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 Outdated or incorrect facility contact information is in fact one of the most common errors for compliance reporting.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By as much as 98%, based on Encamp customer data, automated actions reduce the number of facilities that are behind or out-of-date on compliance updates and notifications.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.

The EPA guidelines on how lead-acid batteries are to be reported for EPCRA and Tier II reporting can be one of the most confusing aspects of environmental compliance. For instance, do compliance and operations teams and facilities report a lead-acid battery as a mixture, or as a component?

Adding to the complexity, certain states like Texas, California, and Oregon, have published their own reporting guidance for lead-acid batteries, so it’s no wonder confusion reigns over issues such as the mixture-or-component question. 

Lead-Acid Batteries: The Ultimate Reporting Guide 

Encamp has just published the 2nd edition of its Lead-Acid Batteries: The Ultimate Reporting Guide, and it answers the most common Tier II questions about lead-acid batteries for you. Where do these batteries fit in the on-site chemical inventory and threshold equation for Tier II reporting? What should the notification include when you report damaged lead-acid batteries? And of course, how do you settle the mixture or component issue? — which we’ve detailed here.

 

Mixture reporting vs. component reporting

According to EPA, there are two ways of reporting lead-acid batteries for Tier II. The agency’s recommended approach states that a facility should be consistent in reporting between 311 (SDS Reporting) and 312 (Chemical Inventory Reporting). EPA also states that the submission of the Tier II form can be used for 311 purposes for hazardous chemicals brought on-site between October 1 and December 31 of a calendar year, although you must confirm this with your SERC and LEPC.

For 311, when a new chemical is brought or produced on-site and it exceeds its threshold:

Based on EPA’s guidance, reporting between 311 and 312 should be consistent:

Mixture reporting

When reporting lead-acid batteries as a mixture, be sure to include physical and health hazards associated with every mixture component listed on the SDS. Depending on what state your facility is in and what reporting system they have chosen to use, you may have to report the overall mixture as an Extremely Hazardous Substance (EHS) or the mixture component (sulfuric acid, in this case) as an EHS.

Tier2 Submit

If you’re required to use EPA’s Tier2 Submit software to file your Tier II report, here’s what your lead-acid battery will look like reported as a mixture.

EHS is marked as Yes because EPA requires the overall chemical to be marked as an EHS if one of the mixture components is an EHS.

E-plan

If your SERC uses E-plan for submissions, the system will require the overall chemical to be marked as an EHS, just like Tier2 Submit. Below is an excerpt from the E-plan instructions.

Tier II Manager

If your SERC (or LEPC) uses Tier II Manager as their portal, you have the option of indicating that the lead-acid batteries contain an EHS and that it exceeds the TPQ. Below is a screenshot from a Tier II Manager report.

Component reporting

If you decide to report the sulfuric acid separately, the reporting is a little more straightforward. Since sulfuric acid is an EHS, you will simply check the EHS box on whichever system your SERC uses.

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.

When our CEO and co-founder Luke Jacobs was asked recently what surprised him most about starting Encamp, his response was this:

“I’ve learned that starting and growing a company and innovating in a specific field takes years — but that, in time, it’s possible to make incredible progress.”

After introducing the groundbreaking Encamp technology in 2018 to make environmental compliance data management more efficient and reporting more accurate, our company’s trajectory has indeed been “incredible.” And in 2021, delivering for our customer’s success has never been more evident. 

2021 By the Numbers

For EPCRA compliance and Tier II reporting, customers used our solutions to prepare and file 3,761 reports for reporting year 2020… and collectively saved 32,047 hours in people hours to do it.

More impressively, our company’s growth in 2021 was marked by a 500% increase in ARR and 200% increase in people growth, setting the stage to more than double both areas by the end of 2022. Additionally on the growth front, Encamp expanded its customer scope throughout 2021 by closing four Fortune 500 customers, two customers from the Fortune 1000, two Global 500 customers, and one new customer from the Global 1000.

“Encamp is fortunate to have an elite team of experts who are passionate about creating software that supports our customers’ environmental endeavors with next-generation technology,” Jacobs said in announcing Encamp’s 2021 accomplishments. “Environmental compliance is essential, yet the need for efficient, purposeful, and data-driven technology for regulatory reporting continually goes unnoticed. We are trailblazing a solution for this untouched space, and our continued growth is a testament to closing the gap in compliance reporting.”

In all, Encamp’s success throughout 2021 reinforced our position as a
premier technology-driven system for environmental compliance and reporting. We also made definitive strides in our mission to create a world where good for business can equal good for the environment.

Notable Encamp Achievements in 2021

Funding and leadership

In April, Encamp secured $12M in our Series B funding to further develop our technology platform and add key members to our strategic teams for leadership, engineering, customer experience, compliance, sales, marketing, and others. 

Key additions in 2021 included Ki Moon as Vice President of Revenue Operations, Samantha Strube as Head of People, Pauline Chen as Head of Product, and industry veteran Heather Shanahan, CPA as Chief Financial Officer. Heather in particular brings an 18-year track record from accounting and finance roles at tech firms including Wistia, Venture Advisors, and inStream, and will focus on strategic planning and financial reporting to scale Encamp’s operations.

“Encamp created a software to help modernize the way companies think about environmental compliance, and I’m excited to use my background in finance leadership to help the company grow and scale to further solve the needs of Encamp’s customers,” Shanahan said.

More trees planted thanks to Encamp customers

In 2019, we aligned with the non-profit organization One Tree Planted to plant a tree for every Tier II compliance report our customers file through the Encamp system. With the 3,761 Tier II reports submitted in 2021 (for reporting year 2020), the total number of new saplings planted via Encamp reached 11,159 — a number that will continue to grow substantially as our number of happy customers increases. Many Encamp employees also donated to the One Tree Planted cause in 2021, with our particular efforts aiding in the reforestation of areas of California affected by recent wildfires. (Look for the number of trees planted to increase even more dramatically once we wrap up Tier II reporting year 2021.)

Awards and recognitions

We’re extremely proud of the awards and recognitions we’ve received since Encamp started, and in 2021 we added a few more. They include:

Technology enhancements

All of us at Encamp are committed to continually developing our technology to encompass all regulations and requirements for environmental compliance reporting within an enterprise, with customer success constantly in mind. In 2021, our amazing team of Encampers took more steps in that direction with the following feature enhancements:

Encamp’s Strengths Entering 2022 

According to Jacobs, “From a financial perspective, our net revenue retention is absolutely amazing. The fact that Encamp has 6- and 7-figure deals as a startup that’s only had employees for three years is a strong underlying signal of the enterprise value we deliver. As environmental regulators continue to transition towards digital compliance systems, large enterprises will start to invest more heavily in the digital transformation of their environmental compliance programs at scale. Therefore, we believe the next year will be defined more prominently by the continued digitization of the environmental compliance lifecycle. 

“In 2022,” Jacobs added, “we’re excited to further leverage modern computer science techniques to not only drive the next generation of environmental compliance technology, but most importantly to provide transformational efficiency increases for our customers. Moreover with our enhanced Guided Environmental Compliance method, we’ll blend digitization, Encamp’s high-tech software, and the high-touch support of our customer experience and compliance experts to drive these increases for customers and promote compliance program unification for enterprises of all kinds.”  

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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