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Regs & Legs


It’s Compliance, Not Complicated


Recent amendments to regulations and associated codes of practice have resulted in some confusion for facilities managers (FMs) around what should be undertaken as part of a maintenance programme. Here, Brian Imrie, managing director of adi Group’s facilities engineering business, advises how FMs can take a proactive approach to legislation to ensure ongoing compliance. Adjusting manufacturing processes so that


they comply with the latest legislation is a necessary evil for FMs and it is important to keep up with any changes, as penalties for non-compliance can be severe. For example, companies that do not adhere to good manufacturing practice (GMP) guidelines may have their licenses suspended by the Inspection Action Group (IAG) if critical deficiencies are found1


. However, compliance


does not have to mean temporary shutdown or increased investment. Whilst in there has not been any dramatic


changes to legislation recently, there have been some subtle amendments that FMs must keep abreast of to ensure they are not penalised for non-compliance. A recent example of this is the renewed focus on phasing out potentially climate-damaging hydrofluorocarbon gases (HFCs), as outlined in The Paris Agreement which came into force on 4 November 2016. The Paris Agreement builds on the


preceding Montreal Protocol and includes a specific revision around the substances used primarily in refrigeration and air-conditioning equipment, with the onus on developed member states to further incrementally limit their production and usage of HFCs. Whilst actual targets are yet to be released, predictions are for a reduction of around 10% from 2019. Information of this kind will play a major


part in future legislative compliance when considering equipment replacement and capital investment. This demonstrates the importance of keeping well informed about changes that could potentially affect the way


34 fmuk


in which FMs manage their portfolio and lifecycles of inherent assets. Modern legislation is moving away from


prescriptive mandates and becoming more consultative, based on recommended practice and guidelines. A good example of this is the pollution prevention guidelines (PPGs), which were withdrawn in December 2015, to be replaced by Guidance for Pollution Prevention (GPP) aimed at providing direction on best practice rather than insisting that specific actions be met. This was also seen in the Health and


Safety Executive 4th revision in November 2013, relating to the control of Legionella bacteria in water systems (L8). The new ACoP and HSG274 guidance moved towards a risk-based management approach covering key equipment that would be found in manufacturing facilities such as evaporative cooling towers, hot and cold water systems and fire suppression systems. Although this change in practice is open


to interpretation, it does constitute a framework for operation that allows FMs to best address and prioritise important issues and develop plans for less pressing items. Compliance is not just about getting


a piece of plant or equipment serviced, it requires a more holistic management approach involving suitable recording, data capture, and managing corrective actions through to closure or alternative remediation where required. Nevertheless, concept and understanding of compliance management can vary massively depending on knowledge, experience and complexity of facilities systems. The key is to be proactive and plans and


processes in place for impending changes, as well as adhering to current standards. This ensures manufacturing sites are always compliant and reduces the risk of getting caught out with costly retrofit work. The old adage that ‘you can’t manage what you don’t measure’ is particularly pertinent


when it comes to compliance; a successful management agenda is dependent on preparation, baselining and understanding of a site’s situation and constraints. Initial steps are to work with a facilities


engineering services provider to undertake a compliance assessment. The provider should use some form of assessment tool as well as consulting with key stakeholders on work activities and compliance management. The findings are then ratified through completion of a scorecard and an audit of site-based evidence, which provides a baseline compliance score. This exercise enables compliance managers to undertake a gap analysis and identify areas of focus, risk mitigation and management to form the basis a master compliance plan. Achieving total compliance is a journey


which may take several years to realise given operational and budget constraints. However, the key is to demonstrate that current systems are operating safety and are being monitored by a competent person or duty holder. Medium to long-term fixes can be established later, by working closely with regulatory bodies to develop a plan of action that works for all parties. A common misconception amongst FMs


is that significant and immediate investment is needed to rectify gaps in compliance. However, in many cases, simply amending process or maintenance regimes can manage and mitigate immediate risk and this does not require vast amounts of capital. The key to achieving and maintaining com-


pliance is staying ‘ahead of the game’ when it comes to legislation. This involves keeping a close eye on the news agenda for announce- ments that may potentially affect compliance and putting plans in place to safeguard against any changes. However, announcements of these kind are not always predictable, so facilities managers must also be flexible and modify the plan where circumstances dictate, as part of a regular review process.


1 https://www.gov.uk/guidance/good-manufacturing-practice-and-good-distribution-practice


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