Environmental Management Systems (EMS) are established to protect the environment and ensure compliance with legal and other non-regulatory requirements. I previously discussed the importance of establishing an Environmental Obligation Register (EOR). The following are nine simple steps to set up your legal and other requirements within your Environmental Obligation Register.
- Create an obligation in the EOR for each of the individual permits associated with your facility.
- For each obligation, reference the specific permit number and regulation. This will provide context for any subsequent successors to your position.
- Create individual action plans/tasks, under each obligation, for each of the individual requirements associated with the permits.
- Set up a reminder in the EOR for each of the repetitive action plans and tasks. When setting up a reminder, consider the time that will be required to complete the task.
- Set up a recurrence interval for each of the reminders.
- Assign a due date to each of the action plans and tasks.
- Assign responsibility for completing the action plans and tasks. Assign the tasks to both an individual and a position. If the responsible individual changes position or leaves the company, reassignment is simply assigning another individual to that position.
- Set up and assign positions of responsibility within the EOR.
- Provide details within the action plans and tasks for how the requirement closeout will be documented. Consider a requirement to attach or provide a link to the documentation required for closing out the action plan or task.
EORs are an essential tool to efficiently manage legal and other non-regulatory requirements associated with your facility. Do you have any unique methods to manage your EOR? Please share your comments and suggestions.