Tag Archive for: Compliance

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:

  1. Fall Protection – General Requirements (1926.501)
  2. Hazard Communication (1910.1200)
  3. Respiratory Protection (1910.134)
  4. Scaffolding – General Requirements (1926.451)
  5. Ladders (1926.1053)
  6. Control of Hazardous Energy – Lockout/Tagout (1910.178)
  7. Powered Industrial Trucks (1910.178)
  8. Fall Protection – Training Requirements (1926.503)
  9. Personal Protective and Lifesaving Equipment – Eye and Face Protection (1926.102)
  10. 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.

See our Health & Safety App.

 

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.

Unified EHS Platform - Infographic

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).

Impacts of COVID-19 on EHS | Locus

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.

Manager in hardhat looking over his factory-Locus automation and sensors solutions prepare your organization for the Internet of Things

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.

Engineer with tablet and oil rig tower- Locus software solutions for the Energy, Oil & Gas industries

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.

EHS Hardhats and Jackets

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.

Regulatory Change Alerts

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.

 

Low maintenance costs

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.

 

Data security - AWS - cloud

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 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.

 

Compliance data consolidation

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:

  1. Fall Protection – General Requirements (1926.501)
  2. Hazard Communication (1910.1200)
  3. Scaffolding – General Requirements (1926.451)
  4. Control of Hazardous Energy – Lockout/Tagout (1910.147)
  5. Respiratory Protection (1910.134)
  6. Ladders (1926.1053)
  7. Powered Industrial Trucks (1910.178)
  8. Fall Protection – Training Requirements (1926.503)
  9. Machine Guarding– General Requirement (1910.212)
  10. 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!

[sc_icon_with_text icon=”tasks” icon_shape=”circle” icon_color=”#ffffff” icon_background_color=”#52a6ea” icon_size=”big” level=”h3″]

New Task Types

Two additional types of task periodicity have been added: Triggered tasks, which allow the automatic creation of a Task based on the creation of a triggering event (e.g., a spill or storm event), and Sequenced tasks, which allow the creation of a series of tasks in a designated order. Learn more about our compliance and task management here.[/sc_icon_with_text]

[sc_icon_with_text icon=”mobile” icon_shape=”circle” icon_color=”#ffffff” icon_background_color=”#9ac63f” icon_size=”big” level=”h3″]

Mobile Form Builder

Users can now create a mobile version of any data input form. Every form in the desktop platform can be mobile-enabled, so you can introduce new ways of streamlining data collection to your team.[/sc_icon_with_text]

[sc_icon_with_text icon=”workflow” icon_shape=”circle” icon_color=”#ffffff” icon_background_color=”#3766b5″ icon_size=”big” level=”h3″]

Process Flow

‘Process Flows’ have been added, which guide users in completing processes following a simple step-by-step interface.[/sc_icon_with_text]

[sc_icon_with_text icon=”facility” icon_shape=”circle” icon_color=”#ffffff” icon_background_color=”#52a6ea” icon_size=”big” level=”h3″]

Expanded Facilities Management App

Our expanded Facilities Management App is designed to map at the enterprise level showing all locations, navigate your facilities hierarchy to review information and quickly take action at every level. Locus Facilities is a comprehensive facility management application that aims to increase the efficiency of customer operations and centralize important company information.[/sc_icon_with_text]

[sc_icon_with_text icon=”settings–configuration” icon_shape=”circle” icon_color=”#ffffff” icon_background_color=”#9ac63f” icon_size=”big” level=”h3″]

User Configurable Dashboards

Users can choose from existing portlets (found on the dashboard pages) to customize their landing page to their unique needs. Create custom dashboards to highlight exactly the information you want in any format (charts, maps, tables, tree maps, diagrams, and more).[/sc_icon_with_text]

[sc_icon_with_text icon=”email–contact” icon_shape=”circle” icon_color=”#ffffff” icon_background_color=”#3766b5″ icon_size=”big” level=”h3″]

Edit via Email

Add notes to any record by sending an email directly into the system. Allows anyone to add or append to a record in the system simply through email.[/sc_icon_with_text]

 

 

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.
Multiple data sources

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.

