For many EHS teams, compliance reporting for EPCRA, RCRA and other program areas usually involves team members who understand the requirements for filing accurate Tier 2 reports. Each person plays a vital role in the process. Unfortunately, for EHS teams in various industries, staff turnover can hamper reporting, let alone efforts to improve Tier 2 reporting processes themselves. 

Given the findings of a 2019 EHS Talent Report that showed turnover on EHS teams to be as high as 20% at the time, it’s safe to say the rate is still close to that now — if not higher. But it’s no reason to let employee movement derail your Tier 2 reporting outcomes. 

By using technology to standardize compliance data management and reporting, organizations can keep turnover from affecting the consistency and accuracy of their compliance process. The right EHS management software can help EHS teams sustain processes and still make sure Tier 2 reports are accurately compiled, formatted, submitted on time, and effectively recorded and retained. 

 

3 Ways to Overcome Turnover by Automating Tier 2 Reporting

There are several ways organizations can keep turnover on their EHS team from negatively impacting Tier 2 reporting. With digitization and automation as the foundation, Encamp Compliance Program Managers Madison Martin and Jennifer Mester identified three aspects of the reporting process that EHS leaders should proactively prioritize:

In particular, these aspects address key EHS team members who have control of the entire process with the compliance knowledge stored in their brain and spreadsheets and formulas saved on their computer. They understand the details of reporting like no one else does. Should anyone ever leave, retire, or be redirected to other compliance priorities, however, the rest of the team must be able to operate with the same institutional knowledge and ensure continuity for reporting tasks.

This business case for centralized data processing demonstrates how Encamp’s EHS management software helps teams achieve data accuracy, reporting consistency, and a centralized document repository to combat turnover, and actually improve Tier 2 reporting overall.

 

Maintaining Consistent and Accurate Data

This is where standardizing data management and reporting processes comes in. The aim is to establish a strong foundation for compliance data and create a continuous data collection process, especially at the facility level. 

“Consistent data, even if someone leaves, is the most critical thing. If a certain person has been doing Tier 2 reporting, or any other (type of) environmental reporting, that person may have their own system for gathering and storing information, which may not make sense to the next person,” said Jennifer Mester.

Begin by pulling in a canonical set of corporate, facility, and personnel information to implement the foundation for compliance data. Then, after organizing the data in one place, identify the different channels data comes from (such as each facility) to establish data collection on a continuous basis for all relevant compliance and Tier 2 reporting information.

To ensure both the consistency and accuracy of the collected data, EHS teams and all stakeholders get a single point of visibility and control for corporate, facility, and contact data for every site being managed. Along with standardizing the data collection process, teams are able to monitor information across all sites in real time — ensuring that data is handled and validated consistently, regardless of who’s involved in the process. This is yet another step teams can take to improve Tier 2 reporting.

 

Automating Compliance for Tier 2 Reporting 

With EHS management software, EHS teams automate the reporting process for report submissions, processing mailers, and billing in accordance with various federal, state, and local regulatory requirementsall in one place. Such automation enables teams to standardize reporting and make the process repeatable year after year for all compliance and reporting stakeholders.

“Encamp pushes out reports the same way each year,” said Madison Martin. “So even if employees change, the report formats are consistent from year to year.” She also points out that EHS teams can utilize the Encamp platform to maintain user credentials for state and other reporting portals. As Martin noted, “Credentials are usually the first things that get lost when an employee leaves.” 

More importantly in the face of employee turnover at facilities, automating regulatory updates and notifications helps to meet a facility’s exact Tier 2 reporting requirements and ensures continuous compliance. EHS teams are able to use rule-based triggers to automatically catch regulatory updates or changes, and then automatically integrate any applicable changes in the platform’s compliance engine.  

To improve Tier 2 reporting and ensure compliance, automated notifications can help EHS teams eliminate almost 100% of reporting errors before they occur. Teams also reduce the number of facilities at risk of non-compliance by nearly the same percentage. Moreover, notifications have helped reduce the time to complete and file compliance reports by as much as 90% for some of Encamp’s fast-growth customers.

 

Centralizing Audit-Ready Documentation

Archiving past reports and associated documents is a function often overlooked by many EHS teams, which can be problematic in the midst of turnover. “The document retention aspect is really important,” Mester said. “It is not uncommon for a long-time employee to leave, and then no one can find critical records.” 

As a platform that simplifies environmental compliance data management, Encamp provides a single repository in which to store prior reports for future reference, including all data associated with those reports. Also by laying the foundation for an auditable and continuous environmental compliance program, and despite the employee turnover that occurs on many EHS teams, ensuring accuracy and mitigating risk across the entire data management and Tier 2 reporting process. 

 

How Encamp Can Help

With Encamp’s EHS management software for Tier 2 reporting, businesses and their EHS teams have a robust system that eliminates the discrepancies, wasted time, and potential errors from different people taking over data collection and reporting roles. Teams realize savings from reducing switching costs and lost time due to employee turnover. 

Teams also mitigate bad habit formation and lay the foundation for a department built on compliance. Instead of relying on an employee who is less familiar with Tier 2 reporting requirements to file a report — and to potentially train someone else improperly — Encamp lets you trust that reports are consistently compiled and submitted in a compliant manner.

Let us show you how Encamp helps your EHS team maintain accurate and consistent environmental compliance data and reporting despite employee turnover

 

Transforming the way enterprises stay in compliance 

Encamp is on a mission to create a world where good for business can equal good for the environment. We help enterprises transform compliance programs and human processes into a technology-driven system that lays the foundation for accurate and ongoing environmental compliance through a blended method of intelligent high-tech solutions and high-touch expert support.

For EHS leaders facing constant changes in chemical inventories and regulatory requirements, collecting EHS data for Tier II reporting on a continual basis promotes informed decision making.

To make the kinds of environmental compliance decisions that prevent non-compliance violations, EHS leaders must have clear, accurate, up to date data readily available at all times

Yet even the most seasoned EHS managers and professionals say collecting facility data for Tier II reports can be exhausting. Decentralized systems, spreadsheets, and a basic lack of time and structure often make the process harder than it should be. But there’s are better ways to get ahead of data collection for Tier II reporting.

 


Continuous Tier II Data Collection: Best Practices and Takeaways

In the first of a 3-part March to March virtual event series from Encamp, we discussed how to improve the data collection process for Tier II by rethinking it. To start, here are three best practices to consider:

    1. Make time to collect and validate compliance data regularly throughout the year. When Tier II data isn’t available or becomes outdated, it’s hard to fill the cracks. 
    2. Standardize data collection processes to make them repeatable year after year. This drives efficiency — and means no more starting from scratch every reporting year.
    3. Identify evergreen tasks that compliance stakeholders can complete at any time during the year. Any completed task is a head start to meeting the Tier II reporting deadline.

At Encamp, we can’t say this enough: The secret to ensuring accurate Tier II reporting is to make data collection a continuous priority first. 

Make more time to collect and validate compliance data 

Depending on chemical inventories, classifications (see the EPA List of Lists), Tier II reporting thresholds and the number of facilities a team must report, one or two months to gather needed compliance information for reporting isn’t always enough. To fully meet EPCRA guidelines, collected EHS data must also be validated and checked for completeness. Where multiple states are involved or when regulations have been updated or changed, EHS operations must additionally verify data applicability for Tier II reporting requirements

Almost every EHS professional we’ve worked with expresses how tracking down compliance data for a Tier II report is too time-consuming. Sometimes it can literally take weeks or even months, on top of other compliance and sustainability initiatives their team is responsible for. But given the consequences of constant regulatory changes, potential reporting violations, and non-compliance, data collection is a critical task — and EHS leaders must make time for their team to complete it. So instead of starting data collection in January, why not implement a more continuous process from August through December to have data ready to review in January?

