Retaile
ers Bewa
are: Grea
ater Envir
ronmenta
al Regula
ation is C
Coming to
oa
Store Near
N
You
u
By Mark Heaney,, Vice Pres
sident, AltterEcho
www.allterecho.c
com
Pop quiz for EH&S managers:
m
Which
W
image best reflectss the currentt trends and focus in
mental regulaation, enforccement and management
m
t?
environm
kely winner is the retail establishmen
nt. This doees not mean that manufaacturing and
The unlik
utility op
perations are seeing a relaxation in ov
versight andd regulation. Rather, thee coverage off the
umbrellaa is just becoming broadeer. After sev
veral decadees as a primaary focus of eenvironmenttal
regulatorry programs,, manufacturrers have fairrly mature ccompliance pprograms andd do not figuure to
be consisstent sourcess of large fin
nes. It should
d also be notted that mannufacturing hhas been a
shrinking
g componentt of the U.S. economy while
w
consum
mer spendingg has been exxpanding,
leading th
he way to significant rettail growth. Given the laarge environnmental com
mpliance-relaated
fines thatt have impaccted the retaiil sector the past few yeaars—includiing the recennt $82 millioon
Wal-Marrt package to
o resolve casses with US EPA,
E
Califoornia and Miissouri—it iss apparent thhat
weak spo
ots in retailerr compliancee are being identified annd targeted. E
Even large, ssuccessful
organizattions with deeep and expeerienced team
ms of enviroonmental heaalth and safeety personneel,
such as Wal-Mart,
W
Taarget and Walgreens,
W
weere unable too recognize tthat their com
mpany’s dayy-today routiines had run afoul of the complex weeb of environnmental law
ws and regulaations.
One size does not fit all when it comes
c
to env
vironmental regulatory ccompliance aand risk
ment. A man
nufacturing setting
s
defin
nitely doesn’tt function inn the same w
way as a retaiil
managem
setting. The daily activities and the staff and systems in place to support them could not be more
different. Unfortunately, the reality is that many federal and state environmental regulatory
schemes were developed primarily for the manufacturing sector and are not a good fit for retail
and distribution operations. The increased risk and real regulatory pain being inflicted via fines
and brand reputation damage call for solutions that understand and work in this different
environment.
For the retail sector, business is primarily conducted in the field at the store level.
Environmental compliance programs may come from the corporate offices, but execution is the
responsibility of the field teams. Many aspects of retail business operations affect human health
and the environment in countless ways and may be regulated by the EPA, state and local entities.
Each decision made regarding items such as freight transportation, packaging, waste
management, product selection, facility management, food service, pharmaceuticals, and
ancillary facilities (such as backup power and fuel tanks) can have significant environmental
impacts. This can encompass a shockingly large number of regulatory programs that require
store-level execution.
The footprint of a retailer’s operations may span several thousand stores in almost all 50 states
and include thousands of hourly employees. Environmental compliance and risk management in
these settings is dependent upon a diverse and very differently-skilled and trained group of
individuals than what is typically found in a manufacturing setting. Understanding and crafting
effective training programs for retail operations, both in content and in delivery, is a critical risk
management measure and brand defense. While regulatory agency scrutiny has been adjusting to
concentrate more outside the manufacturing sector, the rules and regulations have not been
similarly adjusted. Therefore, basic programmatic training drawn from the manufacturing model
content and target audiences may meet regulatory needs. Whether it meets a company’s actual
store-level risk management needs is a different assessment, however.
Of course, no two organizations face exactly the same issues regarding environmental regulatory
compliance. Flexibility in each organization’s risks, budget and culture will be required.
Organizations need to quickly understand:







What state and federal environmental regulatory programs they need to know
Where are their high risk operations/activities
What actions need to be part of routine employee responsibilities to assure compliance
When compliance-related activities need to be conducted
How they impact your organization at the store level
Who actually implements the necessary compliance activities at the store level
Where to find the appropriate tools, training, and resources to address these questions,
and how to apply them
As environmental professionals, we need to go back to the drawing board regarding training
program concepts, content and delivery. Decoding the jargon, adapting the knowledge for storelevel execution and providing meaningful content to implement creative training solutions for
busy store-level staff are critical elements to building successful environmental compliance for
retail businesses. The challenge of building an effective compliance program and successfully
training staff to carry it out on a daily basis has been met before. However, to meet the complex
and varieed needs gen
nerated by th
his shift in in
ndustry focuss, organizatioons should bbe looking
toward cu
ustomized trraining soluttions and too
ols geared tooward leveraaging technollogy, experieence
and know
wledge, ratheer than relyin
ng on dated, one-size-fitts-all solutioons.
Mark Heeaney is Vicee President of
o AlterEcho
o, overseeingg the companny’s day-to-day operatioons
and leadiing support to clients on
n issues involving sustainnability, greeen chemistryy, chemical
alternativves analysis,, regulatory compliance managemennt and trainiing, and suppply chain
analysis. He has morre than 20 yeears of envirronmental reegulatory maanagement eexperience,
particula
arly in suppo
ort of EPA RCRA and CE
ERCLA proggrams conceentrated on ccorrective acction,
permittin
ng, enforcem
ment, combusstion, unexplloded ordnannce, and facility/land resstoration. H
He
also man
naged progra
ams supporting EPA inittiatives in suustainability,, recycling, ppollution
preventio
on and wastee analysis/minimization.
AlterEcho is a proud
d member of the NAEM Affiliates
A
Couuncil. Learnn more abouut AlterEcho’s
services at:
a http://ww
ww.ehsconsu
ultants.org/afffiliates/alteerecho/ or
http://ww
ww.linkedin.ccom/compan
ny/alterecho?trk=tabs_bbiz_home. Y
You can reach Mark at
[email protected], or at 703-818-320
7
01.