ENV-95-171 DEVELOPMENT & IMPLEMENTATION OF THE DOW REGULATORY MANAGEMENT SYSTEM

Description:

Managing regulatory requirements is a major challenge for industry; all industry, but particularly the petrochemical industry. The main causes of deficiencies are: (1) inadequate operating discipline, (2) inconsistent regulatory interpretations, (3) low field-level knowledge of the requirements, and (4) misdirected, incomplete performance measurements. A complete environmental, safety, and health regulatory management system is the best insurance against fines, penalties, and business failures due to performance problems. Managing regulatory requirements in the top companies in the petrochemical industry requires experience, talent and leadership in the personnel who struggle with the day-to-day tasks of disseminating information to field operations personnel for implementation of individual compliance requirements. The same group who must manage day-to-day tasks also are burdened with following regulatory development activities and managing change with regard to capital investments. The Regulatory Management System is a re-engineering solution to managing the day-to-day tasks so that key personnel can provide better and broader over-sight support to: (1) audit system effectiveness, (2) manage issues regarding new regulations and regulatory interpretations, and (3) plan for strategic implementation of regulatory programs. The Regulatory Management System approach moves away from managing compliance requirements on a plant-byplant basis which is redundant, resource intensive and very often hastened in its execution. A comprehensive, practical and systematic approach is the only solution to proactive regulatory compliance management. An information management system is not the answer. A good client-server, easily maintained database has its place in the overall approach, but a detailed performance management system is what is needed. An environmental management system manual is not the answer. A comprehensive, strategic environmental gameplan (a play-book) will serve a key function, but without the execution of the gameplan, nothing about the current resource depletion rate will change. This paper will outline the successful approach taken by The Dow Chemical Company’s Texas Operations facility.