Environmental regulations are established to minimize the impact a company and their operations can have on the environment. In many instances, compliance plans are a requirement of a regulation. Examples of compliance plans include Storm Water Pollution Prevention Plans (SWPPP), Spill Prevention Control and Countermeasures (SPCC) Plans, and Hazardous Waste Contingency Plans. Compliance plans usually require that specific actions be taken such as inspections, recordkeeping and reporting, and employee training.
In many instances, a plan’s effectiveness hinges on the ability of a company to perform the action items required by the regulation and identified within the plan. Herein lies the struggle as many companies fail to meet ALL the requirements of their plans. Depending upon the situation, not following a plan can have a wide variety of consequences such as triggering an agency audit or Notice of Violation and fine, chemical spills, and possibly injuries and lawsuits.
In our experience, many compliance plans are ineffective for the following reasons:
- The plans are voluminous, complicated, and as a result, difficult to understand.
- Required action items are not clearly stated.
- Action items are not assigned to specific personnel and “fall through the cracks.”
- Companies fail to adequately track performance of action items.
To develop and implement an effective compliance plan, EPS follows the four-step process below:
- Plans must be technically accurate, succinct, and written such that they can be readily followed. Consider your audience. Provide a draft of the plan for their review prior to finalizing the plan.
- Explain the plan’s objectives and action items. Answer questions and provide training if necessary.
- Assign action items to specific personnel. Many times, it’s not sufficient to only assign a title (Plant Manager, Shop Foreman, etc.) but rather specific names should be assigned to each task for accountability.
- Develop a compliance calendar. The compliance calendar should include all action items identified in the plan, schedules and due dates, responsible persons, and location of records.
Bridging the gap between simply having a plan and successfully implementing a plan is essential to having a robust environmental program and reducing liability. For more information on implementing effective plans, please contact your EPS consultant.