Professional Working Groups Impacts and Participation
Participation in professional working groups, associations and societies is also a great way to stay current on regulatory issues. There are countless professional organizations that are focused on environmental topics, including hazardous waste, storm water, wastewater, air pollution and environmental sustainability, to name just a few. Many of these groups are not only focused on specific areas of regulatory interest but also promote training, education and certifications. These groups of environmental professionals can contribute greatly to the regulatory process by sharing specialized expertise, direct relevant experience and industry lessons learned with regulatory agency personnel and lawmakers at the federal, state and local levels. The process the EPA must follow when proposing and promulgating new regulations and changes to existing regulations requires that opportunities for public participation be provided (US EPA 2018). At the federal level, public participation mechanisms include publication in the Federal Register for public comment, EPA public affairs publications and brochures, agency websites and public meetings or workshops. Because they do represent a collection of highly knowledgeable personnel and significant cumulative experience, professional working groups can impart a significant amount of valuable input to the regulatory agencies. Regulatory agencies often consider these professional groups as essential resources for the regulatory rulemaking process. When professional working groups are successful at establishing a constructive working relationship with regulatory agencies, their input is often solicited giving them the opportunities to positively influence the regulatory language and content. Professional environmental groups and organizations are quite often very actively involved with state, county and municipal regulatory agencies and the respective rulemaking decision processes. Participation in these types of professional environmental organizations can be of great benefit to individuals as they offer great opportunities for professional growth and networking. These professional groups can also be beneficial to the companies that have employees who are participating members by providing access to a collection of knowledgeable experts and resources that can provide up-to-date information, including regulations, technology, lessons learned, industry trends and professional contacts.
Conveying Legislative Changes
Tracking proposed legislation and legislative changes that are related to environmental regulations can afford companies the opportunity to begin formulating changes in implementation strategies that may be necessitated by an upcoming new or revised regulation. As previously discussed, this could be legislative changes that are being proposed at the federal, state or local levels. Conveying proposed legislative changes as early as possible to relevant managers and stakeholders will allow the opportunity for companies to assess the potential impacts relative to resource needs, operational changes, operating costs, etc. Communicating proposed legislation as soon as the information is available and then providing periodic updates to managers and stakeholders will enable the company to adjust initial implementation strategies as the proposed legislation or regulation undergoes revision as it progresses through the legislative process. This can be a very beneficial planning tool that can forecast potential increases in cost and resource commitments as well as compliance obligations.
A graded approach can be applied when assessing proposed legislative changes in that those changes which pose potentially significant impacts to a company can be monitored more closely with an increased focus on preparatory actions. Initial preparatory actions could include participating in the review and comment of proposed legislation or regulation if opportunities for public comments exist. A good approach that can be applied here is to obtain input from relevant stakeholders within the company and provide a consolidated set of comments to the agency or legislative body sponsoring the legislation. As discussed above, this is also a great opportunity to take advantage of professional working groups that may have direct involvement with the regulatory agency or legislative body. In addition to public participation actions, other preparatory actions that can be taken related to implementation planning include:
- 1. Developing initial implementation strategies, phases and timelines
- 2. Establishing roles and responsibilities
- 3. Evaluating personnel resource needs
- 4. Evaluating cost impacts and budgetary needs
- 5. Assessing operational changes
- 6. Identifying company procedures and/or documents that may be needed
This is not intended to be an exhaustive list, but provides some examples of the types of actions that can be taken in advance when legislative changes and proposed regulations are identified early in the process and properly conveyed to company managers and stakeholders.
Review the case study and respond to the questions that follow.
8.5.1 Case Study
As the new operations manager for Company ABC, you have been made responsible for developing a system for identifying and tracking all of the requirements that the company must comply with. In your role as operations manager, you oversee and direct the operations of the company. The organizational departments that report directly to your position include environmental compliance, health and safety, transportation, manufacturing and finance. Describe your approach for each of the following:
- 1. How would you assign roles for tracking requirements?
- 2. What responsibilities would be associated w'ith these roles?
- 3. How would you propose to keep track of applicable requirements?
- 4. How would you track procedures or other documents used to implement requirements?
- 5. List the information that you think would be important to capture in your system for managing requirements.
U.S. Government Publishing Office. (2019). Federal register. Govinfo, February 11. Accessed March 23. 2020 from HYPERLINK "http://www.govinfo.gov/help/fr" www.govinfo. gov/help/fr.
US EPA. (2018). Laws and regulations. US EPA, November 26. Accessed March 26, 2020 from https://www.epa.gov/laws-regulations/get-involved-epa-regulations.