1. Personnel Changes
The first stressor that will knock you off your compliance track is if there is a sudden personnel change. Turnover can cause stress in any organization. If the person that leaves, is the only person with EHS knowledge of a facility, program, permit, etc., it can cause headaches for not only the facility manager, but corporate managers as well. Your EHS recordkeeping and management system must be effective and up to date at the facility level to relieve some of the stress of a key EHS person leaving the organization.
Institutional knowledge of the facility’s unique operations is a benefit, and that knowledge is not easily transferred when there is a personnel change. Tactical compliance tasks required by the facility EHS manager(s) related to licenses to operate can easily slip through the cracks if they aren’t being actively monitored or if the facility doesn’t have system for managing its records. Missing information or tasks related to discharge monitoring reporting, emissions testing, exceeding permit limits, and more, could result in a non-compliance performance. This could lead to a regulator inspection, a notice of violation, civil or criminal litigation, financial penalty, or even damage to the company brand and reputation in the community.
2. Lack of Resources
Maintaining full facility EHS compliance related to license or permit requirements is a daunting task that requires the necessary resources, consistent efforts, support, and collaboration not only from management, but everyone in the organization. It is common to see a sizable facility staffed with a single EHS resource to manage all EHS related tasks, or an EHS Manager who is responsible for several facilities. In addition to budget, resources for EHS are now even tighter with the ongoing challenges caused by the COVID-19 pandemic.
While regulatory requirements are the same, applying them to various industry segments, understanding which requirements apply to the facility and ensuring compliance with these requirements requires personnel who have a general understanding of the industry the facility is part of. It takes experience and skill for a seasoned EHS professional to understand specific permit terms and conditions, develop actionable tasks and manage them accordingly.
To relieve some of the resource stress, a facility needs a good systematic management system in place to help manage the long list of compliance tasks for multiple permits and complex EHS regulatory implications. Best management practices utilized for many facilities with successful results includes using tools which may include a robust facility compliance calendar. Compliance calendars include all required tasks at the specific frequency over a yearly basis, an automatic reminder for each scheduled task with advanced warning, and follow-up through the entire task cycle to ensure the task has been completed, communicated, and documented.
Another way to relieve resource stress is to look into Antea Group’s Resources-as-a-Service (RaaS). RaaS for EHS is gaining fast popularity as an option for companies in these stressful situations. RaaS assignments are completely flexible in terms of both scope of work and length of engagement. A company may need a professional with 10+ years of experience to manage and lead EHS or sustainability initiatives, or it may need a few employees for day-to-day tactical work.
3. Integration of Companies & Processes After an Acquisition
The third stressor that can knock an organization of their compliance track is when one goes through an acquisition and an integration of the companies, along with their processes (or lack thereof), must occur. If you’ve acquired an organization whose compliance record is less than stellar, where do you start? Conducting a basic gap analysis or assessment to understand compliance gaps can help an organization identify risk and know where to focus their efforts to ensure compliance and begin to integrate their own company policies.
Staying on Track with Compliance
Staying on track with compliance can be a daunting task and can become more stressful should there be a change in personnel, lack of resources, or if you’re part of an acquisition. Identifying a process or management system to help track and keep track of applicable regulatory requirements is a great place to start. With everything going on in the world that requires attention, it is important to understand your options and the resources available to relieve these stressors in order for you to stay on your compliance track.
The next blog post in Antea Group’s compliance assurance series addresses some common challenges EHS managers face, as well as answers common questions they have about where to focus their efforts and possible consequences of non-compliance.
