Excerpt from:  EHS Compliance Management
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October 11, 2006

Five Steps to Manage Title V Compliance

Chemical Processing Article outlining ways to manage Title V Compliance

5 Ways to manage title v complianceIf you are looking for some helpful advice on ways to manage your Title V compliance requirements, you should read this recent Chemical Processing article.  Although I might be a bit biased, as the author is an executive at Enviance, the piece provides 5 successful approaches to manage clean air compliance.  A summary of the steps are described below: 

Step 1 – Start at the End
The first step toward Title V is to anticipate your compliance commitments and build a data management plan that supports them.  Understand which data will be used to determine compliance, the required format of compliance reports, and how the data will be processed into the reports.

Step 2: Improve Transparency
A key to any successful compliance program is ensuring your data is “housed” in one central location, continuously updated and easily accessible by the right people.  A commitment to the development and maintenance of institutional knowledge also is very important. With an increasingly multitasked and mobile workforce, and with the growing prospect of retiring Baby Boomers, companies must retain critical compliance-related information.

Step 3: Technology — only Part of the Answer
Whatever technology you chose to eliminate silos of information, promote collaboration and automate (as much as possible) compliance tasks.  But remember, technology can’t “do” compliance. Technology allows people to meaningfully evaluate data. Not everything that appears to be a problem from a database perspective is a problem from a compliance perspective. Technology sifts. People judge. Compliance is a human decision.

Step 4: Staying Current
With the proper people, technology and processes in place, organizations can gain real value from self-policing. It is estimated that problems fixed proactively cost about 20% of those discovered by an outside agency. The ultimate goal — let’s call it “compliance nirvana” — is that organizations develop the capability to produce reports of any type at any time.

Step 5: Learn How to Play the Game
The specter of noncompliance can weigh heavily on managers responsible for Title V. But awareness of common risks can help you avoid many problems. The most obvious categories of compliance risk are related to managing data, but there are other less obvious, and equally large, risks. These are usually rooted in misunderstanding Title V responsibilities or misaligning resources based on false assumptions.

Closing Words of Advice
If you’re responsible for managing Title V, review your processes to verify that you’re properly aligning technical, technological and human resources so that your best assets — your judgment and the judgment of all employees — are put to work. The benefits of streamlining data and process management include peace of mind and mitigated financial risk.


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