How to Immediately Improve Your EH&S Program


As a facility or plant manager you are busy. I don’t have to tell you that. But I want to show you an easy and inexpensive way to take some of the load off and give you some peace of mind.

I saw an article in an International Facility Management Association (IFMA) publication a few years back that listed out all the daily tasks and responsibilities that fall to a facility or plant manager. They compiled over 36 items… and it was still growing… when they decided to stop counting.

The exact role of a manager is different at every specific facility and company. But it’s safe to say you’re responsible for all the environmental, health and safety (EH&S) regulations and compliance associated with the facility. You have to keep things on schedule… manage employees… all while keeping it cost-effective and safe.

You’re the “go-to person” in all matters. The buck stops with you, so to speak.

We’ve been in many facilities over the years addressing EH&S concerns, including assessments, investigations, remediation activities, compliance with regulations, and addressing safety concerns. From this experience, we have identified four core requirements that all facilities must practice in order to have a sound and successful EH&S program. By adopting the Core Four, your EH&S program will be easier to manage, which will help lighten your daily work load!

Our Core Four includes:

1. Facility Knowledge

You need to fully understand your facility operations. I don’t care if your facility is an office complex, a school, a hospital, a full-blown manufacturing facility, or anything in between - No matter what you do; you need to KNOW what you do. You have to know your facility inside and out. A key part of this is tapping into the institutional knowledge of long-time employees and maintenance personnel. They know all about the key operations at your facility and what lurks in the dark corners of your facility!

 2. Effective Communication

Communication is the key to managing EH&S issues.  Remember to keep your communications simple, clear and brief – get to the point quickly, clearly and thoroughly. Be the manager that employees are happy to speak with. Take a proactive, not reactive, approach to EH&S issues and get everybody on board by including your employees in the process at every step. Remember that you must ensure both management buy-in and employee buy-in to make your EH&S program a successful one. Don’t simply harp on EH&S issues from a distance… or only when things go wrong. Be seen where the action is – on the production floor, in the warehouse, in the office areas. You need to walk the walk, not just talk the talk!

3. Documentation

You could have the most compliant, environmentally friendly, and safe facility on the planet… with all the proper permits, updated spill response and emergency response plans, properly maintained equipment, impeccable material storage areas, and employees with all the required training.


If you haven’t documented it all… it doesn’t matter. Unfortunately, regulators won’t take you at your word. So, put everything down on paper, keep it updated, and have it on hand at all times. Make sure you keep useful and complete records and understand what records are required, what records are useful and valuable, and what records are expendable, which you can get rid of.

4. Property History

Whether your facility has been around for five years or 50, it probably has some buried secrets. That’s why property history is the most significant, yet most underused resource. We’ve seen forgotten underground storage tanks from decades previous that were never properly closed… causing significant contamination to the soil and groundwater and compelling the client to start a six-figure remediation process.

Many places have that piece of outdated equipment that was pushed to the side and never properly decommissioned. And now nobody remembers what it was for.

Again, speak with long-time employees to get a sense of the history of your facility – before they retire! Keep a record of what they tell you because once they retire, all of that valuable historical knowledge leaves with them.

Property history helps to identify risks and liabilities. The “old timers” can provide information that nobody else has and will ever have. That’s perfect for a consultant like us when we are assessing a site. It’s a shortcut that saves you money.

Calling in Outside Help – Where to Turn and When, and How to Save Some Money 

When you wear so many hats as a facility or plant manager, you become a jack-of-all-trades and master of none, as they say. That’s where bringing in outside help can be so beneficial.

For example, an outside environmental consultant can help you keep up with tedious tasks, understand regulations, and help identify potential EH&S exposures. You can lean on outside help when needed.

And, because you can focus on vital tasks in your facility, you’ll be more efficient and be able to increase production. That’s always a good thing.

It’s especially handy to call in an outside consultant when you have regulatory responsibilities tied to certain permits, like regular monitoring or documentation.

With so many rules and regulations, it really is hard to keep track of everything and to determine what exactly you need to be concerned about. Since these types of tasks are time-consuming, they may seem insurmountable due to your already busy schedule. And the consequences for missing them can be serious.

