Have you ever considered the potential chaos when a single person is tasked with industrial recordkeeping? We open your eyes to the dangers of such practices, including the creation of information silos and the vulnerability that comes with employee turnover. In the wake of a terminal manager's recordkeeping blunder, we dissect the repercussions that ripple through an organization, leading to legal entanglements and regulatory nightmares. With a focus on shared accountability, our discussion moves to innovative solutions that involve teamwork in documentation, fostering error detection in real-time, and a management system agile enough to meet the demands of both environmental and safety regulations.
Take a proactive stance in environmental management with our expert advice on maintaining impeccable records that can withstand the scrutiny of any audit. Environmental managers, listen as we stress the importance of your role in quality control and the continuous training imperative to weather the storm of staff transitions. Our final episode in our recordkeeping series is your roadmap to creating a resilient and reliable record-keeping system tailor-made for the ever-evolving landscape of industry standards.
This podcast is for informational purposes only and should not be considered legal or regulatory advice. We are not responsible for any losses, damages, or liabilities that may occur from using this podcast. This podcast is not intended to replace professional regulatory or legal advice, and the views expressed in this podcast may not be those of the host, which would be me or Integrity Environmental. Thank you very much for listening. We would be happy to provide professional regulatory advice as part of our consulting services if you need professional regulatory advice.
Have you ever considered the potential chaos when a single person is tasked with industrial recordkeeping? We open your eyes to the dangers of such practices, including the creation of information silos and the vulnerability that comes with employee turnover. In the wake of a terminal manager's recordkeeping blunder, we dissect the repercussions that ripple through an organization, leading to legal entanglements and regulatory nightmares. With a focus on shared accountability, our discussion moves to innovative solutions that involve teamwork in documentation, fostering error detection in real-time, and a management system agile enough to meet the demands of both environmental and safety regulations.
Take a proactive stance in environmental management with our expert advice on maintaining impeccable records that can withstand the scrutiny of any audit. Environmental managers, listen as we stress the importance of your role in quality control and the continuous training imperative to weather the storm of staff transitions. Our final episode in our recordkeeping series is your roadmap to creating a resilient and reliable record-keeping system tailor-made for the ever-evolving landscape of industry standards.
This podcast is for informational purposes only and should not be considered legal or regulatory advice. We are not responsible for any losses, damages, or liabilities that may occur from using this podcast. This podcast is not intended to replace professional regulatory or legal advice, and the views expressed in this podcast may not be those of the host, which would be me or Integrity Environmental. Thank you very much for listening. We would be happy to provide professional regulatory advice as part of our consulting services if you need professional regulatory advice.
Welcome back, shannon. It sounds like we finally hit the caboose on the record keeping train. Yes, so today we'll be discussing accountability.
Speaker 2:
Yes, my favorite leg of the record keeping stool.
Speaker 1:
What is accountability?
Speaker 2:
Ah, accountability is this vague sort of large term for a whole lot of different things, specifically human behavior. I think it's really heavily misunderstood. A lot of people. If you ask them what's accountability, they'll say things like oh, it's ownership, one person taking responsibility, and that responsibility comes with rewards and consequences, and that is one definition of accountability. But in the context of industrial record keeping, that kind of definition, which is very prevalent in a lot of business models, that sort of mindset results in some unwanted consequences or unwanted results.
Speaker 2:
The two that we see the most is information siloing. Someone was responsible for doing something like the storm water monitoring right, and they were the one person responsible for it. It was their job, all the consequences were theirs and they did it and then they left. There was staff turnover and nobody else knows how to do it. Nobody else knows where the files are located. It's very difficult for the incoming person to access historical records or continue doing it the way it was done, and that information silo creates problems for a company with turnover.
Speaker 2:
The other thing that we see that's really common with that specific mis like accountability definition is we see consequences that are so heavy that they're insurmountable or uncorrectable from the supervisory level.
