Enterprise expansion requires environmental, health, and safety (EHS) managers to sharpen their location-based understanding of regulations, security needs, and associated response plan components specific to each location. As part of a company’s asset management program, experienced personnel should review response plan data , safety and response audits, response plan validation, and regulatory compliance evaluations.
Corporate changes can initiate tensions and reveal undiscovered company perceptions. Regulatory compliance should coincide with each of the following corporate events:
- Merger or acquisition
- Organizational restructuring and expansion
- Downsizing creating operational changes at other facilities
- Facility closings
- Management successions/promotions
Regulation evaluations are particularly important when a facility is added in a new location. Whether the new facility is built from the ground up or acquired through a merger or acquisition, ensuring regulatory compliance and employee safety requires a committed emergency management staff and an established, fundamental preparedness program with streamlined, coordinated, and exercised response plans. All response plans should incorporate site-specific facility details, appropriate response processes, and standardized company-wide best practices, while maintaining compliance with local, state, and federal regulations.
When a new facility is added to a corporate enterprise, is important to build and maintain a credible relationship with regulators. This teamwork-based philosophy may foster relationships, community acceptance, a favorable reputation, and the potential for collaborative interoperability among the response groups. The mergers/acquisition team or newly assigned facility EHS manager/staff should closely examine and implement:
- Regulations and guidelines
- Emerging best practices
- Company policies
- Location-specific, external coordination
- Electronic publishing and compilation practices
- Necessary site and facility inspections
- Employee training
- Local industrial partnerships
Open communications with internal and external responders will ensure plan and response procedures are current, and carried out in accordance with company protocols and federal, state, and local regulations. Groups to consider in planning reviews include, but are not limited to:
- Local responders (fire, police, emergency medical services, etc.)
- Government agencies (LEPC, Emergency Management Offices, etc)
- Community organizations (Red Cross, weather services, etc)
- Utility companies (Gas, Electric, Public Works, Telephone, etc.)
- Contracted Emergency Responders
- Neighboring Businesses
Company growth emphasizes the need for systematic enterprise coordination, especially in the area of emergency management. A dedicated regulatory intelligence team or the EHS manager may be responsible for the daunting task of sifting through the mountains of location specific, yet divergent, regulations, mandates, and guidelines. Those responsible must remain attentive to ensure emergency plans are up-to-date and compliant in order to eliminate potential fines or operational shutdown. If company experts are not available, local compliance expertise should be outsourced in order to leverage site-specific knowledge and impart applicable requirements that should be included in emergency plans.
Ensuring location specific compliance and effective emergency response planning, regardless of location, requires a streamlined, coordinated response plan. A compliant response plan should:
- Provide strategic regulatory guidance for operational safety and incident response
- Establish an efficient planning archive for audits and reviews that corresponds with compliance updates
- Provide high-quality, complete user/reviewer-friendly documents that are able to be electronically transmissible and reproducible
- Identify hazardous product information and applicable effective responses
- Ensure functional units comply with regulatory requirements and common regulatory practices
With extensive information potentially crossing multiple regulatory agencies, emergency plans must become more interactive and transparent. An enterprise web-based emergency management system can unify content and cross-reference regulatory requirements while enabling secured access to approved stakeholders. New site locations under a company umbrella should address site-specific facility details, appropriate response processes, standardized company-wide best practices, and maintain location-associated regulatory compliance.
Planning and regulatory compliance is not a theoretical process that occurs without an understanding of site-specific operations and local hazards. Companies should not try to apply generalized scripting processes that assign hazard and response actions with unjustified precision. Site-specific plans should provide a fact-based starting point for emergency operations and regulatory compliance.