Managing The Compliance Management Process

When it comes to managing all the details that are needed to support the compliance management process there is no shortage of tasks needing to be handled every day. The list, at times, seems endless.  Environmental engineers, EHS professionals and risk management personnel are all faced with the same challenge: accurate tracking of tasks supporting efficient execution of the work. Regardless if you are managing one facility or if you are responsible for the fleet, finding order in the chaos of ongoing compliance can be a nightmare if you don’t invest the time to prepare properly. 

Key Elements to an Effective Compliance Management Process

Establishing a reliable, repeatable and effective compliance management process requires laser focus and can include a significant up-front effort.  Those that can meet this challenge head on are rewarded with a process that largely takes care of itself once implemented.  Others that can’t are left feeling the pressures of daily fire drills and the disappointment of unfulfilled expectations.   Maintaining a compliance program can be hard work but it doesn’t have to be if you take the time to get organized.

 The 7 elements of an effective compliance plan are as follows: 

·         Implementing written policies, procedures, and standards of conduct

·         Designating a compliance officer and compliance committee

·         Conducting effective training and education

·         Developing effective lines of communication

·         Conducting internal monitoring and auditing

·         Enforcing standards through well-publicized disciplinary guidelines

·         Responding promptly to detected offenses and undertaking corrective action

In our opinion, Step 1 – implementing written policies, procedures and standards of conduct is the hardest part of building your plan.  In order to get on the right track, look to the regulations that govern your operations.  This will give you the framework needed to build your daily, weekly, monthly, quarterly and annual task lists.  Start by organizing the higher-level tasks and then assign the sub-tasks needed to support each activity.  Use flowcharts, spreadsheets or a project management system to put your activities into a logical order. 

Once you have the flow organized then build the supporting features around them.  Use your compliance committee to assist you in defining the company specific policies that fall outside those defined in the regulations.  This is where best practices and real-world experience input is used to enhance the plan.  The final plan should be all encompassing bringing in the critical EHS and regulatory compliance requirements needed to keep your operations on track and out of trouble.  

 Changing the Culture to Support the Plan

Company culture comes from the top down.  Although everyone in the organization may understand that compliance requirements are critical to plant operations, not everyone will appreciate the efforts needed to support it properly.  An effective program aims for continuity with normal operations of the plant and support from all departments that are impacted by regular compliance activities. Inviting non-essential personnel into the plan review process is a good way to get folks on board without adding significant work to their list of daily demands. In addition, a strong message from the top prior to implementation goes a long way towards greasing the support wheels for the compliance committee.  An official program launch by the owner or plant manager would do just fine to hold everyone accountable to the mission. 

With the ground rules established and the plan in place you can begin the training and education process.  Training should be as efficient and well thought out as your compliance plan. It should be properly geared to each audience group minimizing their time commitments appropriately.  Compliance is a marathon not a sprint that will have some impact on operations every day.  The better educated the staff, the more reliable the results.  Plan training accordingly and get maximum support, in return.

Training exercises should also define the lines of communications and the communication protocols needed to support the program.  This goes for reporting task completions as much as highlighting areas that need improvement.  Remember a plan is just a plan until it is put into action.  You must have a feedback and corrective action system in place to test the plan as it goes forward.  The plan should be firm enough to operate but flexible enough to accept improvement inputs.  The plan is a living document that should go through regular revisions that reflect end user and the compliance team feedback.  This additional step keeps everyone invested in the results and maintains a higher level of excellence.

Quality of Life Tools for Compliance

You now have defined a program that covers all the requirements and nuances needed to support compliance. You’ve oriented the staff to the program guidelines, performance expectations and the rules of engagement. The trick now is figuring out how to deploy and manage it efficiently. In other words, what tools do you need to help you manage a wide variety of tasks that will require daily visibility and keeps you on track with your compliance needs? The answer is software. Specifically, EHS/CMP software or at the very least “software assisted” management tools through available office programs.  

This software system should include but is not limited to the following basic functions: 

·         Compliance Task Tracking & Acknowledgement

·         Alarms, Alerts & Corrective Actions

·         Multi-Level Access

·         Document Storage

·         Report Generation

Given the size and complexity of a modern compliance program it would be difficult to manage it properly through the standard business office offerings. It can be done but these programs are not specifically designed for compliance management.  They can be made to fulfill the basic functions of the requirements, but it will likely be more trouble that it is worth.  Mixing calendar programs with spreadsheets and data base programs to give the compliance manager the visibility they need to manage the process. Designing and building one this way is lumpy and not an effective use of your time. This is particularly wasteful when you consider there are plenty of established working options already developed and available.  Shop around as we are sure there is something out there that fits every need and budget.

As you research and evaluate 3rd party options, you will find the more sophisticated solutions offer additional features that make your compliance management task easier.  Overview Dashboards, Auto-Escalation Notices, Audit Trails, Inspection Checklists and Email Capability are all to be expected when reviewing EHS or CMP specific providers. Accessibility and ease of use are big features in this space. Most of these tools are cloud-based and can easily be deployed onto many different device platforms (desktop, tablet or mobile).  Software satisfying this application is typically provided as a subscription and does not require any special hardware, licensing or IT services to install/operate. Some providers are suite based, offering various products designed to satisfy a wide variety of EHS needs and others are offered as a single platform, all in one CMS format.  There are lots of choices – so choose wisely.

We recommend starting with features and benefits to help develop a short list of providers.  This should be followed by product demonstrations and reference reviews. Demos are important but can be mind-numbing. Once you start down the demo path it is hard to distinguish one solution from another. Be mindful of the intangibles each brings as it is equally important to the decision-making process and often the key to separating the competition.  Once you have seen the product in action, talk to end users and references.  Do your due diligence, find “like-kind” applications and ask the hard questions. Remember, they wouldn’t be a reference if they were going to tell you horror stories. Focus on how the company handles problems and less on the functionality.  You are shopping for a partner not just a product.

Price is a factor but should not be the driver.  A fair price for an excellent solution clearly beats low price and just ok. Choosing the right product for you often comes down to personal preference, gut feel and comfort with the company offering the solution. Take the time to understand why they do what they do and don’t worry so much on what they do. If they couldn’t do it then they wouldn’t be invited to the table in the first place. Get to know the people you are buying from before you commit – we guarantee this is time well spent.

 In closing

Building and implementing an effective compliance management process that can serve you now and into the future requires a lot of up-front preparation and planning.  Investing your time on your process policies before deploying the working program generally produces the best results.  Include all essential and non-essential personnel to ensure full support of all those impacted by compliance activities. Look for software tools that fit your vision, your budget and that build confidence in your process going forward.  If all else fails, ask for help before starting as there are partners out there able to assist.

Thank you for taking the time to read today’s message.  We hope you found it a worthwhile investment of your time. If you are looking for some direction or ideas on how to get started with EHS/CMP– please give us a shout.  We would be happy to help you out. Thanks, Matt