Compliance programs, corporate practices

The flip side of the benefits that accrue to companies with robust compliance programs is the costs of not having one. One big concern is the big case. Penalties for TSCA violations can be quite large. Penalties do not only impose monetary obHgations on corporations, they can include individual liability and jail terms. With the renewed emphasis on management accountabihty as a result of the recent corporate scandals, it appears likely that the government will renew its determination to go up the corporate ladder to find those responsible for the actions. A picture of the perp walk in practice is worth a thousand words. 

The audit includes a review of the process safety information, inspection of the physical facilities, and interviews with all levels of plant personnel. Using the procedures and checklist, the team systematically analyzes compliance with the PSM Rule and any other relevant corporate policies. The training program is reviewed for adequacy of content, frequency and effectiveness of training. Interviews determine employee knowledge and awareness ofthe safety procedures, duties, rules, and emergency response assignments. The team identifies deficiencies in the application of safety and health policies, procedures, and work authorization practices to determine live actions. 

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