21 Management Systems
Management systems are not necessarily a requirement for compliance or required by legislation. But without them it can be a challenge to stay in compliance in a every complicated world. There are many management systems, some are defined in standards like ISO, others are proprietary to large corporations. They may seem unwieldly, but they do not need to be. In this book we are only going to discuss one system that has been around for a long time.
It is the simple Plan-Do-Act-Review cycle. It has also been called the Deming cycle and can trace roots to the scientific method dating back to the 1600s (Deming, 2022). Here we will show it modified for environmental compliance:
Plan
Planning is itself a two step process. The first part is the gap analysis. In the gap analysis an entity looks at where there is a gap between what a law requires and what the entity is doing. IT may also consider just gaps in knowledge. We ask questions like:
- What regulations apply to us?
- Do we collectively understand them?
- Do we follow them?
- Do we have the tools to make compliance?
- Do we have any examples of non-compliance?
With the gap analysis we can then develop a compliance plan. Elements of the plan should include:
- Priorities established for action on improvements
- Responsibilities assigned
- Establish performance measures
- Budgets in place for the improvements needed
- Training
- Supervision expectations
- Timelines for completion of actions
We can illustrate this with an example of a tank of fuel in Alberta on an oil battery. We know that this falls under the AER, and in particularly Directive 055. The directive states for the size of our tank, we need secondary containment and regular inspection. So on inspection, we find the tank does not have secondary containment (gap analysis). The compliance plan then involves budgeting of secondary containment, training of the requirements of Directive 055 and how to inspect needed for the local operator.
Do
The “Do” phase is the implementation phase. This means that the entity completes the compliance plan.
Following on with the example of the tank; the actions needed are engineering and installation of the secondary containment, Training of the operator and regular inspections.
Check
The “Check” phase is to then make sure that the compliance plan has been followed. This may occur periodically or annually depending on the priorities established during the planning. Checks can include some of these concepts:
- Workplace inspections (daily, weekly, monthly, annually as defined by the priority or the legislation)
- Audits – these involve a systematic review by parties who may not be involved in the day to day operations. Sometimes the audit may be undertaken by external parties
- Performance reviews – this considers individual responsibilities to deliver the plan
- Management reviews of documentation
Following on with the example of the tank; an inspection of the tank shows that the secondary containment was put in place. The performance of operator was reviewed and they completed the inspections. But they had not been trained yet and the records were not consistent.
Act
Based on the information gained from the “Check” phase, the entity must act to correct the deficiencies. Following on with the example of the tank; the deficiency noted was that the operator had not been trained. Management needs to ensure the operator gets the training.
Section Conclusion
On completion of the actions after the review, the process will start again with another planning cycle. This system is just an example of a compliance management system. There are many ways to do compliance systems with more steps, but rarely fewer steps. Much of a system is going to be defined by the type of operation and jurisdiction. But some form of plan-do-check-act is essential to achieving consistent compliance.
Learning Question
- If you were the operator what could you do to ensure that you could do to stay in compliance?
- If you were the operators supervisor?
- If you were the Management?
References
The Deming Institute. (2022). Home page. Retrieved from https://deming.org/explore/pdsa/
