Planning for Compliance Reporting

By Prab Mistry and Tim Dowling
August 2002

Dr. Mistry is an environmental consultant based at AEA Technology, at Culham in Oxfordshire. Mr. Dowling is marketing and sales manager with Monitor-Pro, a division of EHS Data Ltd, based in Wigsley, Nottinghamshire.

Abstract

Companies are already responding to challenging demands for environment, health & safety (EHS) data. These challenges continue to grow both in respect of the amount of data generated and reported and the requirements for data integrity. The growing demands arise both from new legislation and increased interest from a broad range of stakeholders.

The need for better EHS information also applies within the organisation. As companies strive to improve performance EHS information needs to be made available beyond the EHS Function to decision makers and across the organisation.

EHS data exists right across an organisation but until recently has not been brought together in a central point, where different data streams can be compared against each other and used as the basis for business decisions. Generally, EHS data management does not yet have the structures or rigour of financial or other data in organisations, or the sound IT infrastructures needed to support this.

This paper examines the challenges that industry faces and provides a case study showing how two companies have worked together to understand how they can get more value from their environmental data. The paper also gives a framework solution to the challenges being posed by the IPPC permit and reporting requirements.

Contents

Introduction

Gone are the days when EHS managers alone managed EHS data and where it only bore relevance to their own operations – now EHS data has a value to people across the organisation and outside. But why has this change occurred and how are people sharing data?

Compliance is key behind all of this. This is not solely for immediate regulatory purposes such as IPPC and emissions inventories, but may also be extended to compliance requirements of broader stakeholder Group (investors for example). Additional concerns include:

The Challenges

All of these factors point to the need for improved management of EHS data, but many companies that have embarked down this road have encountered significant hurdles:

Reaping the Benefits

The nature of these issues have meant that companies have had to take more time and care than they initially expected in reviewing, understanding and designing their new data management approach. At this point, it's not just about getting in a new bit of software to sort everything out. To apply integrated EHS information management requires alignment of EHS data streams with existing systems, making data available to new people and ensuring that EHS data is used in the wider operations of the company. This requires a degree of planning with broad engagement across those affected before benefits can be realised.

Managing this change in the face of reducing manpower and budgets may seem daunting at first. However, mapping out your data streams can be a useful starting point:

1. Your data What data sources do you have (spreadsheets, plant historian)?
How does your data come in (manually, via e-mail, remote monitors)?
How often is data created (sporadic to continuous)
What format is your data in (standardised units, level of accuracy)?
Is the data aggregated or factored?
Is the data secure?
2. What systems do you link with? Material Safety Data Sheets
Process monitoring equipment
Property/Geographical Information systems
SAP-type financial systems
Personnel records
3. How is the data used? Monitoring and Control
Regulatory reporting
Management reporting
Shareholder reporting
How often do you report?
What KPIs do you use?
What medium do you report to (paper, web)?

One conclusion from this process may be that the data management task is more significant that at first thought. The response of many companies has been to move towards EHS management information systems to replace the spreadsheet or database oriented manual data collation, analysis and reporting. These management information systems provide significant advantages in terms of cost savings as well as improving the reliability, audit trails and transparency of the reports that are submitted to the regulators and/or stakeholders.

Two companies in the NE of England have recently adopted software-based solutions to bring together multiple sources of information to derive more useful management information system (see Box 1). As a result they have a more consistent, effective and timely means of communicating their land quality information.

Monitor-Site Manager helps manage complex site issues for two companies in the North East

The issue of land quality is now increasingly affecting businesses and various regulatory regimes are forcing companies to take stock of their land. IPPC, for example, requires companies to provide land quality information in their application whereas Part IIA of the Environmental Protection Act 1990 may lead to the designation of land as 'Contaminated' and requirements for investigation and a possible clean-up. Consequently, land contamination affect business performance as remediation systems soak up cash and resources. Advanced data solutions have recently been adopted by two Northeast companies, Phillips Petroleum Company UK Ltd and Seal Sands Chemicals Ltd, with promising results. The companies have installed Monitor Site Manager to help manage and review data.

