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Ask Enhesa: Vol. 1

8 Feb. 2017 By Rachel Degenhardt Karpovich

You asked and we answered!
Enhesa’s team of multilingual regulatory analysts are committed to providing quality insight and analysis around the latest EHS news and developments via our Enhesa Flash, webinar series, and weekly blog posts. In response, our team often receives a variety of questions regarding the broad realm of the EHS topics we cover. To meet this demand, we are pleased to announce “Ask Enhesa”, a new reoccurring blog series where Rachel Degenhardt Karpovich, our Head of Policy and Insight and one of our senior thought leaders, will take the lead in answering all of your most relevant and topical EHS questions.
Let’s get started…

Q: There are many U.S. Federal and State tools in place which are being cluttered and confused by smaller County and City rules. What is being done to limit excessive regulation?

RDK: Regulations rarely confuse and clutter the regulatory landscape unless the regulations conflict with federal and state requirements. In most instances, county and city agencies work in conjunction with the state and federal agencies to provide an additional layer of support on already established regulations. For example, New York City issues regulations that add requirements for those businesses located within city limits, and the requirements are very specific in nature--targeting mostly specific industries or specific installations. These city-level regulations work in conjunction with the state regulation, which enforces federal regulations. The city-level regulations include additional monitoring and paperwork for certain affected operations. The requirements are simply more stringent than state and federal requirements in effect and are limited in their applicability and geographical reach.

Not much is done to limit excessive regulation, although impacted operations should regularly communicate with their local authorities with any questions or potential conflicts with state and federal requirements. When appropriate, participating in the rulemaking process is a way to ensure “excessive regulation” is a rare occurrence.

Q: Crystal ball on new administration changes in the U.S.?

RDK: In the U.S. it is clear the new administration will make the American landscape welcoming to new and expanding industrial manufacturing. A great deal of focus has recently been given to a concept of deregulation, or removing or weakening environmental and health and safety protections. In reality, making regulations less stringent takes time beyond a single executive action.

Rather than expect immediate de-regulation in the EHS landscape, I would expect agencies to put efforts into permitting activities to get new sites up and running. So, in the next few years, the U.S. EPA may be more encumbered by issuing large operational permits to major manufacturing operations rather than pursuing major enforcement actions like those we have seen in the past few years. Enhesa expert, Christian Petrangelo, recently commented on possible changes the new administration brings in the Enhesa Flash.

Q: Why should a company develop a sustainability strategy that tackles environmental issues?

RDK: The concept of sustainability is different to every company, but generally means “the quality of not being harmful to the environment or depleting natural resources”.[1] In areas where there are no industry standards governing sustainability, it is difficult to eliminate all environmental considerations completely from sustainable thought. In fact, a significant portion of sustainability reporting focuses on global environmental issues.[2]  Sustainability reports are based, in part, on corporate environmental data from the prior year.[3] This makes environmental and health and safety data even more critical beyond daily compliance; this data will be used, referenced, and evaluated as part of a company’s commitment to sustainability. EHS data provides foundation for goals and commitments set in a sustainability strategy.

Another reason environmental issues are tied to corporate sustainability strategy may be because of a company’s supply chain strategy. In January 2017, Target announced its new policy to drive transparency, [promote] proactive chemical(s) management, and drive innovation across all brands and operations.[4] Beginning over four years ago, Target asked its vendors to complete its own Sustainable Product Index (SPI). Target considered the environmental impact of products it sold as one factor in its SPI because of a product’s potential impact on long-term health.[5] The impact products have on the environment are common components of supply chain assessments, to give all parties increased transparency on consumer goods.[6] Neilsen’s Global Sustainability Report states all requests for proposal (RFPs) include a section on sustainability, to “evaluate our potential supplier’s commitment to the environment”.[7] This means that in order to do business with Neilsen, a potential vendor or supplier must make transparent to Neilsen its own history in and future commitments to environmental compliance.    

A solid sustainability strategy relies on solid environmental data. It would be challenging to develop a sustainability plan or strategy that excludes all environmental considerations. Moving forward, data collected through environmental audits and facility compliance assessments will be critical to the commitments made in sustainability reports.

That’s all for now! Stay tuned for the next edition of Ask Enhesa.

About Rachel:

Rachel Degenhardt Karpovich is a senior leader at Enhesa with more than eight years of experience in regulatory compliance. Rachel has managed teams around the globe and delivered comprehensive solutions to meet evolving client demands.  Rachel regularly speaks throughout North America on regulatory trends, best practices, and emerging issues. Prior to joining Enhesa, Rachel worked in litigation in Texas and Chicago, and held a judicial clerkship in Texas.  Rachel holds a Bachelor of Arts Degree from Saint Mary’s College at Notre Dame, a Masters of Environmental Law and Policy from Vermont Law School, and a Juris Doctorate from Vermont Law School. 

 


[2] See for example Nielsen’s Global Responsibility Report, available at http://sites.nielsen.com/globalresponsibilityreport/our-environment/

[3] Id.

[5] Id.

[6] Id.  See also Nielsen’s Global Responsibility Report, available at http://sites.nielsen.com/globalresponsibilityreport/our-environment/.

[7] Nielsen’s Global Responsibility Report.   

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