Staffing and Environmental Compliance Performance
For most industrial facilities, staying on top of environmental monitoring and reporting obligations is a daunting task. Whether it is filing EPCRA Tier II or Form R reports, maintaining compliance with the RCRA hazardous waste regulations, implementing the provisions of a Stormwater Pollution Prevention Plan or a Spill Prevention Control and Countermeasure plan, the routine inspection, sampling, training and record keeping obligations most often falls on facility personnel as a secondary job responsibility. Only in the largest facilities are these tasks handled by personnel whose only job is environmental compliance.
As a secondary job responsibility, routine compliance obligations are often overlooked or put aside because that person’s primary job responsibility is making money for the company. In today’s lean economy it has become an increasingly common problem.
This issue is often compounded when an employee leaves the company and no one realizes the environmental compliance component of that person’s job needs to be reassigned. Even short-term vacations can lead to missed compliance dates. The employee’s primary job responsibilities are covered to keep production going, but no one was reassigned the environmental compliance tasks. The solution is a comprehensive environmental management system that provides for the seamless monitoring all of a facility’s environmental obligations. Because forgetting to file compliance documents is not an excuse regulators will find acceptable.
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