While some facilities, typically with a corporate hierarchy, regularly conduct internal audits or answer internal questionnaires about their environmental and safety practice, it is not very common for a facility to have a review of all permits, programs, procedures, and equipment to make sure that they follow all federal, state, and local regulations and requirements. We recommend for all facilities to conduct periodical Environmental and Safety Compliance Reviews (ESCR) either with an internal team or by a third party.
The ESCR should include a review of permit and recordkeeping requirements, procedures and SOPs, and employee training. The review should also include a physical walkthrough of the facility and process lines to identify any gaps in safety and environmental compliance. The ESCR can also be conducted in conjunction with global and corporate standards, management systems, as well as specified internal auditing procedures. The ESCR will not only identify gaps in compliance but will allow for the team to prioritize the abatement of the gaps based on capital investment required, time allocations, and employee and environmental safety. It is recommended the ESCR be conducted twice a year, or, at a minimum, once a year.
Some of the benefits of conducting regular ESCRs are as follows:
- Improve worker safety
- Reduce the potential of polluting the environment
- Avoid potential fines and/or penalties by regulatory agencies, an avoid potential visits from regulatory agencies in the first place. Repeat violations could result in exponentially higher fines.
- Reduce liability by facility/employer
- Taking a proactive approach, versus reacting after an incident, allows more time to identify compliance gaps and prevent exposure to hazards. If these disparities are found by a regulatory agency, the agency typically requests a quicker abatement time, usually costing more money and man power to accommodate
- Enable permit updates for new equipment and process in a timely manner prior to start up as required by many local, state, and federal regulations.
- Provides a baseline analysis of facility operations and compliance to be used as a tool to measure a facility’s improvement over time.
- Build a greater understanding of the agencies and laws that regulate your particular business.
- Provide an opportunity to develop key performance indicators which can be reviewed along any preferable time interval.