Amanda
Host
00:10
Welcome back, Shannon. We're excited to have you today. So, continuing our previous chat about record keeping and what makes it difficult, where are we on that?
Shannon
Host
00:56
Well, record keeping is difficult for three reasons, and I call it the three legs of the record keeping stool. We talked last time briefly about each one of those legs and I wanted to dive in deep on one of those legs this time. And that's the poor setup. If you have poorly set up records, that can really impact how good your record keeping can be. We like to talk about it as quality in quality out. There's an opposite phrase that I don't like to use because it's so negative, but when you put quality into a system, you're going to get quality products out. Sometimes, with record keeping, what's going into the system isn't necessarily a very good product for what you're trying to do with it.
Amanda
Host
01:42
Understandable. So how do you know when there is a setup problem?
Shannon
Host
01:46
Well, some of the symptoms of a poor setup problem is the person who's being asked to complete the record keeping is complaining about having to do the same stuff but on multiple records. Right, like, oh, i have like six. I have six checklists facility inspection checklist and they all ask me to look at the secondary containment liner and the condition of the liner. Or you know, i have to do all of these different records just about my oil water separator. I don't know why I have to do three. There's only one oil water separator.
02:24
What that tells me, looking from the outside in as a consultant, is that they had three different plan writers and each plan writer was like oh the oil water separator is an important function of this permit, so I'd better have a form for it.
02:37
And When you have different writers for each permit, they can't see the other permits, they can't see internal documents, they can't see all of the pieces that go into making a record keeping workload for somebody. And so they are meeting the requirements of the permit, hopefully, but they are causing confusion because there's no context of what else is out there And so somebody, whether that's a consultant or an environmental manager within the company they need to be looking at these records and determining if these questions or inspection points have been answered in other places And whether it really needs to belong on this record, or if there can be some consolidation or streamlining of these records so that somebody's not answering the exact same question for four or five different permits. They are only answering it once and that record is used to meet all of those permit requirements.
Amanda
Host
03:37
What causes record keeping to be poorly set up or confusing? I know you did touch on that lightly with multiple hands in the jar.
Shannon
Host
03:46
Yeah, I think that a lot of records are generated for record keeping for environmental stuff, because a planner permit is required by a regulation and the company outsources the writing of that permit. Not always, sometimes someone internal writes it, but they often hire a company to come in and write the permit. But it's not the same company for all the permits, because many companies just specialize in air or water or spill response. They don't necessarily specialize in bulk fuel storage like our company does, and so our company looks at all the permits for an industry, but a lot of other environmental companies look at the permit and they're an expert in the permit but they're not necessarily an expert in the industry, and so what we see is that there is a bit of confusion because they're writing it for, in general right to apply to multiple industries across the entire United States right, because that's what the big companies do and there's nothing wrong with that. But somebody, either the consultant or the environmental manager, needs to look at that record as it comes in with the permit and do some streamlining, do some modification, do some, you know, make some management decisions to allow it to not be confusing all the way down at the terminal manager level, we also see a couple of contributing factors in the fact that updates or renewals to these permits are often lagging like they are ordered, they're on their way, and then when they come terminal managers because they wanna do a good job, they don't necessarily have like copy control and so they may actually be doing multiple years of record keeping because they're afraid to stop doing the old record keeping.
05:31
And then they have new record keeping when a renewal comes through and I can't tell you how many times I've gone in and they're actually doing the exact same record keeping, but it's from two different versions of the permit the one that was written in 2012, and then they had a renewal in 2017, and then in 2020, and they've got some records from all of those floating around and they're completing them all because they're terrified to not do it.
05:53
Well, but it's creating an enormous workload for them. That isn't necessarily needed, and the reason it's not just like it's the exact same record, but with the date on the bottom, is the reason is the regs update and so they all look a little different. So there's not been that executive decision of don't do 2012, don't do 2017, only do the 2020 forward because that's the one that is most current right, and if there is no executive decision-making being done by an environmental manager or an oversight consultant, like what we do, the terminal manager is stuck with all these records and there's no stop date on them, so they continue doing it. That copy control is a really important part of a healthy record keeping system and being able to understand what's due and when.
Amanda
Host
06:42
So why isn't there just one list of all the records required? Where's our easy button? Ha ha ha ha.
Shannon
Host
06:50
Oh, where's the one list to rule them all? The answer to that is two-fold. The first is that if you have multiple companies performing your You know writing your permits, they're only interested in the record-keeping that comes with that permit. The other side of that is that the permits all renew on different schedules and in different years And there's a whole lot of permits for every bulk fuel facility out there. We always joke that like a bulk fuel facility is a small piece of land surrounded by regulations, and it's true, there's so many out there.
07:27
Um, we encourage our clients to perform an audit and create a master record-keeping list and to organize it by Records that are required daily, monthly, quarterly, semi-annually and annually, because most records have some or if not all of those requirements and what you can do when you are Contracting for a plan or permit renewal, as you can request, as part of the scope of work, a List of the records that are required by that permit, broken down by daily, monthly, quarterly, semi-annual and annual right.
08:04
And so if you can get that list from every permit, it makes it easier to manage as an environmental manager, because the permits coming in with that piece already written or it's part of the deliverables that goes with that planner permit. We of course provide that kind of list and we also do audits to develop that kind of list after the fact to try to reduce this level of confusion. But that's why there's no easy button, because there's anywhere from 10 to even 20 permits In that are environmentally based at a facility, and then that doesn't include some of the other ones that are not environmentally based, like fire extinguisher inspections and OSHA checks, and There's a lot going on. I had a sure yeah, so that's why there's no easy button.
Amanda
Host
08:54
Where would we start to fix this? internally or where we are currently?
