Bridge to International Regulatory Compliance
Vanguard’s Turnkey Compliance Model for Multinational Organizations
There are three points to Vanguard’s “Compliance Model for Multinational Organizations” (i.e., those organizations that conduct business activities around the globe. In a sense, Vanguard has the “combination to the compliance vault.”
- In order to satisfy a client’s environmental compliance challenges in any given nation, you must first know and understand that nation’s environmental compliance regulations. With the advent of the Internet and websites leading to every environmental agency in the world, this is not a difficult requirement, other than gathering in the regulations for the top-50 industrialized nations in the world. Vanguard has already gathered those regulations, which was a major undertaking. Therefore, Vanguard clients already have access to those nations’ environmental regulations as a part of their Environmental Management System (EMS USA!, EMS California!, and EMS Canada!.
- You must then gather up all of a facility’s data pertinent to the requirements of the nation’s environmental regulations having jurisdiction over that facility’s compliance responsibilities. This data would include general business information, the facility’s emergency response information, and such items as product inventories, Safety Data Sheets (SDSs) illuminating the content of chemically-oriented products (liquids, solids, and gases), along with inventory quantity information, container types, and locations of such products in the facility.
- Finally, you must have a technology capable of screening the data gathered from such a facility against the regulatory benchmarks established by its nation’s environmental regulations. Primarily, those benchmarks will be those three elements that Vanguard screens for its clients in the United States, the State of California (this state in the U.S. has 12 laws unique to California, beyond any other state within the U.S.), and Canada. Of course, you must also adhere to other related regulations imposed by state, provincial, tribal, county, and municipal agencies also having jurisdiction of that facility. This is why so many compliance officers believe they’re stuck in the proverbial “regulatory maze.”
Now, please consider the following important rationale regarding a chemical hazard. Take toluene, for example. Toluene is a highly toxic chemical, generally found in paints, solvents, and degreasers. Its physical state is most often found in a liquid form. Toluene is also a teratogen; it causes damage to the fetus of an unborn child, typically resulting in birth defects if the mother was exposed to toluene during pregnancy. There is no doubt why it’s on EPA’s regulated list for Toxic Release Inventory or California’s list of 941 Proposition 65 substances known to cause cancer and/or reproductive harm.
Geography does not change the properties or toxicity or teratogenicity of toluene. So, it’s understandable that any given nation would enact environmental regulations controlling the use and exposures of toluene to human life (i.e., the citizenry the nation is striving to protect against such hazards), notwithstanding the adverse impact on the environment within the geography controlled by the nation.
If you’ve studied the second landing page of this website, titled Environmental Management System, you may recall that 93% of regulatory compliance laws are based on three government benchmarks:
- Chemical hazards;
- Thresholds (typically expressed in lbs. (U.S.) or kilograms (Canada)); and
- Regulatory Mandates, or the rules that govern how an organization’s compliance must be satisfied.
This principle is universal. Therefore, as long as an intellectual property is capable of screening a facility’s data against its nation’s environmental compliance laws, a facility’s compliance responsibilities may be satisfied from anywhere in the world.
By the way, that 93% above...is an important number to remember. It may be slightly different from one country to the next. But, another way of understanding that number is to realize that 100% of a nation’s environmental regulations are built around those three benchmarks above. It’s when you include the other 7% - those issues regarding safety and health hazards – that you must distinguish the 93% from the 7%. You see, most nations combine environmental, health, safety and terrorist prevention laws in one large heap of regulations. Let’s face it, safety and environmental regulations can be far afield from one another. So, that’s where the 93% and the 7% numbers are used to separate them from one another when developing due diligence methodologies and technologies to meet the challenges of their compliance directives.
Vanguard draws from the U.S. Environmental Protection Agency to define sustainability.
Sustainability is based on a simple principle: Everything that we need for our survival and well-being depends, either directly or indirectly, on our natural environment. Sustainability creates and maintains the conditions under which humans and nature can exist in productive harmony, that permit fulfilling the social, economic and other requirements of present and future generations.
Energy Efficiency and Environmental Performance (3EP)
Sustainability and Environmental Stewardship at Vanguard is defined as “the art of turning compliance lemons into management lemonade,” hence Vanguard’s programs that encompass 3EP.
Kermit the Frog was right: it’s not easy being green. But sound environmental strategy can be very rewarding. In fact, environmental strategy goes far beyond the pride of stellar corporate citizenship to “triple bottom-line returns.” Wow! And here is a smattering of companies throughout the U.S. and the world who have proven just that:
- Johnson & Johnson
- Interface Flooring
- Procter & Gamble
- International Paper
- United Technologies
- Menasha Packaging
A cursory review of websites among these companies proves to be search for the “holy grail” of sustainability. These companies have proven that a commitment to environmental performance yields bottom-line profitability.
Launching your company’s own 3EP program is a laudatory commitment, a true reflection of corporate vision. To pursue the bottom-line returns offered through sustainability and environmental stewardship, contact Vanguard for a thought-provoking discussion on how Vanguard’s regulatory compliance programs and resultant strategies can turn your own “compliance lemons into management lemonade.”