A facility manager has a lot on his or her plate when it comes to making sure that buildings and services at a facility provide those who work there what they need when it comes to the physical elements, budgeting, training, compliance, safety, and personnel.
Despite this already wide-ranging set of responsibilities, the typical scope of work for a facility manager continues to grow and diversify, making an already challenging job more so.
Environmental, health and safety (EH&S) has only come to the forefront of a facility manager’s set of responsibilities in the last 10 to 15 years.
For facility managers, there is increasing pressure to make sustainability the foundation of all their work with EH&S issues. The watchwords are: recycle, reduce, reuse, and improve efficiency. The goal is to do more with less resources.
This intense focus on sustainability can actually cause more problems, because key EH&S issues like regulations, safety, training, risk reduction, and more are neglected, even though ignoring them can have lasting effects.
They are only paid attention to when they impact the bottom-line – and it then becomes your fault.
The foundation for addressing these issues is to become well-versed in the Core Four Requirements for being an effective facility manager, including…
- Communication – You must be able to work with every level of your organization and become approachable – people should want to work with you.
- Facility Knowledge – You should know everything your facility does and how you do it.
- Property History – It’s important to understand past operations and locations of equipment and take advantage of institutional knowledge.
- Documentation – Maintaining useful, valuable, and required records of any work done at your facility, as well as training, monitoring, and inspections is vital.
You can get an in-depth look at these Core Four principles here.
Now, let’s take a look at typical EH&S issues that are often overlooked so you can be better prepared to address them.
1. Undocumented issues
Do you know what you don’t know about your facility? Do you have a good handle on historical operations and equipment that were used at your facility? Sometimes these types of issues can haunt you in the future. All too often a capital improvement project uncovers underground tanks or some other feature that nobody knew was there. Work must be halted as the environmental impact is assessed, remediated, and regulatory closure accomplished.
The antidote to this is to pay close attention to property history, including historical aerial photos, architectural plot plans, and information from long-time employees before works begins. You can take care of issues proactively.
2. An EH&S policy focused only on compliance
You’re in compliance with regulations but… that is not enough. You can still have significant EH&S issues at your facility that can be difficult and expensive to address.
Instead, you must stay in compliance but also learn from past mistakes and look to the future to identify potential exposures and manage those liabilities.
3. Missing components in your EH&S program
A strong EH&S program is the perfect way to effectively manage and prevent EH&S issues, of course. But too many facilities are missing vital program ingredients. You must make sure all these elements are in place:
- Environmental Component: manage regulations dealing with multi-media issues and associated permits.
- Health and Safety Component: manage regulations for safe work practices and procedures.
- Risk Reduction and Liability Protection Component: understand your history, manage the present and identify potential exposures.
- Compliance Component: engage in consistent training, monitoring, and reporting.
Remember, a strong EH&S program must…
- Be proactive, not reactive. Don’t wait for things to happen. Address potential exposures early.
- Address non-compliance issues, emergency issues, and routine operations.
- Promote continuous improvement. Set goals, achieve them, then set new goals to continually strengthen your program.
4. What are your neighbors up to?
You could have the strongest EH&S program in the world. Your facility could be in tip-top shape. But, if a neighboring facility doesn’t have their act together, their activities could impact your property.
It’s essential that you have an understanding of what they do, including their past history. It could be, for example, that soil contamination on your property is actually the fault of your neighbor… and they could be responsible for remediation.
5. Complex and always-changing regulations
Air quality, water quality, employee safety, security measures, waste management, spill prevention… that’s just a small sample of the many regulations facility managers must deal with on a daily basis.
There are so many regulations, they are complex, and there is very little time to understand and act on them appropriately. The solution is to seek assistance from a consultant, industry association, sister facility, or even online from an appropriate and updated source like regulators’ websites to understand current and upcoming regulations that impact your site.
6. Staying in compliance and ensuring you stay that way
It’s one thing to get into compliance. It’s quite another to maintain that compliance. The thing is that regulations change. Your facility changes. And that might mean you have to take steps to stay in compliance.
You can do this with compliance software or an Environmental Management System (EMS), research regulator resources, use industry association resources to stay up to date on regulatory trends, and conduct regular internal audits.
7. Maintaining proper permits
When you secure a permit it is only valid for the specific purpose under which you applied. If conditions change at your facility, you might need to modify that permit… or get a new one. Many permits also require certain monitoring, recordkeeping, and reporting. In some cases, facilities don’t even know they need permits for certain activities.
Ignorance is not bliss in any of these cases. You must read and understand your permit conditions and follow them to the letter. Most importantly, the person applying for permits must know what the facility does and how they do it in order to make sure the proper permits are obtained.
8. Mistakes with required regulatory training
Training of employees in key processes and procedures makes your facility safer and more productive. Not only that, it’s usually required by regulations. The best training covers the “why” and “how,” as well as the “how not” to do something. I always recommend not to bring in outsiders to conduct training; let the employees participate as trainers because they know the job better than anyone else.
And just as important as training, is documenting when it happened, what you did, and who it involved. If you don’t have that documentation, in the eyes of the regulators, it’s like it didn’t happen.
9. OSHA and worker safety
OSHA’s many rules may seem onerous. But OSHA is actually out there to promote worker safety, which is a good thing. And with thousands of published guidance documents and videos, they are ready to help you stay in compliance. You just have to read and watch them.
Plus, OSHA regularly publishes a list of the 10 most common violations, along with how to address them. Concentrate on those and you’ll eliminate most issues… especially those that OSHA will look for first in any facility inspection.
10. Invisible environmental gorillas
Due to familiarity blindness and tunnel vision in environments where you work every day, you often overlook major exposures and liabilities. The good news is that they are usually obvious to outsiders.
So, bringing in an outside consultant is the key to identifying these invisible environmental gorillas and then addressing them. Once a gorilla is identified, address it, and manage it by making it part of routine preventative maintenance so the gorilla doesn’t come back and cause you further problems.
Use these principles, and you’ll be in a good position to address the top 10 most pressing EH&S issues facing facility managers today.
One of the most common issues that we see at any facility we visit are the invisible environmental gorillas I just mentioned. A good first step to kicking off your renewed effort to bolster your EH&S program is to check your facility against our list of the most common gorillas.