External Factors Affecting Compliance

In some instances, engineering technology as it relates to environmental control can be an internal source affecting compliance. This is especially 

To meet compliance, the current vs. the long term needs of the organization must be evaluated to properly staff the environmental function. If a company has current needs for additional staff but cannot foresee long term demands, they can utilize alternative staffing such as the use ofintems, 

No matter how many environmental professionals an organization has, environmental compliance will not be achieved if the staff is not empowered and supported by management and throughout the company. The responsibilities of the environmental professionals, therefore, must be clearly defined and their authority must be understood throughout the organization. Additionally, if site management is responsible for environmental functions, their role must be elearly defined and they must be held accountable for their actions. In short, the eompany must establish a elear organizational framework that allows environmental staff to be successful. 

Regulatory History. Past history in terms of an organization s ability to comply with regulatory requirements is one indicator of the need for additional staffing. If past practices have been deficient and if an organization has come under enforcement action as a result of such deficiencies, an evaluation should be conducted to determine the number of staff and area of expertise that would be required to bring the organization into compliance. 

As we described earlier in this chapter, there is a wide range of external and internal sources which affect the semiconductor facility s compliance status or its ability to implement its environmental management program. The ability for early identification or detection of environmental problems or issues is one of the most important skills and tools that facility compliance personnel can have. This conclusion is based on the collective experience of industry compliance personnel over the last 10-15 years as they have coped with the sharp increase in the number of environmental regulatory requirements. 

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