Start the year off right by making sure that EHS programs are up-to-date and in compliance.
by Sandy Perry, Senior Project Manager – St.Germain
New EHS Managers – or even seasoned ones with decades of experience – can benefit from a survey of your facility and records each year. There are always ways to improve your EHS program and a seasoned manager recognizes the value of routine assessments.
There are different objectives to having this yearly assessment completed:
- Are you seeking support for requesting necessary resources such as additional staff, equipment or instrumentation?
- Do you need documentation that shows the challenges you face to maintain a consistent and sustainable compliance program?
- Would the assessment be something used to fine-tune an existing, well-established EHS program?
- Are you concerned that there are gaps in your EHS program?
- Are there new regulations (that you may not be aware of) impacting your operations?
- Or is it some combination of the above?
The first step is to establish the objectives up front, keeping “the end” in mind. What is it that you most want to achieve from this yearly assessment?
Answering these questions may help you develop the parameters for your assessment to determine how comprehensive it should be, and just as importantly, help you determine what you will do with the results:
1. What is the depth of the assessment? For instance, should all programs, documents, reports and every square inch of the facility and its operations be assessed? Or would a smaller scale assessment be okay each year?
2. Will this be a multi-media evaluation??
3. What regulatory areas should be covered??
4. Are there areas that may be weaker than others??
5. What is the potential for environmental harm or worker injury under current operations??
6. Who will be involved in the assessment??
7. What should the budget be, and who needs to approve it??
8. To what level of detail should the results be presented? How will the results be used??
9. What if the findings include serious violations? Should self-disclosure (the EPA audit policy) be considered? It will be important to address the findings and implement corrective actions.?
Surveys can be done in-house or done by a third party. A fresh set of eyes can help if there are areas that tend to get overlooked or put on the back burner due to the many other priorities or lack of resources.
Knowing the process and identifying the best approach based on your objective is the key to success. For any questions about completing an annual survey and program review, contact us at 207-591-7000.