By Jennifer Hoisington
Alumna, American Public University
Just as ships can be tossed, battered and disoriented in stormy seas, corporations can be quickly overwhelmed by an ocean of ever-changing regulations governing their operations. In order to stay afloat, businesses must keep track of and comply with all pertinent regulations.
In particular, large organizations that operate across state lines must have a clear understanding of federal, state and even municipal regulations and how they apply in practice.
Creation of the EPA Led to New Environmental Regulations
The 1970s was a decade of new federal environmental regulations, including the creation of the Environmental Protection Agency. Under its authority, Congress passed the Clean Air and Clean Water Acts of 1972 and the Resource Conservation and Recovery Act of 1976 (RCRA). Since then, many new regulations on various related environmental topics have been implemented. But RCRA remains the primary federal law regulating hazardous waste management.
In most cases, the EPA does not directly administer or enforce RCRA legislation. The law itself defers management to the states through a process called “authorization.” Currently all states, except Alaska and Iowa, are authorized to implement and enforce the RCRA. Many other environmental statutes are similarly designed for state implementation. All of these responsibilities add to the complexity of compliance across state lines.
Your Company Can Stay Compliant by Creating a Regulations Library
One way to stay current with the many rules and regulations is for organizations to create an easily accessible library of position statements and regulatory research tools. These documents clearly outline the company’s policies on interpreting and complying with relevant regulations.
Although most industries are subject to complex regulations, waste management is an especially heavily regulated industry. My company, Stericycle Inc., is among the industry leaders in hazardous and medical waste management. Although the company was originally formed to manage regulated medical waste, the organization subsequently expanded into diverse markets, including hazardous waste operations. Through this process we recognized a need to create a repository to stay on top of the ever changing regulations in different jurisdictions.
In response to this need, our Legislative and Regulatory Affairs team undertook to develop both a position statement repository and a regulatory oversight “map” to provide consistent compliance across the organization.
The repository is an online library in which company personnel develop and post a variety of Stericycle position statements. The first categories created for these statements correspond to Stericycle’s primary lines of business: Hazardous Waste, Regulated Medical Waste and Pharmaceuticals. These categories make it easier for employees to find and access the precise position statements they need.
These categories can be expanded and tailored to the specific needs of the company. In fact, the repository includes a request feature that permits users to propose a topic for development. There is also a draft library with limited access for those topics that are still being developed.
The repository is posted on the Stericycle intranet, where it is readily accessible to authorized employees. The system creates a consistent approach to compliance across the company.
Oversight Map Provides Links to Regulatory Questions and Answers
The oversight map that Stericycle created is an online tool that provides short answers to common regulatory questions from employees. It is quite literally a “map” that the user can click on to see the pertinent regulatory information for a particular state. The map provides links to additional regulatory guidance on different topics relative to the management of hazardous and medical wastes and is divided into individual state pages that link to state-specific guidance.
A state-by-state breakdown is crucial for any organization that operates in multiple states and where regulations vary significantly from state to state. Without such clear guidance, it is difficult to navigate and abide by regulations that change as operations cross state lines.
Like the repository, the map is posted on the company intranet and is accessible to employees. As new questions arise, the pages can be updated to incorporate additional state-specific answers. In this way, the map can be expanded to meet the precise needs of the company.
Stericycle employees are the primary audience for both the position statements and the oversight maps. But the most likely employees to use these tools are in-house compliance managers and client account executives who work to ensure both the customer and the company remain compliant with applicable regulations.
For example, client account managers can use the oversight maps to address their customers’ basic regulatory questions. This system eliminates the need to go to the compliance managers with every question. Similarly, when compliance managers are asked to interpret a regulation, they can be sure the interpretation is consistent across the organization.
The team’s challenges of completing the project were primarily related to the regulatory oversight maps. Given the sheer volume of information available, it was imperative to narrow the focus of the information related to each state and the regulations to a manageable size and scope, and be useful to the target audience. Therefore, it was crucial to make sure that the most pertinent topics and issues were selected for inclusion for each state in the maps.
Also, keeping up with ever-changing Internet links is an ongoing challenge for any such research tool. To that end, the project staff included a tool for users to report broken links.
The nature of our form of government creates a sea of ever-changing federal and state legislation and regulations. Any company that hopes to grow and prosper in a heavily regulated industry such as hazardous or medical waste must continually strive for compliance. Position statement repositories and regulatory oversight maps are but two tools to assist companies comply with all applicable regulations.
About the Author
Jennifer Kunz Hoisington holds a B.A. in Theatre Arts from Brigham Young University, and is completing her M.P.A. in Organizational Management with American Public University. Jennifer is a health, safety and compliance professional at Stericycle Inc.
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