ABSTRACT

While regulatory management discourages the rote application of pro forma process, it does encourage and employ formalized procedures where appropriate and practicable. An appropriate starting point for a discussion of internal notification procedures is the mechanism by which the Occupational Safety and Health Administration right-to-know requirements are met. Any activities or operational components that have potential for direct impact on compliance with regulatory mandates or environmental permits should be considered for internal notification procedures. Communication procedures between work groups dependent on one another or relieving one another must be such that all important information is transferred and all actions are coordinated. Checklists are a useful mechanism to guide people through standard procedures. Quality assurance is indispensable to the credibility and defensibility of data and the positions or actions based on them. The internal compliance audit is multipurpose. The final procedural component is a structured program of environmental compliance audits, conducted by the organization itself.