Speaker 2:
And the biggest example of this is a terminal manager is told that record keeping is his responsibility and he is supposed to do it, which he accepts when he takes the job. But after five years nobody's ever checked in with him or verified that these records are being kept or given him any feedback whatsoever. And they have a state or federal inspection and the inspector comes in and says we need to see your records and they aren't any. So you get a nice potential notice of violation letter from the state or the EPA saying we need to see all your records for the last five years. Terminal manager was unable to provide them at our onsite site visit. Whoever the terminal manager supervisor is, there's no way to supervise your way out of a five-year record gap. It's so insurmountable and it's such a huge risk. And yes, the terminal manager was accountable and it was his responsibility. But if it didn't happen and it's a big gap the risk and the potential damage to the company pretty huge. That's why I like to talk about accountability in a different way.
Speaker 1:
Then how should we be looking at accountability?
Speaker 2:
We prefer talking about it more as a joint responsibility, and I actually call it joint accountability when we're setting clients up with this system. But the idea is is that for something so critical like record keeping, especially for risk management, there's two people that have accountability for something like record keeping at least. Sometimes there's more, but at the simplest way to look at it is that someone like a terminal manager has the responsible for creating and filing the record or maintaining the record, and these days it's very often a digital record that's being created, but there are still plenty of people that do it hard copy and have it in a file folder in the office. And there's another person, and that person may or may not actually be the supervisor of the terminal manager, it may be an environmental management staff member and that person has the responsibility to check the filed records on a routine basis and sort of audit for completeness, errors in context, etc. And what that system does. It allows the business to ensure that you're creating this record keeping record. If there's incomplete records, they're corrected in real time. It's not five years later when it becomes a problem, it's at the end of the month.
Speaker 2:
We noticed that you, like a real common example is looking at dailies right. Most facilities have daily records and they perform them every day that they're operational. So if they're closed Saturday, sunday, there's not a record right. So most months you have I don't know 24 daily records. If you open up the file and you're auditing it, like we have done for clients, and there's only 16 records in there, and you look and you realize that there's an entire week where nobody did a daily and you're like what happened here? So you call the terminal manager and she's like oh, that's the week I took personal leave and I went to Vegas and my yard foreman was working for me. However, I failed to tell him he had to do the daily. You can correct that for the future. You can't, of course, go back in time and fill in the record gap, but recognizing the problem, coming up with a solution, providing training, support and resources happens in real time, and it's not just something that happens every time the terminal manager leaves and they just don't, you know, never correct it.
Speaker 2:
The other thing that we see with routine monitoring is if the terminal manager is not getting support from the company, he'll notice like oh, I'm uploading all these records and I've told them multiple times that the secondary containment three inch log doesn't match right what we're doing or we need this thing repaired and I'm having to put it on every record that it's broken, like every day on our dailies.
Speaker 2:
It can also highlight a breakdown in the environmental or record keeping management portion of a company and that can be brought up during all hand meetings with senior personnel and they can say things like and I've heard this before from companies where, hey, when it's safety, we get it resolved immediately and we get everything we need, but when it's environmental, it takes months and months, and months, and that's that's one of the symptoms that we see when there's not a good accountability system set up is that the environmental manager is not being held accountable for their responsibilities, for making sure that the system is creating and producing records that are measurable, complete, have all the right context, are filled out correctly, all of those things.
Speaker 1:
So how does joint accountability work, how would we set it up correctly and how would we avoid bad consequences?
