The ongoing process of comparing requirements to 1) records of past activities or conditions or 2) current observations.
Compliance assurance often involves executing what is described as a “compliance check”. Deciding what to check and how to check it is typically best determined through the development of of a risk-based compliance assurance strategy. Your strategy can be simple!
An ongoing (or periodic) check method can be designed that combines the backward-looking approach of a compliance audit with the periodicity of a task management process. Checks can be assigned to someone other than the task performer, resulting in a check-and-balance system.
Checks should be developed by taking the time to specifically describe the records and documentation that should be checked, and exactly how to check them against the requirements – this is key! Written effectively, a senior environmental auditor is not needed to conduct the checks. Instead, almost anyone familiar with the equipment could do so.
- “Secrets to Meaningful, Sustainable and Efficient Regulatory Task Development for Compliance Certification,” NPRA, 2006, Savage, Alan; McGuire, Lynn, and Beath, John.
- “Use Periodic Checks to Demonstrate Title V Compliance,” CEP, February 2004, Beath, J.M., and McCarthy, C.J.
- “Practical Methodology for Addressing Ongoing Title V Compliance Certification – A Refinery Case Study,” NPRA, 2002, Beath, J.M., Stern, P.C.
- “Rightsize Your Environmental Management System,” CEP, May 2001, Beath, J.M.