Compliance Minute – Waste Profiles
When looking for a GHG reporting program, there is one element that is typically overlooked. This short video gives us more insight.
When looking for a GHG reporting program, there is one element that is typically overlooked. This short video gives us more insight.
Locus Technologies, Nancy-Jeanne LeFevre walks through the process of identifying a project pathway boundary in this short video.
Chris De Cree, an EHS Implementation Manager from Locus Technologies walks us through our container tracking tool.
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.
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.
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.
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.
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.
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.
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.
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:
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.
Let’s take a look back on the most exciting new features and changes made in Locus Platform during 2020!
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.
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.
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.
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.
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.
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.
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.
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.
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:
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.
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Locus Technologies provides cloud-based environmental software and mobile solutions for EHS, sustainability management, GHG reporting, water quality management, risk management, and analytical, geologic, and ecologic environmental data management.