    EPA equations

    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.
Regulatory formats

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.

    Fuel warnings

    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.

    Edit workflows

    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.

    Workflow status

    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.

    Workflow history

    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?

    GHG emissions dashboard

    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.

Robust notification engine


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.

The complete guide to evaluating EHS software

Get more tips for what to look for when evaluating EHS&S software!

Download eBook.

 

 

Blockchain: aggregate emissions reporting

In the next few years, an opportunity exists to make significant advances in how we monitor and manage environmental emissions to the air, soil, and water, potentially resulting in significant disruptions in current approaches. Currently, industries and commercial establishments monitor their emissions and submit reports on a regular basis, often as frequently as quarterly, to federal and state agencies to demonstrate they are meeting regulatory requirements. However, no one on the generating or receiving end of these data dumps and reports is aggregating these emissions to create a more composite, inclusive picture of emissions across sources or media. The reason is that emissions of different types and to different media are reported to separate regulatory entities that, in general, do not interact or talk to one another. And although there are significant potential benefits to both generators and regulators in reviewing integrated environmental data sets, our traditional methods of storing and sharing this information make such integrations a hugely difficult effort.

Only by integrating all available data can we begin to (1) assess local, regional, and ultimately the global impacts of these emissions, and (2) identify net improvements to our environmental practices that are only apparent when looking at the combined, interconnected body of collected data. Blockchain enables the integration of these data sets for quick, yet comprehensive “big picture” assessments.

Blockchain technology is a highly disruptive technology that offers an efficient way of storing records (called blocks) which are linked using cryptography. While still in its infancy, blockchain promises to change the world as we know it, much like the internet did after its introduction in 1991. Today, the technology is most widely associated with digital currencies and money transfers. In time, however, blockchain technology will not only shift the way we use the internet, but it will also revolutionize the global economy and almost all transactional business that relies on an intermediary.

One Environment, Health, and Safety and Sustainability  (EHS+S) sector well positioned to benefit from blockchain technology is emissions monitoring and reporting. I reported more on the technology and its impact on EHS space here.

Environmental monitoring current practice

Presently, companies with emissions monitor these following regulatory requirements, input the resulting data into a database or spreadsheet, perform emissions calculations on the entered readings, and then report the results of these calculations to regulators. The entire focus of this process is to (1) determine whether emissions of a single chemical or chemicals exceed prescribed levels and (2) evaluate the effect of these discharges on the media to which the compounds have been introduced by the polluting industry or other sources. There is no suitable software technology or mechanism to look at aggregate emissions across geographical areas or sectors or how emissions of one type interact with emissions of an entirely different kind. Examining such interactions could be far more critical than monitoring and assessing the impacts on human health and the environment of single parameter emissions to only one media, and may reveal new opportunities for optimizing our EHS+S practices for reduced cost with similar or improved performance.

Aggregate emissions

To take a hypothetical scenario, consider the possible consequential damages when two incompatible streams of chemicals or waste mix to create even worse chemicals as a result of their chemical reaction.  EPA has only recently started looking into these type of scenarios. Its Envirofacts databases allow the public to retrieve information from multiple sources of Envirofacts’ System Data relevant to your area of interest. However, each database is a separate silo of information (Figure 1). The next step that ought to be taken is to assess and as needed, report on the possible interaction of incompatible emission sources that are nearby, but are independently monitored and stored in disconnected databases (see Figure 2 below).

EPA Envirofacts 1

Figure 1: EPA Envirofacts databases allow the public to retrieve information from multiple sources, but only one source at time and disconnected from each other.

