The pulse of an Environmental, Health & Safety (EHS) Program is the measurement of how quickly it responds to the changes in regulatory requirements, new processes and equipment, or modifications to existing processes and equipment. Does your organization’s EHS Program monitor changing regulatory requirements? If an air permit or regulatory reporting requirement were modified is your company proactively able to identify and respond to this change? Does your company have a system to manage processes and equipment changes that may affect its compliance status with local, state and/or federal regulations? The Environmental Protection Agency (EPA), Occupational Safety and Health Administration (OSHA) and the Department of Transportation (DOT) consistently audit companies. In fact, in 2010 alone the DOT collected $1,533,278 in penalties and last year EPA fined companies in excess of $200 Million. Effective regulatory monitoring is a key component of a comprehensive EHS program; regulatory changes occur at a rapid rate and maintaining compliance is critical to reduce the potential for regulatory fines. There are a few key steps that can be taken to keep abreast of changing regulatory requirements
1. Create a regulatory matrix and compliance calendar that identify the regulations with which the company must comply and the timing around any regulatory reporting required; include the citation, permit numbers and departments and/or facilities to which they apply.
2. Frequently audit site compliance to these regulations, document non-compliances and create a corrective and preventative action plan to address each.
3. Implement a management of change process that reviews new or updated processes and includes a regulatory review—this will ensure ongoing update of the regulations applicable to the facility. Ensure that any applicable changes are added to the regulatory matrix.
4. Update the regulatory and compliance matrices annually or when operations change at a minimum.
These four steps are simple but effective in beginning to manage the abundance of environmental, health and safety regulations to which a company is required to conform. Interested in seeing a sample regulatory matrix? Click here.