Part One of The ABCs of EHS Compliance discussed the role of an environmental, health & safety (EHS) Professional. This article will review where to begin when implementing an EHS program or when improving an existing program. EHS is a broad field that encompasses many areas, a compliance evaluation or audit often reveals issues in a variety of these areas. How, then, does a management team along with their EHS professionals determine where to begin in implementing an EHS program?
In our approach a facility walk-through is the first step, this ensures an understanding of the processes within facility and also assists in identification of the applicable regulations. During the walk-through the EHS professional(s) can begin identifying areas that appear deficient and design probing questions to clarifying how the business operates. Many believe that document review is where most time should be spent, however this approach does not truly assess the compliance of the business operations; company documents often indicate the performance of tasks that are never actually completed. Physical observation of the operations and comparison with required standards is the truest measure of compliance.
Following a thorough review of the operations a list of regulatory requirements and/or compliance gaps can be created. Depending upon the complexity of the facility this list may be very extensive and begets the question “where do we begin?” A prioritization matrix can assist with ranking the non-compliances and in determining which to first address. A prioritization matrix is the use of a systematic process of ranking and has a diverse spectrum of application; in this case, it will be applied to the regulatory non-compliances resulting from the walk-through. A number of criteria can be utilized for ranking and each is weighted based on its importance; qualifiers often include, but are not limited to, the following:
- Frequency of the non-compliant activity. How often is this activity performed throughout the departments within the operations?
- Severity of potential harm in which the non-compliance may result. Are there actual or potential negative impacts to the environment, hazards to the employees or external personnel associated with this non-compliance?
- Resource Requirements. Does the facility have the resources or the ability to acquire the resources needed to address the non-compliance?
A business specific list of qualifiers can be produced through brainstorming with a cross-functional team of department representatives; this approach is highly recommended for its collaborative benefits. Alternatively, the EHS Professional(s) can create a list based on their knowledge of facility operations. Once the non-compliances have been rated they can be ranked based on their priority scores—those with the highest rating typically are the non-compliances with the greatest risk for the facility. This matrix will identify a starting point in implementing a new program or in developing improvements in an established system. Its outcome will provide the framework for a mitigation plan in a systematic and cohesive manner.
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