Most everyone taking prescription medicines comes to understand that interactions between drugs are quite common. Imagine something similar to the interaction of drugs in your body happening on a much larger scale in the environment. One does not have to imagine. EPA recently imposed the highest environmental fine ever at the 2,530-acre Eastern Michaud Flats Contamination Superfund site near Pocatello, Idaho. Two adjacent on-site phosphate ore processing facilities, the FMC Corporation and the J.R. Simplot Company, began operations at the site in the 1940s. The J.R. Simplot facility produces solid and liquid fertilizers using phosphate ore, sulfur, air and natural gas. The FMC plant is North America’s largest producer of elemental phosphorus which is used in a variety of products from cleaning compounds to foods.

Operations at these plants have independently contaminated both the groundwater and soil with hazardous chemicals. Both plants have received numerous environmental violations, many of which were settled with the EPA. Each of the sites has its environmental ills (and fines), but the more significant environmental problem is a combined regional plume. Everyone knows that acids and metals do not play well together. Sulphuric acid from the J.R. Simplot operation has leaked from surface impoundments into the groundwater and, on its way downstream, has leached all kinds of toxic metals from the FMC site, creating a highly poisonous plume of contaminants. An accurate assessment of the environmental disaster that exists in this area requires that the environmental impact of the two plants be examined in toto. Blockchain-based monitoring technology would allow both the public and regulators to see the resultant subsurface commingled plume and possibly pave the way to a more comprehensive remedy.

Issues involving contamination of multiple media have also arisen at sites where discharges of volatile organic compounds or VOCs have occurred. In Silicon Valley, where I live, many engineering consultants have made their living chasing plumes of VOC chemicals (e.g., TCE) and then, when deemed appropriate, have installed various groundwater treatment plants tucked in the back of parking lots of companies like Google or HP to ameliorate this contamination. Santa Clara, the central county in Silicon Valley, is home to more Superfund sites than any other county in the United States.

The process is analogous to rinsing detergent from a sponge. After many rinses, it still seems to have more in it. It is an endless process with little environmental benefit. Has anyone looked at the additional impact of the high energy demand for treatment systems that have minimal effect on improving groundwater, but can contribute significant CO2 equivalents to the atmosphere?

With blockchain technology, we could simultaneously measure the positive effect of the treatment plant removing contaminants from water and the negative impact that this same plant produces by contributing to the CO2 emissions. Quantities of removed chemicals over time could be plotted in real time vs. CO2 emissions produced resulting from high energy usage of the treatment plant. This would allow companies operating treatment plants and regulators overseeing them to determine at what point in time continued treatment could be harming, not helping the environment. It is these type of analyses that would benefit society and help with the decision to shut down a remediation process when diminishing returns of the treatment system are reached.

EPA Envirofacts 2

Figure 2: Interaction of incompatible emission sources is better managed if emissions are aggregated than if independently monitored and stored in disconnected databases.

How would blockchain technology help in a scenario like this? Chemical removal rate would be tracked in one block (of the chain) and CO2 emissions in another. Owner and regulator would agree on the formula to determine when the treatment process ceases to produce a significant environmental benefit. At this point, the system would be shut down. All of this would be monitored and measured in real time, and more importantly, it would be transparent to the owner, regulator, and the public.

Emissions measures should be preemptive, not reactive

When you think about emissions, they are generally (except incidents and accidents)  operating problems that can be managed and optimized before discharges even happen. It is to the benefit of companies to do it this way. Every process that has an exhaust or smokestack for dispersing air emissions or pipelines for discharging liquids to surface receptors or water bodies could be managed to reduce harmful emissions coming out the system regardless of regulatory prescribed permissible levels. As an organization with a legacy environmental site knows, it is far more cost-effective to eliminate the original cause of emission than to spend decades of effort to remediate after the fact.

