With 2020 reporting largely behind us (TSCA CDR being the primary exception), now is a good time to shift focus to 2021. The “reporting season” (loosely defined as January through June) presents data and compliance challenges every year, inevitably leading to time crunches and potentially stressful deadlines. Here are three things companies can do now to help alleviate reporting season headaches and stress.
1. Focus on current recordkeeping practices
This time of year presents a great opportunity to get your facility's data organized in anticipation of the 2021 reporting season. Identifying potential gaps now gives your facility the opportunity to fill these gaps before 2020 is over. This review also allows you to ensure existing records are complete and accurate while the information and events related to the records are still relatively recent. This type of proactive approach gives you the opportunity to start updating calculation spreadsheets to incorporate known changes, easing the burden of the upcoming reporting season. Consider reviewing and incorporating the following records now in preparation for a successful 2021 reporting season:
- Production data - ensure relevant production data is being tracked by the facility, especially for new processes that will be considered for the first time in 2021.
- Chemical data - review Safety Data Sheets (SDSs) and current supplier information for chemicals used at your facility to ensure your reporting spreadsheets (Tier II, TRI, emissions inventory, etc.) are using the current data. Request new SDSs from suppliers for any SDSs that are exceedingly dated.
- Manufacturing changes - evaluate new and changed production processes to understand how the changes will affect environmental reports. Document when changes occurred and identify any potential gaps in information that should be gathered before the end of 2020.
- Spill events - ensure all media releases are accurately quantified for potential implications to Toxic Release Inventory (TRI) reporting, emissions inventory reporting, hazardous waste reporting, etc.
- New testing and emissions data - consider how new sampling and test data (e.g. stormwater, wastewater, hazardous waste, stack test or emissions data) will be incorporated into existing calculation workbooks and how this may affect reports (e.g., exceed a TRI reporting threshold for coincidental manufacture).
- Startup, Shutdown, and Malfunction records - ensure these commonly overlooked records are considered for reporting implications.
2. Evaluate EHS software and benefits to your organization
Collecting, validating, and reporting environmental, health and safety data is one of the most time-consuming aspects of EHS management. Companies often use the fall to evaluate the benefits of implementing an EMIS and plan for software selection and implementation projects. EHS management information systems (EMIS) are digital tools that help to ensure facility records are complete, timely, and accurate. When deployed effectively, an EMIS can help:
- Minimize stress and time when compiling annual reports
- Streamline data collection efforts within your organization
- Provide improved visibility into data on a year-over-year or month-over-month basis
- Enable upfront identification and resolution of data quality issues or anomalies
- Minimize efforts on follow up questions and comments from agencies once your report is submitted
These benefits allow you to maintain focus on current operations and data tracking efforts within your organization, and alleviates time constraints during the reporting season.
Whether you already own an EMIS, or are just interested in learning more, Trinity's EHS Digital Solutions team can provide unmatched expertise and guidance to equip you with the proper digital tools for effectively managing your facility's reporting requirements.
3. Know what you don't know
Discovering a compliance gap, or change to regulations in the middle of reporting season activities and deadlines is not a fun experience. Similarly, EHS professionals must stay current and proficient in an increasing number of online reporting programs as individual state agencies and EPA continually push for electronic reporting. EHS personnel often ask “How can I know what I don't know?” Multimedia compliance audits and EHS training are two simple ways to prepare yourself, and your company for new reporting requirements.
Completing internal self-assessment audits, or contracting for an expert, third-party auditor to assess your facility is one way to identify compliance gaps. Learning about changes to regulations and applicability can be challenging for companies, even after a self-assessment audit. Attending training events this fall can help ensure you have the most current information on reporting requirements before the time-intensive reporting season begins. Trinity offers 38 state level courses that focus on environmental reporting and recordkeeping practices, including Introduction to Environmental Regulations (Multi-Media) and state-specific reporting courses.