Planning for Compliance Reporting

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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
    * The Challenges
    * Reaping the Benefits
    * Planning a Management Information System
    * Compliance Reporting
    * Trade Associations and Regulators
    * Summary

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:

    * Corporate image companies now actively engaged in reducing the reputational risk associated with environmental matters
    * Sectoral initiatives which include reporting (voluntary, economic, benchmark driven, formal membership requirement e.g. Responsible Care)
    * Emissions trading maximising opportunities in this new market, whilst complying with trading rules
    * Management systems not just maintaining certifications to ISO 14001 and OHSAS 18001 but also demonstrating continuous improvement
    * Keeping investors happy an increasing need to keep investors appraised of company ethics and approaches to sustainable development issues

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:

    * Managing the workload chemical companies produce multiple reports for different audiences. Just keeping track of what data is needed and what reporting format is required can be time-consuming enough alongside other operational priorities.
    * Avoiding inconsistencies often the same source data is manipulated in different ways to present to different parties. This creates a major challenge when information is updated to avoid inconsistencies. In addition different parts of the organisation can have differing definitions and approaches to deriving what can appear to be the same data.
    * Meeting the standards the standards for EHS data integrity and verification methods are rapidly evolving as are the (emissions trading is the most extreme example of this). Using spreadsheet-based systems to meet these standards will not be feasible for much longer.
    * Keeping the initiative there is a lot more information on environmental performance within the public domain – not all of it accurate! Companies need to maintain the initiative on communicating their performance, disregarding the concept of an annual reporting cycle if needed. For this need, a ready access to up to date information is vital.
    * Facilitating change to achieve the culture change needed to improve EHS performance it must become integrated with the operational responsibilities of staff across the organisation. The number of people needing access to EHS performance information is also increasing – it is no longer the domain of a few specialists.

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.

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