Unfortunately, many businesses are currently not genuinely looking at the aggregated data they collect about their emissions, wastewater, and energy use alongside their operational metrics. Current practices for EHS+S data management only allow for very simplistic comparison of normalized indicators between these disparate data sets.  But it would benefit these operators to gather, aggregate and analyze data, and then make better, more cost-effective decisions as part of their risk-management protocols, while still maintaining their environmental compliance requirements. Blockchain technology allows for review of more detailed data when making decisions with aggregated data sources so that managers can look beyond the simple normalized performance indicators. For example, many organizations only review their environmental and sustainability performance on an annual basis, mainly because the current tools to aggregate this data require them to be evaluated on a consistent time frame, and there is a significant investment in bringing all of the relevant data together. But through blockchain technology, the data maintain their connection at every level.  This allows for trend evaluation at other time frames not currently being examined. So if some short-term operational practice causes a spike in emissions, that issue can be identified and resolved immediately, rather than waiting for the end of the year, when the emissions have already happened, and the effect may not even be apparent when averaged out on an annual time frame. Then, even looking beyond the facility or organization, blockchain also allows for data aggregation across industry, region, and country, so that we will be in a better position to forecast the future and assess the viability of different measures to ameliorate the problems confronting us.

A bigger picture

There is a growing need for companies to bring together information from their vast disconnected databases, single tenant clouds, and spreadsheets, and then mine the data they collect from these sources. In a decade or so, planet Earth may be a meshed grid of static sensors coupled with movable ones installed on people, animals (yes animals roaming in the wild), transportation devices, and other moving objects to collect data in real time. The conversation about the environmental landscape has evolved drastically over the last 50 years as we continue to understand the extent to which human activity has affected the planet. Companies and society need a collective and holistic understanding of the problems we face.

The only way to understand the full picture, and in turn to act meaningfully on a global level, is for all individuals and companies to understand the impact of their activities. It’s impossible to mitigate the net risks and effects of these activities on the planet when we have not fully assembled the data to characterize the problem and understand the full picture. Blockchain technology offers the best path forward, making it possible for environmental data be integrated at multiple levels. Any coordinated effort of this magnitude will be years in the making, but every journey starts with a first step. There are two impediments to institute a change like this: technology (until recently, blockchain did not exist) and a government with the initiative to require such technology. Just as was the case with the internet revolution of the nineties, the rate of progress in technology is surpassing politicians’ ability to come to grips with its impact on society.

So far, there have been no imposed data exchange standards; a prerequisite for a broad data exchange, land for implementation of blockchain technology.  But in the meantime, progressive organizations will want to start taking advantage of this technology to look at their operations and make more informed EHS+S decisions.

Looking forward with blockchain technology

Perhaps blockchain technology is not ready for prime time. Some may argue that it creates a secondary problem of additional energy consumption much like water treatment systems described earlier. This is a theme that is advocated by some media outlets and blockchain skeptics who argue that the computer algorithms require significant amounts of electricity to power the servers on which they run. Estimates of blockchain’s soaring energy use are likely overstating the electric power used as the current debate on power consumption is not backed by hard data. When it comes to technology, history has consistently shown that the cost will always decrease, and the impact will still increase over time. It is inevitable that blockchain technology will become more accessible with reduced infrastructure over the next few years.

Blockchain IoT Decentralization

Blockchain could completely change how companies run their businesses and present new opportunities far beyond sustainability and environmental emissions management.

We are living in a world where companies and governmental agencies are not able to comprehensively analyze  EHS+S information efficiently. Using blockchain technology will allow organizations to track, store, rollup, gain insights into, and also share their data with other interested parties as needed. It has the potential to put accurate and verifiable information into the hands of companies and regulating agencies more quickly. To make better progress on how we use EHS+S information, regulators will need to find ways that reward positive and proactive behaviors. We are not going to solve these issues by fining emitters until they behave. Blockchain technology can help us move us away from the punitive approach and toward a more collaborative one by assisting companies to reduce their emissions while lowering their operating costs at the same time. Social sharing elements may also play a role here, giving companies that benefit from the fruits of blockchain technology a valuable marketing and PR advantage over those who do not adopt this technology, and as such, lag behind in their progress on environmental issues.

12 ways commercial SaaS can save your complex environmental data (part 4/4)

In the final part of our 4-part blog series, find out how cloud environmental databases enable better data stewardship and quality assurance.

Tag Archive for: Compliance

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