Recordkeeping Part I: Complexities

Ever wonder why record keeping in the bulk fuel storage industry seems to be such a formidable task? Is it the operational demands, the maze of multiple permits, or the lack of accountability? Our industry expert Shannon Oelkers sheds light on these challenges to kick-start our Recordkeeping series. She points out the key hurdles terminal managers face, including the balancing act of multiple responsibilities and the confusion arising from numerous permits written by various parties. 

Shannon underscores the vital role of record keeping in modern environmental permitting, as it aids not only in identifying operational issues but also in maintaining documentation of compliance. She emphasizes the need for comprehensible checklists, regular audits, and a robust support system to ensure the smooth running of operations. So, if you're grappling with record keeping, tune in, and let's unravel the complexities of record keeping.

 This podcast is for informational purposes only and should not be considered legal or regulatory advice. We are not responsible for any losses, damages, or liabilities that may occur from using this podcast. This podcast is not intended to replace professional regulatory or legal advice, and the views expressed in this podcast may not be those of the host, which would be me or Integrity Environmental. Thank you very much for listening. We would be happy to provide professional regulatory advice as part of our consulting services if you need professional regulatory advice.  

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Episode Transcript

Amanda (00:10):
Thank you for joining us .
You're listening to Tank Talkwith Integrity Environmental,
where we speak with founderprincipals, consultants and
bulk fuel storage expert ShannonU about regulations, safety and
useful tips for smooth sailingthrough the bulk fuel storage
industry.
Come learn the unique joys ofworking life in Alaska with
industry experts, including ourteam, vendors we work with and
companies we support.

(00:30):
Welcome back, shannon.
How are you doing today?

Shannon (00:46):
I'm doing good, but I am thinking about record keeping
and why it is so hard.

Amanda (00:56):
I remember sending an email around Christmas.

Shannon (01:00):
Yeah, we send emails to our clients at the end of the
year to remind them of some ofthe annual record keeping that's
coming up and also so that theycan sort of double check all
the records at the end of theyear and see if they got
everything for all the differentpermits that we've got.
But I think the reason thatrecord keeping is so hard is

(01:22):
actually unrelated to checklists.
Otherwise we'd be out of a job.

Amanda (01:31):
So what is record keeping i entail?
How do we know when we need it?

Shannon (01:35):
i Well, record keeping is part of all modern
environmental permitting, andthis is really hard for people
who've been in the industry along time because back in the
day, there was very littlerecord keeping and there was a
lot of visual verification Like,hey, I looked at it, it's good,

(01:56):
let's move on.
But record keeping serves manypurposes and functions and the
modern environmental recordkeeping process.
It has two masters.
The first is to actuallyidentify problems, maintenance,

(02:17):
operation, things that need tobe solved, and get them to the
right place within a company,get support and resources to fix
them.
The other master is theenvironmental regulation that is
regulating operations andthere's many for a bulk fuel
farm and the records aredocumentation of the inspection.

(02:41):
We call it credit.
You're getting credit for theinspection that you did.
If you do it and you don'tdocument it in the regulatory
space, then it is the same as ifit didn't happen.
So what makes it difficult?
Well, the problem with recordkeeping and why it's so hard is

(03:03):
there's a lot of things going onwith your average record
keeping.
Bulk fuel farms typically have aterminal manager who's local
and they are in charge ofmaking sure that all inspections
occur and are documented andthey have some competing
priorities.
They are also in charge ofselling fuel.

(03:26):
They're also in charge ofinventory.
They're in charge of accountingand billing.
They're also in charge of humanresources and driver management
and scheduling.
There's a lot of things goingon for the average terminal
manager.
And then record keeping, whichis not an easy thing to do, is
thrown on the top of that.
So that's the first hurdle isjust providing resources and

(03:50):
space to a terminal manager orthe company prioritizing record
keeping compliance.
That will allow the terminalmanager to successfully complete
it.
But there's also the piece whereA whole bunch of different
groups develop these permits andthe inspection checklist and
the actual records that aresupposed to be completed and