But at a company like Envision Environmental, Inc., we’re happy to take these responsibilities off your plate. Sometimes an on-site employee or team should handle a task, but determining what rules and regulations apply to your facility is a great example of a case where an off-site provider, well versed in environmental regulations, can be more appropriate.

However, before you hire Envision or any other environmental consulting firm, make sure you know the answers to the following four questions:

The Four Questions You Must Answer

There is an important element to any relationship you might have with an outside consultant, no matter how you partner with them. When you can answer these four questions, you’ll enjoy a big cost savings. 

You see, these four questions are the basic knowledge base that a consultant needs to know in order to do any work at your facility. Over the years, we have gone into many facilities that could not answer in detail all four questions. As a result, we spent a lot of time, and as a result, a lot of our clients’ money in simply finding the information to answer these questions. For those facilities that knew the detailed answers to these questions, we were able to identify the clients’ issues and address them in a timely and economical fashion.

To be honest, as a facility manager you should have these answers in your back pocket. Not only will they save you money, but they also force you to organize yourself and your work, which makes you and your team more efficient. Your facility will run more smoothly, and it’ll be safer.

  1. What do you do at your facility? Make sure details are provided on raw materials, finished products and waste products.
  1. How do you do the things you do? Make sure details are provided on what processes are involved in all aspects of facility operations.
  1. What do you already have in place to help address your EH&S issues? Make sure you identify and provide details on any existing permits, programs, policies, licenses, certifications, etc. In addition, make sure you identify and provide details on any other existing systems that your facility utilizes that are not associated with EH&S, such as procurement inventory systems or manufacturing systems.
  1. What is it that you don’t know about your facility?

When you are able to give an outside consultant those answers, they can more quickly assess the risks facing your facility and possible areas where you are out of compliance. And it makes it much easier to come back with a solution to achieve compliance with the applicable regulations and a plan to eliminate liability.

Using this as a guide, we can figure out potential gaps and areas in need of improvement. Below are some areas of concern we typically find and can help with.

One of the most common issues we come across relates to permitting. Many facilities do not have permits or do not have the proper permits simply because they do not know the answers to the four questions above. Sometimes we see facilities that have the proper permits, but are still not in compliance. Why? Because they never read their permits!

Environmental Permit Requirement

You secured your environmental permit. But that doesn’t mean your work is done. Did you read the “fine print”?

You must read all the documentation related to any permits at your facility to note any requirements or conditions you must follow to stay in compliance… and in regulators’ good graces.

For example, many permits require ongoing monitoring and strict record keeping. As your outside consultant, we can develop a program to make sure you are collecting all required information to not only remain in compliance, but to also demonstrate that you are in compliance.

Do You Document Training?

Most facilities have to provide required training to employees, including annual refreshers.

But here’s what you may not know about training: If you don’t properly document the training, it’s like it never happened. You’re not in compliance.

We can help you develop a system to document all training to the satisfaction of regulators. There are just a few forms to fill out so you know who was trained and in what… and if they completed it. If you’re ever inspected, you can produce this documentation to satisfy that requirement.

Training is the best investment you can make at your facility. But as we said before, it doesn’t matter how much training you do - you must also ensure that it is properly documented.

Specialized Knowledge You Can Benefit From

The bottom line is that as an environmental consultant with 20+ years experience in working in a variety of facilities on a huge range of projects nationwide, Envision Environmental, Inc. has specialized knowledge and extensive experience you’re not likely to have in-house.

We’ve seen common issues on many sites we’ve visited that we can easily check your facility for. We know regulations inside and out, so we can be your partner for staying in compliance with the terms of your permits.

In many cases we can take on the tasks that are time consuming, but very necessary to avoid being penalized by regulators.

Where do you need help right now?

A great way to get started is to answer the four questions I posed earlier. You can download a document with those questions here. Fill it out and then post it in your office for easy reference. It’ll let you know where you stand currently and what areas of concern might exist.

You can get that free guide here: 4 Questions You Must Be Able to Answer About Your Facility.


No items found.

Our latest articles