you do it, including:
- Raw materials used in your processes
- The finished goods that are produced
- Waste materials generated
- The actual processes involved
- Existing permits
- Existing systems
Now, let’s examine what you do with all that information you’ve collected, because if you don’t keep it organized, updated, and easily accessible, it’s basically useless. It’s the same problem if your entire organization doesn’t know and understand how all this information affects their role at your facility.
Centralize All the Information You Collect
Information you find that builds your facility knowledge and the documentation you collect, including historical photos, permits, plans, files, and more should be kept in a centralized location.
Make sure the files are complete, especially if you go digital. I’ve come across some facilities where they had scanned in all their historical records so they could be stored digitally. This is a great solution for resolving document storage space issues, but please be aware of the following:
- Make sure you scan the entire historical document or record, no matter the size of the document, not just the executive summaries. The reason to keep copies of these historical records is for the valuable detail that they contain. This detailed information may prove to be useful in helping you address many different types of issues at your facility; summaries do not contain such detail. For example, an underground storage tank removal report may be a very large document (several hundred pages), especially if any sampling was conducted. We have come across situations where information found in a tank removal report was helpful (e.g. soil boring logs, soil lithology information, etc.) in providing geotechnical information for building expansion work. Maintain the details that you have already collected, it will prove to be useful in the future and may also help you save some money!
- Make sure you review your scanned images! Verify that the scanned image is legible and that the scanned image contains all of the information found on the paper copies, especially when it comes to maps and figures. And please do this verification before you destroy your paper copies. You only get one chance to do this – once you destroy your paper copy, that history is gone. So, make sure your scanned images have properly captured this valuable information!
- Make sure you save your scanned image as a universal file, like a PDF or JPEG file, that can be opened with a variety of different types of software. Do not use a proprietary file format that requires specific software. What happens to your files if that software company goes out of business? Can you still access your information?
Part of this process is standardizing the information you can collect. You have to know where you are now – your current status – so you can measure forward progress in your environmental, health and safety efforts. Standardizing makes evaluation that much easier.
How Does Documentation Help?
Documentation, of course, is not only for your own use. Many permits and regulations require you to keep track of what’s going on at your facility. This documentation is required in order for you to be in compliance with your permits or applicable regulations. For example, as part of the Resource Conversation and Recovery Act, you must track all hazardous waste from generation to post-disposal.
We often advise clients that the best investment you can make at your facility is training – you always receive a positive return on that investment. Training not only helps you maintain a safe and efficient working environment, but training may also be required by regulation. Of equal importance to the act of training, is the documentation of that training.
Aside from compliance, having thorough documentation helps you respond to environmental incidents, maintain property history, plan future projects like capital improvements, and makes real estate transactions smoother. And when an environmental consultant or regulator comes calling… you have a nice package to hand over.
Say you decommissioned a piece of manufacturing equipment but didn’t remove it.
Document this action and keep a record so that down the road, the next facility manager knows what it was and can take that into account if they’re expanding the building or a production line.
You should also realize that documents fall into three categories and should be organized as such:
- Required to be kept by regulation
- Useful and helpful
- Unnecessary (so you can discard)
Increase Awareness of Environmental Issues
Once you understand what your facility does and the processes involved, and have dutifully organized your records, don’t keep it to yourself.
Everyone else at your facility should be aware of what regulations apply or what must be done to stay in compliance with a permit. That way they know their role and how they can support that goal. This means everyone from supervisors to employees on the line.
You can disseminate that information in a few ways:
- Posters or other materials in break rooms or other common areas (this is handy where many employees do not have access to an office computer).
- Short memos or emails.
- Luncheons or free pizza days where you conduct an informational/educational seminar.
Communication Is Key
You will need help in gathering all the information you need to truly understand your facility. So, you need to be a great communicator…the go-to guy or gal who people feel comfortable speaking with about sometimes sensitive issues.
You have to speak about environmental, health and safety in a simple and clear manner.
Become approachable, noticeable. Become a resource and sounding board. You don’t want people to be intimidated by you or reluctant to speak up for fear of being labeled a “whistleblower.”
Good communication between you and everybody else at your facility has all sorts of benefits, including maintaining a safe, productive workplace that meets environmental standards and is profitable, too.
Do all this and you can start to create your compliance roadmap. Keep an eye out for the next stage in this process, in the next article, Step 3: The Dreaded Regulations and How to Deal With Them.
Until then, download this free Permit Compliance Reminder Chart. Deadlines, “expiration dates,” and regulations related to permits are some of the most important documentation you have at your facility. This will help you stay on track.