Managing Environmental Compliance Can Be Easy — With the Right Tool
Reputation management is of utmost importance to colleges and universities in their constant pursuit of students and research dollars. It envelops all aspects of the institution, including the business of maintaining environmental compliance. One notice of violation from a regulatory entity can be highly publicized, result in fines, and have widespread negative impacts both within and outside the institution. For The Rockefeller University (RU) in New York City, a world-renowned center for research and graduate education in biomedical sciences, chemistry, bioinformatics, and physics, implementing tools to support maintaining environmental compliance has been a strategic investment, with departments across the campus enjoying the benefits.
RU’s Laboratory Safety and Environmental Health (LS&EH) department faces complex and cumbersome environmental compliance responsibilities involving tracking multiple regulatory compliance obligations associated with the oversight of 70 laboratories. These responsibilities involve significant time and attention, and are complicated by the fact that critical information is stored by different groups in different locations, and in voluminous and differing formats. The complexity and communication involved in meeting regulatory deadlines presents a challenge to personnel with multiple job responsibilities. These challenges piqued RU’s interest in identifying information management solutions that could optimize resources while facilitating compliance with the myriad of applicable rules.
Many academic institutions use off-the-shelf software to support business functions associated with environmental regulatory compliance. However, this decision can further tax existing resources by forcing personnel to learn the operations and functions of yet another software package in the department’s repertoire. Moreover, shrink-wrapped software does not cover all of the individual attributes of a college campus and rarely covers all applicable state or local rules. The alternate option, which is working for a growing number of campuses, is to consider the development of a customized software solution that can better integrate into the organization, mimic the existing departmental workflow and procedures, and be specifically designed to meet departmental goals. RU took the alternative approach and, as a result, has been experiencing benefits for the last year.
As part of its overall Environmental Management System (EMS), RU decided on a customized software solution to help maintain regulatory compliance — a critical element of any management system. Amy Wilkerson, associate vice president, research support, explains, “We decided to develop our own system because it would be more comprehensive than any off-the-shelf software. Approaching it this way, we could support compliance program management, capture all regulatory compliance requirements with recurring deadlines, drive program accountability, and easily communicate important information across departments.”
Members of the LS&EH department were an important part of the design team and were involved in all aspects of the system, which the team titled the Compliance Information Management Program (CIMP). The team identified the necessary system features, how information should be organized and presented, decision-making workflow, overall system layout, graphics, and the breadth of the programs to be covered (e.g., environmental, health and safety, life safety, radiation safety, fire safety, asbestos, etc.). The main design themes for system functions consisted of the ability to access or interpret information quickly in a few easy steps and ease of navigation regardless of the user’s level of experience. RU also incorporated graphics, terms, and procedures that have established meaning within the organization. These customizations led to a desired end product and minimized training time involved in system implementation and use.
The team began by conducting a comprehensive and detailed review of high-level system requirements and features. High-level requirements began with incorporating a web-based tool with secure system access via username and password. A user-friendly design that put to use the data collected by the multi-media environmental compliance audit that pre-dated the EMS development was also critically important. External website hosting reduces additional burden on internal information technology resources; however, control and maintenance of the data remained with RU’s LS&EH department.
The primary feature of the CIMP is to track recurring compliance obligations, assigning them to responsible parties. The tool sends automatic e-mail reminders to designated personnel, thereby providing an automated notification system. Staff members have noted that the reminders are especially helpful for tasks with infrequent occurrences.
The notification system’s frequency is customized by task and incorporates escalating urgency by sending additional e-mail notifications to higher-level parties if requirements are not met in a timely manner. Upon system login by secure user identification and password, users are presented with a customized list of scheduled tasks for which the user is assigned as either the primary responsible party for task completion, the backup to the primary party, or the supervisor. Once the task is marked complete, the e-mail notification is toggled off and reset for the next scheduled deadline.
Management reports for compliance status by program can be generated for upcoming or completed tasks for any selected time period. Reports are either standard or customized. Standard reports can be generated very quickly and provide pre-formatted information, while customized reports offer additional search features. Compliance management is further supported by linking related and supporting electronic documents to specific tasks.
With this system in place, campus personnel report an increased overall awareness and participation in compliance obligations. The system is maintained internally through features supporting data entry and editing. When appropriate, pull-down menus are incorporated into the system to facilitate data entry. The CIMP can also be dynamically modified by users to develop new pull-down menus, or add programs or personnel that will subsequently be part of the system’s existing pull-down menus.
System design was completed interactively using an iterative approach. RU was first shown a model of a system interface for a set of features, and then the interface was developed and presented to the users as a partial prototype. Feedback from users was solicited, incorporated into the design, and reviewed during subsequent prototype reviews. The idea was that before any feature set was completed, those features were reviewed and streamlined multiple times. Much of this work was completed remotely to save on project costs and minimize the time required for all team members.
“As a result of this collaboration,” Wilkerson notes, “we have a system that is very simple to use. You see what you have to do, you do it, and then go into the system and mark it done. It can’t be much easier. It’s a great tool for us.”
An added advantage of a customized system is the ability to phase system development and expand it over time. This has been RU’s approach and intent from the outset of the project — to continue to expand the program and eventually address other important EMS elements. The first such expansion added the capability to use CIMP to address health and safety compliance requirements. The next enhancement was to incorporate hazardous waste weekly inspections, laboratory safety checklists, and training.
CIMP is being used by the entire LS&EH Department, a number of maintenance workers, and representatives from Plant Operations, the Boiler House, the RU Hospital, and Security.
This customized software is serving RU well by providing an easy-to-use tool that fits within the existing workflow of the organization and supports departmental functions. Its features were specifically designed to support the primary mission of maintaining regulatory compliance and safeguarding the institution’s reputation — all within an efficient and proactive framework. Improved allocation of limited resources, better management of competing obligations, and elimination of non-compliance attributable to missed deadlines have all added up to substantial benefits within the fast-paced, multi-faceted, and in many cases, understaffed world of environmental regulatory administration.
Frank X. Schaefer is associate director of laboratory safety and environmental health at The Rockefeller University. He is currently working on developing an EHS-MS for the University, as well as implementing a web-based chemical inventory tracking system for campus laboratories. Mary House is a senior project manager and vice president at Woodard & Curran in Portland, Maine. She works closely with clients to develop database and application solutions to manage, interpret and report environmental compliance data.
The views presented in this article are the authors’ own and do not necessarily represent those of the University.