Compliance Minute – Waste Container Status Vlog
Chris De Cree, an EHS Implementation Manager from Locus Technologies walks us through our container tracking tool.
Tag Archive for: Compliance
The Past, Present, and Future of EHS & ESG
To celebrate a milestone 25 years of success in EHS and ESG software development, we sat down with Locus President, Wes Hawthorne for a brief discussion. In this post, we ask him a series of questions highlighting the past, present and future of EHS and ESG.
1. What are the greatest challenges that environmental professionals are facing?
One of the persistent challenges we’ve seen for the past 25 years is that the responsibilities of environmental professionals are continually expanding. Previously, almost all environmental work was localized, with facility-level permits for air, water, waste, etc. That has expanded over the years to include new regulations and reporting requirements for sustainability, social metrics, and other new compliance areas, while the old facility-level programs still continue. This has led to more pressure on environmental managers to keep up with these programs, and increased reliance on tools to manage that information. That’s where Locus has always focused our effort, to make that ever-expanding workload more manageable with modern solutions.
2. What are the most interesting trends in EHS and ESG?
The current flood of interest in ESG is certainly notable as far as bringing corporate attention to the environmental field, as well as having requirements originate from the SEC here in the US. We have become accustomed to managing oversight from multiple regulatory bodies at the local, state, and federal level, but SEC would be a newcomer in our line of work. Their involvement will be accompanied by a range of new requirements that are common for the financial world, but would be unfamiliar to environmental staff.
Across other EHS fields, we are seeing increased demand for transparency in EHS functions. Overall, this is a positive move, as it brings more attention to EHS issues and develops a better EHS culture within organizations. But this also drives the need for better tools to make EHS information readily available across all levels of the organization.
3. What are the most disruptive technologies available today?
As far as technologies, the ones most likely to have significant impact in the environmental field are ones that don’t require a significant capital investment. Although there are definitely some practical advantages to installing smart monitoring devices and other new technologies, procuring the funding for those purchases is often difficult for environmental professionals. Fortunately, there are still many technologies that have already been implemented successfully in other fields, but only need to be adapted for environmental purposes. Even simple changes like using web-based software in place of spreadsheets can have a huge impact on efficiency. And we haven’t yet seen the full impact of the proliferation of mobile devices on EHS functions. We are still working on new ways to take advantage of mobile devices for data collection, analysis, and communication purposes.
4. What do you think are the biggest innovations of the last 25 years in our field?
We’ve seen a number of innovation milestones in the past 25 years, and while we didn’t invent SaaS, we’ve been largely responsible for adapting it and perfecting it for environmental purposes. One of the major innovations we’ve integrated into our products include online GIS tools where users can easily visualize their environmental data on maps without expensive desktop software. Another one was our fully configurable software platform with built-in form, workflow, and report builders tailored for environmental purposes, which allows anyone to build and deploy environmental software applications that exactly match their needs. There have been many other innovations we’ve incorporated into our software, but these two stand out as the most impactful.
5. Where do you see Environmental and ESG reporting in the future?
More and more, we are seeing all types of reporting being converted into pure data exchanges. Reports that used to include regulatory forms and text interpretations are being replaced with text or XML file submittals. This transition is being driven largely by availability of technology for EHS professionals to generate and read these files, but it is also promoted by regulatory agencies and other stakeholders receiving these reports. Stakeholders have less time to read volumes of interpretive text, and are becoming more skeptical of potential bias in how facts are presented in text. These are driving the need for more pure data exchanges, with increasing emphasis on quantifiable metrics. These types of reports are also more readily compared against regulatory or industry standards. For reporters, lengthy corporate reports with volumes of text and graphics are becoming less common, and the success of an organization’s programs will be increasingly reliant on robust data sets, since ultimately only the data will be reported.
6. What has been the key reason for Locus’ success for the past 25 years?
There are actually a few that immediately come to mind. One reason is the nature of our continually evolving products. By providing our solutions as SaaS, our software adapts with new environmental requirements, and with new technologies. If our software was still the same as it was 25 years ago, it simply wouldn’t be sufficient for today’s requirements. Since our software is updated multiple times each year, it is difficult to notice the incremental changes, but they can be readily seen if you compare today’s software with the original in 1997. And we’re committed to continuing the development of our products as environmental needs change.
