What if you could drastically reduce the amount of site visits and violations given from regulators?
I can’t count the number of times I’ve worked with people who are certain that the regulator, be they municipal, state, or EPA level, have it out for them. They are sure their site is being unfairly targeted, tracked and scrutinized. I tell them all the same thing I’m about to tell you.
If you want to keep the regulators off your sites, you just need to show them that you are serious about compliance.
If the regulators see that you know your stuff and that you are keeping up with your side of the regulations, I promise you will see them a lot less. And when you do, the visits will be shorter and easier; for you AND for them.
So how do you do it?
How do you show a regulator that you are serious about compliance and that you are taking care of your side of the regulations?
This is the part where I lose people. And that’s because it all boils down to one, simple, little, thing. Transparency.
I don’t know why that’s such a buzz-word in our industry. I can’t figure out why there is anything to hide. That is the crux of the whole situation. When you aren’t transparent with a regulator, they automatically think you are trying to hide something. When that happens, they start digging deeper. They look at every question on their checklist. They check for dirt between your toes and behind your ears.
When regulators think they are being toyed with or lied to, they will do everything they can to take the power back.
The answer really is transparency. I encourage every environmental manager that I work with to share all of their inspection reports, corrective action logs, plans, maps, and any other documents with their regulators.
In ComplianceGO, our compliance management program, I tell them all to add the regulator as a view-only user and to also add them as a notification recipient for inspections and reports. With that set up, every time you conduct your self-monitoring inspections on your site or at your facilities, it automatically sends the inspection report right to the regulator.
In essence, you are telling the regulator, “Look, I’m doing what I’m supposed to.”
Building a Relationship of Trust
In less time than you think, the regulators that you are working with will start to see you as someone who gets things done and does them the right way. They’ll know that you are doing your inspections, fixing things on your site, and taking the regulations seriously.
Of course, that means that you have to do your inspections, document and correct action items, and keep your site clean and maintained. Honestly, though, that’s not hard.
Many of the companies and environmental managers that I work with have had great success with this. Regulators only end up on their sites during their regular inspections, if that. That cuts it down to just one visit a month, quarter, year, or 5 years, depending on the site type. Sometimes the regulators are pretty busy and end up having to skip their visits to the sites they know are doing things right.
When they do come out to the sites, they are much less likely to dig deeply into the documentation and scrutinize every nook and cranny. They know they can peruse the site documents back at their office (but they won’t, because who has time for that).
And finally, if they do happen to find something wrong, they are much less likely to issue a stop-work order, fine, or other violation. Instead, because they know you are usually on top of things, they’ll just mention it and ask you to fix it.
Can it really be that easy?
I’m telling you, I’ve seen this time and time again. Site operators and environmental managers are extremely hesitant to give full viewing access to regulators so they can see everything that’s going on. The truth is, the regulators don’t have the time or desire to wade through your documentation unless they think you are hiding something.
When the regulators have access to all the documents and reports, they feel a lot more confident that you are taking care of things on your site and they stop bugging you.
So make friends. Play nice. And offer up something that no regulator expects to see. In my experience, it usually ends up saving you time and hassle, and can help you avoid fines, shutdowns, and fees.
Want to learn more about ComplianceGO? – Visit us at www.compliancego.com