 

Continuous EHS data collection for Tier II promotes informed decision making in response to constant changes in chemical inventories and regulatory requirements.


Standardize and streamline data collection tasks

The lack of time and a structured process for data collection makes Tier II reporting more difficult than it should be. However, rushing compliance reporting can result in invalidated data and missing details that regulators see as red flags. The following safeguards can be invaluable for EHS teams.

More specifically, streamline data collection tasks for distributed facilities — which is especially critical when sites are located in various states. Technology-wise, systems like Encamp let your team digitize and centralize data for product inventories, then standardize the process your facilities and EHS operations use to gather and validate that data. Once a process becomes a standardized function, making it repeatable is an inherent next step to streamlining data collection tasks over an extended period of time, as well as from one facility to the next.

Further, when technology is a single unified platform, it provides a foundation on which to integrate to existing enterprise systems, build data pipelines to individual facilities, and create a core data repository that all EHS data feeds into from these and other sources, such as spreadsheets and even emails. Archiving data this way, along with previous years’ Tier II reports, also gives you a comprehensive, auditable record that regulators appreciate.

Make Tier II reporting strategic across sites

At the facility level, site managers should be able to confirm their facility’s compliance responsibilities by fully determining current product inventory, including thresholds for each reportable chemical. Managers should then reach out to their respective State Emergency Response Commission (SERC) and Local Emergency Planning Committee (LEPC) to make sure the data being collected is in accordance with specific state and local requirements.

For EHS operations, this approach makes Tier II reporting more strategic across sites. More importantly, it provides a safety net to keep details from slipping through the cracks that could result in reporting non-compliance. 

Get evergreen tasks out of the way early

Again, the process for EHS data collection is better when collection and validation tasks are scheduled on an extended timeline. It sounds simple, but this is where starting data collection and completing associated tasks in August instead of January-February is a benefit for EHS professionals who are constantly stretched for time. Starting earlier in the year also fits the rule of thumb to have EHS data ready to review by early January for the March 1 Tier II filing date.

From August through December, for instance, focus on evergreen tasks that can be completed at any time: Track changes to reporting requirements at all levels. Confirm emergency contacts at your facilities and update their info as needed. Get in touch with appropriate SERCs, LEPCs and Fire Departments to answer any questions you have, and to build and maintain those relationships. Even review and update things like facility sitemaps and safety data sheets (SDSs). 

Come crunch time to start compiling your Tier II reports, evergreen tasks such as these will already be completed.

 

Data equals knowledge. The earlier you have data, the better position you’ll be in to make informed reporting decisions.


A Checklist to Simplify the Tier II Data Collection Process
 

In collecting EHS data for Tier II reporting, a checklist is a foundation to standardize and track data collection tasks across facilities. But the new Tier II checklist from Encamp’s regulatory compliance experts goes a step further. 

For continuous compliance throughout the year, it lets EHS operations prioritize data collection tasks from August to December while creating a data gathering process that’s streamlined, repeatable and efficient. The intent of this timeframe is to have all data collected the first week of January, while allowing compliance stakeholders to analyze and validate data as information is collected, eliminate gaps (and doubt) in the data itself, and make informed reporting decisions as part of the process. The extended timeframe for data collection further allows more time to compile and submit final Tier II reports before the March 1 due date for EPCRA. 

    1. Annual Tier II reports often rely on a variety of data managed by different groups of people: EHS leaders, teams, facility managers, and other stakeholders such as purchasing and shipping departments. Encamp’s centralized platform for direct data entry and tracking reduces the time and effort required to aggregate data across your organization — and do so accurately. 
    2. Along with collecting data for a new reporting year, EHS leaders must often compare it with reporting data from previous years to make sure any and all changes are accounted for. This is where leaders can confirm changes to product inventories, thresholds, regulations, emergency contacts at facilities level and so on. Comparing data lets them determine whether certain new EPCRA notifications must be submitted, or even when Tier II reports don’t need to be filed. 
    3. Environmental laws continually evolve and are regularly amended on both a state and local level, which makes it difficult to collect and track data specific to a compliance program’s requirements. With Encamp, automated threshold calculations for each product can be applied broadly across the organization rather than in a piecemeal fashion during report compilation. Adjusting threshold calculations because of a regulation or permit change is much more manageable when a set of calculations is automated and tracked in a single platform. 

Getting started on Tier II data collection

The following tasks for data collection are just one segment of Encamp’s Tier II checklist.

Evergreen tasks that you can do monthly:

One final, critical note: Sitemaps are important information for first responders to have in the case of an incident, as are SDSs and the info for facility emergency contacts. For every facility that falls under EPCRA requirements, updating this information anytime something changes is a crucial step that states often require for Tier II reports. 

Watch the March to March: Data Collection webinar on-demand for more expert insights on successful Tier II reporting.

Transforming the way enterprises stay in compliance 

Encamp is on a mission to create a world where good for business can equal good for the environment. We help enterprises transform compliance programs and human processes into a technology-driven system that lays the foundation for accurate and ongoing environmental compliance through a blended method of intelligent high-tech solutions and high-touch expert support.

Accurate and timely EHS compliance requires reporting data to be both visible and clean, particularly at the facility level. When every facility’s compliance information meets the exact Tier II reporting requirements for program areas like EPCRA and RCRA, EHS and corporate leaders can rest easy. But when leaders don’t trust the data their facilities are reporting, they lose sleep. The penalties for non-compliance, after all, can get expensive.

Where dispersed facilities are involved, creating clarity in the compliance data you report for each site is the key to avoiding non-compliance violations. And clarity begins by centralizing the data for all facility locations — which starts by centralizing the way data is collected itself. Enterprise-wide, this enables stakeholders at every level of the EHS compliance function to:

  1. Increase data visibility across sites
  2. Ensure control throughout the compliance process
  3. Understand reporting nuances at all regulatory levels to stay in compliance

Centralize Data Collection for Visibility & Tier II Clarity 

More than any other aspect of compliance reporting, those three outcomes (rewards!) make centralizing how you collect, process and validate required data for every facility a must. So is keeping data in full view at every step.

Only 35% of executives have a high level of trust in their organization’s data. Source: Guardians of Trust, Forrester Consulting and KPMG International

A Tier II reporting need for businesses of all kinds

Businesses of all kinds maintain different facilities for production, distribution, fulfillment and the like, and often house hazardous chemicals of some type in those facilities. Even businesses that don’t always immediately come to mind. Think of non-store retailers, merchant wholesalers, general merchandisers, and companies in the food and beverage industry whose operations are often dispersed. Others could be businesses specializing in building materials, garden equipment and supplies, warehousing and storage, truck transportation, and rental and leasing services. 

While businesses such as these don’t manufacture hazardous chemicals, they do typically use and store them. That means the business is responsible for reporting chemicals included on the EPA List of Lists, and must do so with complete and accurate compliance data. 

Common problems for EHS compliance data management

For many businesses with distributed facilities, one glaring compliance reporting problem is siloed information sources and very few established data pipelines to each site they operate. Another problem is the lack of a single, central repository to organize and verify collected data for Tier II reports. Other issues? Manual data collection and disorganized spreadsheets. Little or no data visibility. Not fully understanding reporting requirements for respective state and local agencies. Even employee turnover can interrupt data collection and processing tasks and schedules.

