November 22, 2023 • 15 mins
Discover the tangled world of record-keeping and how to streamline your system to avoid confusion and extra work. Our founder, Shannon Oelkers, brings her expertise to the table as we unravel the complications of writing permits and the effects of a poorly structured setup. We highlight the importance of executive decisions, quality control, and navigating the maze of regulatory compliance renewals. Shannon guides us through understanding record-keeping requirements outlined in plans and permits and how to consolidate to avoid repetition. Join us as we underline the power of proactive planning and knowledge in creating effective record-keeping systems. This episode promises to be an eye-opener, equipping you with the tools and insights to optimize your record-keeping process.
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
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Speaker 1 (00:00):
All right, welcome back, shannon.
We're excited to have you todayContinuing our previous chat
about record keeping and whatmakes it difficult.
Where are we on that?
Speaker 2 (00:10):
Record keeping is difficult for three reasons, and
I call it the three legs of therecord keeping stool.
We talked last time brieflyabout each one of those legs and
I wanted to dive in deep on oneof those legs this time.
And that's the poor setup.
If you have poorly set uprecords, that can really impact
(00:31):
how good your record keeping canbe.
We like to talk about it asquality in quality out.
There's an opposite phrase thatI don't like to use because
it's so negative, but when youput quality into a system,
you're going to get qualityproducts out.
Sometimes with record keeping,what's going into the system
isn't necessarily a very goodproduct for what you're trying
(00:53):
to do with it.
Speaker 1 (00:54):
Understandable.
So how do you know when thereis a setup problem?
Speaker 2 (00:59):
Well, some of the symptoms of a poor setup problem
is the person who's being askedto complete the record keeping
is complaining about having todo the same stuff but on
multiple records.
Like oh, I have six checklists,facility inspection checklists
and they all ask me to look atthe secondary containment liner
(01:22):
and the condition of the liner.
Or I have to do all of thesedifferent records just about my
oil water separator.
I don't know why I have to dothree.
There's only one oil waterseparator.
What that tells me, lookingfrom the outside in as a
consultant, is that they hadthree different plan writers and
each plan writer was like oh,the oil water separator is an
important function of thispermit, so I'd better have a
(01:44):
form for it.
When you have different writersfor each permit, they can't see
the other permits, they can'tsee internal documents, they
can't see all of the pieces thatgo into making a record keeping
workload for somebody, and sothey are meeting the
requirements of the permit,hopefully, but they are causing
(02:04):
confusion because there's nocontext of what else is out
there, and so somebody whetherthat's a consultant or an
environmental manager within thecompany they need to be looking
at these records anddetermining if these questions
or inspection points have beenanswered in other places, and
whether it really needs tobelong on this record, or if
(02:25):
there can be some consolidationor streamlining of these records
so that somebody is notanswering the exact same
question for four or fivedifferent permits.
They are only answering it onceand that record is used to meet
all of those permitrequirements.
Speaker 1 (02:41):
Well, what causes record keeping to be poorly set
up or confusing?
I know you did touch on thatlightly with multiple hands in
the jar.
Speaker 2 (02:50):
Yeah, I think that a lot of records are generated for
record keeping forenvironmental stuff, because a
planner permit is required by aregulation and the company
outsources the writing of thatpermit.
Not always, sometimes, someoneinternal writes it, but they
often hire a company to come inand write the permit.
But it's not the same companyfor all the permits, because
(03:11):
many companies just specializein air or water or spill
response.
They don't necessarilyspecialize in bulk fuel storage
like our company does, and soour company looks at all the
permits for an industry, but alot of other environmental
companies look at the permit andthey're an expert in the permit
but they're not necessarily anexpert in the industry, and so
(03:33):
what we see is that there is abit of confusion because they're
writing it for, in general, toapply to multiple industries
across the entire United States,because that's what the big
companies do and there's nothingwrong with that.
But somebody, either theconsultant or the environmental
manager, needs to look at thatrecord as it comes in with the
permit and it's so easy to makethem.
(03:55):
Do that, do some streamlining,do some modification, do some,
you know, make some managementdecisions to allow it to not be
confusing all the way down atthe terminal manager level.
We also see a couple ofcontributing factors in the fact
that updates or renewals tothese permits are often lagging
(04:15):
like they are ordered, they'reon their way, and then when they
come terminal managers becausethey wanna do a good job, they
don't necessarily have like copycontrol and so they may
actually be doing multiple yearsof record keeping because
they're afraid to stop doing theold record keeping.
