Multi-Media Compliance & Auditing
At JBE, our consultant team has been there – we’ve filled out report forms, poured over mountains of data, and been frustrated by complicated mechanical processes needed to produce required records and reports.
Our experience comes from years of time in facilities as compliance staff, as well as lots of quality time as consultants trying to make things better.
As a result, we want to skip the fluff and get right to on-target results for you. That doesn’t come easy, but the reward can be worth it.
Compliance Journey - Key Elements
Prioritize – Is Your Calendar Practical?
What regulators know about you in part comes from the reports you submit to local, state, and federal agencies.
Every project should start with a focused regulatory requirements review.
Priorities should be ranked based on factors such as the protection of human health, risk, community impact, and available resources.
We have helped clients focus their efforts around deliverable tracking and the assignment of enough resources to do this critical activity well.
Improve Data – Can We Trust This?
Process data in its raw form is full of missed data points, meter glitches during start-up and shutdown, and impossible values.
It can take a lot of time for staff to sort through it all, find the problems, and decide how to address them.
JBE has saved clients lots of analysis time by using formulas that flag and substitute data automatically and transparently.
This process helps build in the level of confidence need for reasonably inquiry.
Roadmap – Do You Have the Right Path?
Compliance audits don’t look at workflow nor do they cover all program elements effectively.
But set a consultant down to develop a report where there are no instructions and the program element will get a real review.
JBE’s experience helps us intervene at the start of work to take note of the current conditions and create a roadmap to delivery focused on improving the process without compromising the timeline.
Analyze Data – Automate Parts of It?
Recurring work steps are inevitable as data moves from its point of origin to a report or record.
Our tools have dramatically reduced the time to compile and review complex calculations.
JBE helps clients identify places where data can be organized effectively to reduce errors when methods or data elements are changing over time (e.g., a tabular approach vs. a one page per process element approach).
Compliance Implementation and Enhancement
Sample Implementation and Enhancement Projects
Some recent examples of our work:
Dynamic Threshold Determination – Changed a hard-wired Toxic Release Inventory (TRI) chemical results table into a database style so chemicals could be added or deleted as TRI threshold determination results change over time.
Deploy Multiple Plans at Once – Used Microsoft Excel® to create three flare management plans from a single master table for the best of both worlds: still have three separate plans, but also have a concise way to compare the differences between them. The plans were configured using formulas for each paragraph to resemble a Microsoft Word® document, but each was fed from a common source. This investment up-front makes future updates to reflect changes easy and consistent between each plan.
Best Use of Easy-to-Gather Data – Developed a solution for estimating storage tank throughput using only level gauge data, as meter data results were not tank-specific. Initial efforts to use monthly tank level difference (the client’s previous solution) did not account for liquid level rise and fall during the month, which was important since emissions occur mainly during drawdown for floating roof tanks. JBE implemented a modification to the data gather sheets to filter out days when the tank had a net rise in level. This moved our client much closer to an accurate estimate with minimal effort.
Workflow & Process
JBE’s staff focuses on workflow and process as we are confronted with each new client situation. We are driven by the desire to find the best ways to deliver compliance results such as reports, plans, calculations, and required records. Of course, we make it a priority to deliver quality results for a reasonable budget, but there is more to compliance implementation and enhancement than that from where we sit.
Facility work processes evolve, which results in changes to the helpfulness and effectiveness of tools over time. We help our clients to see what can be accomplished and to make informed choices when selecting tools and adapting to facility changes. Two key aspects we’ve learned are that typically no one tool can solve all the workflow issues that arise, and that a complicated EMS tool is not always needed. Often what is best is a smart combination of a number of good tactical solutions.