The other primary reason for our success is our excellent staff and the environmental expertise we bring to our customers. We simply could not provide the same level of support without our team of environmental engineers, scientists, geologists, chemists, and an array of others. Having that real-world understanding of environmental topics is how we’ve maintained customer relationships for multiple decades. And our software only has value because it is maintained and operated by staff who appreciate the complexity and importance of environmental work.
Mr. Hawthorne has been with Locus since 1999, working on development and implementation of services and solutions in the areas of environmental compliance, remediation, and sustainability. As President, he currently leads the overall product development and operations of the company. As a seasoned environmental and engineering executive, Hawthorne incorporates innovative analytical tools and methods to develop strategies for customers for portfolio analysis, project implementation, and management. His comprehensive knowledge of technical and environmental compliance best practices and laws enable him to create customized, cost-effective and customer-focused solutions for the specialized needs of each customer.
Mr. Hawthorne holds an M.S. in Environmental Engineering from Stanford University and B.S. degrees in Geology and Geological Engineering from Purdue University. He is registered both as a Professional Engineer and Professional Geologist, and is also accredited as Lead Verifier for the Greenhouse Gas Emissions and Low Carbon Fuel Standard programs by the California Air Resources Board.
Top 10 OSHA Cited Violations of 2020
OSHA has released their list of the ten most cited violations of the 2020 fiscal year. The same mistakes and mishaps from years before are still here, though some have moved around from last year. They are:
- Fall Protection – General Requirements (1926.501)
- Hazard Communication (1910.1200)
- Respiratory Protection (1910.134)
- Scaffolding – General Requirements (1926.451)
- Ladders (1926.1053)
- Control of Hazardous Energy – Lockout/Tagout (1910.178)
- Powered Industrial Trucks (1910.178)
- Fall Protection – Training Requirements (1926.503)
- Personal Protective and Lifesaving Equipment – Eye and Face Protection (1926.102)
- Machine Guarding– General Requirement (1910.212)
Locus can help your organization prevent, report, and track these workplace mishaps. From configurable smart notifications to follow-up assignments when accidents, near misses, or when other incidents are logged, Locus EHS&S compliance software offers assurance that your safety procedures can be followed promptly and correctly.
Top 10 Enhancements to Locus EHS Compliance Software in 2020
Let’s take a look back on the most exciting new features and changes made in Locus Platform during 2020!
Unified EHS Platform: Enter Once, Report to Many
Is your organization still using multiple software systems for EHS&S when you can (and should) be using one robust and unified platform? Unify your compliance, sustainability, water, air, and environmental data with Locus’ cloud platform for EHS&S. It’s easier, cheaper, and more efficient.
With Locus Platform, you can easily and securely feed all of your different EHS data sources to the cloud via a wide array of import options. You will then be able to analyze and report to virtually any regulatory agency, meeting any specific requirements they may have. We believe in making EHS compliance simpler.
Indirect Impacts of COVID-19 on EHS Industry
For the better part of 2020, it’s safe to say that predominant changes to our daily lives have been brought on by COVID-19 and the associated response measures. This is certainly true for those of us working in the EHS field. EHS workers have an active role on the front lines, preparing our workplaces with new safety measures, including social distancing signage, training, and personal protective equipment (PPE).
Beyond those direct response actions, the realities of the ‘new normal’ have already impacted how other compliance and sustainability programs are implemented. And for good reason… many of the routine activities like inspections and onsite data collections now have a new safety issue to consider. Even with all the new protective measures we’ve implemented to address this pandemic, there remains some unavoidable added health risk caused simply by staff presence and interaction. For activities that are not mandated by a permit or regulatory requirement, the benefit of continuing those activities must now be weighed against the added health risk. For example, a daily waste inventory walkthrough may have been a standard routine for many EHS managers to collect data on waste generation as a key performance indicator. The value of that data collection effort may now be called into question, since it may increase travel and contact between staff. Depending on the value of those optional activities, some may be temporarily suspended simply because they are not worth the additional risk to health and safety.
