At first, to the new environmental, health and safety (EHS) professional, achieving regulatory compliance can seem like a difficult task. However, after many years of professional EHS experience, I’ve found that meeting the regulatory requirements is actually easy when compared to the more difficult challenge of developing an EHS culture that is integrated into the business. To develop a program where regulatory compliance is easy, you should follow these 6 simple practices.
Practice #1 – Learn how to read and understand the regulatory text. I once heard someone indicate that “reading regulations is like trying to read a document that is written in Greek with footnotes in Latin. However, if you begin with the mindset of understanding what is the regulatory intent, then this is a smooth process. To start off, understand that most U.S.-based EHS regulations have a similar structure to them. This structure consists of a scope, definitions, and then a requirements section. If you’re just getting started in developing your skill of reading regulatory text, it may be useful to begin with one of the shorter regulations and get experience with identifying where the scope, definitions, and the different requirements start and end. Practice by using a highlighter and mark where each section begins and end.
Practice #2 – Ask yourself “what does this regulation require me to do?” For the health and safety regulatory requirements look for items that have a “shall” in them. This can be accomplished using the “find” feature in your browser. For example, OSHA’s respiratory protection standard has 115 “shall’s” in the regulatory text. Once you have identified all the “shall’s” then it’s a simple process of listing out the written programs, inspections, training, and testing requirements contained in the regulatory text.
Practice #3 – Read the corresponding compliance directives and letters of interpretation. For those parts of the regulatory text that you are unsure of, regulatory compliance directives and letters of interpretation can help. These will provide insight into the specific items that a regulatory agency will look for during an inspection.
Practice #4 – Create a list of all regulatory requirements and tasked them out. Think about how you would develop “actionable” tasks for each of the regulatory requirements, then compose a task description into a simple language that you will be able to understand. Think about the who, what, when, and how often requirements.
Practice #5 – Input all regulatory tasks into a tracking system. Use a compliance management software system, such as Affytrac to track the completion of all regulatory tasks. While at the simplest level, spreadsheets will work, they typically require a lot of manual updating which involves time on your part. I often see EHS professionals believe that they’re computer programmers. If you were hired to be an EHS professional, then your expertise is better served out in the workplace working on the strategic issues facing your company, and not holed-up in a cubicle being a code jockey.
Practice #6 – Execute on your regulatory tasks. Now that you have everything planned out, it’s now time to execute. This is where I often see people struggle. Yes, things come up, but you have to stay focused. While it’s way more fun to go to seminars and get involved in professional development activities, those things can detract from getting your core regulatory compliance duties done.
So there you have it – regulatory compliance made simple!