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.
Over the last couple of decades, the rules and regulations governing mining and other industries has become increasingly complicated. It is not unusual for a company to have over a hundred separate permits and programs to manage for a particular operation. Each of these permits may have many obligations and requirements associated with them. Keeping track of all the legal obligations associated with these permits and programs can seem overwhelming at times and requires some good organizational skills to manage them effectively. I once had a boss who said that the three most important things to maintain your license to operate are: Compliance, Compliance, and Compliance! A complete and detailed obligation register is essential to consistently achieve compliance.
So how do you best manage and track all of these obligations? The most effective way that I have found is to develop and maintain a detailed obligation register. An obligation register can take many forms. It may be as simple as a table created with a spreadsheet that you post to your office wall, or a more intricate database with integrated reminders to keep you informed of upcoming commitments. The key is to carefully go through your permits, understand what the requirements and obligations are, and compile a comprehensive list of actions needed to maintain compliance.
There are several popular out-of-the-box software packages that will help you manage your legal and other requirements. These software packages are somewhat versatile and can track not only your environmental commitments, but also your safety and health and community related obligations. My first experience utilizing one of these software packages was with a product called Intelex. BSI Entropy Software makes a similar database product that also tracks legal and other obligations. Either of these solutions will help to organize your obligations and make managing your environmental commitments much simpler. While both of these products have the same objective, the interfaces and functionality is quite different.
Before investing the time and money required to implement one of these software packages, explore what others in your industry are using. Find out what they like and what they don’t. Make sure the solution meets your needs and will be simple to use. If it isn’t simple and straight-forward, employees won’t use it, and your efforts will be for naught.
How do you manage and track the environmental obligations at your organization? Please feel free to comment and provide feedback, as with all of my blogs.