Make Sure Your EHS Recordkeeping is "Turnover-Proof"
It happens all the time... an inspector from EPA or OSHA goes to a facility and asks for copies of required documentation and compliance records.
What happens if you are new to your position and are asked to produce those documents?
You're certain that the previous EHS Manager kept them ‘somewhere’, but you don’t know where. You fumble around at an unfamiliar desk, rifle through a couple of file cabinets, and frantically click files in your company’s shared hard drive. While you are doing that, the regulator is getting annoyed, looking around, and thinking of other questions he or she is now going to ask you.
If the information had been readily available, you could have had them out the door already but, instead, you’re scrambling to locate anyone who might know where the information is stored.
As the economy continues to return to normal and a demand for higher wages increases in many sectors, employee turnover has become one of the biggest issues manufacturing companies must address. It isn’t only hourly employees leaving for greener pastures. EHS personnel are finding new opportunities as well.
So, what happens when they leave and take all their knowledge with them?
Develop a Team to Manage EHS Recordkeeping
EHS recordkeeping requirements don’t stop just because you lose the expertise you’ve come to depend on. If your facility is still operating, you must continue to keep records as required by federal, state, and local regulations. One of the issues that I run into as an onsite environmental auditor is facility personnel not knowing where the records are kept. When longtime EHS personnel leave, many times you don’t know what you don’t know. So, you don’t know what to ask. In other words, when that employee is gone, so are years of institutional knowledge about who submits Tier II reports, who collects used oil bills of lading, who completes stormwater sampling, etc.
One way to prevent this is to create an internal storage system controlled by one person but accessible by many. Have your EHS Manager train two or three people on how to access information in your system. Have those two or three people assess the system and make changes based on their suggestions. One person controlling a recordkeeping system will almost always lead to confusion when someone else tries to use it. Use plain language in file descriptions and group things by media (air, water, hazardous waste, SDSs, HazCom, etc.) and by year.
Have your IT team create a file structure to store those records that is accessible by authorized personnel and regularly backed up to prevent file loss. Make sure that everyone who receives documents (EHS, purchasing, maintenance, quality) knows where those documents are stored. You could even use an outside vendor like Cornerstone and our electronic file cabinet system to help you maintain your documentation. Whatever method you choose to manage this information, ensure it is secure, regularly backed up and that multiple people understand how to access the system.
Turnover is inevitable but you don’t have to be caught scrambling when it happens. Plan for the future by creating redundancy and putting in place a system that can be handed down to the next person.