With all potentially contaminated land work it is important to manage data and within the framework of environmental risk. Both companies have implemented the Monitor Pro - Site Manager software that allows users to view and understand the issues in a spatial form (i.e. is there any risk of contamination?). The system provides both the flexible analytical tools required by specialists and predefined templates which allow rapid routine reporting. Their greatest benefit has been the rationalisation of and access to all monitoring data for potential land contamination issues for both groundwater and soil, and for sites going back several years.

Site Manager incorporates powerful Geographic Information System (GIS) and database tools, which enable users to view sample locations (i.e. boreholes) on a map, site drawing and aerial photograph and interrogate the data (groundwater levels, contaminant concentrations) associated with the boreholes over time. Data can be visualised in the GIS as well as in graphical and tabular format and reports produced at the touch of a button. All the data contained in the system can be linked (hyperlinked) to project reports, borehole logs and any other relevant management documentation and comments.

Not only does this mean that Phillips Petroleum and Seal Sands Chemicals are better able to understand their own data but they also benefit from the ability to present information to third parties more effectively. In these cases others too can far more easily understand the nature of the issues arising from the whole project and the effective management of the environmental risks is clearly demonstrated.

Planning a Management Information System

Companies already possess sophisticated IT systems (and often multiple systems) to manage different operations or functions. These include finance, personnel and production, but rarely EHS.

It is only recently with the increasing standardisation of computer-based systems that companies have considered it feasible to integrate EHS data into the wider business information system. For those who have tried, the results can bring business performance improvements by spotting trends and problems earlier and through improved communications with regulators and other stakeholders. Along with this can come a very substantial time savings by reducing the routine and low-value elements of EHS data processing and management. Box 2 illustrates key features of a management information system (MIS). A MIS infrastructure requires a tailored structure for data flow and auditable data trails, before it can be used as a tool for compliance reporting.

Key features of Management Information System

Consistency vital to ensuring that common rules apply to all data.
Auditability being able to identify the source of data and track any changes made
Integrity ensuring that imported data is correct and any KPI calculations are traceable
Efficiency importing, processing and reporting data quickly and accurately within minimal human intervention
Scalability having the ability to increase in size and capability to meet organisational changes
Output formats able to communicate with other corporate systems and adaptable to multiple formats such as web, paper and electronic.

Compliance Reporting

Many UK companies are preparing to apply for an IPPC permit, as required under the Pollution Prevention and Control Regulations 2000. Even with effective (and often certified) environmental management systems in place it can be difficult to demonstrate control over their processes and emissions. Figure 1 illustrates a good practice IPPC permit monitoring and reporting system which can be implemented using an Environmental Management Information System (EMIS).

These systems cannot be installed overnight. As previously discussed they require planning, integration and implementation through broad engagement across an organisation. It is easy to underestimate the time needed to define a solution. Future IPPC applicants should do well to examine their requirements towards an EMIS well in advance (at least a year) of the requirement.

Figure 1. IPPC permit monitoring and reporting system
IPPC permit monitoring and reporting system

Trade Associations and Regulators

Trade associations and regulators are already aware of the emerging EHS data management technologies. These organisations are custodians of huge amounts of data and need to ensure that scarce resources are directed where they can have the most impact, both to regulate and understand the impact of regulatory policy. Where EHS regulations and technology applications are changing rapidly, more rapid turnaround of performance data analysis for reporting and benchmarking is vital to help industry make informed decisions about compliance.

Some regulators are already receiving live telemetric data (for example from power stations). Such technology development opens up opportunities to re-define the way in which regulators monitor industry.

There is also interest in data management systems from those trade associations looking to more-effectively represent their members to the public and other stakeholders. The future is likely to see more open reporting of interactive or information-only access to the members and to public over the web.

Summary

Increasingly companies are realising that their EHS data is an asset that should be more effectively used for purposes beyond simple compliance. These demands are likely to require more than a sticking plaster solution – as data is generated across the whole of the organisation and needs to be reported back to them and others outside.

A thorough look at what data your organisation has and what you need to do with it is likely to pay dividends when you come to look at how it will be managed in the future. Whilst software will help overcome the day-to-day activities, without proper planning, its value will diminish.

The practical benefits that companies can reap from implementation of Environmental Management Information systems include:

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