(Ed. note – Yes, that title is a shameless takeoff from the credit card commercial. AND,  our goals are the same – your financial wellbeing.)

 Over the 37 years spent in this industry I have done many presentations to various manufacturing business groups on the topic of what a CEO needs to know about the risks of environmental and safety non-compliance at their companies. After all, since the CEO is the ‘checkbook stop’ for EPA and OSHA when things go wrong from a compliance inspection, I preferably want them to know in advance how they may be able to prevent that from happening.

Hardly a month goes by that we don’t get a call from an owner telling us that they have had a negative-results inspection by EPA or OSHA, have lots of programs to fix, and are being slapped with a financial penalty as well.   I and our associates hear lots of anger and denial about the “unfair” situation, but we get past that and on to the solutions. More importantly, we try to get a plan set up that helps the CEO properly manage and delegate their facility’s environmental and safety risks. This is where the folder comes in.

CEO’ don’t need to know what’s in an air permit, how to construct an SPCC plan, what makes up a Lockout-Tagout program, how an employee wears a respirator safely, or the details about myriad other regulatory programs. But, they need to have a folder containing a list of ALL such regulatory programs affecting their facility.  More importantly, they need to know that the list is absolutely correct. That reassurance can come from inside or outside of the CEO’s facility, but it must be accurate.

The CEO must then delegate the task of preparing individual regulatory program folders (the air permits, SPCC plan, respirator program, etc.) to a knowledgeable and trustworthy individual. This is the person, on their own or with expert assistance, who is authorized to build up the program folders that actually include the air permits, the SPCC plan, individual safety plans and training records,  storm water permit, waste management documents, and on and on for everything affecting the facility. These folders MUST be always up-to-date and even have a management schedule that can be transferred to an overall compliance calendar, a copy of which should also be in the CEO’s single compliance folder. Using just a few sheets of paper, the CEO can then ask pertinent program compliance questions of their personnel and get an update about the condition of any program.

The overall objective is that if an EPA or OSHA inspector comes to the door with probing questions in hand, facility management can easily pull any program folder replete with historical and current information that proves compliance. The better the records are, the sooner the inspector realizes that there isn’t a need to pitch a tent and dig-in for the long haul. Surviving an inspection in this manner is worth the relief and facility pride that comes with it.

Now you know a reliable method to plan for, and survive, a regulatory inspection.

So, what’s in your folder?

Published by Stephen Kovatch

Senior Client ManagerĀ  Stephen J. Kovatch focuses on assisting clients in establishing corporate regulatory compliance programs in the areas of air, water, and waste management. Mr. Kovatch also provides direction to industrial facility owners who are active in the transaction of contaminated property by defining objectives, coordinating soil and water sampling protocols, risk assessment, and remedial / cleanup activities. He frequently represents clients in property sales negotiations and regulatory agency and insurance proceedings.

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