For compliance requirements, this situation is more complex, due to the involvement and oversight of the applicable regulatory agency. The ultimate decision about whether a compliance activity must proceed generally lies with the regulator. The majority of EHS managers initially proceeded with meeting all their obligations without any changes. Although there are many applicable state and local ordinances and shelter-in-place orders related to COVID-19 that prohibited normal business operations, most of them include exceptions for activities that are ‘essential’ or required to maintain compliance with other regulatory programs. Public agencies have made very few blanket decisions to waive requirements for regulatory programs, even when they conflict with those local ordinances.
Despite the lack of a uniform response from agencies about whether or how compliance programs should be modified to accommodate COVID-19 precautions, I’ve observed several cases where regulatory staff have been given some level of authority and discretion to suspend or modify requirements. This is happening at federal, state, and local levels for various regulatory programs ranging from Superfund to GHG programs to land use covenants. I’ve experienced required deadlines delayed on remediation projects, modified approaches accepted for health risk mitigation, and on-site inspections postponed or drastically modified to accommodate social distancing. Any of these changes would have been unthinkable just a few months earlier. But now the regulators are seriously considering whether the continued enforcement of these requirements would create a potential health risk, and how their agency would defend their decision if the implementation of their requirements impacted someone’s health.
This ad hoc approach to compliance modifications brings its own new challenges for EHS managers, most of whom have detailed programs to track their efforts and ensure they stay on top of all the applicable compliance programs. Most of the regulatory programs that we work in have been in place for many years or decades, so the systems we’ve built up for those programs have been operating with minimal deviation for a long time. But now, in addition to the original set of requirements we’ve been implementing, we have new modified versions to track. In all the cases I’ve observed, the original requirements aren’t officially edited by the agency. Rather, the agency staff have issued temporary amendments in the form of a letter, memo, or email. So EHS managers will need to maintain the original requirements as well as the approved modifications in these various formats. Regulators are still planning that eventually these COVID-19 precautions will be lifted, so they can get back to the ‘old normal’ with the previous requirements we’ve implemented for years. This means that we can’t just overwrite the requirements in our compliance program, so we stay prepared to revert to the original official requirements if/when that happens.
The long-term impact of these compliance modifications is yet to be seen. The COVID-19 pandemic has forced more thought to be put into the cost/benefit of routine EHS activities. This is true not just for EHS managers but for regulators as well.
Since many EHS compliance programs have been largely unchanged for years, this is a rare opportunity to rethink or update those requirements. Technology has advanced significantly since many EHS requirements were written. This technology offers better and safer methods to achieve the same objectives. For example, I’ve attended several remote EHS inspections over the past few months, which were previously conducted in person. And after those inspections were completed, I can’t think of anything that was reduced or lost in terms of oversight. For some facilities, I’ve also seen remote automated monitoring used in place of manual field measurements, where it was previously only considered supplemental to the required manual data collection. Although the regulations technically required this work to be done in person, the remote versions were just as effective, and completely avoided the added health risks associated with physical gathering and travel.
So instead of wondering ‘When can we go back to the old normal?’ we might ask ‘Should we go back to the old normal?’ The regulatory programs we work with were designed to be protective of human health and the environment, but they were also mostly developed when things like handheld phones with live video were present only in science fiction. Obviously, these technologies are not new anymore, but this situation has provided an unprecedented opportunity to implement these alternatives, and ultimately confirm that they can be just as protective as the former methods they replaced. In addition to the cost savings that these options provide, there is a very real safety concern that they circumvent. And while cost-effectiveness is usually a difficult point on which to drive regulatory change, a safety issue is harder to dismiss.
While it still may be a while before we reach the end of this pandemic, there’s a lot we have already learned about how resilient EHS programs can accommodate this kind of major event. If we use this opportunity to engage with regulators, and closely review and update our programs, there’s no doubt they will only become stronger and better suited to the modern workplace and way of life.
See How Locus EHS Software Helps.
5 Common Compliance Issues for EHS Managers
At Locus, we understand the unique requirements of EHS managers. More than many, EHS managers are dealing with a wide range of duties instead of a few pointed ones. With so many responsibilities, it can be hard at times to stay on top of your organization’s EHS needs. In this blog we highlight a few common compliance-related issues that should resonate with most EHS managers and the steps we’ve taken to help you with them.