And then they have new recordkeeping when a renewal comes
through and I can't tell you howmany times I've gone in and
(04:38):
they're actually doing the exactsame record keeping, but it's
from two different versions ofthe permit the one that was
written in 2012, and then theyhad a renewal in 2017, and then
in 2020, and they've got somerecords from all of those
floating around and they'recompleting them all because
they're terrified to not do it.
Well, but it's creating anenormous workload for them.
(04:58):
That isn't necessarily needed,and the reason it's not just
like it's the exact same record,but with the date on the bottom
is the reason is the RECsupdate and so they all look a
little different, and so there'snot been that executive
decision of don't do 2012, don'tdo 2017, only do the 2020
forward, because that's the onethat is most current right, and
(05:19):
if there is no executivedecision making being done by an
environmental manager or anoversight consultant, like what
we do, the terminal manager isstuck with all these records and
there's no stop date on them,so they continue doing it.
That copy control is a reallyimportant part of a healthy
record keeping system and beingable to understand what's due
(05:40):
and when.
Speaker 1 (05:41):
So why isn't there just one list of all the records
required?
Where's our easy button?
Speaker 2 (05:48):
Oh, where's the one list to rule them all?
The answer to that is twofold.
The first is that if you havemultiple companies writing your
permits, they're only interestedin the record keeping that
comes with that permit.
The other side of that is thatthe permits all renew on
different schedules and indifferent years and there's a
(06:08):
whole lot of permits for everybulk field facility out there.
We always joke that like a bulkfield facility is a small piece
of land surrounded byregulations, and it's true,
there's so many out there.
We encourage our clients toperform an audit and create a
master record keeping list andto organize it by records that
(06:29):
are required daily, monthly,quarterly, semi-annually and
annually, because most recordshave some or if not all of those
requirements.
And what you can do when you arecontracting for a plan or
permit renewal is you canrequest, as part of the scope of
work, a list of the recordsthat are required by that permit
(06:52):
, broken down by daily, monthly,quarterly, semi-annual and
annual right.
And so if you can get that listfrom every permit, it makes it
easier to manage as anenvironmental manager, because
the permit's coming in with thatpiece already written or it's
part of the deliverables thatgoes with that plan or permit.
We of course provide that kindof list and we also do audits to
(07:12):
develop that kind of list afterthe fact to try to reduce this
level of confusion.
But that's why there's no easybutton, because there's anywhere
from 10 to even 20 permits thatare environmentally based at a
facility, and then that doesn'tinclude some of the other ones
that are not environmentallybased, like fire extinguisher
(07:32):
inspections and OSHA checks, andthere's a lot going on at a
tank farm.
Speaker 1 (07:39):
Sure, where would we start to fix this?
Internally or where we arecurrently?
Speaker 2 (07:45):
So let's say that you're a terminal manager or an
environmental manager and youjust walked in the door and
there's a lot of records and itseems like there's a lot of
duplication and a lot of effortbeing spent.
And you, there's a lot ofconfusion right, like which ones
which, which ones, right?
How to fix that is to sit downand do an audit and be familiar
(08:08):
enough with that plan or permitto understand what the record
keeping requirements are.
Most plans and permits have arecord keeping section and they
lay out what are required.
And if you have that list, youcan start creating that master
Excel sheet of the dailies andthe monthlies in the Quarterlies
and you can start filling themin.
And then, once you get thatmaster list of what you think is
(08:31):
absolutely Required by all theplans and permits, then you can
start working on copy control.
For example, the, the ODPCPrequired by 18 AC 75 in Alaska,
has a routine facilityinspection requirement.
Most people perform it monthly,right, so there's a monthly and
then there's also dailyrequirements and you could audit
(08:53):
how many daily facilityinspections are you performing
right now and you might besurprised at the answer.
I've asked that of many, many,many terminal managers and
sometimes I get back.
I've got a daily for the marina.
I've got a daily for our mainfacility.
I've got a daily for the truckrack.
I've got a daily for the truck.
I have a daily for the airportfacility.
I have a daily for the airporttruck that's related to a TA 103
(09:15):
.
I also have a daily for the oldwater separator and I have a
monthly force bill responseequipment.
That's a lot of dailies.
Do they need every single oneof those dailies?
and the answer is maybe in thatspecific example they probably
don't need a daily for the truckrack and the facility they
should be together.
(09:35):
But the ATA 103 does require adaily of Specific aviation fuel
trucks and they require it ofaviation fuel tanks and aviation
service.
So it sort of depends on yourlist and how you're looking at
it.
