Environmental Management System

The Virtuoso of Vanguard…An EMS Symphony in Five Movements

Vanguard’s Environmental Management System (EMS) features a $20,000,000 intellectual property unique to the field of regulatory compliance management, assuring that the Government’s regulatory benchmarks are met in terms of site-specific compliance. With precision due diligence as its starting point, Vanguard’s mission through its EMS technology is to determine in behalf of each client which laws require compliance and which ones don’t. This one-of-a-kind technology, therefore, positions Vanguard’s team of EHS professionals to satisfy and manage each client’s compliance requirements for any zip code in the USA. The Government’s expectation of site-specificity emphasizes key issues focused on chemical hazards, thresholds and regulatory mandates in order for Industry to meet the compliance benchmarks set by the Government in its various EHS laws. Vanguard’s EMS technology accomplishes that and more!

MOVEMENT 1.  The Compliance Gap Analysis.  Precision due diligence begins with the meat and substance of Vanguard’s EMS technology, namely the Compliance Gap Analysis (CGA).  The CGA screens the client’s site-specific EHS issues against the government’s compliance benchmarks for over 60 laws imposed upon Industry by the U.S. EPA, OSHA, DOT and Homeland Security. 

It is important to understand that a major disconnect exists between industry executives and the government’s regulatory compliance laws.  From the government’s perspective, virtually all the laws – 93% in fact(!) – are based on three elements: 1. Chemical Hazards;  2. Thresholds (assigned to chemical hazards by government agencies); and 3. Regulatory mandates, or rules that govern how any given company’s compliance must be satisfied.  Yet, far too many people throughout Industry think in terms of the other 7%...those things that can only be seen by the naked eye.  This disconnect is prone to leave compliance officers with a false sense of security. As a result, senior managers don’t discover their company is out of compliance until the very day an enforcement inspection takes place.  The science of regulatory compliance is such that nobody can see a threshold, a carcinogen, or the toxicity of a chemical hazard.

Vanguard covers 100% of the client’s compliance…the 93% category by the Compliance Gap Analysis, to screen for those laws based on chemical hazards and thresholds; plus…the 7% category, for those hazards that can actually be seen as hazardous. The CGA identifies all your company’s compliance gaps, but also eliminates many not actually required by law.  This saves the client much time and money by placing its attention and capital on only those laws requiring compliance.  This helps the client “get his arms around the compliance problem” by shrinking it to its actual size.  This defines the scope and magnitude of the client’s compliance responsibilities with accuracy, the end-result being that regulatory compliance is reasonably achievable.  Vanguard calls this outcome “Destination Total Compliance.”

MOVEMENT 2.  The Client’s Regulatory Compliance Agenda (RCA). The simplicity of this movement is a direct outgrowth of the precision due diligence performed during Movement 1.  Vanguard’s personnel often hear from industry executives and senior management: “I’d just like someone to provide me with a list of all the laws, help me understand the requirements for each one in plain English, then inform me of which ones require compliance of my company and which ones don’t!”  With Vanguard's team and technologies, the answer to that question is not at all difficult.  We simply gather and input all your site-specific facility data through Vanguard’s intellectual properties in Movement 1, to give you your own site-specific Regulatory Compliance Agenda (RCA).  The client’s RCA displays, in chart form, how the client stands on each and every law with the #1 objective being to satisfy and manage the client’s regulatory compliance going forward. 

MOVEMENT 3.  The client’s Decision Matrix and Regulatory Calendar.  It’s often been said, “There are five points to the compass: north, east, south, west…and where you are;   and you can’t get to where you need to go until you know your current location.”  Movements 1 and 2 put you into a position to make wise business decisions about your regulatory compliance. In fact, decisions regarding regulatory compliance happen to be the top 2-3 most important decisions a senior manager will make on an annual basis, especially when his RCA Chart indicates noncompliance with one or more laws.  Since setting priorities, implementing decisions, and meeting compliance deadlines are just as important as knowing your company’s regulatory compliance agenda, Vanguard’s Regulatory Specialist performs a regulatory review for your senior managers’ awareness, then provides a “power tool” for taking action on the timeline appropriate to your priorities.  Yes, your own Decision Matrix is a part of Vanguard’s  EMS.  Yet another tool that accompanies the Decision Matrix is your Regulatory Calendar.  It’s important to know the regulatory deadlines applicable to those regulations requiring compliance of you at the federal, state, county and local levels.  This is where client service – be it in person, or via web-hosted conferencing – is provided by your Regulatory Specialist. 

MOVEMENT 4.  Turnkey Compliance.  Vanguard files all reports, permits and documents with the appropriate agency(ies) to government specs by the compliance deadline mandated, often in quadruplicate, to account for each agency having jurisdiction over the client’s facility (federal, state, county and local) and sometimes to adjunct agencies, such as a tribal authority or airport trust.    In the case of OSHA, DOT and Homeland Security documents, a site-specific written plan is always required, thus developed to satisfy compliance directives per the standards and regulations from those regulatory agencies.  Vanguard files all reports by certified mail – return receipt requested – as further documentation as to what was filed and when.  Our record-keeping is impeccable!

MOVEMENT 5.  Defensible Documentation.  Also known as Evidence-based Compliance, each completed project performed by Vanguard is given to the client in the event of an enforcement inspection.  Since Vanguard serves hundreds of clients throughout North America, our compliance projects have been the object of dozens of inspections.  Inspectors know Vanguard’s reputation for precision due diligence, reporting/permitting mastery, chemical accounting and the defensible documentation (evidence-based data) to support the client’s compliance programs for what’s required, as well as why certain compliance requirements are not applicable to the client’s facility.  Though an inspection can present some tense moments for almost anyone, an inspection for a Vanguard client is a veritable “coffee break” for the client’s facility designee.  Moreover, a Vanguard representative makes every effort to be available for the purpose of technical representative in person, or by teleconference, if the time and nature of the inspection is announced in advance.