Shannon
Host
08:59
So let's say that you're a terminal manager or an environmental manager and you just walked in the door And there's a lot of records and it seems like there's a lot of Duplication and a lot of effort being spent. And you, there's a lot of confusion right like which ones which, which ones, right? How to fix that is to sit down and do an audit and be familiar enough with that planner permit to understand what the record keeping requirements are. Most plans and permits have a record keeping section and they lay out what they're, what are required. And if you have that list, you can start creating that master Excel sheet of the dailies and the monthlies and the Porterlies and you can start filling them in. And Then, once you get that master list of what you think is absolutely required by all the plans and permits, then you can start working on copy control like. Like, for example, the, the ODP CP required by 18 AC 75 in Alaska Has a routine facility inspection requirement.
10:03
Most people perform it monthly, right, so there's a monthly and then there's also daily requirements and You could audit how many daily facility inspections are you performing right now? and you might be surprised at the answer. I've asked that of many, many, many terminal managers and sometimes I get back. I've got a daily for the marina. I've got a daily for our main facility. I've got a daily for the truck rack. I've got a daily for the truck. I have a daily for the airport facility. I have a daily for the airport truck That's related to a TA 103. I Also have a daily for the old, our separator, and I have a monthly force bill response equipment.
10:41
That's a lot of dailies, every single one of those dailies, and the answer is maybe in that specific example They probably don't need a daily for the truck rack and the facility. They should be together. But the ATA 103 does require a daily of specific aviation fuel trucks and they require it of aviation fuel tanks and aviation service. So It sort of depends on your list and how you're looking at it. But once you have a list then you can start looking at what they're doing to meet those regulations and requirements and seeing if there's any that are out there That can be taken away and replaced with one that's already being done. Or maybe that one that's already being done could be modified just a little bit and have that form replace another one so that they're only doing one form instead of two or three.
Amanda
Host
11:32
Got it, so that sounds like it can get a little overwhelming. How do we fix it in the long run?
Shannon
Host
11:38
Well, in the long run, like I mentioned earlier, having part of your scope of work include a deliverable that lists out record keeping that the permit is setting up for you. I would also recommend you can always hire someone like us to come in and give you consulting and say do that hard work for you, provide a list and sort of get you started. But I think in the long run the biggest fix is having plans and permits written that consider other plans and permits and also consider operational restrictions.
12:10
I think many plan writers are in offices, myself included, and if you don't fully understand what happens or what goes on at a bulk fuel facility because you're writing general permits for any industry instead of one specific industry, you don't understand that taking a daily gauge of a fuel facility may involve somebody standing on top of a tank in a 35 mile an hour wind, when it's cold, maybe 15 below zero, and you don't understand that there's not a ladder to this tank, it's a barrel cage or, sorry, it's not a stairway, it's a barrel cage ladder And you have to climb that barrel cage ladder to the top of the tank, which is not easy and it's often not safe when it's really cold and icy and slippery right. Or daily inspections of things that are completely covered by snow, like how do you perform those, what do those look like? And so I think having a knowledgeable firm do your plan and permit that knows your industry, knows your ecosystem, knows your weather conditions, all of that can help the person who's writing that plan can put those considerations into that record keeping effort And then also making sure that that record keeping or that sorry, that plan and permit writer is aware of the other things that you're doing So when you're ordering a plan or permit to be written, or if you're writing one yourself. Look at all the other reports and record keeping that you're having your terminal managers do already and see if you can meet the regulatory requirement with what's out there. I think adding that bit of experience and context to a plan or permit development will really help keep the problem from occurring in the future and sort of build a stronger, more proactive system going forward. And I also think keeping a master record list is really important, like understanding what needs to be delivered and when, and we can talk about this.
14:06
There are two other legs to this stool. One is context for the person filling out the record keeping, like what they're supposed to be writing down and documenting. But there's also accountability, like who is responsible for making sure that these records get done and are uploaded and put into your records like documented in certain specific ways, and so we'll talk about those in future podcasts. Um, another thing that you can do to prevent, another thing you can do to ensure that you're getting quality in from a plan or a permit, is to review records or forms when they come in from the permit right And actually sit down with your terminal manager and review them when it's still in draft form and maybe test it out and get the terminal manager's feedback. When you can still send it back to the consultant for changes, updates, elimination, right, you can say, oh, we don't drain our SCA in inches, we drain it in gallons and we have a flow regulator that measures it on the outside right, like those are things that if you can change it, it's going to make sense to the terminal manager later when he goes to look at it.
15:19
And so I feel like when you are writing a plan or permit, part of the clients review process has to include review of a record-keeping form that's been proposed and making sure it makes sense for the operations and the facility that it's being proposed for, and then taking it to the person who's going to fill it out and asking them what they think of it and if it's doable. And if you do those steps as part of your plan and permit renewal process, that's going to eliminate a lot of confusion in the future because you're giving your terminal manager the context, you're giving them a chance to change things when it makes sense. We often see that it doesn't happen because of time constraints, because they need to get it done and there's only seven days and the terminal manager is always very busy. But most of these permits renew every five years. Five years is a long time to be keeping a record that's not optimized and is causing duplicative effort on somebody's part. It's a long time to do something twice when you only need to do it once.
Amanda
Host
16:16
Yeah, we like simplicity. Are there additional resources we can point our listeners to?
Shannon
Host
16:23
to get started, Yeah, you know, as part of developing this podcast, we went ahead and developed an organizer that I think will be really helpful. It's a simple excelsior categories like daily, monthly, quarterly, and you can download that from the show notes or from our website And it should help you get started tracking on it. It also has columns for due dates and notes. We left it blank because we don't know the context that you're going to be using it in.
Amanda
Host
16:54
Thank you for joining us today. I look forward to our next talk, continuing the record keeping Until next time.