Resources for EHS Regulatory Information 2015 MIDWEST ENVIRONMENTAL COMPLIANCE CONFERENCE JOSEPH TELL TELLEVATE MAY 13, 2015
Jul 27, 2015
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.