If you missed Step 1 or Step 2 of this series, use these links to read the articles. One of the biggest challenges for any facility or plant manager is to stay in compliance – and in the good graces of regulators. As your facility changes, the permits you have might need to be modified. Or, you might even need totally new permits. Not to mention, regulations are always changing.
But perhaps an even bigger challenge is to get in compliance in the first place.When you’re starting from scratch, it’s a goal that can seem unachievable. But, because of the very real risk of financial penalties or even facility shutdown, it’s something you have to do… and you should get started now.
The best way to face this big task is to break it into smaller pieces that you tackle one by one:
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
(Be sure to read Step 1: Understand Your Facility Operations and Step 2: Get It Together and Become a Well Organized and Efficient Manager if you haven’t already.)
There are hundreds of regulations – and thousands of pages – covering environmental, health and safety at the local, state, and federal level.
How do you know what rules apply to your facility and the work you do? It can be overwhelming, but there is help available.
There is a catch…
You have to be willing to ask for it. You have to put yourself out there and say, “I don’t know.” But don’t think of it as admitting weakness. Being a good communicator in this way, and ready to collaborate with colleagues and team members, will only help you in your role as facility manager.
Who better to turn to for detailed information about your facility’s processes than those who are intimately involved every day? So, go down to the production floor and talk to the team, especially the long-service employees who’ve been there awhile.
Those who have experience in the same process from a previous job are especially good sources because they’re familiar with what regulations or permits were required. And that probably matches up with what you need now.
Larger companies often have several facilities that have similar, if not identical, operations. So, make a call to your fellow manager to get the details on what regulations they’re following.
Seems like a simple solution. But in my experience, it’s all too common for managers to treat their facilities as independent fiefdoms. One long-time client just changed jobs and is now managing process engineering at seven separate facilities. He says nobody talks to each other.
It’s a shame because open communication could save time and money. For example, one facility might need a part, but they’re out of stock. That means four weeks of downtime. But if they practiced good communication with sister facilities, they might discover one of them has a part to spare. No more downtime.
I’d suggest a weekly call among all the facility managers. Get to know each other, form relationships. Creating a “safe” environment like that will cut down on the reluctance to seek help.
As environmental consultants, my team and I visit so many facilities throughout the year, it feels like we’ve seen everything. We can draw on this experience at facilities similar to yours as a starting point to figure out what regulations apply to you.
Plus, it’s our job to stay on top of all environmental regulations, including all changes and new developments. On top of that, we maintain good relationships with regulators and can always make a call for clarification if need be.
An association or trade group in your industry can be a great source of information about applicable regulations and any changes coming down the pike that could affect their members.
Subscribe to newsletters, check out their websites, network with fellow members… simply give the association a call.
Regulator websites post notices of new or modified regulations coming up. They are drafted, published for public comment, and only enacted a year or two later. There’s also a grace period after the new regulation takes effect. This is a great resource. Where else should you go, but to those who wrote the regulations – straight from the horse’s mouth, so to speak.
One thing to keep an eye out for specifically are “guidance documents.” These are easy to understand, brief summaries of full regulations that will give you an idea of what might apply to your facility. Basically, all you need to know in a simple format to follow.
But a caution: remember that everything stays online forever. So, make sure any sources you are reviewing are up to date and current.
Who better to ask about regulations that might apply to your facility than… the organization that put them in place? Go on. They don’t bite.
Ideally, you’ve already established a relationship with the regulators in your area in the past. That makes it easy to pick up the phone to ask a quick question. If not, you can still make the call – but carefully.
There’s no harm in checking in through a helpline and asking “hypothetical” questions about what regulations might be needed. Many regulators also offer free compliance assistance programs.
Before engaging with regulators or making a final decision on what regulations apply to your facility, we always recommend that you review what you are doing with legal counsel for guidance in moving forward.
Regulations are a key part of making sure your facility is in compliance. And they don’t have to be scary.
Taking a methodical approach to figuring out what regulations apply to you, using a variety of sources, can get you on the good side of local, state, and federal regulators relatively easily and quickly.
Every facility is, of course, different. And that means a whole different set of regulations you have to consider depending on your particular raw materials, manufacturing process, storage methods, finished products, and other factors.
You can download this free chart that lists The 15 Most Common EH&S Regulations. It’s a great starting point as you begin your journey into regulatory compliance.