In our first blog of this series we discussed the trap of a piecemeal approach to managing environmental compliance and the benefits of implementing a more streamlined program. There are common pain points and hindrances when a compliance program is lacking or mismanaged. These often manifest as unclear permit conditions or expired permits, miscommunication between personnel, poor or missed communication with regulatory agencies, lack of awareness of regulatory changes, or failure to submit compliance reports accurately or by their respective deadlines.
We know what doesn’t work, so what does?
Identifying what doesn’t work is easy (and almost second nature). But over the years, we have been able to identify commonalities between successfully managed compliance programs. At a minimum, they are established and maintained by:
Continual, current and centralized recordkeeping. Create a system to ensure records are updated when necessary, and keep updated records in an easily accessible and centralized location.
Tracking deadlines. You cannot comply if you don’t meet reporting deadlines. Find a system that works best for you, and you are more likely to stay on track. This system can look like a simple Word document, Excel file, or entries on your Outlook Calendar; or something more complex such as deadlines and reminders recorded in your company’s preventative maintenance program.
Understanding permit conditions and reporting requirements. Most permits and regulations require different types of reporting and recordkeeping due throughout the year. Spend time with your permits to create a detailed permit condition document.
Recognizing existing and potential compliance gaps. You can enlist an environmental consultant to conduct a Regulatory Applicability Screen (RAS) to better understand your facility’s specific compliance gaps without a requirement to report.
Checking that existing compliance programs reflect current site conditions and operations. Some plans are easy to maintain and adjust while others are more cumbersome, but your permits need to reflect current (or future) changes to your facility. For example, if your site requires a Stormwater Pollution Prevention Plan (SWPPP), determine if it needs to be updated to meet new requirements and that it accurately reflects current activity at your site.
Staying up to date with environmental rules. Not only are there an abundance of rules to understand, but they are regularly updated by state and federal agencies It is important to track the current rules that apply along with rule updates.
A reliable organizational culture. Behind a successful compliance program is top-down management commitment, buy-in, and ownership of the common goal. This will ensure that each employee understands their own and others’ roles in achieving and maintaining environmental compliance.
Good communication with regulatory agencies. Be upfront and honest about your facility and its activities. You don’t like surprises, and regulatory agencies really don’t like surprises. A great way to initiate communication and open dialogue is through pre-meetings with regulatory agencies when preparing a permit application.
These are just some of the contributing factors to a successful program, but they can help you as you begin to implement a more holistic program approach to environmental compliance.