Given hurdles like these, digital transformation firm Softengi — which provides many of its services to the EHS industry — has uncovered what they term “some sad statistics” for EHS teams in general:

There’s a better way to process data for compliance and Tier II reporting. 

Central Data Collection Across Facilities: 3 Rewards

Especially for data that lives in different places, such as spreadsheets and data systems that aren’t fully integrated, gaining greater control over information helps ensure that Tier II reports are accurate, as well as auditable. At one end of this effort is data collection. At the other is final Tier II reporting. In between is keeping data visible and being able to monitor it for accuracy throughout the process, all within a single continuous view. 

This is where environmental data management software can make a positive impact. The aim is to centralize data collection functions and establish a single data repository for all information across EHS compliance operations. Then for each facility you oversee, it becomes easier to track and access all required compliance information, from digitally storing safety data sheets (SDSs) to threshold determinations and proof of compliance.

The result is improved data processing for EHS compliance, and better clarity and understanding for Tier II reporting by enhancing these three aspects of the compliance function.

1. Increase data visibility across sites

Again, centralizing information from dispersed facilities into one place increases data visibility for tracking and validation. Think of things like confirming chemical inventories, determining thresholds, and verifying SDSs.

2. Ensure control throughout the compliance process

In terms of compliance, the process is a chain of events: Product characterization, data verification, and final report submissions. Having control over the entire EHS compliance process is imperative to ensure the quality, completeness and accuracy of data throughout all phases of data collection and report compilation, not just at the final submission stage. 

“The voracious appetite for data is a challenge in general,” according to Bob Johnson, Environmental Affairs Manager for Lennox International, which operates 250 distribution locations in 40 states. “And then you add multiple systems, various types of database management, and a proliferation of (state) reporting portals. Trying to stay ahead of it all is a huge challenge.”

Making sure the process and chain of events are connected and run efficiently helps streamline Tier II reporting as a whole.

3. Understand reporting nuances at all regulatory levels to stay in compliance 

When sites are located in various states, tracking compliance updates and notifications specific to an EHS program area or local regulatory level is an ongoing obstacle. Automated alerts and notifications in an environmental data management software system help EHS leaders navigate regulatory requirements (and even fee structures) from state to state and at local levels. 

Now, consider one more stat from a study by business data and reporting solutions provider Workiva, published on esgtoday.com: 

More than 70% of executives surveyed across multiple industries and regions reported they lack confidence in their organizations’ own ESG reporting, and nearly two thirds feel unprepared to meet ESG goals and disclosure requirements.

Most EHS leaders who juggle Tier II reporting data across different sites feel the same way.

Transforming the way enterprises stay in compliance 

Encamp is on a mission to create a world where good for business can equal good for the environment. We help enterprises transform compliance programs and human processes into a technology-driven system that lays the foundation for accurate and ongoing environmental compliance through a blended method of intelligent high-tech solutions and high-touch expert support.

Consistently ensuring Tier II reporting accuracy for environmental compliance has long been an inexact science. Enter automation, and the emergence of EHS digital transformation, for more precise ways to collect compliance data, validate it, and file it in line with state and local Tier II reporting requirements. Just knowing the data you submit is accurate and void of non-compliance red flags is reason enough to automate the Tier II process. 

Yet the path to error-free Tier II reporting is constantly changing. For some common examples: Other pressing compliance initiatives pull EHS employees away from reporting. Tracking state and local regulations is an ongoing obstacle course, especially for updates. And as regulations get increasingly exact, verifying which ones apply to which facilities in which states and locales is mind-numbing.  

This is where automation goes further along the Tier II path than just final, accurate reports. Automating the process also lets EHS leaders:

Benefiting businesses of every kind

In the NAEM 2017 EHS&S Software Buyers Guide, 46% of EHS leaders said outdated software limited their operations’ compliance reporting effectiveness. It’s somewhat surprising, but that sentiment still holds true today: For many businesses and their EHS operations, a lack of technology like automation remains a roadblock to more efficient and accurate reporting. 

Also surprising is who these businesses are. Many are indeed ones that manufacture, store or use chemicals by the hundreds, with facilities in two or three states. But many others are ones like food and beverage chains, telecom companies, utilities, auto dealers and parts stores, repair and maintenance companies, and businesses that provide rental and leasing services. Or even gas stations and the oil & gas and pipeline transportation companies that provide the gas they sell. 

Such businesses typically maintain a low count of chemicals (by types and volume), and their business operations often include facilities across several states. Which means they’re still governed by state and local regulatory requirements for environmental compliance, must file Tier II reports — and can reap the same rewards of automating their reporting functions.   

3 More Positives of Automated Tier II Reporting 

This is where newer-generation environmental data management software comes in. By intersecting with EHS digital transformation to make automation possible, EHS stakeholders are able to enhance compliance reporting accuracy throughout the reporting process — in accordance with all applicable federal, state and local requirements, and all the way to final submissions, mailings to regulatory agencies, and even the process for paying filing fees.  

In between are three additional outcomes of automation that positively impact EHS operations as well as Tier II reporting.

1. Free up EHS resources for other environmental compliance priorities

Another aspect of environmental data management software and EHS digital transformation is the ability to digitize compliance data and centralize it in a single database. Automation takes over from there to reduce time spent inputting reporting information into different state portals, mailing hundreds of reports to local agencies (primarily LEPCs), and paying countless filing fees, among other tasks. The more EHS leaders and teams reduce their administrative burden, the more they can focus on other pressing strategic activities.

“For Tier II, in the past, we had about four EHS staff. But our recent focus on ESG has pulled some of those resources into other critical areas. Last year it was down to three, then it trimmed down to two. And this year (reporting year 2021), other than working with the people at each facility, I was down to me and you guys (at Encamp). So we’ve essentially replaced manpower with software.”

– Bob Johnson, Environmental Affairs Manager for Lennox International, which operates 250 distribution locations in 40 states

2. Navigate state and local regulations with expert support

Compliance updates and notifications specific to an EHS program area or local regulatory level present ongoing obstacles, especially when sites are located in various states. Automated alerts and notifications in an environmental data management software system help EHS leaders both track and navigate regulatory requirements (and even fee structures) from state to state and at local levels. This is particularly helpful in determining which sites are over threshold and must report for EHS compliance. 

“There’s no way to keep up with regulatory compliance issues across the U.S. and all 50 states. When you start getting into SERCs and LEPCs and their ever-changing requirements, it’s almost impossible because those requirements are changing so rapidly. So having a partner like Encamp to streamline (updates and notifications) is just phenomenal.”

– Denton Bruce, Senior Director of EHS at Bunzl Distribution, which maintains more than 200 facilities across the U.S. 

3. Manage regulatory and Tier II reporting requirements and mailings more effectively 

Go back to the issue of having to interpret constantly-changing regulatory requirements at the state and local level. It’s stressful, and can introduce a lot of doubt to the compliance reporting process. Reporting automation can actually help you be comfortable in managing complex regulations by verifying which ones apply to specific facilities and state and local agencies. Again, automated alerts and notifications serve notice to new regulations and others that have changed or been updated. 

And of course, automated reporting to all states and U.S. territories ensures that compliance reports and additional mailings meet all regulatory requirements and get to the right federal, state and local agencies.

