As manufacturing facilities struggle to cut costs to meet business conditions many are forced to cut personnel responsible for environmental and safety programs. Small to medium sized companies have been operating without internal EHS staff for several years. The question becomes “How do we maintain compliance with complex EHS regulations in a lean manufacturing environment?” The following process will help manage this process.
Step 1 Accountability: The responsibility for compliance with environmental and safety regulations must be assigned to specific staff. Initially, staff given these new responsibilities will feel overwhelmed and less than qualified. Often times safety programs may be delegated to HR and environmental may be assigned to engineering, facilities, or maintenance departments. The key is to incrementally increase their competency with the regulations through MDEQ/agency workshops and working with technical experts (consultants, agency resources, other companies).
Step 2 Compliance Snap Shot: The next step is to determine specifically what regulations apply to your operations and a detailed understanding of the requirements. This can be best accomplished by bringing an external consultant to review yourvoperations and the a detailed summary of the requirements. The summary should not be a mere list of regulations but a detailed list of specific requirements. This information should then be explained to the onsite personnel responsible for compliance. This can be done as part on an initial compliance audit and the checklist can be used by onsite personnel to periodically verify compliance. Depending on your facility this type of assessment could cost between $1,500 and $3,000.
Step 3 Training and Associations: Personnel assigned responsibility for environmental and safety regulations should periodically attend training programs and plan to participate in local chapters of technical associations. Most state agencies will sponsor periodic workshops and other training is available. Environmental and safety associations typically will have local meetings monthly or quarterly. These meetings may provide technical updates and will an opportunity to network with others with similar responsibilities.
Step 4 Periodic Compliance Evaluations: The facility should periodically review their compliance with regulations. This can be done with internal staff using the checklist developed in Step 1 or every 1 to 3 years the facility may wish to bring in an external consultant to conduct a compliance evaluation. The external audit will help the facility maintain compliance and be prepared for agency inspections.
Using this simple compliance management process a company can effectively manage their environmental and safety requirements.