But once you have a list thenyou can start looking at what
they're doing to meet thoseregulations and requirements and
seeing if there's any that areout there that can be taken away
(09:57):
and Replaced with one that'salready being done.
Or maybe that one that'salready being done could be
modified just a little bit andhave that form replace another
one, so that they're only doingone form instead of two or three
.
Speaker 1 (10:11):
Got it, so that sounds like it can get a little
overwhelming.
How do we fix it in the longrun?
Speaker 2 (10:17):
in the long run, like I mentioned earlier, having
part of your scope of workinclude a deliverable that lists
out record keeping that thepermit is setting up for you.
I would also recommend you canalways hire someone like us to
come in and give you consultingand say you know, do that hard
work for you, provide a list andsort of get you started.
(10:37):
But I think in the long run thebiggest fix is Having plans and
permits written that considerother plans and permits and also
consider operationalrestrictions.
I Think many plan writers arein offices, myself included, and
if you don't fully understandwhat happens or what goes on at
a bulk fuel facility Becauseyou're writing general permits
(10:59):
for any industry instead of onespecific industry, you don't
understand that taking a dailygauge of a fuel facility may
involve somebody standing on topof a tank in a 35 mile an hour
Wind, when it's cold, maybe 15below zero.
You know and you don'tunderstand that it's not a
stairway, it's a barrel cageladder right and you have to
(11:21):
climb that barrel cage ladder tothe top of the tank, which is
not easy and it's often not safewhen it's really cold and icy
and slippery, or Dailyinspections of things that are
completely covered by snow, likehow do you perform those?
What are those look like?
And so I think having aknowledgeable firm do your plan
a permit that knows yourindustry, knows your ecosystem,
knows your weather conditions,the person who's writing that
(11:42):
plan can put thoseconsiderations into that
record-keeping effort.
Also, making sure that plan andpermit writer is aware of the
other things that you're doing.
So when you're ordering a planor permit to be written, or if
you're writing one yourself,look at all the other reports
and record keeping that you'rehaving your terminal managers do
already and see if you can meetthe Regulatory requirement with
(12:05):
what's out there.
I think adding that bit ofexperience and context to a plan
or permit development willreally help keep the problem
from occurring in the future andsort of build a stronger, more
proactive system going forward.
And I also think keeping amaster record list is really
important, like understandingwhat needs to be delivered and
(12:26):
when.
There are two other legs to thisstool.
One is context for the personfilling out the record keeping,
like what they're supposed to bewriting down and documenting.
But there's also accountabilitywho is responsible for making
sure that these records get doneand are uploaded and put into
your records like documented incertain specific ways, and so
(12:48):
we'll talk about those in futurepodcasts.
But another thing you can do toensure that you're getting
quality in from a plan or apermit is to review records or
forms when they come in from thepermit right and actually sit
down with your terminal managerand review them when it's still
in draft form and maybe test itout and get the terminal
(13:08):
manager's feedback when you canstill send it back to the
consultant for changes, updates,elimination, right, like you
can say oh, we don't drain ourSCA in inches, we drain it in
gallons and we have a flowregulator that measures it on
the outside.
Those are things that if youcan change it, it's going to
make sense to the terminalmanager later when he goes to
look at it.
And so I feel like when you arewriting a plan or permit, part
(13:31):
of the clients review processhas to include review of a
record keeping form that's beenproposed and making sure it
makes sense for the operationsand the facility that it's being
proposed for, and then takingit to the person who's going to
fill it out and asking them whatthey think of it and if it's
doable.
And if you do those steps aspart of your plan and permit
renewal process.
(13:52):
That's going to eliminate a lotof confusion in the future,
because you're giving yourterminal manager the context.
You're giving them a chance tochange things when it makes
sense.
We often see that it doesn'thappen because of time
constraints, because they needto get it done and there's only
seven days and the terminalmanager is always very busy.
But most of these permits renewevery five years.
(14:13):
Five years is a long time to bekeeping a record that's not
optimized and is causingduplicative effort on somebody's
part.
It's a long time to dosomething twice when you only
need to do it once.
Speaker 1 (14:22):
Yeah, we like simplicity Are there additional
resources we can point ourlisteners to.
To get started.
Speaker 2 (14:30):
Yeah you know, as part of developing this podcast,
we went ahead and developed anorganizer that I think will be
really helpful.
It's a simple Excel sheet.
It has room for all theperiodic inspection categories
like daily, monthly, quarterly.
You can download that from theshow notes or from our website
and it should help you getstarted tracking on it.
