Compliance Planning Environmental Compliance September 30, 2024 David Rieser
Summary Purpose Process Components Implementation
Purpose Organize Planning Process Identify Resources/Gaps Decide Accountability
Process Key questions to ask before starting Why is the organization adopting a compliance plan? Are there resources to develop and implement the plan? Is there stakeholder buy-in? Is it built to last?
Process Identify requirements Laws Regulations Permits What permits are necessary Process, timeline for obtaining What plans do the permits require
Process Identify team Leaders Areas of responsibility Lines of command Specialists Consultants
Process Create plan Prepare segments Meet Consolidate Review Finalize
Process Integrate Environmental Management System (“EMS”) Methods to organize and implement a compliance plan ISO 14000.2015 is gold standard PDCA approach Plan – Establish objectives and processes Do – Implement the process Check – Measure and monitor and report the results Act – Improve the EMS based on the results
Process EMS Planning process to identify regulatory tasks and responsibility for compliance Implement process Monitor and record the implementation Data management system Meetings to discuss Constant improvement
Components Statement of Purpose Why are we doing this? Outline scope of plan Leadership Who is in charge Who has responsibility for what tasks
Components EMS Communication Data management Meetings
Components Additional Plans Training Communications Government Community response Spill reporting Emergency response Media specific plans Air emissions Water discharge Waste management
Components QA/QC Plan for sampling Reporting Non-compliance reporting What will be reported to the leadership group What will be reported to management Accountability How will accountability be allocated Benefits – Bonuses, raises, promotions Demerits – write-ups, employee improvement plans
Tappan Zee Hudson River Crossing Project Environmental Compliance Plan
Tappan Zee Bridge Permitting and Environmental Compliance Environmental Compliance Team Organization Compliance Tracking and Reporting Environmental Plans Environmental Performance Commitments