Lately, I’ve been working on self-improvement and trying to pick up better habits in my personal life. I admit, I need a lot of work, so I’ve been doing it in a methodical and careful manner.
During this process, I thought about how a facility or plant manager could also put together a plan for getting their facility in order, just like how people work to improve themselves. Think of it like “site-improvement.” I’m talking about working on getting your facility into compliance with environmental, health and safety regulations.
That is one of your primary responsibilities as a facility manager, but it’s a complicated issue, with a lot of moving parts. And that means your approach must be systematic and consistent. Take that approach and get your team on board… and EH&S compliance becomes a habit.
A Five-Part Personal Approach to EH&S Compliance
EH&S compliance is about more than simply having the right permits and procedures in place. Those can change. So, what you need is a solid foundation that guides you through consistent compliance with ever-changing environmental regulations. And this foundation is built on you and all your employees cultivating solid regular habits and behaviors that create an atmosphere of compliance.
Unfortunately, without that effort, poor individual practices can quickly lead to issues, like violations, fines, accidents and more. To avoid those issues, you need buy-in from your entire team.
On the flipside, good practices and habits help create a very proactive compliance culture.
I’ve identified five personal habits you should adapt to keep your facilities compliant, safe, productive, and profitable.
Document Everything (Try to be meticulous)
I’m a huge believer in detailed record-keeping. It’s the backbone of EH&S compliance.
The most common compliance issue at facilities I see as an environmental consultant is inaccurate or limited documentation, which can often obscure not just non-compliance items but also minor issues of concern, until it’s too late to prevent them from becoming serious problems.
Detailed records can help save a business in case of an EH&S incident or if some other environmental concern pops up. The detailed records will help demonstrate that you actually did the related due diligence, the maintenance, the monitoring, the evaluation… or whatever else you were supposed to… to try to prevent the issue from happening. It shows you tried to be compliant and followed the rules/regulations.
Many EH&S managers I work with have no problem embracing record-keeping for themselves but find it challenging to extend that enthusiasm to their team.
I always urge them to remind their staff that documentation is part of the job, just like pressing a switch on a production machine, changing a filter, or collecting a sample for permit monitoring. Documentation should be automatic, a part of the standard operating procedure (which I’ll be going into next).
It should be done concurrently with the work, not later. Document what you did right after you do it, not later or the next day… which can sometimes become too late or often never. I’m guilty of that habit! I’ll tell myself that I’ll take care of documenting that issue later and later comes and goes without detailing that important item.
Simply put - documentation prevents issues and helps you identify the cause of those problems that do come up.
Stick to the Plan (Try to be a stickler)
Whenever you have a goal, whether at work or in your personal life… you must stick to the plan if want to achieve it.
This means establishing procedures and protocols that will keep you moving forward in the right direction. And these procedures and protocols need to be strictly followed in order to comply with the many environmental regulations you must deal with as a facility manager.
I recommend putting task specific standard operating procedures (SOPs) in place. Make following them a habit for yourself and everyone else… from executives all the way to production floor workers.
You see, many environmental incidents and violations come about because people cut corners. They think they know how to do it “better” and ignore SOPs.
Training is one way to avoid this. Make the SOPs part of the new employee onboarding process. And make every employee take refresher courses regularly so that they never forget how to do things properly.
As part of this training, explain why things are done a certain way and not another way to avoid non-compliance issues or potential incidents. This helps remove the temptation to take shortcuts.
Involving your team in developing SOPs is a great way to have them take ownership. Start with the people that are already doing the job, because they're the folks that know how to do it the right way and safely.
That doesn’t mean you can never change. Change is good… if it’s an improvement in terms of safety and efficiency over the current procedure. So, encourage your employees to speak up if they have ideas to improve SOPs and assess their suggestions thoroughly to see if they’ll have a positive impact.
Be Vigilant and Stay Dependable (Try to be watchful and attentive)
You have systems in place. You’ve established buy-in from the team. And you’re reinforcing it all with training. But you can’t rest on your laurels. You must always stay vigilant about what needs to be done to keep your facility running smoothly.
This should be part of your SOPs and covers items like inspections and preventive maintenance.
Unfortunately, we often find that at many facilities maintenance isn’t done until a machine breaks down. That would be like never getting an oil change for your car or never having your tires rotated and then waiting until the engine fails or a tire goes flat to fix it.
Stay proactive on maintenance and make that schedule part of an SOP.
Likewise make “housekeeping” part of your SOPs as well. A well-ordered facility, free of hazards, runs more smoothly, but it takes work. You must stay vigilant to make sure people don’t get “lazy” and allow items to be left wherever to be cleaned up later. That’s not a good look for customers, upper management, or even employees who might adopt a similar “lazy” attitude in their own departments.
So put procedures in place to maintain clean, well-organized work areas, for example. Soon enough those tasks should become automatic, you don’t have to think about doing it. That way it becomes another good habit.
Keep things tidy, and you arm your whole team with a “ready to work” mindset. It’s like having a clean desk, free of disordered piles of papers, it just makes you more productive, even though you don’t think about it.
Never Stop Learning (Try to be a good student)
Environmental regulations, industry best practices… nothing is set in stone. Things are always changing. And it’s your job to stay current.
My attitude is, as with your personal development, how you do your job should always be evolving. You should always be learning and considering ways to improve processes and procedures.
This makes you aware of what's going on and your obligations, especially when it comes to EH&S issues. It’s a process that never ends, to stay educated takes continuous learning. Make learning a habit.
As part of this, you must again get buy-in from your team and have them adopt the same attitude. You must make sure your people not only know how to comply with the new regulation (or current regulations, for that matter), but also why it's important to comply.
I stress this point because the most common violations that are cited by regulators involve the person responsible for compliance of a specific regulation not being aware of what is needed to comply with the regulation. Ignorance is not an excuse for not knowing. Again, training and SOPs are key here.
Communication Is Key (Try to be a good teacher)
Many marriages fall apart because of lack of communication. A couple simply stops talking to each other in a meaningful way, which leads to resentment and misunderstandings that can spiral out of control.
To create a culture of compliance at your facility, you need involvement from every level of the organization. And that means opening the lines of communication.
This goes both ways. Yes, you impart important information in a timely manner to employees. But you’re not just telling everybody what to do. You must allow employees to speak up too. They might have a suggestion for improvement, or they could have noticed something that is a potential issue to be fixed.
Make sure your team knows they are encouraged to speak up.
For example, say an employee suggests a new way of packaging a product to avoid repetitive use injuries. Investigate this proposed process and go with it if applicable.
You must also ensure your team knows they won’t be punished for changing the status quo. Say you have a chemical storage room packed with drums. Employees have to walk in there to get materials for use on the production floor. But… it’s unorganized and heavy drums have to be moved to access others. And that results in material easily spilling out of the drum or even employees being injured.
Your employees should know that they can suggest a new layout for this material storage that is safer and more efficient. They won’t be whistleblowers, so to speak. You should be open to change and improvement.
Silence can be costly. It’s well worth opening the lines of communication at work, just as in your personal life.
Next Steps
Cultivating these five habits will help create a culture of compliance at your facility. And that leads to a safer, more efficient, more productive, and more profitable facility. Not to mention, it'll make it a lot easier to get through those regulatory inspections and stay on top of any routine reporting or monitoring you’re compelled to do.
My team and I at Envision Environmental, Inc. are happy to help you stay on track. Just call me, Mark Roman, at 609-208-1885 or get in touch via e-mail at markroman@envisionenvironmental.com
