Are you Moving the Needle on EHS Compliance?
In light of complex, ever-changing rules, proactively managing the risk of noncompliance with environmental, health, and safety (EHS) requirements is an enormous challenge. Human error and challenges with properly functioning equipment and control devices add to the challenge.
Penalties can be exceedingly high. For example, the US EPA has considered raising hazardous waste violations (per day/per violation) to $70,000. The state of California recently passed a law raising its penalties to this level for violations of the California Hazardous Waste Control Law.
In your role as in-house counsel, you are the person charged with managing this risk. I suspect you are always in search of ways to shrink the compliance target for your company.
As you no doubt know, root causes underlying EHS violations include lack of awareness of requirements and improper delegation of these duties within the enterprise.
In my experience, here are three of the most productive strategies for moving the needle on compliance performance:
Meaningful Training: “Check-the-box” trainings, even if required by law, often fail to convey the importance of HOW TO comply with EHS obligations;
Useful Procedures: addressing the “who, what, when, and how” of obligations to be accomplished throughout the year; and
EHS Legal Registry: Listing all potentially applicable EHS regulatory requirements including confirmation of exempt operations and activities.
These are the top strategies that I most often see; however, each company is different. So, I’d like to offer you a complementary one-hour EHS compliance strategy session designed to help you figure out what’s right for your company.
During our call, we will:
Do a high-level review of your potential EHS risk
Identify the highest risks that face your company
Zero in on at least one strategic priority that can help close the compliance risk
As a thank you for scheduling this session, you will receive a 50% discount of my new book (California Environmental Law and Policy: A Practical Guide), retail value $130. As you may know, this is the only book that covers the entire field of California environmental, land use, and natural resources law in a concise, user-friendly format.
To schedule an environmental compliance strategy session, please email me at glucks@baylawgroupllp.com.
Best regards,
Gary Lucks JD CPEA