(04:12):
signed.
They're not always developed byone person who's really
familiar with operations.
They might be done by anengineering group that worked on
a project five years ago andthey might be done by a company
like ours, because there was aproblem with stormwater and we
were brought in to help fix itand write a stormwater plan.
They could also be somebodyinternal to the company reading

(04:32):
the regulations and deciding.
I can do this myself, which istotally cool.
Many people can, right.
But sometimes a terminal managerwill inherit permits that are
written by all three of thosepeople that I just described,
and some of those peopleunderstand operations really
well and some don't, and sosometimes what I see is that the
records compete with each other, like somebody's filling out a

(04:54):
routine facility inspection fora stormwater plan, they're
filling one out for a spillresponse plan, they're doing a
routine facility inspection forair regulations, they're doing
another one for any other numberof regulations insert here.
They all are very similar butyet critically different because

(05:16):
they've been written to meetthis very specific regulation
and so the terminal managerlooks very repetitive.
Why am I doing this four times?
Well, it's because fourdifferent regulations have these
very specific requirements.
Also, these record keepingchecklists or inspection
checklists, if there's not abasic understanding of
operational knowledge underneathit, the wrong information can

(05:40):
be tracked, or they're set up ina way to where it's not easy
for a terminal manager orsomebody he's assigned to do the
inspection, to capture the data.
Well, a good example of this isan inspection checklist that's
asking you to visually survey asecondary containment area for
the presence of sheen and thennoting whether there's sheen or

(06:01):
not, and then also documentingwhen and how much discharge for
the secondary containment.
One record might say is sheenpresent, w or N, and you're
supposed to circle the Y or theN, and then the next question is
the start of a o d drainage.

(06:23):
Well, if you're not trained oror you weren't paying attention
during that thing in class, youmight click oh yeah, there's
sheen, yes, and then you willstart discharging because
there's nothing in that recordthat says if, why, do not
discharge.
So we see that a lot, where therecords aren't really written
to help whoever's doing themunderstand if they're not an

(06:44):
expert in this regulation, andthen they're written by somebody
who's not an expert inoperations.
So they're writing them to whereit's kind of awkward and clunky
.
So that's the second hurdlethat I see like it makes record
keeping hard because they'rebeing given forms to fill out
that don't make sense or feelrepetitive or don't have
built-in breaks for certainbehaviors.

(07:05):
And then the last thing I seeis it's just accountability,
like they're asked to do allthese records but then they're
not actually audited, or maybethey're only audited at the end
of the year after 12 months havegone by and they're like oh
yeah, you should have been doingthis daily.
And now here we are, inDecember 1st, I need you to go

(07:27):
back and pull 364 records out ofyour filing cabinet that you
don't have, and so withoutroutine periodic check-ins and
some sort of accountabilitysystem in place, it's really
easy to let things slide.
And no, it's not even terminalmanagers.
Remember all thoseresponsibilities that I talked
about that come first and likeare tied to profit and money and

(07:49):
their paycheck.
It's very easy.
I mean, we all do it in our ownpersonal lives, right, and so
it's just sort of that humanbehavior piece where having
accountability on a morefrequent basis, like monthly or
quarterly, helps prevent reallybig record gaps.
And I see all over Alaska, withalmost all of our clients, some

(08:12):
version of one of those threehurdles, and I think that's the
root of why record keeping is soso hard, and you have to
address all three before recordkeeping gets better, and I think
that's also what makes itdifficult.

Amanda (08:27):
You can't just be like okay, here's a better inspection
form.

Shannon (08:30):
Well, if that doesn't come with support and high
priority from the corporateoffice and it doesn't come with
accountability from yourenvironmental manager checking
in and saying where is it?
You could have the best form inthe world, but it's still
probably not going to get filledout.
So those are my thoughts onrecords today.

Amanda (08:52):
Well, thank you for sharing.
I appreciate it and I hope thathelps somebody out.
Yeah, yeah, I'd love to dive intheir record keeping.
It sounds like.
Sounds like a joy.

Shannon (09:03):
Everybody loves record keeping so much.

Amanda (09:12):
Thank you for tuning in to tank talk with integrity
environmental.
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