January 2, 2024 • 17 mins
Have you ever considered the potential chaos when a single person is tasked with industrial recordkeeping? We open your eyes to the dangers of such practices, including the creation of information silos and the vulnerability that comes with employee turnover. In the wake of a terminal manager's recordkeeping blunder, we dissect the repercussions that ripple through an organization, leading to legal entanglements and regulatory nightmares. With a focus on shared accountability, our discussion moves to innovative solutions that involve teamwork in documentation, fostering error detection in real-time, and a management system agile enough to meet the demands of both environmental and safety regulations.
Take a proactive stance in environmental management with our expert advice on maintaining impeccable records that can withstand the scrutiny of any audit. Environmental managers, listen as we stress the importance of your role in quality control and the continuous training imperative to weather the storm of staff transitions. Our final episode in our recordkeeping series is your roadmap to creating a resilient and reliable record-keeping system tailor-made for the ever-evolving landscape of industry standards.
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.
intro/outro created with GarageBand
Mark as Played
Transcript
Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Speaker 1 (00:00):
Welcome back, shannon .
It sounds like we finally hitthe caboose on the record
keeping train.
Yes, so today we'll bediscussing accountability.
Speaker 2 (00:08):
Yes, my favorite leg of the record keeping stool.
Speaker 1 (00:11):
What is accountability?
Speaker 2 (00:13):
Ah, accountability is this vague sort of large term
for a whole lot of differentthings, specifically human
behavior.
I think it's really heavilymisunderstood.
A lot of people.
If you ask them what'saccountability, they'll say
things like oh, it's ownership,one person taking responsibility
, and that responsibility comeswith rewards and consequences,
(00:37):
and that is one definition ofaccountability.
But in the context ofindustrial record keeping, that
kind of definition, which isvery prevalent in a lot of
business models, that sort ofmindset results in some unwanted
consequences or unwantedresults.
The two that we see the most isinformation siloing.
(00:57):
Someone was responsible fordoing something like the storm
water monitoring right, and theywere the one person responsible
for it.
It was their job, all theconsequences were theirs and
they did it and then they left.
There was staff turnover andnobody else knows how to do it.
Nobody else knows where thefiles are located.
It's very difficult for theincoming person to access
(01:21):
historical records or continuedoing it the way it was done,
and that information silocreates problems for a company
with turnover.
The other thing that we seethat's really common with that
specific mis like accountabilitydefinition is we see
consequences that are so heavythat they're insurmountable or
uncorrectable from thesupervisory level.
(01:42):
And the biggest example of thisis a terminal manager is told
that record keeping is hisresponsibility and he is
supposed to do it, which heaccepts when he takes the job.
But after five years nobody'sever checked in with him or
verified that these records arebeing kept or given him any
feedback whatsoever.
And they have a state orfederal inspection and the
(02:06):
inspector comes in and says weneed to see your records and
they aren't any.
So you get a nice potentialnotice of violation letter from
the state or the EPA saying weneed to see all your records for
the last five years.
Terminal manager was unable toprovide them at our onsite site
visit.
Whoever the terminal managersupervisor is, there's no way to
supervise your way out of afive-year record gap.
(02:28):
It's so insurmountable and it'ssuch a huge risk.
And yes, the terminal managerwas accountable and it was his
responsibility.
But if it didn't happen andit's a big gap the risk and the
potential damage to the companypretty huge.
That's why I like to talk aboutaccountability in a different
way.
Speaker 1 (02:47):
Then how should we be looking at accountability?
Speaker 2 (02:50):
We prefer talking about it more as a joint
responsibility, and I actuallycall it joint accountability
when we're setting clients upwith this system.
But the idea is is that forsomething so critical like
record keeping, especially forrisk management, there's two
people that have accountabilityfor something like record
(03:10):
keeping at least.
Sometimes there's more, but atthe simplest way to look at it
is that someone like a terminalmanager has the responsible for
creating and filing the recordor maintaining the record, and
these days it's very often adigital record that's being
created, but there are stillplenty of people that do it hard
copy and have it in a filefolder in the office.
And there's another person, andthat person may or may not
(03:34):
actually be the supervisor ofthe terminal manager, it may be
an environmental managementstaff member and that person has
the responsibility to check thefiled records on a routine
basis and sort of audit forcompleteness, errors in context,
etc.
And what that system does.
It allows the business toensure that you're creating this
(03:58):
record keeping record.
If there's incomplete records,they're corrected in real time.
It's not five years later whenit becomes a problem, it's at
the end of the month.
We noticed that you, like a realcommon example is looking at
dailies right.
Most facilities have dailyrecords and they perform them
every day that they'reoperational.
So if they're closed Saturday,sunday, there's not a record
(04:19):
right.
So most months you have I don'tknow 24 daily records.
If you open up the file andyou're auditing it, like we have
done for clients, and there'sonly 16 records in there, and
you look and you realize thatthere's an entire week where
nobody did a daily and you'relike what happened here?
So you call the terminalmanager and she's like oh,
that's the week I took personalleave and I went to Vegas and my
(04:43):
yard foreman was working for me.
However, I failed to tell himhe had to do the daily.
You can correct that for thefuture.
You can't, of course, go backin time and fill in the record
gap, but recognizing the problem, coming up with a solution,
providing training, support andresources happens in real time,
and it's not just something thathappens every time the terminal
(05:03):
manager leaves and they justdon't, you know, never correct
it.
The other thing that we see withroutine monitoring is if the
terminal manager is not gettingsupport from the company, he'll
notice like oh, I'm uploadingall these records and I've told
them multiple times that thesecondary containment three inch
log doesn't match right whatwe're doing or we need this
(05:25):
thing repaired and I'm having toput it on every record that
it's broken, like every day onour dailies.
