Case Study:  A Dramatic Improvement in
 EHS Compliance Performance

     A multi-facility manufacturer of packaging materials struggled to maintain a high level of environmental, health and safety ("EHS") performance.  Many can relate to the problems the company faced:

• missed regulatory deadlines;
• late submittals of environmental reporting;
• individuals unsure of EHS responsibilities; and
• turnover of individuals with EHS responsibilities.
   

     Facility audits identified systemic operational compliance deficiencies.  The manufacturing operations had a basic understanding of compliance requirements, but there were a number of activities (monitoring, recordkeeping, etc.) which were unaddressed and exposed the company to noncompliance liabilities.  The audits also found the company lacked a system to track the timeliness of submitting required environmental reports (such as quarterly Title V monitoring reports, annual Tier II and Toxic Release Inventory ("TRI") reports).  Although individuals understood the regulatory reporting deadlines, numerous reports were still submitted late. 

     As with many manufacturing operations, the individuals at the facilities were not, for the most part, full-time EHS professionals.  Plant engineers, maintenance supervisors, and human resource managers frequently were given "add on" EHS responsibilities.  In discussions with these individuals, we learned that in most cases, the individual inherited EHS responsibilities with little or no documentation.  Further, many times the individuals found the compliance records poorly maintained/organized.  More often than not, they did not have the benefit of an orderly transition of EHS responsibilities due to abrupt employee turnover.

     After resolving the audit issues, the company decided to implement Webco's electronic compliance management system, called E-Man.   The system provides automatic email notifications to remind personnel of upcoming compliance deadlines and exception-based email notifications to management personnel on deadlines about to "slip through the cracks", to enable management to react and prevent a missed deadline.

     The electronic system also provides a detailed compliance calendar to assist in organizing a facility's or individual's compliance deadlines.  Additional resources, such as procedures, work instructions, spreadsheets, web pages, etc. are electronically linked to a compliance deadlines to provide reference material.  Finally, scanned copies of completed reports, monitoring, or inspections may be included in the system.

After implementing and using the system for several years, the company identified several benefits:

• Timely Compliance:  Email reminders and exception emails prevent missed deadlines and facilitate management tracking compliance progress;

• Organization:  Centralized deadline information, including compliance calendars, are linked to work instructions, procedures, etc.;

• Succession Planning:  Organized deadlines and documentation facilitates transition of compliance responsibilities and reduces the time to bring new personnel up to speed;

• Quick to Implement:  Common EH&S "template" deadlines assist and streamline facility setup.  No elaborate data entry required;

• Easy to Use and Administer:  The system has a simple, intuitive interface.  Minimal time is required for users to access/use the system (minutes per week) and maintain the compliance documentation; and

• Reasonable Cost:  Minimal initialization fee, with a reasonable annual fee based on number of facilities.