Speaker 2:
That's a really great question, and it's one we answer for our clients. Many of our clients start with the terminal manager is solely responsible. As I mentioned before, record keeping is a three part stool, and so if they also had problems with context, they also had problems with quality in and quality out. Accountability is often also affected. It's hard to keep good, complete records when the record that you're filling out isn't set up for the way you need to do it and it's also not something that you've been trained on, so you don't fully understand what you're filling out, and then there's nobody telling you or giving you feedback about how complete or well done the record is right. And so we set this joint accountability up to provide that mechanism for feedback, training, support when they need it in real time, and what we typically do. Because we're moving into the digital world. They're like I said, there are still hard copies, but those are the exception at this point. Digital copies they have a. They have quite a few benefits that, in my mind, ensure that they are the future of record keeping one. They create time stamped and date stamped records that show they got completed on a specific date. They're easily accessible by staff or personnel and other locations, like the main leadership group and Anchorage, can drop in and look and see at how record keeping is being performed at a satellite facility or a facility in a different community. And so when we set up this joint accountability, we set up a filing system that makes it pretty easy to see where things go and it matches our record keeping organizer right. So if there's daily records and monthly records, there's folders that say daily and monthly and there's one for each month of each year and the terminal manager is supposed to upload these to the folders. And then it makes it real easy for whoever's auditing them from the environment, like an environmental manager or sometimes the terminal manager supervisor, whoever that is a general manager. Maybe they can go in and look and say, okay, there's supposed to be four monthly records in here, one for the facility, one for the tank truck and a few others secondary containment, drainout, jog, whatever. And if he opens up the folder and there's only three records in there, he knows right away you've got a master list of all the records you're supposed to be keeping that one is missing and he can follow up with an email to the terminal manager and say hey, rosie, could you get me this record that seems to be missing and if it occurs in real time, it's small amounts of time, a 30 minute meeting once a month maybe. At the most it avoids panicked meetings three years in the future when all these records are missing and there's huge data gaps and a firm like ours has to be brought in to audit, summarize, identify and prepare all this stuff to be submitted.
Speaker 2:
Because all of these records are auditable to all these different regulatory agencies. They can be asked for at any time and they are almost always asked for after some sort of event, like a spill or infrastructure failure or a near miss or something, and sometimes it's just part of the regular inspection schedule. They just want to know all the records for the last three years. So creating an auditable record is pretty important, as important as your accounting records, and I'm still working on changing everybody's mind about the importance of all of that. That's generally how we set it up as we use the quality and quality out to create the master list.
Speaker 2:
We have training for everybody environmental manager and the terminal manager. So everyone's got context about what needs to be filled out completely and why, and then we have this accountability where the terminal manager is uploading the required records and somebody an environmental manager, we'll say, for argument's sake is reviewing these on a monthly basis and giving feedback, requesting missing and just sort of helping and supporting that terminal manager and making sure that the record is created and then that what is created is quality, and then that environmental manager is creating an auditable record for the company that reduces risk and allows the company to operate safely, securely and also have all of the information it needs if it ever does get audited or inspected or whatever from the state or the feds.
Speaker 2:
That's how we look at accountability and it's a very effective system, but it does require some resources. You have to have somebody who's going to look at those records on a routine basis. Some of our clients don't have those resources. They're real lean at the leadership level, and so our firm also offers something called Shield Record Keeping Services and we actually do those audits. We set up the list of, you know, the master list of record keeping.
Speaker 2:
We provide the training for the terminal manager and then we audit all of those files each month and we provide reports to the manager on a monthly, quarterly, semi-annual and annual basis.
Speaker 2:
And what that allows the person like a general manager, who has a lot more responsibilities than just environmental management what it allows that person to do is look at the holes or gaps that our team has identified and have a very targeted, specific conversation with the terminal manager about the things that need to be fixed or that may need more support, or that you know or that are not working quite right, instead of reviewing all 26 dailies to make sure that they're correct, right, our team does that and then they can focus on the fact that we identified that they were all filled out but they never noted any maintenance. And he can say you know, look, rosie, you have got to get the maintenance onto these dailies. You've got to show when you found a weep and corrected the weep. And it makes for a much more efficient use of some of our senior leadership's time when they have a lean leadership team.
Speaker 1:
I know you had mentioned one symptom of lacking a healthier joint accountability for record keeping is when someone steps out on vacation and no one else knows how to step in place for them or fill in that gap. Are there any other symptoms that we can watch out for?
