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Six Pillars of an EHS Compliance Program: Findings & Corrective Actions

February 2, 2021 by Ryan Donahue

Since the creation of EPA in 1970, companies have seen growth in the number of environmental regulations, tied key performance indicators more closely to regulations, and shown global acceptance that government-led initiatives are required to drive change. 

These conditions led businesses to adopt EHS Compliance Programs: to meet the requirements of increased environmental regulation at the global, national, and local levels and have the processes in place for employees to be accountable to corporate goals when it comes to compliance.

In this blog series, RegScan will examine the six pillars of an EHS compliance program. The first four are implementation pillars meant to provide consistency across a business, create employee-level accountability, and offer transparency to regulators, auditors, and stakeholders. The last two are verification pillars which demonstrates that the organization is serious and committed to implementing its Compliance Program fully and effectively.

Verification Pillar #2: Findings and Corrective Actions

Findings and Corrective Actions comprise the final pillar of the EHS Compliance Program. You may balk at the thought of “standardizing” your audit findings and corrective actions: you may claim that your site is “different” and that it is not feasible to pre-define what your findings and corrective actions could be. But consider the big picture when it comes to EHS compliance and review the example below before you make any final judgements.

When thinking about compliance with regulatory requirements, they all originate from the same place – the underlying laws and regulations. This is the same legislation upon which the Legal Register, Requirements, Tasks, and Inspection lists were built. Although sites may be “different”, essentially each site is working toward the same compliance goal based upon the same content.

If you still believe your organization is different, consider the following example regarding fire extinguishers. Imagine completing the Implementation portion (Pillars 1-4) of your EHS Compliance Program. Corporate is now here to help, and, of course, one of the fire extinguishers in one of your offices is blocked. Regardless of industry, site, or company, a blocked fire extinguisher is a blocked fire extinguisher. These findings may be a bit more consistent than you expected.

Now you might concede that findings can be standardized, but you might still be thinking that corrective actions cannot be standardized because either your business is unique, or management requires findings to be written in a certain manner. Keep in mind, though, that the starting point does not have to be different.

If you have a Finding of a fire extinguisher is blocked, your starting Corrective Action is: Ensure that the fire extinguisher is not blocked. If you are thinking that this is like a Requirement, you are correct. This compliance content begins from the same place, and it all works together to support your EHS Compliance Program. Services like RegScan provide that compliance content.

Having pre-populated, standardized Findings and Corrective Actions creates consistent starting points for all your sites.

In terms of mobile audits and using tablets or phones during an audit, it is much easier to employ pre-determined Findings and Corrective Actions that are provided in a drop-down list than entering data on mobile devices. Take a moment to consider the resulting efficiency. For your corporate reports, the consistency from site to site in all aspects of your EHS Compliance Program would be easy to track, manage, and view.

Next up: Create and Sustain a Successful EHS Compliance Program

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Address: 800 West Fourth Street - Suite 202, Williamsport, PA, United States

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