The worry of missing a regulatory change
They say it takes a village to raise a child, but it also takes a village to keep up with your organization’s regulations. If you are dealing with compliance, then chances are you’ve not been the first to know about a regulatory change, or you’ve found out about one later than you would have liked.
When you’re getting notifications from OSHA and the DOT and you’re checking specific permits and getting letters and emails about changes, sometimes it can all be too much. With Locus, you have the added benefit of an extra set of eyes, well… multiple sets of eyes. Our team keeps up with every rule and regulation used in our applications to further assist you with the breadth of information you have to manage. Locus EHS software is also integrated with RegScan, giving users seamless real-time access to current EHS regulations. This will allow Locus users to customize a watchlist in RegScan to quickly and readily view EHS regulations relevant to them.
Managing maintenance costs
When you have to worry about ever-changing costs that touch several parts of your business, the last thing you need is a gated product update from your EHS software vendor. With Locus’ SaaS model, you see reduced implementation costs and no costly upgrades – everyone is on the same version. And since everything is in one place, you have a reduced amount of wasted time finding information and making it actionable.
Being cognizant of your data security
EHS managers deal with sensitive data, ranging from social security numbers to workman’s comp issues. Not taking proper care of this information can be anything from a PR debacle to a legal battle. With Locus, you have the peace of mind in knowing that your data is stored in entirety on the most secure cloud, Amazon Web Services (AWS). Not only that, but you have extensive security and admin access options, so you can have the relief in knowing only those with privileges can see certain information.
Quick access to stored information
Whether you’re looking for purchase documentation of PPEs or you need to reference yesterday’s GHG numbers, you need access to that data without having to wade through multiple applications. And with all of your data stored in one secure repository, not only can it be accessed quickly, but it can be incorporated with other tools like automated reporting.
Consolidation of compliance data
Are you still dealing with a different filing cabinet or file folder for each type of compliance? Not having your compliance data consolidated into one application means wasted time and time spent re-entering information (possibly incorrectly). Locus combines water, air, hazardous waste, DOT, PPE, workman’s comp, incidents, and more into one streamlined application to help with your organization and efficiency.
We are determined to support the needs of the user, you, first. By focusing on product development and customer service first, we feel that we have created a software as a service model that is both flexible and time-saving. If you are experiencing any of these issues with your current provider, we ask that you speak with a Locus representative today for a consultation or in-depth demo of what we can offer.
Top 10 OSHA Cited Violations of 2019
OSHA has released their most cited violations of the 2019 fiscal year, and perhaps unsurprisingly, the same mistakes are being made year after year. They are:
- Fall Protection – General Requirements (1926.501)
- Hazard Communication (1910.1200)
- Scaffolding – General Requirements (1926.451)
- Control of Hazardous Energy – Lockout/Tagout (1910.147)
- Respiratory Protection (1910.134)
- Ladders (1926.1053)
- Powered Industrial Trucks (1910.178)
- Fall Protection – Training Requirements (1926.503)
- Machine Guarding– General Requirement (1910.212)
- Personal Protective and Lifesaving Equipment – Eye and Face Protection (1926.102)
With over 30,000 cumulative violations for the top ten alone, and the same mistakes being cited repeatedly, there is an obvious need for an EHS software solution that provides a number of tools to prevent these missteps from being made. From configurable smart notifications to follow-up assignments when accidents, near misses, or when other incidents are logged, Locus EHS&S compliance software offers assurance that your safety procedures can be followed promptly and correctly.
Top Enhancements to Locus EHS Compliance Software in 2019
Let’s take a look back on the most exciting new features and changes made in Locus Platform during 2019!
Top 8 Things to Look For in Sustainability Software
Sustainability is a corporate necessity, and finding the right software to support company-wide sustainability goals and initiatives is imperative to streamlining this time-consuming activity. This is especially true if you are managing inputs from many facilities/locations or have required or optional reporting requirements. Not to mention, most corporate annual reports demand a summary of key sustainability initiatives as part of the corporate annual reporting process.
Here are some features to look for when selecting a sustainability software—to make sure your new software will actually help your company track and report its sustainability initiatives more accurately and efficiently.