Now, ask yourself a few questions

If any of the following situations are familiar, automating Tier II reporting tasks for EHS compliance should be a priority. Have you ever:

And here’s one last question: Did you ever think compliance reporting could be completed “at your convenience”? 

“Encamp has allowed us to modernize compliance reporting (largely via automation). Our compliance team is able to quickly review and prepare reports from our various locations across the country, at our convenience. There are summary screens which quickly organize the list of reports and the reporting status. Final reports are saved to a filing cabinet on a cloud-based system and are available any time we need them.” 

– Emily Z, EHS Manager (Capterra)

Transforming the way enterprises stay in compliance 

Encamp is on a mission to create a world where good for business can equal good for the environment. We help enterprises transform compliance programs and human processes into a technology-driven system that lays the foundation for accurate and ongoing environmental compliance through a blended method of intelligent high-tech solutions and high-touch expert support.

Encamp has raised $30M in a round led by Drive Capital, with participation from existing investors OpenView, High Alpha Capital, Allos Ventures, and more. The round follows on the back of a 500% increase in ARR in 2021 and rapid people growth, and values the company at $150 million. 

I’m grateful for these investors’ conviction in Encamp, for the employees that have gotten us to this point, and for our incredible clients, who make all of this possible.

We started Encamp four years ago with a dream of a future where businesses are able to automate environmental compliance data tracking and reporting at every facility to all the right regulatory agencies across all jurisdictions for every requirement — in one unified system.

However, that’s not how it works today.

Compliance and Sustainability

Facility environmental data is typically spread across a vast number of unrelated internal enterprise systems. Maintaining the integrity of facility environmental data across all these disconnected and constantly changing systems makes it challenging for companies to sustain robust and streamlined environmental compliance programs.

Encamp’s core thesis is that facility environmental data is essential to enable high performing environmental and social governance (ESG) initiatives and protect companies from compliance risks — and that unifying this data in a single system will help companies grow while protecting the environment.

Technology that Transforms Compliance

Encamp provides companies and environmental health and safety (EHS) teams a single system to track facility environmental data, assess compliance requirements based on that data, and automate compliance reporting to all the right regulatory agencies across a rapidly growing number of regulations

This system doesn’t just eliminate the complexity, cost, and constraints inherent with approaches involving billable hours and manual work—we believe it will be a critical foundation for driving environmental initiatives and sustainable growth in the world’s largest companies going forward.

We’ve been humbled to see our customers join our vision and transform their environmental compliance programs. Enterprises that invest in EHS software and a data-first approach to their environmental initiatives aren’t just more efficient. They are better environmental stewards—with more intelligent workflows, more robust compliance reporting processes, and more powerful analytics to achieve environmental and operational goals. This is also why we have seen a 500% revenue growth in 2021 and have many of the Fortune 1000 companies as customers.

What’s Next?

We’re on a mission to create a world where good for business can equal good for the environment. 

Looking ahead, and with this funding, we will be laser focused on building the environmental operating system that allows companies across the globe to use data to not only comply with environmental regulations, but to also unlock their potential for sustainable growth to build a better future. We believe that economic growth and environmental sustainability can fuel one another through technology—and we are looking for remarkable people who believe the same to help us build this future. 

Sic Parvis Magna (thus great things from small things).

Read the full press release here.

Does this mission excite you? Are you an exceptional individual looking to make an impact on the environment using technology? Check out our open job postings and apply today!

In EHS program areas for environmental compliance, sustainability applies in two ways. Naturally the first is complying with regulatory requirements for hazardous chemicals and waste to contribute to a sustainable environment. The second, is making risk management and compliance reporting a more efficient and sustainable process for EHS operations. 

Automated notifications and compliance reporting drive sustainability from both ends of this EHS program spectrum. As importantly, they provide a collective safeguard against non-compliance violations.   

Reasons for Automated Notifications and Reporting

Tracking updates and notifications within EHS program areas

A notable obstacle for many enterprises with distributed facilities is tracking compliance updates and notifications specific to an EHS program area or regulatory level. Especially when sites are located in various states, monitoring changes in each facility on a continuous basis is demanding, if not impossible. 

While updates to regulations and exceeding thresholds based on site-specific data are common triggers for notifications, so are actions such as adding or updating a facility’s emergency personnel and contact info. Outdated or incorrect facility contact information is in fact one of the most common errors for compliance reporting. Triggers like these and others can add up, which is where the value of automation for notifications comes in. (Read more in the Encamp eBook: Guided Environmental Compliance.)

By as much as 98%, based on Encamp customer data, automated actions reduce the number of facilities that are behind or out-of-date on compliance updates and notifications. Technology research firm Gartner offers additional insight on the value prop. For businesses in general, Gartner analysts predict that 70% of organizations will track data more rigorously for accuracy and quality in 2022, reducing operational risks and costs by 60%. Applied to EHS operations, reducing the risks of non-compliance and costly fines is always a positive.

Gartner analysts predict that 70% of organizations will track data more rigorously for accuracy and quality in 2022, reducing operational risks and costs by 60%.
– “12 Actions to Improve Your Data Quality”

To take advantage of automation, the most effective way is with technology that incorporates rules-based triggers and automates the process of recognizing necessary updates or notifications. Even better is when that technology also automatically submits updates or notifications in the right format and with audit-ready documentation. 

Setting sustainability goals

According to Program Manager Katie Wascom of Encamp’s Compliance & Customer Success team, automated notifications can also serve other critical purposes. 

“They can help tremendously in setting sustainability goals, especially regarding waste,” Katie said. “If an EHS team is able to accurately and timely capture chemical amounts on site (using notifications), including changes within a certain percentage, they can proactively tackle on-site management. This in turn sets the site up for success because they’re always prepared.”

Case in point: One chemical manufacturer and valued Encamp customer reported that “We were able to bulk upload chemicals, and add notifications for changes over 10% to notify (EHS staff) and have a meeting to discuss.” The notifications have helped the company identify potential threshold issues and address them accordingly.

“We were able to bulk upload chemicals, and add notifications for changes over 10% to notify (EHS staff) and have a meeting to discuss.”
– Large U.S. chemical manufacturer

Another potential aspect of goal-setting for sustainability comes from Julie Ragains, Encamp’s director of Customer Success and Fulfillment. “Imagine a notification to automatically alert you when something is quite different from your previous year’s report.” 

The issue in such a case could be the amount being reported for a product that, when compared to the previous year’s compliance report, has increased or decreased below a regulated threshold. As Julie explained, in a scenario like this, an automated notification could conceivably help the company avoid a non-compliance violation for submitting inaccurate data in their latest Tier II report.  

Automating task suggestions

A bit of background first on the Resource Conservation and Recovery Act (RCRA) for hazardous waste. RCRA requires such wastes to be properly managed from the point of generation — the “generator” — to the point of final destruction. Generator categories are based on the amount of waste generated per facility per month (i.e., a threshold).

An activity that causes a generator to exceed the threshold for its normal generator category for that month can be unplanned or planned. For an unplanned event, a company must notify regulatory authorities within 72 hours of the activity. When the event is planned, notification is required 30 days before. Jess Martin, a compliance program associate at Encamp who has an extensive background in RCRA, brought up the concept of automated task suggestions for when a generator exceeds their compliant generation limit.

“They could evaluate and either determine it was an unplanned episodic generation event and submit the proper forms for that,” she explained, “or completely update their generator status and submit necessary forms.”

