Recordkeeping Part I: Complexities

Ever wonder why record keeping in the bulk fuel storage industry seems to be such a formidable task? Is it the operational demands, the maze of multiple permits, or the lack of accountability? Our industry expert Shannon Oelkers sheds light on these challenges to kick-start our Recordkeeping series. She points out the key hurdles terminal managers face, including the balancing act of multiple responsibilities and the confusion arising from numerous permits written by various parties. 

Shannon underscores the vital role of record keeping in modern environmental permitting, as it aids not only in identifying operational issues but also in maintaining documentation of compliance. She emphasizes the need for comprehensible checklists, regular audits, and a robust support system to ensure the smooth running of operations. So, if you're grappling with record keeping, tune in, and let's unravel the complexities of record keeping.

 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.  

Transcript

Amanda: 0:10

Thank you for joining us. You're listening to Tank Talk with Integrity Environmental, where we speak with founder principals, consultants and bulk fuel storage expert Shannon U about regulations, safety and useful tips for smooth sailing through the bulk fuel storage industry. Come learn the unique joys of working life in Alaska with industry experts, including our team, vendors we work with and companies we support. Welcome back, shannon. How are you doing today?

Shannon: 0:46

I'm doing good, but I am thinking about record keeping and why it is so hard.

Amanda: 0:56

I remember sending an email around Christmas.

Shannon: 1:00

Yeah, we send emails to our clients at the end of the year to remind them of some of the annual record keeping that's coming up and also so that they can sort of double check all the records at the end of the year and see if they got everything for all the different permits that we've got. But I think the reason that record keeping is so hard is actually unrelated to checklists. Otherwise we'd be out of a job.

Amanda: 1:31

So what is record keeping i entail? How do we know when we need it?

Shannon: 1:35

i Well, record keeping is part of all modern environmental permitting, and this is really hard for people who've been in the industry a long time because back in the day, there was very little record keeping and there was a lot of visual verification Like, hey, I looked at it, it's good, let's move on.

Shannon: 1:58

But record keeping serves many purposes and functions and the modern environmental record keeping process. It has two masters. The first is to actually identify problems, maintenance, operation, things that need to be solved, and get them to the right place within a company, get support and resources to fix them. The other master is the environmental regulation that is regulating operations and there's many for a bulk fuel farm and the records are documentation of the inspection. We call it credit. You're getting credit for the inspection that you did. If you do it and you don't document it in the regulatory space, then it is the same as if it didn't happen. So what makes it difficult? Well, the problem with record keeping and why it's so hard is there's a lot of things going on with your average record keeping.

Shannon: 3:08

Bulk fuel farms typically have a terminal manager who's local and they are in charge of making sure that all inspections occur and are documented and they have some competing priorities. They are also in charge of selling fuel. They're also in charge of inventory. They're in charge of accounting and billing. They're also in charge of human resources and driver management and scheduling. There's a lot of things going on for the average terminal manager. And then record keeping, which is not an easy thing to do, is thrown on the top of that. So that's the first hurdle is just providing resources and space to a terminal manager or the company prioritizing record keeping compliance. That will allow the terminal manager to successfully complete it.

Shannon: 4:00

But there's also the piece where A whole bunch of different groups develop these permits and the inspection checklist and the actual records that are supposed to be completed and signed. They're not always developed by one person who's really familiar with operations. They might be done by an engineering group that worked on a project five years ago and they might be done by a company like ours, because there was a problem with stormwater and we were brought in to help fix it and write a stormwater plan. They could also be somebody internal to the company reading the regulations and deciding. I can do this myself, which is totally cool. Many people can, right.

Shannon: 4:38

But sometimes a terminal manager will inherit permits that are written by all three of those people that I just described, and some of those people understand operations really well and some don't, and so sometimes what I see is that the records compete with each other, like somebody's filling out a routine facility inspection for a stormwater plan, they're filling one out for a spill response plan, they're doing a routine facility inspection for air regulations, they're doing another one for any other number of regulations insert here. They all are very similar but yet critically different because they've been written to meet this very specific regulation and so the terminal manager looks very repetitive. Why am I doing this four times? Well, it's because four different regulations have these very specific requirements. Also, these record keeping checklists or inspection checklists, if there's not a basic understanding of operational knowledge underneath it, the wrong information can be tracked, or they're set up in a way to where it's not easy for a terminal manager or somebody he's assigned to do the inspection, to capture the data.

Shannon: 5:47

Well, a good example of this is an inspection checklist that's asking you to visually survey a secondary containment area for the presence of sheen and then noting whether there's sheen or not, and then also documenting when and how much discharge for the secondary containment. One record might say is sheen present, w or N, and you're supposed to circle the Y or the N, and then the next question is the start of a o d drainage. Well, if you're not trained or or you weren't paying attention during that thing in class, you might click oh yeah, there's sheen, yes, and then you will start discharging because there's nothing in that record that says if, why, do not discharge. So we see that a lot, where the records aren't really written to help whoever's doing them understand if they're not an expert in this regulation, and then they're written by somebody who's not an expert in operations.

Shannon: 6:50

So they're writing them to where it's kind of awkward and clunky. So that's the second hurdle that I see like it makes record keeping hard because they're being given forms to fill out that don't make sense or feel repetitive or don't have built-in breaks for certain behaviors. And then the last thing I see is it's just accountability, like they're asked to do all these records but then they're not actually audited, or maybe they're only audited at the end of the year after 12 months have gone by and they're like oh yeah, you should have been doing this daily. And now here we are, in December 1st, I need you to go back and pull 364 records out of your filing cabinet that you don't have, and so without routine periodic check-ins and some sort of accountability system in place, it's really easy to let things slide. And no, it's not even terminal managers.

Shannon: 7:43

Remember all those responsibilities that I talked about that come first and like are tied to profit and money and their paycheck. It's very easy. I mean, we all do it in our own personal lives, right, and so it's just sort of that human behavior piece where having accountability on a more frequent basis, like monthly or quarterly, helps prevent really big record gaps. And I see all over Alaska, with almost all of our clients, some version of one of those three hurdles, and I think that's the root of why record keeping is so so hard, and you have to address all three before record keeping gets better, and I think that's also what makes it difficult.

Amanda: 8:27

You can't just be like okay, here's a better inspection form.

Shannon: 8:30

Well, if that doesn't come with support and high priority from the corporate office and it doesn't come with accountability from your environmental manager checking in and saying where is it? You could have the best form in the world, but it's still probably not going to get filled out. So those are my thoughts on records today.

Amanda: 8:52

Well, thank you for sharing. I appreciate it and I hope that helps somebody out. Yeah, yeah, I'd love to dive in their record keeping. It sounds like. Sounds like a joy.

Shannon: 9:03

Everybody loves record keeping so much.

Amanda: 9:12

Thank you for tuning in to tank talk with integrity environmental. For additional information, please visit our website, m. com com. com. com. integrity-envcom. If you're interested in becoming a guest on tank talk or have a topic you'd like to learn more about, send integrity-envcom com com email to marketing at integrity-envcom. Until next time,