Embed Size (px)
Citation preview
Resources for EHS Regulatory Information2015 MIDWEST ENVIRONMENTAL COMPLIANCE CONFERENCE
JOSEPH TELLTELLEVATEMAY 13, 2015
2015 MECC; 5/13/2015 2
• EHS management systems development and implementation
• Information management systems and tools
• Compliance program support
• Environmental Compliance and EMS Auditing
• Training
• Offices in Atlanta, GA; Lincoln, NE; and Bethesda, MD
Tellevate Overview
32015 MECC; 5/13/2015
Joseph Tell
• Tellevate Owner and Director
• 20 years experience providing EHS management and compliance services to commercial and government clients
• Development and implementation of IT tools and software
• B.S. Civil Engineering, Northwestern University
2015 MECC; 5/13/2015 4
• Defining the need• Strategy• To buy or not to buy?• The “Updates Myth”• Sources
• Finding value
EHS Regulatory InformationPresentation Objectives
52015 MECC; 5/13/2015
• EHS staff resource to ensure organization maintains regulatory compliance
• Align organization policies and procedures
• General environmental awareness – employees are aware of applicable legal obligations
• Referenced when corresponding with regulators
• Support when considering process changes
• Used during audits and inspections – audit protocol
EHS Regulatory InformationHow is it used?
2015 MECC; 5/13/2015 6
• EHS Managers
• Operational employees – need to know about requirements specific to their jobs
• Supervisors and Management
• Legal staff
• Other stakeholders?
• Regardless of source, regulatory information needs to be customized for your audience
EHS Regulatory InformationWho needs it?
72015 MECC; 5/13/2015
• Consider organizational structure, size and environmental profile
• Communicate some information to employees based on roles and responsibilities
• Hard copy? Online should be more efficient
• Subscription and update services
• Leverage existing systems and tools
Plans and permits
Audit protocols and/or software
Legal staff
Existing subscriptions
EHS Regulatory InformationStrategy
82015 MECC; 5/13/2015
• Evaluate cost vs. benefit
•Who is target audience? How will information be communicated?
• Applicability determinations still needed
• Environmental impacts of organization – profile
• Are most requirements in plans and permits already?
• Internal capability to review?
• Need to purchase additional consulting services?
EHS Regulatory InformationTo buy or not to buy?
92015 MECC; 5/13/2015
EHS Regulatory InformationThe “Updates Myth”
• Regulations are not frequently revised or updated
• Having access to real-time content updates may not be worth the cost, if updates don’t apply or aren’t used
• Resources are needed to analyze new regulatory information
• Consider semi-annual or annual updates that are focused on applicable requirements only
• Low-cost, annual update services may be sufficient
102015 MECC; 5/13/2015
EHS Regulatory InformationFree Sources – Federal
• US Federal Register (www.federalregister.gov)
• US Code of Federal Regulations (www.ecfr.gov)
• EPA (www.epa.gov)
• OSHA (www.osha.gov)
112015 MECC; 5/13/2015
EHS Regulatory InformationFree Sources - States
State/Agency LinksIowa DNR www.iowadnr.gov/InsideDNR.aspxIowa Div. of Labor Services
www.iowaworkforce.org/labor/iosh/administrativerules.htm
Kansas DHE(No OSHA)
www.kdheks.gov/environment/index.html
Missouri DNR(No OSHA)
http://dnr.mo.gov/assistance/laws-regulations.htm
Nebraska DEQ(No OSHA)
http://deq.ne.gov/NDEQProg.nsf/OnWeb/Laws
2015 MECC; 5/13/2015 12
• There are many regulatory subscription and update services available commercially
• If free sources of information are not sufficient, pay services may be the answer
• Examples include: Bloomberg BNA (www.bna.com); RegScan (www.regscan.com); and Specialty Technical Publishers (www.stpub.com); Federal TEAM Guide partners
• Consultants provide a host of technical services that may be applicable to your needs: add-ons
• Clearly define need, research and comparison shop
EHS Regulatory InformationSubscription / Pay Services
132015 MECC; 5/13/2015
EHS Regulatory InformationFinding Value
• Environmental awareness – more knowledgeable staff
• Improved compliance
• Avoid unnecessary violations and fines
• Management awareness and assurance
• EHS Manager more confident and efficient with quality, updated information
• Related services can add value – customized protocols, updates, integration with systems, training tools, etc.