Jess adds that tracking waste that’s generated, shipped, or both on a monthly or annual basis is instrumental in reaching sustainability goals. “You can’t track progress when you don’t have the data,” she said. For notifications, “the automation aspect could come from syncing with existing data pipelines, such as waste vendor data or internal waste tracking software.”

Improving Tier II reporting and data quality

Another common problem in many EHS program areas is data quality. Ideally, compliance data and Tier II reports should undergo QA/QC checks throughout the report compilation process. But the reality is that submissions are often hurried to meet due dates and quality goes largely unchecked. Are reports being filed with the right data? Going to the right agencies? In the right format? On time?

Along with standardizing processes and making them repeatable and sustainable across EHS program areas, automation reduces the “friction” of manual work — like pulling compliance data together from scattered sources and constantly checking the quality of information they have. 

Within the reporting process, automation can be applied to: 

Data collection

Data validation

Task notifications

Report submissions 

Some further numbers to confirm automation’s value: Based on Encamp’s  customer data for reporting, automation helps them reduce the time to complete and file compliance reports by more than 90% — and often eliminates 100% of errors before they occur. Relatedly in a study by Smartsheet, with employees in multiple industries estimating that a quarter of their workweek is spent collecting, copying, and “cleaning data,” 66% said automation would help reduce data errors. And finally, a study from Gartner research has found that organizations believe poor data quality to be responsible for an average of $15 million per year in losses.

In more ways than one for the environment and EHS program sustainability, automation is invaluable.

Organizations believe poor data quality is responsible for an average of $15 million per year in losses.
– Gartner

Transforming the way enterprises stay in compliance 

Encamp is on a mission to create a world where good for business can equal good for the environment. We help enterprises transform compliance programs and human processes into a technology-driven system that lays the foundation for accurate and ongoing environmental compliance through a blended method of intelligent high-tech solutions and high-touch expert support.

Credible and trustworthy data is central to an organization’s environmental compliance. Every day. Because for hazardous chemicals, hazardous waste, or both, state and local regulations don’t allow days off. The risk of disastrous events and the potential impact to the community and environment is too high — and too constant. 

In line with a business’s compliance program areas and Tier II reporting requirements, compliance information must therefore be consistently up to date, validated, complete, and accurate. Which means monitoring and collecting relevant data should be a continuous effort, right?

Unfortunately for many EHS operations, continuous data collection isn’t always doable, for notable reasons: Multiple facilities, often in different states. A shortage of trained EHS staff, particularly at the facility level, where non-EHS employees are forced to handle compliance tasks they’re not familiar with. But the biggest roadblock for gathering data is scattered data sources, the lack of a central database, and no established information flows or pipelines. 

The result is that data needed for environmental compliance isn’t always available. And when it isn’t, it can invite non-compliance and potentially costly penalties and reputational damage.

Achieving Continuous Environmental Compliance

A much stronger safeguard for environmental compliance is to build a centralized compliance foundation to manage and monitor data in one place — continually. Equally vital is a continuous data collection process tied to the compliance foundation you establish. The purpose of these measures is twofold:

  1. Businesses and their EHS teams drive continuous environmental compliance via a single source of truth specific to applicable program areas, and
  2. Should the business scale and add or acquire facilities, a compliance foundation’s course of persistent data collection and improved data management, quality, visibility, and control supports growth and continuous environmental compliance accordingly. 

These measures are also the first two steps of Encamp’s Guided Environmental Compliance method, which additionally introduces digital transformation to compliance data management and the reporting process.

From our experts: “Technology and best practices must work together” 

Although technology plays a key role in achieving continuous environmental compliance, best practices for data collection and building your respective compliance foundations are just as key. No one knows this better than Megan Walters, VP of Compliance & Customer Success at Encamp, and Eugene Simonds, Encamp’s Compliance Program Manager. They discuss the uppermost best practices for continuous environmental compliance in the sections that follow.  

Establish your environmental compliance foundations 

Without sound compliance foundations for your company’s program areas, according to Megan, the biggest problem for environmental compliance and reporting is poor data quality. The accuracy of information suffers due largely to data not being fully visible and monitored on a continuous basis. Subsequently, compliance reports that are inaccurate or incomplete because of unchecked or unvalidated data pose glaring risks for non-compliance — and for the financial, operational and reputational penalties that can come with it.

A worse outcome is that leaders across the organization begin to question whether environmental compliance efforts are able to meet the requirements of federal, state and local regulatory agencies. 

Building a reliable compliance foundation for each regulatory program area, whether EPCRA, RCRA, the Clean Air Act, or the Clean Water Act, should therefore become a priority for compliance operations. This is also a first step towards environmental digital transformation. 

Where technology and environmental digital transformation comes in

“Within a given compliance foundation, data should consist of all existing corporate, facility, and personnel information relating to that program area,” Eugene said. “Data should also be organized in a way that’s readily visible and available to those who need it, enterprise-wide.” 

Technology and environmental digital transformation come into play here in the form of digitized data and a single centralized system for managing compliance information. (Encamp is such a unified data system). When data is organized in one centralized location, the unified system serves as your organization’s single source of truth for compliance operations and continual environmental compliance alike. Within the system, digitized data is additionally more visible and easier to manage electronically.

For data collection and establishing a compliance foundation, Megan suggests making these best practices a staple of your compliance program:

For a centralized data system, also consider the various data it should house. According to Eugene, key data for continuous environmental compliance should include: 

(Note that when Encamp is your chosen data system, a dedicated Encamp Customer Success Manager (CSM) works with your environmental compliance and operations teams to collect existing data during initial onboarding. Centralizing data into the single Encamp portal then sets the tone for the system to become your compliance foundation for a particular program area.)

Greater control of environmental compliance information

“The premise of any unified data system and centralizing environmental compliance information is to increase control of your data, both in collecting it and in building compliance foundations,“ Eugene added. Encamp is built on this premise, and even extends control to being able to push compliance data to all relevant regulatory databases at a state or federal level. Completing this critical step means you no longer need to manually access or update information in individual state and federal systems, which can be especially time-consuming. 

For new facilities, scalability and best practices are built in

If your organization adds facilities (whether through company growth or acquisition), it’s important to have a robust and flexible system that scales and correspondingly makes changes to your compliance foundation, including all places in which data lives at a state and federal level. As an inherent change management system for all new sites, your environmental compliance operations are able to:

Technology research firm Gartner predicts that in 2022, 70% of organizations will rigorously track data quality levels, improving quality by as much as 60% to significantly reduce operational risks and costs.

Establish continuous data collection

“Collecting data for environmental compliance purposes is hard enough as it is” as Eugene also pointed out. “But when data lives in different locations such as spreadsheets and separate databases, information is harder to obtain in a sustained manner.” For compliance foundations and continual environmental compliance, this makes creating a constant, real-time data monitoring and collection process all the more critical. 

Eugene’s recommended top best practices to establish data collection on a continuous basis are to:  

Whereas you once had countless spreadsheets being passed around via email and internal drives, establishing a continuous data monitoring and collection process allows all relevant compliance data for each program area to be collected in a systematic and largely automated manner. 

“For environmental compliance in a continuous manner,” as Eugene said, “the end result is greater data visibility and control, with less effort and fewer errors.”

Standardizing the data collection process across all locations ensures that needed data is collected more accurately and in real time. According to a recent study, 66% of operations professionals cited automation as being key in reducing data errors.