Speaker 2:
Yeah, I mean, some of the symptoms are just records not being kept because nobody's given feedback or held the terminal manager accountable for completing that record. One of the other symptoms we often see if you don't have healthy accountability in place. Joint accountability how these records are filed means that nobody else can access them or audit them or investigate them without spending hundreds of hours. And so one of those systems that I see is that they're all on the hard drive of the terminal manager or they're in hard copy in a filing system and auditing them is very difficult. Or my favorite one is I emailed it to you every day. I emailed you the dailies, I emailed you the monthlies, I emailed you the everythings right. If you've got somebody who's an environmental manager and they're getting several hundred emails a year related to dailies monthly, so I just and they're not in one place and they're not organized and they're not named in a way that you could like save them all in a folder and have them all sort themselves out. That system's not healthy because you can't audit it easily, you can't see the gaps, you can't go in and easily see that only 17 dailies got performed in this month and it should have been 24 or something.
Speaker 2:
So, like I've said before and throughout this series on record keeping, it's a three-part stool. You've got to have all of the parts in place, but if there's no accountability, you see drift. You see, like maybe you had the best record in the world, you had the best training, and then a terminal manager turned over and it's a new terminal manager, and if there's not accountability from an environmental manager, they may not ensure that the new one gets the right training and then maybe the context goes away. When accountability is not working, you're going to see drift or shifting in the other aspects of the record keeping system. You're going to see that the context maybe gets dropped or the records are not as quality, or maybe they were quality five years ago but they haven't been updated and managed and so now they are out of date and they are not quality anymore. They're not working for the terminal manager because so many things have changed.
Speaker 1:
Do you have any resources for our listeners to get better at accountability? Hmm?
Speaker 2:
yes, I do. We have a naming guidance for naming these digital files, and it really helps organize them. Even if they're all dumped into a folder, they'll at least be in date order, and almost any time that we have done work to respond to a federal or state inspector's request for records, or records requested by legal teams as part of Notice of Violation negotiations, the legal team will need all of these records sorted by context and by date order, and so, if you are interested in creating the best record keeping system on earth, I would recommend using our naming guidance, because it'll help. Starting from the beginning, you will be able to create a record that's ready for anything you may need it for, and so we'll include that in the show notes. You, of course, can adapt it in any way you need to for your own company.
Speaker 2:
The big key, though, is, once you do select a record naming protocol, you have to be consistent with it, and that consistency can be difficult because of human nature. But yeah, if you've got a naming guidance and you're using it, and the terminal manager is using it, and you're performing a monthly audit and you're saying hey, I noticed that all of your dailies came through with the scanner name. You know, scanner ZYZ1001529,. I renamed them for you this month, but you need to do it next month, right? Those are much better files for your digital record keeping than all the files that have the scanner name and an individual number on it. If you've got a date, a location, a record type, context, anything like that, it'll make for a better record. So we'll provide that resource to the listeners because I think that that is a really big hurdle for a lot of records as we move into the digital age. As you know, before we had file folders and the record was in the folder and you could tell what it was clearly by looking at it.
Speaker 2:
Digital files are numerous. You can't really look at them without like opening them, and they do need to be sorted into their own digital files. It gets a little more complicated with digital and so having context in the name of the file means you can search for it independently of where it's located, and we find that really helpful. When there's misfilings, like they file it in the wrong folder, you can still find that file. Is there an annual for 2022? If you've named your files consistently, you can search for that ANL for annual and see all of the files and you'll be able to find it. And oh look, someone put it in 2019 on accident. That's where it is, so I think that'll be helpful.
Speaker 1:
Well, thank you so much, Shannon. I learned so much from these three legs of the stool record keeping. I look forward to learning more with you in future episodes.
Speaker 2:
Yeah, thanks so much for having me again, amanda. I really appreciate your good, thoughtful questions and I was really excited to talk about record keeping. Our firm handles a lot and if we can help make it better for others, I would really like to see that happen.