The Coronavirus – A Compliance Mindset

As with most organizations around the world, Witt O’Brien’s is concerned with the health of our employees and their families during the Coronavirus pandemic. For the moment we are limiting personnel travel, instituting a work from home policy and began forecasting different company outlooks based upon different variables. We’ve also further strengthened our pandemic and contingency plans and have been regularly corresponding with both vendors and clients regarding their contingency efforts. We know your companies are making similar decisions, all while juggling business continuity, employee well-being and maintaining your company’s regulatory compliance.

As with every organization, our personnel are now inundated by the 24-7 news reports and social media posts solely focused on Coronavirus. This constant feed has undoubtedly raised anxiety levels, contributing to all the stress that already exists during this tumultuous time. Beyond that, personnel are being faced with potential job losses, lock-ins, key essentials being closed, and family members now being stuck at home that may require their care. Globally, we are, for the first time in a very long time, singularly focused.

Within industry, the saying “keep your eyes on the ball” is truly being tested now – as regulatory compliance is being stretched and tested like never before.

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Witt O'Brien's will be hosting Troy Swackhammer, Mark Howard and Chris Perry, EPA Region 6 Spill Prevention Control and Countermeasure (SPCC) Plan and Facility Response Plan (FRP) Coordinator in Houston for an all-day Free SPCC Plan and FRP workshop on June 11th, 2020. Click here to RSVP.

Coronavirus - We are monitoring this closely and have been in discussions with our presenters. If events require event hall to close, we are working on a WEBEX solution. As of today, plans are to continue to move forward, so do not let that stop you from RSVPing.

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As with many of you, I subscribe to numerous agency and industry forums to keep up to date on what’s happening. Within the past week I too have been inundated with countless agencies extending deadlines, loosening requirements, and offering forbearance.

A great article that speaks to this is by Law360 entitled "Enviro Attorneys Pivot To Clients' Coronavirus Concerns." The author, Juan Carolos Rodriguez, reminds everyone to be proactive and reach out to reporting agencies for guidance or extensions due to limited personnel, and when under a court order speak with counsel to find out your options. The key message, be proactive. There will be some leniency in these times; however, companies cannot simply utilize the Coronavirus as an excuse to be completely complacent.

Activities such as discharge monitoring reporting (DMR), certain air reports, Spill Prevention Control and Countermeasure (SPCC) Plan visual inspections, Storm Water Pollution Prevention Plan (SWP3) facility inspections, tank testing, have the potential to be impacted. If a report must be submitted, reach out directly to the governing agency and ask what the protocol is given you are now in lockdown. If an action must be logged, make a record of why the deadline was missed and spell out what actions are in place to ensure it will be addressed as soon as feasible.

Don’t let setbacks cause more issues than needed. If you pause for a second, there are some surprising opportunities that can come out of this. For example, virtual training. With many homebound, and operations running slower, this is a great time to knock out some personnel training – Annual: SPCC, SWP3, Tabletop Drills, “PANDEMIC PLAN”, etc.

Recent articles tackling thinking out of the box:

• Leveraging your FRP: Coronavirus: Is your Pandemic Plan up to date?
• Your FRP: Is it just a plan, or effectively leveraged to support your communication plan?

For a complete listing of archived blogs and compliance insights, click here. Past blogs cover training requirements, clarification on additional confusing elements within the above rules, and much more.

We are here to help solve your compliance questions and challenges. Need some compliance assistance, or just have a question? Please email John K. Carroll III (jcarroll@wittobriens.com) Associate Managing Director - Compliance Services or call at +1 281-320-9796.

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