Transforming the way enterprises stay in compliance 

Encamp is on a mission to create a world where good for business can equal good for the environment. We help enterprises transform compliance programs and human processes into a technology-driven system that lays the foundation for accurate and ongoing environmental compliance through a blended method of intelligent high-tech solutions and high-touch expert support.

Katie Waskom is a Program Manager at Encamp, and is one of the top proponents of our mission to create a world where good for business can equal good for the environment. Given the growing relationship between environmental compliance and sustainability, we got her thoughts on the current state of sustainability, and how digital transformation fits into the sustainability equation with advancements in environmental compliance management and reporting.

Here’s what Katie had to share (responses have been edited for clarity and length).

Putting Environmental Compliance and Sustainability in Perspective 

Where did your interest in environmental compliance and sustainability start? 

I first took an interest in sustainability in college when I was part of an on-campus initiative and recycling program. Then when I studied abroad in Germany, my course work was in sustainability. Germany is extremely forward thinking in those terms, and they actually embed sustainability in their laws and environmental regulations. That’s where I learned what being sustainable really looks like — how it affects some 4,500 German companies and plays out in day to day life, how easy it is to transition, and especially how environmental compliance and sustainability work together.  

After college, I took what I learned in Germany to my first job, which was at Cummins, Inc. Cummins is a global manufacturer of power systems for industries including trucking, agriculture, mining, rail, shipping, and others, and they have an extensive ESG | Sustainability Reporting program. They had some lofty goals for sustainability while I was there, and a lot of pieces to still put in place. So it was a very good experience. But Encamp is where the environmental compliance aspect has come into a much clearer focus.

How would you define sustainability and its current state? 

Sustainability applies to a lot of different things. Right now, the sustainability movement is based largely on the three pillars of environmental, social, and economic concerns. For businesses in particular, an effective sustainability program considers how such an initiative gets paid for and its economic benefit, plus the initiative’s social reach and who will benefit. Businesses also want to show they’re good stewards of the environment. This is where environmental compliance and sustainability are becoming more aligned. 

As an investment decision-making criteria, sustainability reporting is becoming more and more critical… It allows people to determine a company’s stance on social issues and protecting the environment. 

Yet as ESG has taken center stage, sustainability has increasingly involved environmental and social governance as a financial component, especially for investing. This is why sustainability reporting is so critical now, since it allows people to determine a company’s stance on social issues and protecting the environment as investment decision-making criteria. 

Writer’s note: As the Corporate Governance Institute says, Environmental, Social, Governance criteria are “a set of standards for how a company operates regarding the planet and its people.” (See our related Encamp blog on ESG.)

How does digital transformation contribute to a company’s sustainability cause?

Technology contributes to the mix of environmental compliance and sustainability in multiple ways. For a company’s sustainability program, knowing where data originates and where it resides is integral to pursuing sustainability goals. Encamp’s unified data system, in particular, enables companies to centralize compliance data and validate its sources and quality. Data also becomes more visible for compliance reporting, which lets compliance teams and other organizational stakeholders track and QC/QA data in a more thorough manner to ensure its accuracy.

forest filled with trees at sunriseAlso on behalf of our customers, we partner with a non-profit called One Tree Planted to plant a tree somewhere in the world for every Tier II report a customer files using Encamp. The effort ties directly to carbon offsetting. Since 2018 when Encamp started working with One Tree Planted, we’ve had more than 18,000 new trees planted!

Another positive contribution for sustainability is that advancements in digital technology make data management and reporting more efficient with a digital transformation approach. Along with digitizing their compliance records, EHS teams can turn report compilation tasks into standardized, sustainable processes through automation. In addition to centralizing compliance data, for instance, the Encamp solution also automates final report submissions to all applicable regulatory agencies at the federal, state and local level. Depending on the number of facilities they have to file compliance reports for, our customers routinely save hundreds of hours every year just in the reporting process. 

How can businesses drive sustainability efforts by way of compliance?

Back to sustainability’s environmental aspect, companies can reduce their carbon footprint significantly just by adopting sustainable business processes. This is why environmental compliance technologies like Encamp continue to build more automation into the process for compliance data and reporting management, which continually improves productivity by maximizing technology resources as well as human resources.

For social responsibility, environmental compliance enables companies to report hazardous chemicals they manufacture, use or store on-site to regulatory agencies. With consistent monitoring, environmental compliance and sustainability goals alike are easily tracked and achieved. Here again, utilizing a unified data system provides comprehensive monitoring capabilities to know the status of a facility’s chemical list and inventories at all times and stay in continuous compliance.

When a company’s compliance program becomes sustainable this way, it benefits nearby communities and society as a whole — which can enhance a company’s environmental responsibility as well as its brand, customer base, and even decision-making and profitability. This is what we mean at Encamp when we say what’s good for business can be good for the environment.

Lastly for the economic part of sustainability, non-compliance with environmental regulations can be costly in more ways than one. For the most severe or repeated violations, financial penalties and legal fees can easily reach six figures, or sometimes in the millions. But unsustainable practices for compliance and reporting management can be also expensive because they’re largely inefficient and often fail to put the right resources to use. Sustainable business practices for environmental compliance can help companies and their EHS operations pinpoint areas of improvement and reduce such inefficiency, including costs.

What is your outlook for sustainability in the next few years? 

I think sustainability is definitely a topic people are becoming more aware of. And whether as consumers or B2B decision-makers, they’ll want to do business with companies that are like minded. This is a really powerful dynamic, and will continue to make environmental compliance and sustainability a package deal for businesses and consumers alike who want to protect the environment and take a sustainable approach to doing it.

I also see the economic aspect of sustainability being an even greater consideration for investors than ESG has already made it. If a business wants to attract investors, expand operations, or even position itself for acquisition, its sustainability efforts will have to be of top level importance in the eyes of potential investors as well as customers. In that sense, a company’s sustainability efforts are visible. They’re tangible. And especially with a well-managed sustainability program, businesses can make a positive impact with it. 

Organizationally, larger enterprises will continue to make the most impact with sustainability programs. Primarily, they have bigger carbon footprints that benefit from sustainable practices. But larger brand-name companies also tend to have boards of directors who are very forward thinking toward environmental and social causes. They’re environmentally and socially responsible, naturally, but they also understand how their businesses are perceived by the public. And they certainly have the financial and economic clout to promote sustainability. 

These enterprises will increasingly set the tone for companies of all sizes to implement sustainability initiatives going forward. Environmental compliance and sustainability will also continue to become a common cause for businesses in general.

Transforming the way enterprises stay in compliance 

Encamp is on a mission to create a world where good for business can equal good for the environment. We help enterprises transform compliance programs and human processes into a technology-driven system that lays the foundation for accurate and ongoing environmental compliance through a blended method of intelligent high-tech solutions and high-touch expert support.

How would a digital strategy impact our company’s EHS process and compliance outcomes?” It’s a good, thought-provoking question, and a lot of EHS leaders are asking it right now when considering a digital game plan of their own. Which I’m glad they are. For one thing, it echoes my own belief that companies must pick up the digital pace for their EHS and compliance operations. But more than that, consistently positive compliance and business outcomes are how Encamp views the merits of EHS digital transformation — or in our case, the environmental aspect of EHS and what we call environmental digital transformation.

Encamp CEO and Co-founder Luke Jacobs

Thankfully the interest in environmental digital transformation is spreading. With digital transformation in general being recognized as a strategy since 2015, many businesses have discovered its value and extended digital technologies and practices to their environmental compliance efforts. Many others, however, are just starting on the digital journey for EHS. 