(14:50):
It also has columns for duedates and notes.
We left it blank because wedon't know the context that
you're going to be using it in,but it is definitely a start.
Speaker 1 (15:00):
Great.
We'll have that posted on ourwebsite along with the show
notes.
Thank you for joining us today.
I look forward to our next talk.
Continuing the record keepingtheme.
All right, welcome back, shannon.
We're excited to have you todayContinuing our previous chat
about record keeping and whatmakes it difficult.
Where are we on that?
Speaker 2 (00:10):
Record keeping is difficult for three reasons, and
I call it the three legs of therecord keeping stool.
We talked last time brieflyabout each one of those legs and
I wanted to dive in deep on oneof those legs this time.
And that's the poor setup.
If you have poorly set uprecords, that can really impact
(00:31):
how good your record keeping canbe.
We like to talk about it asquality in quality out.
There's an opposite phrase thatI don't like to use because
it's so negative, but when youput quality into a system,
you're going to get qualityproducts out.
Sometimes with record keeping,what's going into the system
isn't necessarily a very goodproduct for what you're trying
(00:53):
to do with it.
Speaker 1 (00:54):
Understandable.
So how do you know when thereis a setup problem?
Speaker 2 (00:59):
Well, some of the symptoms of a poor setup problem
is the person who's being askedto complete the record keeping
is complaining about having todo the same stuff but on
multiple records.
Like oh, I have six checklists,facility inspection checklists
and they all ask me to look atthe secondary containment liner
(01:22):
and the condition of the liner.
Or I have to do all of thesedifferent records just about my
oil water separator.
I don't know why I have to dothree.
There's only one oil waterseparator.
What that tells me, lookingfrom the outside in as a
consultant, is that they hadthree different plan writers and
each plan writer was like oh,the oil water separator is an
important function of thispermit, so I'd better have a
(01:44):
form for it.
When you have different writersfor each permit, they can't see
the other permits, they can'tsee internal documents, they
can't see all of the pieces thatgo into making a record keeping
workload for somebody, and sothey are meeting the
requirements of the permit,hopefully, but they are causing
(02:04):
confusion because there's nocontext of what else is out
there, and so somebody whetherthat's a consultant or an
environmental manager within thecompany they need to be looking
at these records anddetermining if these questions
or inspection points have beenanswered in other places, and
whether it really needs tobelong on this record, or if
(02:25):
there can be some consolidationor streamlining of these records
so that somebody is notanswering the exact same
question for four or fivedifferent permits.
They are only answering it onceand that record is used to meet
all of those permitrequirements.
Speaker 1 (02:41):
Well, what causes record keeping to be poorly set
up or confusing?
I know you did touch on thatlightly with multiple hands in
the jar.
Speaker 2 (02:50):
Yeah, I think that a lot of records are generated for
record keeping forenvironmental stuff, because a
planner permit is required by aregulation and the company
outsources the writing of thatpermit.
Not always, sometimes, someoneinternal writes it, but they
often hire a company to come inand write the permit.
But it's not the same companyfor all the permits, because
(03:11):
many companies just specializein air or water or spill
response.
They don't necessarilyspecialize in bulk fuel storage
like our company does, and soour company looks at all the
permits for an industry, but alot of other environmental
companies look at the permit andthey're an expert in the permit
but they're not necessarily anexpert in the industry, and so
(03:33):
what we see is that there is abit of confusion because they're
writing it for, in general, toapply to multiple industries
across the entire United States,because that's what the big
companies do and there's nothingwrong with that.
But somebody, either theconsultant or the environmental
manager, needs to look at thatrecord as it comes in with the
permit and it's so easy to makethem.
(03:55):
Do that, do some streamlining,do some modification, do some,
you know, make some managementdecisions to allow it to not be
confusing all the way down atthe terminal manager level.
We also see a couple ofcontributing factors in the fact
that updates or renewals tothese permits are often lagging
(04:15):
like they are ordered, they'reon their way, and then when they
come terminal managers becausethey wanna do a good job, they
don't necessarily have like copycontrol and so they may
actually be doing multiple yearsof record keeping because
they're afraid to stop doing theold record keeping.
And then they have new recordkeeping when a renewal comes
through and I can't tell you howmany times I've gone in and
(04:38):
they're actually doing the exactsame record keeping, but it's
from two different versions ofthe permit the one that was
written in 2012, and then theyhad a renewal in 2017, and then
in 2020, and they've got somerecords from all of those
floating around and they'recompleting them all because
they're terrified to not do it.
