January 22, 2016 | Brian Bennett
EH&S compliance challenges are growing in scope and complexity. And they seem to be growing at an increasing rate. You and your team have handled this challenge admirably so far and your company has avoided hefty fines due to noncompliance. Your process may not be perfect (or maybe it is!) but you feel you’re squarely in the “Acceptable Risk” bucket as relates to the likelihood of falling out of compliance.
Looking forward, the question (and the challenge) is: “Are you moving towards the “Unacceptable Risk” bucket? And how will you know?
Here are 3 things for you to consider as you contemplate your EH&S Risk Assessment:
Are Your Permits Smart?
A static permit just sits in storage somewhere. A Smart permit will give you advance notice of renewal and will make itself easily available for increased visibility with responsible parties and management. Smart permits also protect against situations where “the process” works so long as “the person” doesn’t leave. The problem is that “the person” does leave sometimes, and their inner knowledge of your permit situation leaves with them. Key personnel turnover is one of the most common contributors to process failure resulting in compliance failure.
If you have a manual process and static documents, then your process is necessarily at risk.
One way to mitigate the inherent risks of a manual, static permit process is to store key documents digitally and set up an email alerting mechanism for key dates. Intelligent digital storage also promotes easy sharing and dissemination of permit covenants to responsible parties and management. This also applies to warranties, safety trainings, inspections, etc.
How Many Hands Touch Your Documents?
It’s likely that you use outsourced Service Providers for testing, training, inspections, etc. and they give you copies of necessary work documents. These documents can come via emails with attachments, or with scanned images. Via fax. Via US Mail and person to person. This is a situation where you’re dealing with employees and vendors, firewall issues, multiple formats, and document ownership issues.
If you have many “hands” touching your documents, which are coming via many different methods, and you don’t ultimately own all of these documents, then your risk of document mishandling is high.
One way to mitigate these risks is to standardize and simplify the process for document capture with technology. A good example would be to give your Service Providers the ability to use smart phones to takes pictures of documents for direct upload into your EH&S data base as smart documents.
Do You Still Rely On Attachments and File Cabinets For Your EH&S Data Base?
Documents delivered and stored via email as attachments can be stored and accessed, right? Yep. And then good luck trying to find Permit #1287 for Building #23 for Asset #9 that was completed in May of 2014. The inherent risks of having your key compliance documents physically stored in file cabinets should be obvious. The inherent risks of thinking that emails with attachments is a good alternative is also dangerous. You need to spend 80% of your time on smart, proactive EH&S programs, not on document management.
If you have key compliance documents residing in multiple locations, in multiple formats, in email and in file cabinets, then you are at risk of document mishandling which can lead to noncompliance and ultimately fines.
One way to normalize the capture, storage, management, and retrieval of your EH&S documents is to keep them all in an EH&S data base that is backed up to the cloud and has an intuitive user interface that facilitates on-demand document access anytime, anywhere.
When you look forward several years and consider all of the potential influences and changes that could affect your ability to keep your company on top of the compliance game and away from fines, are you feeling “Acceptable Risk” or “Uncomfortable Risk”?