Elements of Environmental Compliance Demonstration, Considerations for Developing an EMS

摘要

Compliance demonstration has been heightened by the compilation of regulatoryrequirements into air permits and compliance certifications of subsequent periodicreporting requirements of the Clean Air Act Title V Program. To adequately manage andtrack compliance with each specific underlying requirement typically requires thedevelopment of a customized system designed for this purpose in order to assure thatroutine actions will be managed in such a way as to stand the scrutiny of reasonableinquiry as part of the certification process for monitoring, reporting, and recordkeeping.The purpose of this work is to identify and discuss the elements that should be includedin such a management system with insight that evaluates issues for consideration beyondthe mere mechanism for management of the data itself. Such issues would includeassignment options for methods of compliance, responsibility for actions, andimplementation concerns. Additionally, the system development would allow foradaptation of the system to programs for other environmental media. By incorporatingthese elements into an environmental management system as a designed and methodicapproach to compliance, it is concluded that data gaps of necessary subsystems may beidentified proactively in the early stages of systems development and further correctiveactions may be tracked for improved future environmental performance.