Mandatory Electronic Environmental Reporting is Coming … Are You Prepared?
The days of using a word processor, spreadsheets and piles of paper for your environmental, health and safety reporting are coming to an end. The Environmental Protection Agency (EPA) has fully committed to requiring electronic reporting for new environmental regulations and many major annual compliance reports. This shift away from paper-based reporting has the potential to completely change the way you approach any EHS responsibilities.
Two major environmental management reports that are getting a lot of attention and are at the forefront of the switch to electronic reporting include the Toxic Release Inventory (TRI) report and the new Mercury and Air Toxics Standards (MATS).
EPA lately has proposed a new ruling that would require all TRI reporters to stop submitting paper reports and begin using only their online reporting tool, known as Toxic Release Inventory – Made Easy (AKA TRI-MEweb). This ruling is expected to pass, as approximately 95 percent of TRI reporters already are using the program consistently.
MATS: A Glimpse Into the Future
MATS, which came into effect during spring of this year, is a slightly different story. EPA's final MATS ruling came built in with the condition that nearly all tests, reports, summaries, notifications and continual monitoring results “must be submitted (except in limited cases) to EPA's WebFIRE database by using the electronic reporting tool (ERT) and the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed through EPA's Central Data Exchange (CDX)” (Federal Register, Vol. 77, No. 32).
Basically, MATS will be one of the first air emissions reports that has come out of the gate requiring electronic reporting. If the MATS regulation is any indication, which it most likely is, then we can expect all future air emission and waste generation regulations also will require electronic reporting.
Finally, a new EPA proposal will make electronic reporting mandatory for all chemical information submitted under the Toxic Substances Control Act (TSCA). When this ruling comes into effect, as is expected, paper submissions will need to be replaced with the EPA's CDX program. Clearly, EPA is making big moves to digitize the biggest compliance reports and to pave the way for even further electronic reporting requirements in the near future.
Electronic reporting promises to be faster and easier for EPA auditors to process and verify. It also will help EPA create public databases faster, increase transparency and greatly reduce the agency's environmental footprint and paper usage. But what we all really want to know is what's in it for us, the actual reporters?
Some of the common concerns reporters have about mandatory electronic reporting, and what ERT systems have to offer, are outlined below.
Quality Assurance
Nothing is more frustrating than writing a report only to discover you've made a small calculation error somewhere along the way that skews the entire report. Though far from perfect, EPA has made efforts to incorporate quality controls and real-time safeguards in their reporting tools. According to the agency, these controls will notify reporters when the data they've entered just doesn't add up. That alone could save EHS managers some serious headaches.
However, electronic reporting still needs a quick review before clicking that submit button. One manager I spoke with warned that even with built-in QA/QC, they found an error in a dilution factor that could have penalized the company.
Will It Be Any Easier?
EPA has said that electronic reporting will make things faster and easier for reporters. These are two magical words for any busy EHS manager. We've all got too many things demanding our attention: compliance reports, safety audits, accident prevention, emissions monitoring and more, so anything that promises to save a few hours in the week can be a lifesaver.
With that said, many have raised concerns about the usability of some of the EPA's tools. Since the vast majority of reporters already have embraced electronic reporting, however, only a small percentage will have to struggle to catch up and learn the ropes of the EPA's CDX. The primary benefit of electronic reporting is that it beats getting bogged down in a pile of spreadsheets. As one EHS manager once told me, "It will cause disruption at first, but 5 years from now, it will be as basic as email."
How Safe Is Your Data?
For those reporters concerned about the safety of their confidential and trade secret information, EPA continues to offer paper-based submissions in certain cases. Even if your information isn't strictly secret, the online security of EPA ERTs has an excellent track record. It operates much in the same way as your online banking (in fact, part of the EPA's justification for online reporting is to catch up with the technological advancements of the banks).
If you're part of that minority not currently using electronic reporting, the time to start is now! Start familiarizing yourself with the EPA's various Web tools and download some of their free educational material. TRI reporting season just finished, so you'll have the maximum amount of time possible to learn the ropes before the pressure is on.
Gary Vegh co-founded ERA Environmental Management Solutions in 1995 to provide the local wood furnishings industry with software and consulting to comply with environmental regulations. The company now provides environmental management software to some of the world's leading environmental manufacturers, including Volkwagen, Moog, BMW, Nalco, Medtronics and Nissan.