Edward Ballo uses the input of stakeholders, a compliance calendar, a site assessment tool, risk assessments, technology reviews, personnel capability analysis (RACIX), A3s, history, regulatory requirements, scheduling and funding to ensure zero citations. Priority is given to the biggest compliance risks and a project and communication plan is generated for the stakeholders to work with for implementation of the plan.
It has always been Edward’s philosophy to work closely with the regulators and grow a trusting relationship with them. An example of compliance recovery included a Title V program risk, such as a site that Edward was leading was tasked with having a volatile organic compound (VOC) tracking program per the regulations. At the time of his arrival, there wasn’t a tracking program that was considered robust enough to satisfy the regulators. The first step taken was to form a team that included subject matter experts, site leadership and corporate personnel. The project was broken down into scope, schedule and cost components.
Through proper communication with the stakeholders, resources and approval was given to the project, and the team began its work. A corrective action was entered into the system and it was tracked at the highest level of the company. Twice monthly meetings with stakeholders were held to ensure adequate progress was being made. Major aspects of this project included purchasing scales, providing crib space for all the associated accouterments, the generation and linkage of a VOC software tracking system and training of all the associated stakeholders. Audits and continuous improvement efforts were conducted both ad hoc and as scheduled. Continuous improvement tools that were used included a project charter, SIPOC, Process mapping, FMEA, rolling action item lists and A3s. Project management tools included Gantt charts and budgets.
Shortly after the project was completed an unannounced air inspection took place, by the regulators, and there were no finding issued to the site, so it was a great success story.
Contact Edward Ballo with e3s Consulting for your company’s compliance recovery needs.