VelocityEHS recently hosted the webinar “Regulatory Recap & Ways to Stay Compliant Using an ISO Approach to EHS Management,” presented by VelocityEHS Senior EHS & ESG Content Manager Greg Duncan, MELP, CSP and STP ComplianceEHS Director of Partnerships Shannon Major, BES(Hons), EP (CEA). Key themes and highlights from the discussion included:
- Core elements of management system standards like ISO 45001 and 14001, and their benefits and collective function in maintaining compliance.
- Recent changes to some of the most broadly applicable EHS regulations and what upcoming changes employers can expect, including:
- New requirements for chemical manufacturers, suppliers, and employer end-users under the 2024 OSHA Hazard Communication Standard (HazCom) Final Rule
- New and updated 2024 reporting requirements under EPA EPCRA 313 Toxics Release Inventory (TRI)
- New employer classifications and reporting requirements under OSHA’s 2024 Injury and Illness Recordkeeping Final Rule
- New and modified requirements within the 2024 EPA Risk Management Program (RMP) Rule
- Steps and best practices you can take today to improve your own EHS management systems and strengthen compliance.
What are the Relevant Elements of Management System Standards?
International management system standards, namely the ISO 45001 Occupational Health and safety (OH&S) Management and ISO 14001 Environmental Management standards, are largely rooted in helping organizations to not only achieve compliance, but to provide agility and adaptability in the face of changing regulatory requirements.
ISO 14001
An Environmental Management System (EMS) designed to help organizations improve their environmental performance through more efficient use of resources and reduction of waste, gaining a competitive advantage and the trust of stakeholders.
ISO 45001
An Occupational Health and Safety Management System (OHSMS) that offers a single, clear framework for all organizations wishing to improve their OH&S performance. Directed at the top management of an organization, it aims to provide a safe and healthy workplace for employees and visitors.
In addition to laying the groundwork for building a safer and more sustainable business, ISO management system standards such 14001 and 45001 provide numerous advantages for organizations that commit to aligning to their guidance. For one, all ISO standards are built around a common framework that allows for integration of multiple management system standards within a unified structure. This greatly simplifies alignment and provides a consistent management system structure across the full range of ISO standards. In addition, all ISO standards are also rooted in the common underlying principle of risk management, meaning that organizations that implement ISO 45001 and/or ISO 14001 are provided with a systematic process to move their EHS programs from a more reactive, compliance-focused approach toward one that is more proactive and adaptable to changing requirements. Lastly, ISO management standards such as ISO standards 45001 or 14001 are voluntary, heavily focused on both “top-down” management involvement and “bottom-up” worker engagement, and involve taking a proactive, systematic approach toward reducing risk—meaning when companies choose to align or certify to them, it visibly demonstrates an organization’s genuine dedication to EHS management and continuous improvement.
What EHS Regulations are Changing?
Recent changes to EHS regulations not only present challenges for EHS professionals tasked with compliance but are a blaring signal of future directives and priorities for environmental and OH&S regulators. Here are some highlights from the big regulatory changes discussed during the session:
OSHA Hazard Communication (HazCom) Updates
OSHA’s 2024 Hazard Communication Standard (HazCom) Final Rule introduces new hazard classes and categories, GHS pictogram requirements, container labeling requirements, and multiple SDS information changes. In total, according to OSHA, 94.4% of SDSs and 64% of labels (non-small/very small) will need to be revised.
EPA EPCRA 313 (TRI/Form R) Reporting
2024 updates to EPA’s EPCRA 313 TRI reporting requirements include newly added chemicals to the TRI 313 list, most notably Per- and Polyfluoroalkyl substances (PFAS), as well as several updates to the TRI-ME Web online reporting portal.
OSHA Injury and Illness Record Keeping Final Rule
The 2023 updates to OSHA’s Injury and Illness Recordkeeping Rule revises the reporting requirements and applicability criteria for employers covered under the rule. It also expands electronic reporting requirements to include Form 300 and 301 injury and illness data, and the publication of these injury records.
EPA Risk Management Program (RMP) Rule
EPA’s 2024 updates to RMP requirements include Safter Technology and Alternatives Analysis (STAA) for Program 3 facilities to conduct practicality assessments for safter technologies. Updates also include new requirements for all RMP covered facilities to formally assess natural and adjacent hazards, implement prescribed methodologies for incident root cause analysis, assess need and feasibility of backup power systems for monitoring and control equipment, and submit to 3rd-party audits in the event of most hazardous chemical releases.
What can you do to Improve your Management System?
In light of these significant regulatory changes on top of existing compliance obligations, EHS professionals are likely asking how they’re going to get ahead of their requirements. To address this most pressing question the presenters discussed several best practices and strategies EHS professionals can apply to help strengthen their compliance management processes and overall EHS management systems in line with ISO 14001 and 45001 management system standards, including:
- Nurture stakeholder engagement and involvement in ISO management system planning, implementation, review, and improvement processes.
- Leverage the capabilities of EHS software and regulatory content providers like STP ComplianceEHS in management system scoping and planning processes (and throughout the EHS program management process) to strengthen applicability analysis and ensure comprehensive recognition and completion of compliance requirements.
- Recognize that when knowledge and expertise in EHS compliance resides within individuals, the business can easily be disrupted if those individuals leave the organization. Prioritize both business continuity and resilience when implementing compliance management systems and strategies.
- Give special emphasis and sufficient consideration to Management of Change (MOC) processes as you adapt your EHS management system to changing risks and regulatory requirements. Ensure all affected stakeholders are involved in MOC processes and promoting visibility and accountability for successful change implementation. Review and improve MOC processes often!
- Implement systems that translate written compliance requirements into concrete compliance actions to promote high levels of accountability and ownership for compliance, and to better track compliance status.
- Recognize how EHS management functions, including compliance management, map onto the Continuous Improvement Process, and where tools and technologies can be implemented to simplify and enhance those EHS management functions.
Want to learn more? Watch the full webinar on demand.
VelocityEHS and Partner STP Can Help!
Velocity’s Chemical Management and Safety software make it easy for you to maintain compliance with a wide range of EHS regulations, including OSHA HazCom, OSHA Injury and Illness Recordkeeping, EPA EPCRA TRI reporting and many more. You get intuitive tools that let you and your employees manage your chemical inventory and SDS library from anywhere 24/7, along with other core safety tasks including safety meetings, incident investigations, and corrective actions. You also get powerful Audit and Inspection capabilities which, when combined with STP ComplianceEHS AuditHub regulatory content integration, give you pre-built, auto-updated and customizable compliance checklists to simplify compliance and help you stay ahead of an ever-changing regulatory landscape.
Contact us today to learn how VelocityEHS and STP ComplianceEHS can help you!