Question

You accepted a job Eastern Regional Distribution Center (ERDC) in Nashville, Tennessee. You have taken on a completely new set of responsibilities, as an environmental, health, and safety (EH&S) manager of the entire ERDC. On your first day, the new boss, the director of environmental, health, and safety (EH&S) operations, makes it quite clear that a significant part of your new role is to “get a handle” on the compliance issues facing the facility. In short, you must identify the EH&S requirements of the various regulations, then put the proper plans and procedures into effect without interfering with the facility’s day-to-day operations. The director also shows you several filing cabinets full of records and miscellaneous reference materials collected by the previous manager. Clearly, this will be a multi-task process. You decide that her first task is to review the existing files.   Your review of recent notices of violation (which provide citations of the laws and regulations broken) makes you realize that a multitude of regulations applies to the ERDC’s operations. To get more information that is specific on actions needed to ensure compliance, it appears you will have to plow through volumes of information contained in the regulations.

As your next task, you make plans to learn all facets of the ERDC’s operations as they relate to EH&S by taking a walking tour around the facility. You plans to group all of her findings into EH&S related categories, so you can design an action plan that makes sense. The tasks seem overwhelming, and it is clear your new boss expects results right away. During the tour in the areas of the ERDC that received the Notices of Violation for improper hazardous waste storage and citations from OSHA for forklift training after a serious incident involving an employee. You also notice elevated work hazards, machinery being worked on with no energy control procedures, and exposure to physical and chemical hazards (gasoline, diesel fuel, and welding fumes). No safety training or occupational health training completed in two (2) years.

The facility has 150 employees working five days a week (24 hours during the week) with occasional weekend overtime. The facility has distribution specialist (60), maintenance personnel (25), Mechanics (10), Truck drivers (35), and fifteen (15) staff/office personnel.

Detail in at least 750 words (APA format) the compliance plan of action with milestones (POAM). Compliance can best be achieved by thinking ahead and developing an organized compliance program, rather than reacting to each problem on a case-by-case basis after it occurs. Your compliance program should have:

• Current requirements that apply to your facility

• Decisions with management of changes requirements on what changes you will make to your facility or activities, as needed to comply with environmental regulations

• Procedures to get required permits and take required actions;

• Emergency Action Plan (EAP)

• Training program to make sure that everyone with compliance responsibilities knows what to dop each program, priority, auditing, training, budgets, equipment, etc needed.

Staffing is one (1) EHS professional, one (1) EHS trainer, and three (3) technicians (COSS – Certified Occupational Safety Specialists)). POAM Should include 30 day, 90 day, 120 day, 180 day, 270 day, and 360 day checklists).  

Answer 1

Solution:

COMPLIANCE ACTION PLAN WITH MILESTONE

Division: Environmental, Health, and Safety Divison

Compiled by: (EH&S) manager of ERDC

Date Published: 07/11/2019

Action Plan Subject: To address all the issues which have come up in the past  2 years and ready action plans for it.

Action Plan Objective and milestone : To give an world class environment health and safety facilities to the people of  Nashville, Tennessee.

In the coming year  we have to maximise our working strategy so that we can go step by step in order to achieve our goals .In order to complete the goals the primary recquirements from all of you is that we should remember that people's health and safety responsibilities are in our hand as a responsible government officials the first thing to change is our attitude towards our work.

• In the coming days each and every employee will be given specific work which needs to be done within a span of time .
• Progress will be checked regularly by the proper authorities.

Based on the current issues it is seen that some urgent environmental regulations changes needs to be :

• Working conditions of machinery and hazard control mechanisms will be updated according to the recent technologies.
• Also waste storage and waste collection techniques will be updated in such a way that types of waste will be divided according to the type of wastes also surroundings to the storage area will be checked if in near future these will there be any difficulties due to the storage and also keeping a check on the storage area itself.

Procedures to get required permits and take required actions will be :

• All the distribution specialist , maintenance personnel , Mechanics , Truck drivers , and   staff/office personnel will take the permission for  any type of requirements from the staff members .
• Staff members have to submit a daily report of all the requirements being granted along with all the necessary documents regularly to the (EH&S) manager.
• A specific form will be available at the office for the permissions.
• These forms will be kept in a proper and safe way for future refrences.

Emergency action plan:

• In case of emergencies all the  distribution specialist , maintenance personnel , Mechanics , Truck drivers , and   staff/office personnel directly report to the (EH&S) manager for the permission and required actions.
• Emergency meetings will be held and accordingly actions will be taken.
• Also if required only in particular cases of emergency the staff personnels can take the recquired actions on an urgent basis.

Training programs

All the staff personnels and workers have to take training programs very seriously regular reports and introspection will be done by the   (EH&S) manager.

Experts in all the fields will be called so that the employees are uptodate with the recent updates and

program, priority, auditing, training, budgets, equipments these will be the primary areas which will be touched in these programs. After all the training programs some basic interviews will be taken if recquired so that these are done according to the recqiurements to check the output of these training programs.

Checklists:

Coming 30 days:

All the urgent and important complaints needs to be addresed within these 30 days.

Coordination is an important key which needs to be developed between all the departments in these 30 days development of coordination within all the departments so that the work is done in a smooth manner is the primary objectives in the coming 30 days.

Also the citations from OSHA for forklift training after a serious incident to the  employee needs to be seen on an urgent basis.

Coming 90 days:

Summary of all the work done during these 90 days will be accumalated and an deep analysis will be done of all the shortcomings .

All the recquirements which will be recquired in the next 30 days are need to be send to the    (EH&S) manager.

Coming 120 days:

Whether the recquirements of these 120 days are met or not.

Coming 180 days:

An half yearly budget will be proposed for the coming 180 days and deparment wise meeting will be held with the  (EH&S) manager .

Also all the casulaities if were done in these 180 days will be addresesed .

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