Luke Jacobs, Encamp CEO & Co-founder

Investing in Tomorrow, Today 

Answering the question for digitalization in EHS

It’s encouraging that more EHS leaders are asking how a digital strategy can impact compliance processes and outcomes. But the more pressing question is typically, “How do we start?,” which doesn’t always have a clear-cut answer. 

One article on EHS digital strategies puts an answer in motion. The article’s author is Rebecca Dabbs, a Climate Change and Sustainability Services partner at consulting firm Ernst & Young (EY), and she makes some excellent points about digital technologies in EHS.

“It is not the role of EHS professionals to know it all,” Dabbs says in her article’s final assessment. “Instead, those seeking to leverage digital technology to improve EHS should understand their needs and strategically engage support as required. This includes seeking out trusted advisors who understand the elements required for success. Accessing the right support to achieve successful initiatives, and to build an integrated digital architecture, is critical.”

Some EHS leaders might call it an environmental digital transformation epiphany. A call to action, perhaps. But let’s also be realistic about the transformational scope required to achieve better EHS process outcomes for environmental compliance. 

Because as Dabbs also points out in her article, “There are no simple solutions; one size does not fit all and one shiny, new gadget is not going to lead to long-term improvement.”

The simple math of compliance

Before founding Encamp, I worked in the environmental consulting world and was constantly buried in compliance reporting. And like most anyone who’s ever filed a Tier II report, I always thought the process was basically a mess of endless tasks and data… with no rhyme or reason to any of it. Ironically, though — and what truly reveals compliance reporting as being harder than it needs to be — is that the framework of compliance itself is really quite simple. I call this, accordingly, the “simple math of compliance.”

Compliance is a function of facilities across discrete jurisdictions
that define requirements applicable to operations that have
environmental impact.
 

Now think of how digital technologies fit into this equation. With no universal playbook on how to implement and optimize such technologies for compliance functions, knowing where to start on the transformation path isn’t easy. 

Obviously, it helps if an organization already has an existing digital foundation for other business functions. But even then, integrating digital technologies for EHS and compliance operations in particular can be a puzzle with no discernible starting point. 

Guided Environmental Compliance

So here’s the next question for EHS leaders: 

“What can our environmental operations do to successfully plan and adopt environmental digital transformation across our organization?”

Encamp has been fortunate enough to work with well-recognized businesses in industries of all kinds, and based on the steps many of them have taken in their own digital journey, we’ve formulated a method we call Guided Environmental Compliance.

The 5 steps to environmental digital transformation

eBook, Guided Environmental Compliance

You can read all about the method in our interactive eBook Guided Environmental Compliance, but the gist of its five core steps are in the following chart.

And don’t think of these steps in terms of starting from scratch. Think of them as unlocking more of the digital energy your organization likely already has in place.

 

Encamp's 5 steps to environmental digital compliance

A digital path to compliance simplification

The principle of Guided Environmental Compliance is that environmental digital transformation brings a simplified method to the complexities of compliance and reporting. As your organization integrates digital technology into its compliance program areas, it empowers EHS and operations teams to centralize information, make data more visible, construct a continuous and auditable data collection process, and ultimately gain central control over your entire compliance program. 

Several businesses that incorporate Encamp’s technology into their digital strategy, in fact, have extended our method’s framework to compliance stakeholders throughout their organization, including at the executive level.

In effect, the digital simplification path runs from gathering and validating data to submitting final reports, and taking our method’s transformational steps makes the most immediate impact toward realizing continual compliance and strategic sustainable value. 

It’s also how organizations effectively join Encamp’s mission to, as we say, create a world where good for business can equal good for the environment.

Where and how to start

From my own experience, gaining a better understanding of your organization’s environmental compliance requirements and goals is a top prerequisite for any environmental digital transformation. 

As part of their digital strategy assessment, EHS leaders should consider all the places technology would fit within their compliance management requirements to make goals more achievable, especially from an end-user’s perspective. For instance, how might solutions like digitalized processes for data collection make data management and reporting functions more efficient for an EHS team? (Answer: No more time-robbing manual work and human error. Processes become easier to automate, standardize, and repeat from one reporting year to the next. Subsequently, process consistency improves the quality and accuracy of your data, along with your trust in it.)  

Compliance goals naturally vary from one organization to another for its EHS and compliance operations. But to reiterate the five steps in Encamp’s Guided Environmental Compliance method, most organizations we work with cite the need to establish compliance foundations and a continuous data collection process. Automating the compliance reporting process, including receiving regulatory updates and notifications, is also a primary aim. 

Ultimately, when you’re weighing long-term strategic EHS and sustainability value for your organization, a final step — and key goal — is to unify compliance processes across all of your organization’s applicable program areas for continual compliance. 

High-tech solutions and high-touch support

After determining your requirements and goals for environmental digital transformation, a strategy requires formulating a course of action, both with your organization’s IT team and a valued digital technology partner. Of specific note here, the more this digital technology partner can guide you, the better the plan. 

Understandably, the adoption of digitalization in EHS is often met with fear of the unknown, which is often the case for any digital transformation effort. As you strategize and assemble your foundation for environmental digital transformation, having the right experts dedicated to overcoming current and future challenges is absolutely vital. Long-term, a knowledgeable digital technology partner can help prepare your organization to see ahead and successfully manage change.

Fundamentally, Guided Environmental Compliance blends this kind of high-touch expert support and high-tech solutions to transform compliance programs and human processes into a technology-driven system. The system is intrinsic to your organization’s own environmental operations, cementing the digital foundation you create to achieve accurate and ongoing environmental compliance. 

Also because organizations grow and add or acquire more facilities, this foundation scales appropriately when needed.  

This is why our guided method applies a data-driven paradigm to transform environmental compliance on an ongoing basis, a first principles approach that inspired the founding of Encamp in 2017, and that continues to influence us now.  

A relational database and operating system 

At its core, our method builds the relational database and operating system for your environmentally relevant operating data. Or in simple-math-of-compliance terms, you get a unified data system to manage the endless mess of tasks and data with a clear path and understanding. 

Compliance support from EHS industry veterans

Providing a great customer experience and helping customers achieve their goals is one of Encamp’s benchmarks and has been since we started. Central to the Guided Environmental Compliance method are our own environmental compliance experts, who can help a business’s environmental operations untangle a web of data, standardize processes, and preserve institutional knowledge. They also help align all of this into a compliance program that works across multiple facilities, states, and operational systems. 

I’m proud to say the compliance experts at Encamp are EHS industry veterans who were previously environmental supervisors, managers, scientists, engineers, state regulators, and consultants. As they like to say, “We’ve been there,” and they mean it.

Our Vision Beyond Environmental Digital Transformation  

I’ll reiterate Encamp’s mission here because I truly believe in it: We’re out to create a world where good for business can equal good for the environment. By making environmental compliance faster, simpler, and more accurate, we align incentives between regulated industry and regulators, and especially the public. Going forward, this will continue to make for a healthier and safer environment. 

For businesses, It will reduce compliance costs and risk. And for regulators, it will give them the data that’s most critical to effectively achieving public policy goals to protect the world in which we live.

Finally, in building the unified data system for environmental information, we’ll continue to help companies unlock strategic sustainability and drive continual compliance. As they do, they’ll continue to align business outcomes with social responsibility, and become better stewards of the environment.

