EMS – 9 Simple Steps to Set Up an Obligation Register

reminder

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.

  1. Create an obligation in the EOR for each of the individual permits associated with your facility.
  2. For each obligation, reference the specific permit number and regulation.  This will provide context for any subsequent successors to your position.
  3. Create individual action plans/tasks, under each obligation, for each of the individual requirements associated with the permits.
  4. 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.
  5. Set up a recurrence interval for each of the reminders.
  6. Assign a due date to each of the action plans and tasks.
  7. 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.
  8. Set up and assign positions of responsibility within the EOR.
  9. 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.

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