What to believe about certain new age terms bandied about these days?

“Sustainability”… “Green”… Our culture has a longstanding romance with sound-bytes. Cynically, one might say that the bamboo floor installed in your HQ doesn’t really make your business green or sustainable. Bamboo floors do look nice, but it feels like a bit of “correlation-stretch” to assume that bamboo use in construction will save the planet’s rain forests.

More tangible is BMW’s announcement several years ago that their driving machines would be 95% recyclable by 2015. Today, there’s a good chance that most of your new BMW used to be an old BMW. The “recyclable car”, a sound-byte starting to feel a little more “sustainable”…

Whether driven by thoughtful science, radical activists, slick marketers, or good intentions of the citizenry most societies have chosen to regulate business activities toward a more sustainable future. And just like safety and health earlier, it’s important to get it right.

Stated purely, regulation is the imposition of societal wishes on business activity. You may rest assured; it does not pay to be a “regulatory denier”. At a minimum it makes the cost of operating far too expensive in monetary terms or even worse: revocation of the license to operate.

Now more than ever, it is important to get regulatory compliance right as certain agencies entrusted to bring societal wishes to fruition are behaving more like radical activists. Just pick up any Mining Industry magazine or a recent copy of Oil & Gas Journal and read the editorials. The O&GJ has recently suggested that the Federal EPA has outlived its usefulness. There is much evidence of frustration amongst those being “regulated”. Sound-bytes are not the solution.

We work with mining and hydrocarbon producers to improve their performance. Of late, we have received more and more queries regarding regulatory compliance. A fair number are pointed questions about how we train organizations on regulatory compliance. We do that, but not in the way that most folks are asking the question. Why? Because we believe that it’s more important to manage compliance versus train on it. We also believe training alone will often deliver sound-bytes, concepts, and slogans while often leaving the necessary results at risk.

Here is how Certitude approaches this topic with our clients:

  •  Compliance must be integrated with production: We approach health, safety, and environmental regulatory compliance as a component of overall process integrity. Operations are too complex for businesses to entrust compliance activities to a specialized function. It must be part of “what we do” for every manager, supervisor, and operator. Experience has taught us that failure to connect compliance with each employee’s daily work greatly increases the risk of failure in meeting the requirements. Functional excellence in this approach is still very important but more so in the context of keeping the compliance “hooks” in the business process evergreen based on the ever-changing regulatory landscape.
  • Rigor in real-time: Ultimately, it’s really all about the details and timely execution. As part of process integrity, controls and reporting must be rigorously managed and executed timely. We were in a mining operation a few years ago and found that samples of a wastewater stream were required every few hours. The samples were faithfully collected on schedule. Unfortunately, the lab had a rather large testing backlog. The operation had been polluting for over 60 hours by the time the lab tested the samples. Strong citation, damage to reputation, and expensive fine to follow…
  • Accountabilities must be explicit: We deploy a mixture of training workshops and hands-on experiential learning to ensure every individual understands their specific role, tasks, and metrics. This custom package includes operational and compliance requirements. Compliance is described alongside production procedures and other process elements and reporting in the workshop setting. The training element is more like orientation with most of the learning being hands-on with Certitude coaches. Combined with the reinforcing metrics, we have found this approach yields the best levels of overall performance and continuous improvement.

As always, at your service…

If you’d like to see case studies and results go here:  http://www.certitudegroup.com/downloads

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