Keeping Pace with EHS Compliance Management

An effective safety/environmental compliance management program cannot be executed without well-managed, accessible, and dynamic data.

Corporations and government agencies continually seek ways to improve their environmental, health, and safety (EHS) performance. This quest for better performance often leads to the realization there is a need for an organizational shift from reactive management toward proactive management of EHS issues. Turning this realization into action is not easy, however; it requires a methodical, well-organized approach.

To support this shift, many organizations are adopting EHS management systems (e.g., OHSAS 18001, ANSI Z10, ISO 14001) that offer a more structured approach to management of EHS issues. These systems involve many requirements that induce the organization to understand, define, and implement numerous inter-related system elements.

Compliance Management: Critical Element of an EHS Management System
"Compliance management" is often considered the most important of the EHS management system elements. It is also one of the most challenging elements to implement effectively. This central component of the systems approach requires EHS departments to track and maintain extensive libraries of "legal and other requirements" and permits and, of course, prove compliance to those requirements. It also involves understanding, documenting, and evaluating compliance.

As an example, OHSAS 18001 states: "The organization shall establish and maintain a procedure for identifying and accessing the legal and other OH&S requirements that are applicable to it. The organization shall keep this information up-to-date. It shall communicate relevant information on legal and other requirements to its employees and other relevant interested parties."

While essential, compliance management alone is not the core objective of the management systems approach. The often-overlooked goal of a safety/environmental management system is not just meeting each of the required ISO/OSHAS elements individually and then obtaining the relevant certification, but also to improve overall health, safety, and environmental performance. Thus, the real value of the management systems approach is not simply fulfilling the individual requirements. It is found in the overlap and interaction of all of the system elements. When companies come to this realization, they are able to take advantage of the full "system" benefits.

All of the elements of a safety/environmental management system, then, work together to achieve the common goal of improved performance. Compliance management is a critical common thread connecting all of these elements together. The rest of this article will examine how to improve compliance management in a way that is beneficial to your entire management systems approach.

Subscribing to an EHS management system has myriad benefits but requires a commitment and investment from the organization and its EHS managers to ensure standards are followed and requirements met or exceeded. As an example, part of compliance management is tracking and maintaining a library or inventory of "legal and other requirements," a time-consuming administrative exercise that often goes to waste. With good intentions, a company may begin documenting all of its requirements but then abandons the effort and reduces the information to a binder gathering dust on a shelf or an electronic file left untouched on someone’s computer. The requirements inventory never receives the attention or maintenance it requires because there is no effective system in place.

Running an effective compliance management program is not easy; the above example is but one of many possible scenarios that may hold an organization back. With that in mind, let’s isolate the key compliance management challenges an organization can face as part of its safety/environmental management system implementation.

Key Challenges of Compliance Management
1. Maintaining an up-to-date inventory of all "legal and other requirements" that includes a history of all changes made to the list over time.
2. Recording the actions associated with each requirement and ensuring appropriate management of change when the requirements change.
3. Effective tracking of findings and corrective actions for addressing non-conformance as they relate to specific requirements.
4. Developing an effective and visual monitoring and measuring system for tracking performance of the complete compliance management system.
5. Integrating your compliance management program into the other elements of your safety management system.

To elaborate on challenge #5, it is important for companies to recognize that an optimal compliance management program is not only run efficiently as a stand-alone component, but also should efficiently integrate with the other components of the a safety/environmental management system. That is the true nature of the management system: achieving a holistic and integrated "world view" of your EHS programs.

The Roadblock: Inefficient, Disconnected Data Systems
For organizations implementing a safety/environmental management system, implementing a compliance management program that overcomes the challenges listed above can be a daunting notion. It is important then for these organizations to assess what may be holding them back.

It is clear from reviewing the challenges above that an effective a safety/environmental compliance management program cannot be executed without well-managed, accessible, and dynamic data. Good data will inform EHS managers whether requirements and performance goals are being met and, even more importantly, can offer invaluable insight into shortcomings and problem areas.

The most common roadblocks to effective compliance management are the tools used to track and collect data from an organization's various EHS programs. These programs are often managed with different, inefficient, and disconnected data management systems, such as spreadsheets, home-grown databases, and paper files. Different departments may even be responsible for different pieces of the data, with each using its own isolated methods of recording information. More sophisticated companies may have some software systems in place, but these systems are often still disconnected from one another and cannot effectively support a holistic compliance management process. This type of disjointed approach often relies on inefficient and possibly manual gathering of information.

In this scenario, tracking all of the various elements of your compliance management program and gaining business intelligence (reporting and analysis) to inform decision-making proves cumbersome at best, impossible at worst. The EHS manager(s) and team are probably putting in maximum effort to track and maintain the information, only to get frustrating, fragmented data as a result.

The Solution: Integrated, Automated Data Management
To support a complete and effective compliance management program, it is critical to consider how the organization can integrate, organize, and manage all components into the same database. An ideal compliance management system process would allow for cohesive, holistic management of EHS data across functions and even departments. All of the system elements should be interconnected and integrated, thus promoting effective communication, efficient data sharing, good data quality, and valuable reporting.

An integrated, automated system will allow you to:
1. Set up automated workflows and processes that promote standardization across EHS functions
2. Seamlessly share data between safety programs to inform business intelligence
3. Link compliance inventory and tracking to each component of your safety program to efficiently and automatically update information, due dates, completion statuses, etc.
4. Automate notifications and reminders to ensure that requirements are satisfied in a timely and complete manner.

All of these elements integrate with one another and feed into your compliance management program, allowing for effective data management of all compliance-related items.

Action Plan: Improving Compliance Management Practices
An organization cannot realistically take the leap from the disjointed approach outlined in Figure 1 to the holistic, well-organized system of Figure 2 overnight. This transition is a process that requires careful assessment of current practices, documenting of requirements, and evaluation of possible solutions.

Once the initial work is done and you are ready to evaluate solutions, it is critical to ensure that the data management system you select does not merely handle compliance management alone; the ideal solution should allow you to track, manage, and analyze the data from your various programs under one roof. Having this synergy between components not only will prove invaluable for effective compliance management, but also will greatly contribute to helping you achieve the overall goal of improved performance.

If you determine your current data management tools fall short, consider evaluating new solutions. Most companies either consider building their own database in house or decide to purchase one off the shelf. Either way, it is important to ensure your solution is scalable and allows you to manage not just compliance management, but all of your EHS programs in a holistic, integrated fashion. With that in mind, you’ll likely find that it is more efficient and cost and resource effective to consider the off-the-shelf applications that are already built to address these requirements.

Compliance management is a central a safety/environmental management system component that can be effectively performed with integrated, automated data management tools. Bear in mind, however, that in the management systems approach, compliance management does not exist in a vacuum. It is part of a whole program that, if properly implemented, can lead you down the road of improved EHS performance.

This article originally appeared in the July 2012 issue of Occupational Health & Safety.

About the Author

John Easton is a CRSP and MHSc (Industrial Hygiene). He currently works as the Safety Product Manager at Medgate Inc., a leading provider of integrated Health and Safety Software Solutions. He previously worked for 12 years at Toyota in various Health & Safety roles including Industrial Hygienist, Safety Specialist, Project Lead for Toyota Safety Management System, and Assistant Manager. He can be contacted at jeaston@medgate.com or 519-304-3471.

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