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.

No matter what industry they’re in, many businesses have started using lithium-ion batteries as an alternative energy solution to maximize their bottom line, for good reason. Compared to its lead-acid battery counterpart, a lithium-ion battery is 95% more efficient.  However, reporting lithium-ion batteries for Tier II continues to raise questions for EHS teams.

Although lithium-ion batteries are sealed, they have the potential to leak flammable chemicals. Due to this, EPCRA requires facilities to complete a Safety Data Sheet (SDS) and Tier II report if the applicable reporting thresholds for batteries on-site are met or exceeded.

3 Common Questions for Lithium-Ion Battery Reporting

Here are three common questions usually asked on whether lithium-ion batteries fall under a facility’s specific Tier II reporting requirements:

      1. When is a Tier II report required for lithium-ion batteries?
      2. What are the Tier II reporting thresholds for these kinds of batteries?
      3. How does a facility report lithium-ion batteries for Tier II? 

1. When is a Tier II report required for lithium-ion batteries?

Some lithium-ion batteries qualify under EPCRA Section 311(e)’s “consumer product exemption,” which excludes from reporting “any substance to the extent it is used for personal, family, or household purposes, or is present in the same form and concentration as a product packaged for distribution and use for the general public.” 

When determining whether any lithium-ion batteries at a facility are exempt from Tier II reporting, consider if they’re in the same packaging and concentrations as lithium-ion batteries sold for personal use.  If the answer is yes, regardless of whether they’re intended to be distributed for use by the general public or used for the same purpose as a consumer product, then those batteries are exempt.

All other large commercial type lithium-ion batteries stored in a facility are not exempt and should be included in a Tier II report. For example:

Report batteries that are used to power forklifts, because these batteries are not sold for use by the general public.

Report solar batteries of a particular size (approximately 100kWh) that typically have only industrial applications.

Don’t report batteries that the maintenance department uses to power their cordless drills, because these are batteries sold for use by the general public (i.e., the same batteries available for purchase at a hardware store).

Don’t report solar batteries of a particular size (approximately 3 kWh) that consumers would use in their homes. 

A gray area exists in what constitutes a lithium-ion battery packaged for distribution and use for the general public. The burden for making this determination is on the facility and they should be able to justify why lithium-ion batteries are exempt.

If you’re in any doubt about whether an exemption applies at a specific facility, be sure to err on the side of caution and report the batteries as a chemical. Doing so will cover the facility from a regulatory compliance perspective, while also increasing safety for first responders and emergency planners. If further guidance is needed, it’s best to reach out to the SERC or LEPC.

 

2. What are the Tier II reporting thresholds for lithium-ion batteries?

Step 1: Determine the reporting threshold

Because lithium-ion batteries are flammable and present potential safety issues, they’re subject to EPCRA regulations and the reporting thresholds determined for Tier II filing. But unlike lead-acid batteries, lithium-ion batteries do NOT contain any Extremely Hazardous Substances (EHS). Therefore, the reporting threshold for lithium-ion batteries (at the federal level) is 10,000 pounds.

At a state and local level, reporting thresholds are more complex in that they vary among states and even counties and local jurisdictions. While many states have adopted the 10,000-pound reporting threshold for hazardous chemicals, a handful of states have lower Tier II reporting thresholds. This makes it imperative to determine the appropriate requirements for a specific state. For example, Louisiana has a hazardous chemical reporting threshold of just 500 pounds — meaning, having just one lithium-ion battery for a forklift may be enough to require Tier II reporting.

In other cases, specific counties and cities may have even lower reporting thresholds. For example, Gilbert, Arizona has stricter reporting requirements than the state-level.

Step 2: Perform the threshold determination

Now that it’s been determined a Tier II report is needed and what the reporting threshold is, the next step is to quantify the amount of lithium-ion batteries at a facility and make a threshold determination. There are two options available when performing a threshold determination:

Quantifying as Mixture 

Quantifying by Component

In nearly every situation, it’s more appropriate to perform a threshold determination using Option 1, for these reasons:

If a facility has previously fulfilled obligations for EPCRA Section 311 (SDS reporting) by reporting their lithium-ion batteries as a mixture, the same should be done on the facility’s Tier II report. The opposite is also true — if it’s previously reported as components on the Section 311 reporting, then the facility must do the same on its Tier II report.

To illustrate the difference in complexity between these two approaches, consider the following examples for the same facility (based on requirements in the State of Indiana).

 

Example 1. Quantifying as a mixture for the state of Indiana

quantifying lithium-ion batteries as a mixture

13,250 lb. > 10,000 lb. threshold – Lithium-ion batteries need to be reported at this facility.

