At many of the talks I give at industry conferences, I often hear from facility and plant managers whose sites are not in compliance.
These managers want to play by the rules. But they don’t know where to start.The process and many of the associated regulations are confusing. Time in the workday is short and already busy. A lack of buy-in from those in the organization makes it an uphill battle. And there is often institutional inertia; things have always been done a certain way… why change?
But facilities are in serious trouble if there is ever a surprise regulatory inspection, with fines and other penalties often at the ready.
The good news, is there is a relatively easy way you can get into compliance by breaking up this big goal into smaller action steps.
So far in this series, we’ve covered steps 1 – 3 in achieving compliance with environmental, health and safety regulations. If you haven’t already, I would recommend reading them first:
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
Now, it’s time for Step 4: Keep Moving Forward and Maintain Progress
You’ve come this far; you don’t want to lose all the progress that you’ve gained. The goal is complete compliance at your facility and for you not to lose that status due to falling back into old habits.
There are several ways to stay in step.
As you well know, regulations from local, state, and federal regulators are constantly changing. The regulations you follow and permits you’ve secured in the past might no longer apply to your facility.
To stay current, you should network with other facility managers, both within your company if you have sister facilities and with outside organizations. Maybe have a weekly phone call to discuss issues you’re having and how they’ve solved them.
You should also join industry organizations, which keep track of regulatory changes and then let their members know. There are also subscription services that will send you an alert when regulations that impact your facility have changed.
You might also consider establishing an Environmental Management System (EMS) at your facility. An EMS is a facility-specific program that helps you identify environmental, health and safety issues, maintain those issues, and helps you maintain compliance. An EMS monitors changes at your facility and lets you know where you stand with the relevant regulations. There is EMS software available that can make this challenging endeavor a little easier to address.
Two of the Core Four elements you need at your facility are Property History and Documentation. These are the two elements of ensuring you have detailed records for everything done at your facility.
Decommission a piece of machinery… change the ingredients in your manufacturing process… have an underground tank no longer in use… keep it all in one place and organized so you can quickly find what you need, whether that’s an electronic data storage system or a regular filing cabinet.
Try to include historical records, aerial photos, past regulatory actions… anything you can find. And be sure to always document when employees receive required training.
You want to be the historian, documentarian, and record-keeper for your facility. This will make you intimately familiar with what’s going on at your facility now… what happened in the past, and how your facility’s future is affected.
Along with Property History and Documentation, Communication is another element of the Core Four. Essentially, you want to interact with everyone, from executives to managers to employees on the line. And you want to make sure everybody is on the same page regarding your environmental, health and safety programs and any regulations that must be followed.
Communicate to increase awareness. Have regular team meetings where you go over these issues; throw in free pizza. Put up posters in common areas.
To get buy-in, you have to become the go-to guy or gal, not the pain in the butt that issues commands. Ask employees for their take on processes and new environmental, health and safety programs. Make sure your team feels comfortable bringing issues to you without feeling like a whistleblower.
Mistakes happen. Your attitude should be to learn from them.
When it comes to management, make sure you are able to clearly convey to them the importance of your facility’s environmental, health and safety issues and programs by showing them the cost/benefit of having sound programs. In addition, make sure you are involved in facility planning and capital improvements. Being in the loop avoids future issues and project delays due to environmental, health and safety issues.
There is no reason to view your local, state, and federal regulators as the enemy. Find out who covers your area and give them a call to introduce yourself. Be friendly. Do so, and you’ll find that they’ll work with you a lot more if there is a compliance issue or other environmental issue at your facility.
If there is a regulatory inspection, talk with the regulators while they are there. Discuss their approach and what they are looking for. This will guide your future efforts.
You might even consider a mock audit and self audit to identify any potential compliance issues. But check with legal counsel first.
When you achieve compliance, it improves the company image and reputation, as well as increases productivity and efficiency of operations, while lowering costs.
Plus, you won’t always be looking over your shoulder for regulators looking for improper permits and other violations.
Achieving compliance makes you valuable to your company, making your job more secure and easier to do.
To keep this top of mind, be sure to check out this free download, The 4 Steps to Maintaining Compliance.