
Jan, the environmental person, just retired, and now you need to wrap your head around the environmental obligations and whether you're in compliance. Are there upcoming due dates, permit renewals, missing paperwork? Fred remembers Jan mentioning that a permit renewal is due soon. Let's get started.

## The File Room

You find yourself in the file room and discover a binder labeled "Environmental," overflowing with papers from the last two decades. Thumbing through it, you find quite a mess: old permit copies, out of date plans, and the last three years of records missing entirely. Maybe Jan's laptop has the latest documents. Let's find out.

## Laptop Search

After an ordeal with IT, you finally get into Jan's laptop to find yet another mess. The desktop is packed with folders galore, but at least there's one called "environmental." Inside you find two more years of files, but the last year is still missing. Thanks, Jan. Time to check the server.

## Server Fun

On the server you find the current permit, discover it expires in ten weeks, and turn up another six months of logs. You also find a note: the production team keeps the latest logs on paper. Time to get the rest.

## Paper Log Collection

You call the site and learn they don't know how to scan and upload to the server, so you drive out and collect the last six months of paper logs yourself. Then you work with the site to fill in the data gaps. That should be everything. Now it's time to start the renewal forms.

## Renewal Madness

You have the current permit, all the logs, and it looks like you're going to file on time. Right?

Except one month is missing. Not misfiled, just never recorded. Nobody can reconstruct it.

Then you review the permit and notice a requirement the logs don't track. Asking around, you discover that the business intelligence department maintains a database with all the production records you need. Jan knew this. She never wrote it down.

Now you request the data, wait on approval, and hope it arrives with time to spare. The data was never lost. Nobody knew it was there.

## The System That Should Have Been There

The lesson from the compliance egg hunt is that having permits and logs isn't enough. Jan had a system. Jan was the system. And it stopped existing the moment she wasn't there.

This happens even at well-run companies. The regulation tells you what to record. It never tells you to write down where you keep it, and no agency inspects you for that. So it often falls to whoever's been there longest, until they leave.

An environmental management system (EMS) is what that looks like on paper. It can be a simple written plan, or an ISO 14001 program running on a commercial platform. No matter the type, it comes down to the same thing: a documented plan that ensures compliance obligations are met, recorded, and monitored, that corrective actions are taken when deficiencies turn up, and that documents are stored in a known, documented location.

The best EMS is the simplest one that works for the staffing available. An EMS only works if somebody maintains it, and that's where it usually breaks down. It's the first thing to slip when everything else is urgent, so if you've had a recent compliance issue, consider whether your EMS needs a review.

We do environmental data engineering for defensible decisions. If you need help reviewing your EMS or auditing your facilities, Calo Consulting can help.


The person who tracked your environmental obligations just retired. Here's what a permit renewal looks like without an environmental management system.

Insights

Get in Touch