1. Make sure software is accessible to everyone who needs to input data
It is very important that data owners/data collectors throughout your facilities can directly enter their own relevant Key Performance Indicator (KPI) and greenhouse gas data—no more searching for data from disparate company groups, or searching through email for spreadsheets or invoices, and no more tracking down the field technician for the field log, or hunting for other assorted documentation.
This is especially important when dealing with company locations in various geographic regions. A well-designed software system can solve this most vexing problem: finding the relevant data.
Check for the following features in any sustainability software you’re considering:
- Data stored in one managed location
All sustainability data should be stored in one place—whether text or numeric, and whether from an automatic data acquisition system, external database, hand-written field logs, or third-party documentation (e.g., air permits). - Streamlined reporting from centralized data
Reporting is streamlined because all input is consolidated in one managed location. - Standardized terminology and units
A centralized system enforces common terminology, units, and values (numbers vs. text) that are so important for final reporting. No one wants to get energy data from 10 different sources, all in different units, formats, and terminologies. - Built-in notifications and workflows
Also, look for built-in reminders, notifications, and escalations to ensure the inputs are completed in a timely manner, and if deadlines are missed, you know exactly what is missing and who to contact.
Data can come from multiple sources, and your sustainability software should be able to handle them all—then consolidate this data into a single source of truth.
2. Make sure the software application includes quality assurance and third-party review tools
Any decent software can make data collection easy, but to truly improve your company’s sustainability initiatives, it must also have tools for quality assurance reviewers and third-party verifiers to easily review the information, track the reported values to source data, and understand how the data were processed. Ultimately, the software also needs to allow the reporter to easily make updates or corrections as needed. Because these data are reported to regulators or shareholders, accuracy is paramount.
Look for the following features to support transparency and auditing:
- Visible and accessible calculations
All embedded rules, queries, and calculations should be visible and traceable to anyone reviewing so they can check the calculations and raise a flag if issues are found.
Your sustainability software should make it easy to see and understand the formulas that produced any calculated data values.
- Accessible and auditable source data and final values
All source data and final reported values should be visible, traceable, and tracked. Watch out for “black box” calculations that will confound auditors and cost you in labor hours while you are determining how the reported value was obtained, what the data inputs were, and where the source data originated. - Complete audit trails
Ensure audit trails are present for any changes in key data. You should be able to find out exactly who entered a value or who changed it. Be sure the software is keeping track and that everything is recorded and traceable to ensure the integrity of the process and reports. Good software will have an audit tool that tracks who did what, who is responsible for which datasets, and who changed which values and how.
3. Make sure the software includes tools for reporting to multiple regulatory or voluntary bodies
Many companies report to various regulatory or voluntary bodies, and the software you select should support all the major reporting requirements to avoid the need for separate calculations for some jurisdictions.
- Enter once, report 10x
Look for the concept of “enter once, report many times” when reviewing software applications. The gold standard is the capability for reporting methodologies and calculations configured for reporting to multiple agencies from a single dataset, all in a single tool. - Check support for your actual, specific needs
Review your reporting requirements to see if the software handles them. Key reporting requirements include state or federal regulations, internal corporate social responsibility (CSR) and other sustainability reporting, the Carbon Disclosure Project (CDP), Global Reporting Initiative (GRI), and The Climate Registry (TCR). - Consider export formats
Ensure the software includes exports to XML, which is a common format for EPA and ARB reporting, and an option for reporting to other agencies. Having such outputs easily generated from the software will save time and money during the reporting season.
Find out what formats you need for regulatory reporting, and make sure your software supports exporting in these formats.
4. Look for data verification flags so you don’t spend time fixing obviously bad data
If you normally report 500 metric tons of GHG per year and you are finding entries of 500,000 metric tons per year in your data, chances are, it’s just simple data entry errors. However, no one wants to track these down months after the data entry event. Look for software that will flag these anomalies on entry and force the user to fix them before you ever get to the data review step.
- Ability to set validation rules
Look for software that allows you to set rules to flag data entries that fall outside of expected thresholds, catching errors before they make it to QA personnel or auditors. - Options to specify acceptable ranges and add comments for unusual values
Look for features that will help you avoid last-minute questions about the validity of your data. Look for the ability to specify an outlier range to flag values so that you can address them immediately before the report is due. Allow for the opportunity to enter a comment right alongside the flagged value, providing a record that the value was double-checked and is correct for a specified reason.