 

Example 2. Quantifying by battery component (copper) for the state of Indiana

quantifying lithium-ion batteries by battery component

11,338 lb. > 10,000 lb. threshold – Copper would need to be reported at the facility.

 

Note: The exercise in Example 2, quantifying by battery component, would need to be repeated for each constituent in the batteries (lithium-cathode, lead, etc.).

If the threshold is being determined using threshold Option 1, quantifying as a mixture, the following information is needed:

As shown in Option 1, all that’s needed is to add up the total weight of the lithium-ion batteries and compare the weight to the hazardous chemical reporting threshold.

 

3. How does a facility report lithium-ion batteries for Tier II?

Now that the quantity of reportable batteries has been confirmed, and it’s been determined that it exceeds applicable thresholds, the last step is creating a Tier II report. Here, we discuss the individual sections that need to be completed. Note: Where examples are provided, the data and scenario from Example 1 are used.

Chemical details in a Tier II submission

Although the Tier II reporting portal interface will vary depending on the state, the following will be true when reporting lithium-ion batteries:

Physical and health hazards

Most lithium-ion batteries will have similar hazards, but it is very important to reference the lithium-ion battery SDS from the manufacturer specific to the batteries at a facility. This way, first responders and emergency planners will be working with the most accurate information. Hazards can typically be found in Section 2 of your SDS.

Typical hazards as they are reported on a Tier II report may be:

Physical hazards:

Health hazards:

Storage locations

Lithium-ion battery storage locations will consistently be reported with the following properties:

Frequently Asked Questions

I have different SDSs for different types of lithium-ion batteries at my facility. Should I consider them different mixtures, each with their own reporting threshold?

Generally no. While it is ultimately up to the facility to use professional judgment to determine whether the amounts of two mixtures (e.g., two batteries from two separate manufacturers) should be aggregated or counted separately, most lithium-ion batteries present the same physical or health hazards and should be aggregated for threshold determinations. 

How do I determine the weight of my lithium-ion batteries?

First, determine the manufacturer and model number of the battery. Most manufacturers post specifications (including weight) on their website for the various lithium-ion battery models they sell. If the weight specification of a particular battery model is unavailable, contact the manufacturer directly.

 

Reporting lithium-ion batteries on a Tier II report is critical

Again, even though lithium-ion batteries are sealed, they can leak or spill and cause potential exposure to hazardous chemicals. Their flammability also presents safety concerns for local emergency agencies as well as fire departments and first responders. Reporting lithium-ion batteries on a Tier II report therefore is critical. This guide helps facilities ensure their report is accurate. Do you have further questions about reporting lithium-ion batteries? Reach out and learn how Encamp can simplify environmental compliance data and reporting for you.

 

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.

As if environmental compliance reporting isn’t confusing enough. What chemicals, for instance, does the EPA consider “hazardous.” If they are hazardous, what are their Tier II reporting thresholds? And why do Tier II reporting requirements (a.k.a., Tier 2 reporting requirements) for states and local jurisdictions constantly change? 

When EPA reports are inaccurate, incomplete, or never even filed when they’re required to be, the last thing compliance leaders need are notifications of non-compliance and potential EPA violation fines. Nor do many EHS teams have the time and resources to spend on remediating EPA violations, instead of working on higher priority initiatives like sustainability. 

Within the scope of environmental compliance reporting, the best way to avoid any violation is to first understand what constitutes non-compliance. Equally vital is understanding how proper reporting can guard against your organization being reported in environmental complaints or for a company violation of some kind.

What Is an EPA Violation Where Reporting is Concerned?

There are far too many potential causes of compliance and Tier 2 reporting violations to delve into here. There’s also no “official” EPA violations list, per se. But a good example of documented violation triggers comes from an EPA alert that took effect in November 2021 for Tier 2 reporting year 2022.

To address chemical storage concerns for EPCRA, the EPA issued an Enforcement Alert on the Risks of Improper Storage of Hazardous Chemicals at Chemical Warehouses and Distribution Facilities. The Alert noted that businesses filing compliance reports constantly failed to:

Among these concerns, the failure to submit a Tier II form is clearly a violation. Less clear, however, is an issue such as an up-to-date Safety Data Sheet (SDS). 

Safety Data Sheets are often outdated

Even when SDSs are filed as needed to meet Tier 2 reporting requirements, they’re often outdated and don’t meet OSHA’s modified Hazard Communication Standard (HCS). The HCS guideline in turn conforms to the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Given that compliance stakeholders must sometimes manage hundreds of SDSs for their product inventory, then, HCS and GHS guidelines can easily get overlooked and be cited as an EPA report violation. 

