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Re: Incentives for "Beyond Compliance"



A couple of thoughts for you:

1)  Under "criteria" you may wish to add a requirement for facilities to
report areas of non-compliance, when they occur, their fix of the problem
and/or their time frame for correcting the problem.  (This MAY be minor if
the facility has a good EMS and good people working for them...remember even
the best EMS may not insure compliance with every regulation, there are just
too many regulations.)

Along similar lines you may want to consider how a facility, once adopted
into the program, will be handled by the program if found to be seriously
out of compliance (even if a correction is in progress by the
facility...some environmental regulations have mandatory penalties).  What I
suggest you avoid creating is a "fair weather friend" situation.

2)  In my opinion "reduced inspections" should not be offered or categorized
as an "incentive".  Inspections can be viewed as an opportunity to validate
the success of the partnering effort, help the facility stay abreast
changing and new regulations, maybe even educate the inspector about good
things being done at the facility that could be applied at another facility
that may not be part of the program.

Some efforts to work together actually seem to create a wider distance
between regulator and facility rather than a closer relationship.  If the
regulator (who should be the primary source of regulatory information)
adopts a "compliance assistance" attitude in working with receptive
facilities, they ought to be inviting the inspector to visit at regular
intervals.  In other words the regulator should be an active part of the
EMS.