As a consultant performing environmental audits, I see many industries and companies throughout the Midwest (Indiana, Ohio, Michigan, Kentucky, Illinois, and Wisconsin). It’s funny…there’s not much difference in their environmental compliance deficiencies. Sometimes, there are easy fixes to findings: a better filing system, getting data backups, or having a different person log the daily pressure drop readings for their air permit.
But, the biggest problem for EHS departments is employee turnover and the resulting loss of institutional knowledge. I have a friend that is the environmental director for a global company. He spends 80% of his time filling vacant EHS jobs!!! Most companies can hire someone who can manage the daily, weekly, monthly, and periodic requirements. The problem consists of keeping those individuals long enough and having a contingency plan when those employees decide to leave.
Turnover has tremendous costs to the bottom line that affect quality, production, engineering, as well as EHS. So, if you can’t address turnover through your Human Resources department, I recommend beefing up your EHS management system by using a Six Sigma concept of Standard Work. Require your staff to write down all of their responsibilities with frequency and save those requirements to a shared drive where the environmental director can access them. Excel spreadsheets are the commonly used form here. Annual updates to these documents insure that they stay current and controlling those documents as ISO 14001 would also be advised.
I also like the use of a shared calendar. Microsoft Outlook allows individuals in your company to share the tasks and record the responsibilities per day. Excel spreadsheets can also serve as a not-so-fancy compliance calendar.
Also as part of Standard Work, an environmental compliance calendar should be updated annually. Then, require your staff to sign and date each requirement as it’s completed, then have your plant manager review it monthly. Involving an extra layer of management can head off several long-term deficiencies.
A less inexpensive approach is using a consultant to just send reminders. Then, the next step up is having consultants performing all reporting and coordinating the record keeping.
A long term solution is to develop an online environmental compliance calendar. With this, your company can have an online database for your documents and an email sent to the environmental manager, director, and the CEO (if necessary) if those under you haven’t responded by the programmed action dates BEFORE the due dates. Thus, avoiding the non-compliance. These are not free. However, if employee turnover is costing your company as much as I’ve seen in many cases, the savings and comfort in knowing can be well worth it if you have multiple sites and environmental requirements. There are custom and packaged solutions that are available to meet your company’s needs.