The Compliance Cycle – Step 2
Action planning by developing your environmental compliance plan.
A Compliance Plan is the action plan your team develops as Step 2 of the Compliance Cycle . The level of action required for compliance will largely depend on your initial assessment. If you are unfamiliar with the first step in the compliance cycle, follow this link: Compliance Cycle – Step 1 – Assessment. Then continue below.
Do we already have policies in place?
In many organisations, particularly medium to large businesses, an integral part of the company operations manual covers safety and the environment. A part of the operations manual will include your Environmental Management System (EMS). It may be called an environmental management plan (EMP). The EMS is the document that an auditor will look to for a performance benchmark – against which your actual operations will be judged as a part of the audit (or assessment).
Having policies in place is just one step. These policies and your environmental compliance obligations should be reviewed:
- annually or
- anytime there are changes with
- your operations (such as dangerous goods handling, moving, renovations, or adding a new site)
Why do I need to develop a compliance action plan?
This plan is important as it gives guidance to your organisation and your team, so they can effect any changes and/or improvements. This action plan should detail the activities, resources and budgeting required for you to achieve pre-audit environmental compliance. The action plan can then be used as part of your internal reporting and used during the next review.
How do we develop an action plan?
The compliance planning you undertake will naturally result in an action plan.
First you have to complete an assessment (Step 1 – Assessment) so you have a starting point. Bringing Akuna Services on board will simplify the process by providing guidance and expertise.
Once we understand your needs and requirements the planning begins. Planning involves determining what services, products and policies are involved. We will introduce you to tools and templates that can be used to review and create the compliance plan. For example:
- ISO14001 (updated in 2015) offers a structure and framework for an EMS, which can be adapted for your specific business. There are also other framework tools that can be used to create an action plan or EMS.
- AS/NZS4801, or ISO9001 offer a framework for the development of your action plan or EMS, and these frameworks can be used by any business – regardless of size or operation.
If you are an SME, you may not have a full operations manual, let alone an EMS. You still need to have a compliance action plan.
The development of an EMS, or environmental compliance action plan, needs the buy-in of all people involved, particularly management. Without the commitment of management, the plan risks failure, as staff whose responsibility it is to administer the plan will have little or no backup (procedural or financial).
In consultation with you we work out the timing and human resources required for implementation to ensure compliance.
What are the main areas addressed during compliance planning?
Reviewing your sites’ risk mitigation products, systems and services are important parts of the action plan. Indeed, the plan itself will include an assessment, review and continual improvement process through consultation, feedback and performance review. Overall, the compliance plan will:
- Be comprehensive, systematic, planned and documented (there may be goals set in the plan).
- Be achievable for your operation.
- Be created in consultation with all relevant staff or people and management.
- Always be tailored for your operation and your site, regardless of size or the framework under which it was created.
- List the identified hazards and associated risks for a site, then propose methods, products and systems to mitigate those risks.
- Help understand legislative requirements for the business to be compliant.
- Have the commitment of management and allocation of accountability and responsibilities for the plans’ instigation.
- Have an amount set aside in the annual budgets.
- Be the subject of regular staff training.
- Be subject to ongoing and regular monitoring, review, correction and continual improvement.
What financial impacts should I consider?
An important facet for the success of a plan is budgetary. Achieving environmental compliance will cost money. It can be easy to estimate the use of outside resources and products, but don’t forget to account for the time your team will spend planning, participating in activities, collaborating and undergoing training. These are all legitimate and necessary components of environmental compliance.
If your operation has an ongoing plan for environmental compliance, where small, regular actions and monitoring are a part of normal operations, then demand on your resources will be spread across a longer time period.
Waiting for an audit (or worse, an incident) to trigger implementing an action plan will cause much greater strain on your resources and have a greater impact on your day to day operations. This can, in turn, impact cash flow and staff morale, both of which are important to business continuity and success. It can be a spiral, where the cheapest option is the most attractive to lessen the cash flow burden. Being in a desperate and reactive situation does not often get you the best results. Action planning will save you money in the long run!
What do I do after creating the action plan?
After generating your action plan, you will be able to use it as a task list. The major areas to be addressed next:
- updating policies and procedures
- purchasing and installing compliance products to protect the environment and facilitate response needs
- staff training
- scheduling ongoing services, inspections and maintenance to remain compliant
We’ll address these and related subjects in Steps 3-5 of the Compliance Cycle.