MOVEMENT 2. The client’s EMS Summaries I & II and Regulatory Calendar with Compliance Deadlines. It’s often been said,
“I’d just like someone to provide me with a list of all the laws, help me understand the regulations in plain English, inform me of those requiring compliance of my company, then embark upon a mission of putting my company in compliance!”
Movements 1 and 2 position the client to make wise business decisions about his regulatory compliance matters. In fact, decisions regarding regulatory compliance happen to be the top two- or-three most important decisions a senior manager makes on an annual basis, especially when his Regulatory Compliance Agenda – thus his Compliance Action Plan – indicates a status of non-compliance on one or more EHS laws. Since setting priorities, implementing decisions, and meeting compliance deadlines are just as important as knowing the disposition of your company’s Regulatory Compliance Agenda, an important component of Vanguard’s service to the client is that of performing a regulatory review (annually, or as needed) with the client’s various stakeholders. This would include Sr. Management, the EHS Manager(s), Quality Assurance Manager (due to his role with ISO certifications, and all personnel associated with a client’s risk management planning.
The centerpiece of the client’s Environmental Management System is best illuminated through EMS Summaries I & II. These summaries yield fact-based revelations on how the client’s company stands against 60+ laws and regulations imposed upon it by the government. The client’s facility data has been screened against the Government’s regulatory benchmarks to reveal compliance gaps, or simply to eliminate such regulations that might otherwise become a part of the client Compliance Action Plan. These revelations can best be described as Evidence-Based Compliance. With exactitude, it provides any inspector with the kind of Defensible Documentation to undergo the most rigorous of enforcement inspections. Since Vanguard serves hundreds of clients throughout North America, our compliance projects have been the object of dozens of inspections. Inspectors know Vanguard’s reputation for precision due diligence, reporting/permitting mastery, chemical accounting and the Defensible Documentation (evidence-based data) to support the client’s compliance programs for what’s required, as well as why certain compliance requirements are not applicable to the client’s facility. Though an inspection can present some tense moments for almost anyone, an inspection for a Vanguard client is a veritable “coffee break” for the client’s facility designee. Moreover, Vanguard makes every effort to be available for the purpose of technical representative in person, or by teleconference, if the time and nature of the inspection is announced in advance.
An important tool within this movement is Vanguard’s exhaustive Regulatory Calendar with Compliance Deadlines. Whether for the U.S. or Canada, the client’s EMS is set to federal deadlines for each month throughout the calendar, or state/provincial deadlines applicable to companies within those jurisdictions.