August Mack's Monthly Newsletter

Because the days when people work for one company over the course of their career are a thing of the past, managing personnel changes can be challenging. Not discounting the loss of institutional knowledge, there can be problems with compliance deficiencies if a smooth transition is not made between environmental, health and safety (EH&S) personnel. Unfortunately, there typically is no transition period and in some cases a gap of months while the position remains vacant. When this happens, what happens to the facility’s EH&S compliance obligations?

Suppose a great recordkeeping system has been established with an associated detailed calendar of compliance obligations. Does someone in a management position recognize the importance of fulfilling these obligations until the position is filled? Are the obligations re-assigned? Ideally, yes. However, the more typical scenario is tasks go undone until the position is filled or until a regulatory agency inspection occurs and the records review reveals required inspections, reports, monitoring or other compliance tasks have not been done since the position was vacated.

August Mack’s compliance assurance program (eCAP^®) is an effective way to manage these EH&S personnel changes. Some of the ways eCAP^® can be used to manage personnel changes include:

Routine compliance inspections are performed by August Mack personnel. During these inspections, compliance obligations are discussed with the facility’s management team. Any gaps in the completion of obligations due to a vacancy at the facility and a means to address these gaps are discussed.
Regulatory agency reports are prepared and submitted by August Mack so there are no issues with reporting deadlines.
An online, electronic filing system is developed and updated by August Mack so the necessary files are always available.
The need for plant personnel to receive outside training on regulatory requirements is eliminated, as August Mack personnel maintain expertise in all areas of EH&S compliance.
Compliance activities for plant personnel are reduced or eliminated.

Consider eCAP^® as a means to maintain your facility’s compliance whether you have a vacancy in your EH&S department, your department of one has just given notice, or you just do not have time to train another new EH&S person.

Susan Burkett, ASP is a senior engineer for August Mack Environmental, Inc. in Lancaster, Pennsylvania. She has spent the last 23 years working on projects related to environmental, health and safety compliance for government, industrial, manufacturing and commercial facilities in AL, AZ, CA, CO, CT, DE, KS, KY, LA, MA, MD, MI, MN, NC, NJ, NY, OH, OR, PA, TX, and VA. She has assisted numerous industrial facilities in complying with a wide-range of EH&S requirements. She can be reached at 717.399.9587 (ext. 24) or sburkett@augustmack.com.