MARCH – DECEMBER
At this time of year, the best compliance teams are starting to think about how data is being collected, how changes are documented, and what documents need updated.
Questions to Ask Yourself & Your Team
For leading and fast-growth EHS teams, Tier II reporting is a year-wide project. As early as August, teams are starting to look at their purchasing information and chemical inventory to review updates needed for reporting requirements such as updating facility contacts or SDSs, adjusting reporting thresholds, or whether regulatory laws have changed.
Staying vigilant during the data management process leads to increased foresight that helps EHS teams make better decisions leading up to Tier II season. Here is a comprehensive list of compliance tasks to guide you during the data management phase.
EVERGREEN TASKS (IMPORTANT EVERY MONTH)
By gathering their facility data and verifying state-specific requirements with the help of regulatory compliance experts, Bunzl was able to gain full view into their compliance process, determining reporting thresholds at each facility and when facility contact and product details need to be updated.
Madison, our Compliance Program Manager, previously worked with a larger manufacturing company that worked with their LEPC to host a large-scale exercise at the facility. This exercise allowed for local responders to have better response information and get a better understanding of where things were located at the facility. Within a couple years the facility did have a real-world incident and the first responders were able to use the insight they had from the exercise to reduce damage to the building and make sure that there were no injuries from the release.
Point of Interest
Pennsylvania passwords expire every 60 days and require facilities to login within 6 months of a password expiration or the account will be revoked.
“The best advice I can give an EHS manager is to look at Tier II as a year-wide project instead of just a Jan-Mar project. If Tier II data becomes outdated, it can be more harmful than helpful, so updating the data throughout the year helps keep this from happening.”
Madison Martin – Compliance Program Manager