Well, but it's creating anenormous workload for them.
(04:58):
That isn't necessarily needed,and the reason it's not just
like it's the exact same record,but with the date on the bottom
is the reason is the RECsupdate and so they all look a
little different, and so there'snot been that executive
decision of don't do 2012, don'tdo 2017, only do the 2020
forward, because that's the onethat is most current right, and
(05:19):
if there is no executivedecision making being done by an
environmental manager or anoversight consultant, like what
we do, the terminal manager isstuck with all these records and
there's no stop date on them,so they continue doing it.
That copy control is a reallyimportant part of a healthy
record keeping system and beingable to understand what's due
(05:40):
and when.
Speaker 1 (05:41):
So why isn't there just one list of all the records
required?
Where's our easy button?
Speaker 2 (05:48):
Oh, where's the one list to rule them all?
The answer to that is twofold.
The first is that if you havemultiple companies writing your
permits, they're only interestedin the record keeping that
comes with that permit.
The other side of that is thatthe permits all renew on
different schedules and indifferent years and there's a
(06:08):
whole lot of permits for everybulk field facility out there.
We always joke that like a bulkfield facility is a small piece
of land surrounded byregulations, and it's true,
there's so many out there.
We encourage our clients toperform an audit and create a
master record keeping list andto organize it by records that
(06:29):
are required daily, monthly,quarterly, semi-annually and
annually, because most recordshave some or if not all of those
requirements.
And what you can do when you arecontracting for a plan or
permit renewal is you canrequest, as part of the scope of
work, a list of the recordsthat are required by that permit
(06:52):
, broken down by daily, monthly,quarterly, semi-annual and
annual right.
And so if you can get that listfrom every permit, it makes it
easier to manage as anenvironmental manager, because
the permit's coming in with thatpiece already written or it's
part of the deliverables thatgoes with that plan or permit.
We of course provide that kindof list and we also do audits to
(07:12):
develop that kind of list afterthe fact to try to reduce this
level of confusion.
But that's why there's no easybutton, because there's anywhere
from 10 to even 20 permits thatare environmentally based at a
facility, and then that doesn'tinclude some of the other ones
that are not environmentallybased, like fire extinguisher
(07:32):
inspections and OSHA checks, andthere's a lot going on at a
tank farm.
Speaker 1 (07:39):
Sure, where would we start to fix this?
Internally or where we arecurrently?
Speaker 2 (07:45):
So let's say that you're a terminal manager or an
environmental manager and youjust walked in the door and
there's a lot of records and itseems like there's a lot of
duplication and a lot of effortbeing spent.
And you, there's a lot ofconfusion right, like which ones
which, which ones, right?
How to fix that is to sit downand do an audit and be familiar
(08:08):
enough with that plan or permitto understand what the record
keeping requirements are.
Most plans and permits have arecord keeping section and they
lay out what are required.
And if you have that list, youcan start creating that master
Excel sheet of the dailies andthe monthlies in the Quarterlies
and you can start filling themin.
And then, once you get thatmaster list of what you think is
(08:31):
absolutely Required by all theplans and permits, then you can
start working on copy control.
For example, the, the ODPCPrequired by 18 AC 75 in Alaska,
has a routine facilityinspection requirement.
Most people perform it monthly,right, so there's a monthly and
then there's also dailyrequirements and you could audit
(08:53):
how many daily facilityinspections are you performing
right now and you might besurprised at the answer.
I've asked that of many, many,many terminal managers and
sometimes I get back.
I've got a daily for the marina.
I've got a daily for our mainfacility.
I've got a daily for the truckrack.
I've got a daily for the truck.
I have a daily for the airportfacility.
I have a daily for the airporttruck that's related to a TA 103
(09:15):
.
I also have a daily for the oldwater separator and I have a
monthly force bill responseequipment.
That's a lot of dailies.
Do they need every single oneof those dailies?
and the answer is maybe in thatspecific example they probably
don't need a daily for the truckrack and the facility they
should be together.
(09:35):
But the ATA 103 does require adaily of Specific aviation fuel
trucks and they require it ofaviation fuel tanks and aviation
service.
So it sort of depends on yourlist and how you're looking at
it.
But once you have a list thenyou can start looking at what
they're doing to meet thoseregulations and requirements and
seeing if there's any that areout there that can be taken away
(09:57):
and Replaced with one that'salready being done.
Or maybe that one that'salready being done could be
modified just a little bit andhave that form replace another
one, so that they're only doingone form instead of two or three
.