Worse than a reporting violation, outdated Safety Data Sheets can put first responders and communities in danger when the latest safety information for hazardous chemicals isn’t fully made available.

But a much worse consequence is that out-of-date SDSs can put first responders and local communities in danger when the latest safety information for hazardous chemicals isn’t fully made available. Fortunately, EHS-based technology can now actually extract and update the information in SDSs to ensure the information they contain is accurate. 

Other common errors in EPA reports that can lead to violations 

Outdated and insufficient SDSs are just one of many common Tier II reporting errors EHS teams encounter every year. For program areas like EPCRA and RCRA, such errors often result from having to interpret EPA reporting requirements that change constantly — especially at the state and local level — or that aren’t always clear to begin with. A good example is how to report mixtures for lead-acid batteries and the confusion it can lead to. 

A lack of visibility

Another root cause of reporting errors is not having adequate visibility into information and compliance data. Along with SDSs, for example, errors in chemical inventory lists and reporting thresholds can easily go undetected if not monitored regularly. Outdated emergency contact and site plan info at facilities likewise often goes undetected until it’s pointed out in an EPA notice of violation. Like outdated SDSs in the event of a disaster, not being able to reach an emergency contact or knowing where hazardous chemicals are stored at a site can put first responders at risk. 

The EPA reportable quantity list

Other frequent errors can be traced to the EPA reportable quantity list, commonly known as the List of Lists, for chemicals reported under EPCRA, the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the Clean Air Act (CAA). One common issue stemming from the list is that businesses incorrectly mark chemicals as extremely hazardous substances (EHSs). Here again, a lack of visibility into chemical inventories can result in chemicals being mislabeled or miscounted by way of quantity. 

Further, especially in distributed companies, chemicals often tend to get reported inconsistently across facilities, leaving chemical inventories to get reported inaccurately. By digitizing data for chemical lists, inventories, threshold quantities and so on, compliance leaders and EHS teams can more effectively manage their product inventory and properly identify chemicals to avoid non-compliance violations. 

Or, as was the case in the following EPA violation, a company can simply fail to report certain chemicals when required.

EPA violation fines and settlements: One recent example

In one recent example of EPA cases and settlements, the agency took action against a chemical warehousing company in June 2022 for “unsafe practices and inadequate reporting.” Environmental complaints in the case centered on “alleged” violations of both the CAA’s General Duty Clause (GDC) and EPCRA requirements for reporting years 2019 and 2020. (The recurring reporting violations likely did not sit well with EPA inspectors.)

Specifically, the warehousing company failed to report several EHSs under EPCRA Section 311 and 312 chemical inventory reporting requirements, and in line with CAA GDC requirements applicable to “sources producing, processing, handling, or storing EHSs.” As part of the EPA settlement, the company agreed to pay a penalty of $109,635, and to certify compliance with all of its CAA GDC and EPCRA requirements under the watchful eye of the EPA. The company also likely damaged its reputation — as a business, as a member of the community, and as a steward of the environment. 

Could more proactive environmental compliance reporting processes and guardrails like data visibility and automated regulatory alerts have helped prevent this particular EPA case? Most likely, yes. And as far as EPA violation fines go, the six-figure penalty in this case was steep, but not uncommon.

Are EPA violations getting more costly? 

In a compliance snapshot of EPA reports and non-compliance violations from Q4 2020, 150 settlement agreements for EPA violations cases resulted in total financial penalties of nearly $4.6 million for the timeframe. Most notable among them was one fuel distribution company that was fined more than $1.3 million when it violated the EPCRA Section 313 Toxics Release Inventory (TRI) and “failed to report the releases of several TRI-listed chemicals at its terminals, denying the public access to this information.” Yet again, such a failure put first responders and the nearby area at risk.  

Are steeper financial punishments like this warranted for companies that get cited for an EPA report violation? That’s really up to the Environmental Protection Agency administrators. But in the instance of the chemical warehousing company that failed to meet its EPCRA obligations, at least, the nearly $110,000 penalty they paid was part of a new EPA commandment.   

As EPA New England Regional Administrator David W. Cash put it, “EPA was particularly concerned that emergency responders were not provided adequate information about the type and amount of chemicals stored on site, and that the facility is located in an area with environmental justice concerns.

“With this settlement, EPA is sending a strong message to companies that deal with dangerous chemicals — they have an obligation to comply with environmental laws in order to protect the communities around them.” 

Congress enacted EPCRA almost 40 years ago to protect local communities and emergency responders from potential accidents at facilities that manufacture, store, distribute or use hazardous chemicals. That’s why environmental compliance reporting has mattered since then, and still matters now.

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.

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

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