Immediate, inline alerts about outlier data values help prevent last-minute surprises.
5. Look for user-defined workflows to help you and your users step through sustainability reporting and tracking process
The sustainability software you select should help simplify data entry and reporting by supporting your preferred workflows. Software with configurable workflows can be a huge help for both data entry personnel and managers reviewing data, by making the status of all data entry and reporting business processes abundantly clear.
- Options for lockdown after manager review
Look for the ability to include manager overrides to data entry and workflows that will lock the data entries to editing once reviewed. This will help ensure others are not modifying data while you are in the report preparation process.
Options for managers to lock down data are important for preventing edits to data that is being prepared for reporting.
- Quickly identify current workflow status
Check for easy visual indicators of workflow status to ensure the process is on track to be completed by the reporting deadline.
There should be an easy way to see the current workflow status of any data in your system.
- Easily modify workflow along the way
Also look for the ability to easily modify the workflow if your original configuration was not optimal. Not everyone knows the best workflow for new software when they initially start using it. The ability to modify the workflows—without needing a software developer—is an important feature to consider when choosing a sustainability software solution.
6. Look for robust audit trails to help solve “whodunit” issues
All software that handles critical or regulatory data should provide auditing on key data fields. Find out the details of what is audited and how you will be able to access the audit information.
- Full history of all changes
Software should retain a history of values with every report change. - Who, when, what
Look for a complete audit trail of who did what, and what was changed, and when. Tracking any modifications to values supports a rigorous audit and is sure to make your QC staff really happy.
Your software should be automatically recording a history of all changes at each step of your workflow.
7. Look at out-of-the-box data outputs—but also consider how easy (or hard) it will be to create specific reports for your corporate needs
Every software has built-in report and dashboards, but they may not meet all your needs out-of-the-box. Assume some reports will need to be configured, and review the software accordingly.
- Tracking specific KPIs
Does the software provide an easy way to track year-to-year KPIs for internal evaluation or for preparation of public-facing sustainability reports? - Consider future reporting and visualization needs
If you need a new report, chart, or other visualization of your data, will this request incur a custom software development charge, or is it an easy configuration? - Adapt dashboards to your needs
Can you easily customize the software’s default dashboards?
Look for options to easily configure reports, charts, and other visualizations that help you easily review summaries of your data.
8. Make sure the software has a robust notification engine
Software can shoulder the burden of getting people to do what they are supposed to do (reminders), alerting people to when an action is needed (notifications), sharing information (messaging) and sending them information (report notifications). Be sure to review the strength of all notification features of the software, as this can be a huge help during reporting season—and it can lighten the burden on your inbox as well.
- Multi-purpose notifications
Look for routine workflow notifications to ensure you are notified when a workflow step is completed AND if a workflow step is ignored beyond the due date. - Actionable notifications
Look for reporting notifications that will send the link (URL) to applicable users so they can quickly jump to the information in the software. No one likes knowing a report is ready, but then having to log in and search for it. - Group and individual notifications
Ensure you can send notifications by individual user OR to user groups. It can be very tedious to select large numbers of individuals for routine notifications—it is much easier to select “all Facility XYZ EHS staff”. - Decide where to receive notifications
Consider in-app messaging to keep important information in front of the users and spare their inbox.
Final thoughts: Imagine what implementation success looks like
While you are evaluating software options, use these points as a guide to make sure you choose a solution that will truly make a difference for your organization’s sustainability initiatives and reporting goals.
As more sustainability software solutions appear in the marketplace, it can be difficult for a company to discern which features really matter for its workflow. Try a simple exercise—imagine what a perfect sustainability management business process would look like if you found the perfect software solution. Consider the challenges you face now, and what it would look like if those problems were handled by your software.
Then, ask how well the sustainability software you’re considering will make this dream a reality. The right software selection can help reduce operational risk, fulfill regulatory reporting requirements in less time and with less effort, and provide safeguards against bad data and missed deadlines. All you have to do is ask the right questions.
Get more tips for what to look for when evaluating EHS&S software!
Tag Archive for: Compliance
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