Chat again soon,

Luke

The Emergency Planning and Community Right-to-Know ActEPCRA — was passed in 1986 in response to chemical-related safety and environmental concerns in communities throughout the U.S. Specifically, the concerns stemmed from hazardous chemicals stored and handled in facilities located in these local communities. 

EPCRA in simple terms

Since 2018, Encamp’s Tier II Reporting software for section 312 EPCRA compliance has made us the EHS industry’s largest third-party filer of Tier II reports. Compliance reporting is also one of the critical steps in Encamp’s Guided Environmental Compliance method that integrates digital technology into compliance program areas to centralize information, make data more visible, and build a continuous and auditable process for EHS operations. This guided method also blends Encamp’s high-tech software with the high-touch support of our compliance experts, who know the in’s and out’s of EPCRA and its sections that set regulatory provisions for regulated facilities within a local jurisdiction.

Yet given the complexities of EPCRA, we get questions about it virtually every day. Especially for Tier II and reporting, here’s what you should know about EPCRA… in simple terms. Call it our way of helping you and your EHS team avoid the common reporting errors we see companies make every year in their Tier II filings. 

Glossary

Why is the “Community-Right-to Know” section of EPCRA so important?

Community Right-to-Know provisions help increase the public’s knowledge and access to information on chemicals stored at individual facilities, their uses, and releases into the environment. States and communities, working with facilities, use the information to improve chemical safety and protect public health and the environment.

SERC, TERC and LEPC roles

Gotta love all the acronyms, right? At the state level is a State Emergency Response Commission (SERC), or where applicable, a Tribal Emergency Response Commission (TERC). A Local Emergency Planning Committee (LEPC) resides on the local level in each community within a state.

The duties of SERCs and TERCs

The SERC supervises and coordinates the activities of the LEPC, establishes procedures for receiving and processing public requests for information collected under EPCRA, and reviews local emergency response plans. In regards to TERCs, the Chief Executive Office of the Tribe appoints the commission’s members; TERCs have the same responsibilities as SERCs.

What LEPCs do

LEPCs are composed of local officials including police, fire, civil defense, public health, transportation, and environmental professionals. Also serving on these committees are representatives of facilities subject to the emergency planning requirements, as well as community groups and the media. LEPCs must develop an emergency response plan, review it annually (at a minimum), and provide information about chemicals stored or used in the community to local citizens.

EPCRA sections and their four key provisions

EPCRA entails four core responsibilities for chemical use and storage, classified by sections. These sections apply to all regulated facilities within a local jurisdiction.

A fifth EPCRA section is section 322, Trade Secrets. For companies that wish to claim trade secrets for chemicals reported under EPCRA, EPA requires a facility to submit a substantiation to justify the claim of trade secrecy as specified in Title 40 of the Code of Federal Regulations (CFR), parts 350 to 372. The section 322 form has four parts:

See EPA’s EPCRA website for more in-depth sections information, frequently asked questions, and guidance documents.

Tier II falls under EPCRA section 312 

Tier II reporting is housed under EPCRA section 312. For regulated facilities, the requirements of this section dictate that facilities submit an annual inventory of hazardous chemicals onsite that surpass a stated quantity threshold. Thresholds are federally mandated, but can be superseded by state or local requirements. Chemical inventories are submitted to the facility’s SERC (or TERC), LEPC, and local fire department.

Section requirements in more detail

Sections 301-303, Emergency Response plan guidelines 

LEPCs are tasked with emergency response planning and notification for their communities, which directly involves the facility that stores extremely hazardous substances. You must comply if your facility meets the following conditions:

  1. Any EHS is present in an amount equal to or greater than its threshold planning quantity (TPQ).
  2. Has been designated for emergency planning purposes, after public notice and opportunity for comment, by the SERC, State Governor, or the Chief Executive Officer of the Tribe for the Indian Tribe under whose jurisdiction your facility is located

Emergency Response plans contain information that community officials can use at the time of a chemical accident.

A response plan report must include:

  1. Emergency planning notification
  2. A designated facility emergency coordinator
  3. Changes relevant to emergency planning
  4. Requested information if the LEPC requests it

Section 304, emergency notification guidelines

Emergency notification reports must be submitted immediately to officials at both the local (LEPC) and state (SERC, TERC) levels whenever a facility accidentally releases hazardous substances and/or EHSs. 

Substances include any of the EPA’s listed types of chemicals in an amount equal to or greater than its reportable quantity.

Regulated chemicals include ammonia and hydrogen peroxide and any substance in Appendix A of the EPA hazardous substances list, or formaldehyde, nicotine, and any substance included in Appendix B.

An emergency notification report must include:

  1. The chemical name
  2. An indication of whether the substance is extremely hazardous
  3. An estimate of the quantity released into the environment
  4. The time and duration of the release
  5. Whether the release occurred into air, water, and/or land
  6. Any known or anticipated acute or chronic health risks associated with the emergency, and where necessary, advice regarding medical attention for exposed individuals
  7. Proper precautions, such as evacuation or sheltering in place
  8. Name and telephone number of contact person

Sections 311-312, thresholds and reporting requirements

Again, Tier II reporting is a section 312 requirement. Per Occupational Safety and Health Administration (OSHA) regulations, facilities must maintain an MSDS or SDS for any hazardous chemical used or stored in the workplace. 

Regulated chemicals:

Note that these guidelines apply at the federal level. States may have a lower threshold.

  1. EHSs listed in Appendix A and Appendix B with a TPQ of 500 lbs or less
  2. Gasoline at a retail gas station, with a threshold level of 75,000 gallons
  3. Diesel fuel at a retail gas station, with a threshold level of 100,000 gallons
  4. All other hazardous chemicals with a TPQ of 10,000 pounds.

A Tier II report must include:

  1. The chemical name or the common name as indicated on the MSDS or SDS
  2. An estimate of the maximum amount of the chemical present at any time during the preceding calendar year and the average daily amount
  3. A brief description of the manner of storage of the chemical
  4. The location of the chemical at the facility
  5. An indication of whether the owner of the facility elects to withhold location information from disclosure to the public

Section 313, Toxics Release Inventory (TRI) guidelines

As a mandatory program for toxic chemical releases and pollution prevention activities reported by industrial and federal facilities, TRI typically applies to larger facilities involved in manufacturing, chemical manufacturing, or hazardous waste treatment. Currently, more than 21,000 facilities around the U.S. are subject to TRI requirements, which is determined by your facility’s NAICS Code, number of full-time employees, and chemical thresholds. 

Verify if your facility is a TRI-covered industry

In all, TRI examines wastewater discharges, air emissions through stacks, air flow through doors and windows (fugitive air release), off-site transfer of waste or by-products to landfills or recycling facilities, and surface water discharge like storm water. TRI reports are due annually on July 1st.

Regulated chemicals:

Chemicals covered by the TRI program are those that cause cancer or other chronic human health effects, significant adverse acute human health effects, and significant adverse environmental effects. See TRI chemical changes as of January 2022.

Additional EPA resources

List of Lists

Updated Tier II forms and instructions

State-specific Tier II reporting instructions and procedures

Important schedules and due dates

Note that these are federal schedules. For sections 302 and 304, states may have more stringent timelines.

Transforming the way enterprises stay in compliance 

Encamp is on a mission to create a world where good for business can equal good for the environment. We help enterprises transform compliance programs and human processes into a technology-driven system that lays the foundation for accurate and ongoing environmental compliance through a blended method of intelligent high-tech solutions and high-touch expert support.

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