Managing EHS Compliance Risks: Essential Tips
Are You Moving the Needle on EHS Compliance?
Managing the risk of noncompliance with environmental, health, and safety (EHS) requirements is increasingly complex in today’s regulatory landscape. With ever-changing EHS regulations, human error, and equipment failures, achieving compliance can be daunting.
Understanding the Stakes of EHS Noncompliance
Noncompliance with EHS standards can lead to severe penalties. For instance, the US EPA is considering raising hazardous waste violation fines to $70,000 per day, per violation. California has already increased penalties under the California Hazardous Waste Control Law to this level. As an in-house counsel, managing EHS compliance risk is a critical part of your role. Reducing the risk of EHS noncompliance and enhancing your company’s environmental compliance performance are top priorities.
Common Root Causes of EHS Violations
Key reasons behind EHS compliance issues include a lack of awareness of regulatory requirements and improper delegation of compliance responsibilities. These challenges make it essential to adopt strategies that effectively address these root causes.
Top Strategies to Enhance EHS Compliance
In my experience, the following three strategies are highly effective in improving EHS compliance performance:
Meaningful EHS Training: Avoid “check-the-box” training sessions that merely fulfill legal obligations but fail to teach employees how to comply with EHS regulations effectively. Implement comprehensive EHS training programs that emphasize the practical steps for maintaining compliance.
Clear EHS Procedures: Develop detailed procedures that outline the “who, what, when, and how” of compliance obligations. This clarity ensures that all EHS tasks are accomplished accurately and on schedule.
Comprehensive EHS Legal Registry: Create an EHS legal registry that lists all potentially applicable regulatory requirements, including exemptions. This tool helps in systematically tracking compliance and mitigating EHS risks.
Schedule Your Complimentary EHS Compliance Strategy Session
Every company has unique EHS challenges. To help you determine the best compliance strategies for your organization, I’m offering a complimentary one-hour EHS compliance strategy session. During this session, we will:
Conduct a high-level review of your potential EHS risk
Identify the highest EHS compliance risks facing your company
Focus on a strategic priority to mitigate your compliance risk
As a thank you for participating, you'll receive a complimentary copy of my latest book, California Environmental Law and Policy: A Practical Guide. This essential resource covers the full spectrum of California environmental, land use, and natural resources law in an accessible format.