Speaker 1 (10:11):
Got it, so that sounds like it can get a little
overwhelming.
How do we fix it in the longrun?
Speaker 2 (10:17):
in the long run, like I mentioned earlier, having
part of your scope of workinclude a deliverable that lists
out record keeping that thepermit is setting up for you.
I would also recommend you canalways hire someone like us to
come in and give you consultingand say you know, do that hard
work for you, provide a list andsort of get you started.
(10:37):
But I think in the long run thebiggest fix is Having plans and
permits written that considerother plans and permits and also
consider operationalrestrictions.
I Think many plan writers arein offices, myself included, and
if you don't fully understandwhat happens or what goes on at
a bulk fuel facility Becauseyou're writing general permits
(10:59):
for any industry instead of onespecific industry, you don't
understand that taking a dailygauge of a fuel facility may
involve somebody standing on topof a tank in a 35 mile an hour
Wind, when it's cold, maybe 15below zero.
You know and you don'tunderstand that it's not a
stairway, it's a barrel cageladder right and you have to
(11:21):
climb that barrel cage ladder tothe top of the tank, which is
not easy and it's often not safewhen it's really cold and icy
and slippery, or Dailyinspections of things that are
completely covered by snow, likehow do you perform those?
What are those look like?
And so I think having aknowledgeable firm do your plan
a permit that knows yourindustry, knows your ecosystem,
knows your weather conditions,the person who's writing that
(11:42):
plan can put thoseconsiderations into that
record-keeping effort.
Also, making sure that plan andpermit writer is aware of the
other things that you're doing.
So when you're ordering a planor permit to be written, or if
you're writing one yourself,look at all the other reports
and record keeping that you'rehaving your terminal managers do
already and see if you can meetthe Regulatory requirement with
(12:05):
what's out there.
I think adding that bit ofexperience and context to a plan
or permit development willreally help keep the problem
from occurring in the future andsort of build a stronger, more
proactive system going forward.
And I also think keeping amaster record list is really
important, like understandingwhat needs to be delivered and
(12:26):
when.
There are two other legs to thisstool.
One is context for the personfilling out the record keeping,
like what they're supposed to bewriting down and documenting.
But there's also accountabilitywho is responsible for making
sure that these records get doneand are uploaded and put into
your records like documented incertain specific ways, and so
(12:48):
we'll talk about those in futurepodcasts.
But another thing you can do toensure that you're getting
quality in from a plan or apermit is to review records or
forms when they come in from thepermit right and actually sit
down with your terminal managerand review them when it's still
in draft form and maybe test itout and get the terminal
(13:08):
manager's feedback when you canstill send it back to the
consultant for changes, updates,elimination, right, like you
can say oh, we don't drain ourSCA in inches, we drain it in
gallons and we have a flowregulator that measures it on
the outside.
Those are things that if youcan change it, it's going to
make sense to the terminalmanager later when he goes to
look at it.
And so I feel like when you arewriting a plan or permit, part
(13:31):
of the clients review processhas to include review of a
record keeping form that's beenproposed and making sure it
makes sense for the operationsand the facility that it's being
proposed for, and then takingit to the person who's going to
fill it out and asking them whatthey think of it and if it's
doable.
And if you do those steps aspart of your plan and permit
renewal process.
(13:52):
That's going to eliminate a lotof confusion in the future,
because you're giving yourterminal manager the context.
You're giving them a chance tochange things when it makes
sense.
We often see that it doesn'thappen because of time
constraints, because they needto get it done and there's only
seven days and the terminalmanager is always very busy.
But most of these permits renewevery five years.
(14:13):
Five years is a long time to bekeeping a record that's not
optimized and is causingduplicative effort on somebody's
part.
It's a long time to dosomething twice when you only
need to do it once.
Speaker 1 (14:22):
Yeah, we like simplicity Are there additional
resources we can point ourlisteners to.
To get started.
Speaker 2 (14:30):
Yeah you know, as part of developing this podcast,
we went ahead and developed anorganizer that I think will be
really helpful.
It's a simple Excel sheet.
It has room for all theperiodic inspection categories
like daily, monthly, quarterly.
You can download that from theshow notes or from our website
and it should help you getstarted tracking on it.
(14:50):
It also has columns for duedates and notes.
We left it blank because wedon't know the context that
you're going to be using it in,but it is definitely a start.
Speaker 1 (15:00):
Great.
We'll have that posted on ourwebsite along with the show
notes.
Thank you for joining us today.
I look forward to our next talk.
Continuing the record keepingtheme.
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