Track, Train, Comply: How to Build an Effective Compliance Calendar for EHS Regulations

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When an Environmental, Health, and Safety (EHS) manager joins a new organization, one of the first steps is to review the company’s compliance calendar. If one does not exist, creating it should be a priority, as it provides a clear overview of upcoming regulatory tasks. This tool allows managers to quickly identify which tasks need immediate attention, ensuring critical deadlines are met and nothing slips through the cracks.
In 2024, the U.S. Department of Labor announced adjustments to OSHA's civil penalty amounts due to inflation. The maximum penalties for serious violations increased from $15,625 to $16,131, while penalties for willful or repeated violations rose from $156,259 to $161,323. This reinforces the importance of having a compliance calendar, because failure to meet deadlines can result in costly fines.
Stay on top of key tasks
A compliance calendar is essential for tracking safety, health, and environmental obligations. It helps EHS managers stay on top of key tasks such as submitting reports, conducting mandatory training, and maintaining safety audits. Without it, the risk of missing deadlines and facing legal or financial consequences increases. By maintaining a well-organized calendar, EHS managers can ensure that all regulatory requirements are met, while keeping everyone in the organization informed and minimizing the risk of non-compliance.
When selecting items for the compliance calendar, it’s important to categorize them into distinct groups. First, prioritize requirements that are mandated by federal legislation with fixed deadlines, ensuring that no critical regulations are missed. Second, include obligations set by state or regional laws, which may vary across different jurisdictions and often have their own unique deadlines. Third, factor in legal obligations that are company-specific, such as training sessions, emergency evacuation drills, and license renewals, where deadlines can differ based on the organization’s operations. Additionally, it’s essential to account for the requirements of voluntary certifications, such as ISO 45001:2018, which the company must uphold in order to maintain its certification status.
A well-structured compliance calendar should include the following components:
- Item Description: Clearly defines the task or requirement, such as submitting hazardous waste reports or conducting employee safety training.
- Agency: Identifies the governing body (e.g., OSHA, EPA, NYSDEC) responsible for the regulation.
- Requirement: A summary of what needs to be done to meet the regulation (e.g., submit emissions data, provide training on specific hazards).
- Deadline: The exact date by which the task must be completed or a recurring frequency (e.g., annually, quarterly).
- Regulatory Reference: Cites the regulation or law (e.g., OSHA 29 CFR 1910.95 for noise exposure) to clarify the source of the requirement.
- Status: Tracks progress with categories like "Complete," "Pending," or "Overdue."
These components ensure that every task is clearly defined, tracked, and actionable, making it easier to stay on top of compliance requirements. An example of a compliance calendar for a fictional company in New York State, with over 250 employees and ISO 45001 certification, is provided in the table below.
Action plan
The compliance calendar works best when paired with an action plan that outlines specific steps to complete each task. The calendar provides a timeline and an overview of the deadlines, while the action plan is a more strategic document. It typically includes tasks, responsible parties, deadlines, and measurable outcomes to ensure that compliance requirements or project objectives are successfully met. For example, for a task like “Conduct audiometric testing for employees exposed to noise levels above 85 dBA,” the action plan would include the responsible people and steps like scheduling the testing, notifying employees, and ensuring proper documentation.
The compliance calendar is also valuable during EHS committee meetings. By regularly reviewing the calendar, the team can stay aligned on upcoming deadlines and ensure that everyone is on track. This shared awareness fosters accountability and encourages team members to raise any concerns or risks before they become issues. It also helps identify areas where additional resources or support may be needed.
Another benefit of a compliance calendar is that it helps EHS managers plan for employee absences. If someone responsible for a task is unavailable, the calendar allows for easy reassignment or cross-training. This prevents delays. For example, if an employee is going on vacation, tasks can be reassigned or planned in advance to avoid missing deadlines.
In a past role, I was called in to assist with an internal investigation after a company received a fine for missing the deadline for a required environmental report. Although the company had a compliance calendar in place, it hadn’t been updated for several months, leading to the missed deadline.
The EHS leader, though experienced in occupational safety, wasn’t as familiar with environmental regulations. She relied on the calendar to track tasks, assuming it was up to date. However, a newer environmental officer noticed discrepancies in the calendar, but hesitated to bring them up, fearing it might reflect poorly on her. The outdated calendar led to a compliance failure and a costly fine. This experience highlights the importance of maintaining an up-to-date calendar and ensuring clear communication within the team.
To prevent such issues, I believe that the compliance calendar should be reviewed annually, as well as whenever there are changes in legislation. The "Regulatory Reference" column is particularly valuable in this regard. It allows managers to track which items need to be revisited if the corresponding regulations are amended. This ensures that all compliance tasks remain aligned with current laws and that nothing is overlooked.
Utilize cloud-based resources
While a simple spreadsheet can work for a compliance calendar, modern tools offer better tracking and automation. Programs like Outlook can help by setting reminders a week or a month before a deadline, giving responsible employees time to prepare. More advanced software like Enablon sends automatic reminders and notifications to ensure tasks are completed. These systems reduce the risk of missing deadlines and help keep everything organized, making compliance easier to manage.
Additionally, cloud-based tools allow for real-time updates, so any changes are immediately reflected across the team. This way, everyone can stay up-to-date and ensure compliance is always top of mind.
Here’s an example of what a well-organized compliance calendar might look like:
# | Items | Agency | Requirement | Deadline | Reference | Status |
---|---|---|---|---|---|---|
1 | Submit annual hazardous waste report | EPA | Annual reporting of hazardous waste to the state EPA | January 1 | RCRA | Complete |
2 | Submit OSHA Form 300A electronically | OSHA | Submit OSHA Form 300A for businesses with 250 or more employees | March 2 | OSHA 29 CFR Part 1904.41 | Pending |
3 | Maintain OSHA Form 300A in visible location | OSHA | Post injury and illness summary | Feb 1 - April 30 | OSHA 29 CFR Part 1904 | Pending |
4 | Conduct annual emissions statement | NYSDEC | Submit annual emissions data to NYSDEC | April 15 | Clean Air Act, 6 NYCRR Part 202 | In Progress |
5 | Audiometric testing | OSHA | Provide audiometric testing to employees exposed to noise above 85 dBA | August 1 | OSHA 29 CFR 1910.95 | Overdue |
6 | Forklift safety training | OSHA | Conduct refresher training every 3 years | June 30, 2026 | OSHA 29 CFR 1910.178 | Pending |
7 | External recertification audit (ISO 45001) | n/a | Conduct external recertification audit for ISO 45001:2018 | July 1, 2025 | ISO 45001:2018 | Pending |
8 | Internal audit of OHSMS | n/a | Conduct internal audit of the Occupational Health and Safety Management System (OHSMS) | June 1, 2025 | ISO 45001:2018 | Pending |
Conclusion
A compliance calendar is an essential tool for EHS managers to stay on top of regulatory deadlines and responsibilities. By maintaining an up-to-date calendar and linking it to a clear action plan, managers can ensure that their team is prepared to meet all obligations on time. Using technology to track and automate reminders makes the process even easier, helping organizations avoid the costly consequences of non-compliance. Ultimately, a well-organized compliance calendar supports a safer, more efficient work environment and ensures that all safety, health, and environmental regulations are met consistently.
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