It can also highlight abreakdown in the environmental
or record keeping managementportion of a company and that
can be brought up during allhand meetings with senior
personnel and they can saythings like and I've heard this
before from companies where, hey, when it's safety, we get it
(05:46):
resolved immediately and we geteverything we need, but when
it's environmental, it takesmonths and months, and months,
and that's that's one of thesymptoms that we see when
there's not a goodaccountability system set up is
that the environmental manageris not being held accountable
for their responsibilities, formaking sure that the system is
creating and producing recordsthat are measurable, complete,
(06:11):
have all the right context, arefilled out correctly, all of
those things.
Speaker 1 (06:15):
So how does joint accountability work, how would
we set it up correctly and howwould we avoid bad consequences?
Speaker 2 (06:22):
That's a really great question, and it's one we
answer for our clients.
Many of our clients start withthe terminal manager is solely
responsible.
As I mentioned before, recordkeeping is a three part stool,
and so if they also had problemswith context, they also had
problems with quality in andquality out.
Accountability is often alsoaffected.
It's hard to keep good,complete records when the record
(06:45):
that you're filling out isn'tset up for the way you need to
do it and it's also notsomething that you've been
trained on, so you don't fullyunderstand what you're filling
out, and then there's nobodytelling you or giving you
feedback about how complete orwell done the record is right.
And so we set this jointaccountability up to provide
that mechanism for feedback,training, support when they need
(07:06):
it in real time, and what wetypically do.
Because we're moving into thedigital world.
They're like I said, there arestill hard copies, but those are
the exception at this point.
Digital copies they have a.
They have quite a few benefitsthat, in my mind, ensure that
they are the future of recordkeeping one.
They create time stamped anddate stamped records that show
(07:27):
they got completed on a specificdate.
They're easily accessible bystaff or personnel and other
locations, like the mainleadership group and Anchorage,
can drop in and look and see athow record keeping is being
performed at a satellitefacility or a facility in a
different community.
And so when we set up thisjoint accountability, we set up
(07:50):
a filing system that makes itpretty easy to see where things
go and it matches our recordkeeping organizer right.
So if there's daily records andmonthly records, there's
folders that say daily andmonthly and there's one for each
month of each year and theterminal manager is supposed to
upload these to the folders.
And then it makes it real easyfor whoever's auditing them from
(08:12):
the environment, like anenvironmental manager or
sometimes the terminal managersupervisor, whoever that is a
general manager.
Maybe they can go in and lookand say, okay, there's supposed
to be four monthly records inhere, one for the facility, one
for the tank truck and a fewothers secondary containment,
drainout, jog, whatever.
And if he opens up the folderand there's only three records
(08:35):
in there, he knows right awayyou've got a master list of all
the records you're supposed tobe keeping that one is missing
and he can follow up with anemail to the terminal manager
and say hey, rosie, could youget me this record that seems to
be missing and if it occurs inreal time, it's small amounts of
time, a 30 minute meeting oncea month maybe.
(08:55):
At the most it avoids panickedmeetings three years in the
future when all these recordsare missing and there's huge
data gaps and a firm like ourshas to be brought in to audit,
summarize, identify and prepareall this stuff to be submitted.
Because all of these records areauditable to all these
different regulatory agencies.
(09:16):
They can be asked for at anytime and they are almost always
asked for after some sort ofevent, like a spill or
infrastructure failure or a nearmiss or something, and
sometimes it's just part of theregular inspection schedule.
They just want to know all therecords for the last three years
.
So creating an auditable recordis pretty important, as
important as your accountingrecords, and I'm still working
(09:41):
on changing everybody's mindabout the importance of all of
that.
That's generally how we set itup as we use the quality and
quality out to create the masterlist.
We have training for everybodyenvironmental manager and the
terminal manager.
So everyone's got context aboutwhat needs to be filled out
completely and why, and then wehave this accountability where
(10:01):
the terminal manager isuploading the required records
and somebody an environmentalmanager, we'll say, for
argument's sake is reviewingthese on a monthly basis and
giving feedback, requestingmissing and just sort of helping
and supporting that terminalmanager and making sure that the
record is created and then thatwhat is created is quality, and
then that environmental manageris creating an auditable record
(10:22):
for the company that reducesrisk and allows the company to
operate safely, securely andalso have all of the information
it needs if it ever does getaudited or inspected or whatever
from the state or the feds.
That's how we look ataccountability and it's a very
effective system, but it doesrequire some resources.
(10:43):
You have to have somebody who'sgoing to look at those records
on a routine basis.
Some of our clients don't havethose resources.
They're real lean at theleadership level, and so our
firm also offers somethingcalled Shield Record Keeping
Services and we actually dothose audits.
We set up the list of, you know, the master list of record
keeping.
We provide the training for theterminal manager and then we
(11:06):
audit all of those files eachmonth and we provide reports to
the manager on a monthly,quarterly, semi-annual and
annual basis.
And what that allows the personlike a general manager, who has
a lot more responsibilities thanjust environmental management
what it allows that person to dois look at the holes or gaps
that our team has identified andhave a very targeted, specific
(11:28):
conversation with the terminalmanager about the things that
need to be fixed or that mayneed more support, or that you
know or that are not workingquite right, instead of
reviewing all 26 dailies to makesure that they're correct,
right, our team does that andthen they can focus on the fact
that we identified that theywere all filled out but they
never noted any maintenance.
And he can say you know, look,rosie, you have got to get the
(11:50):
maintenance onto these dailies.
You've got to show when youfound a weep and corrected the
weep.
And it makes for a much moreefficient use of some of our
senior leadership's time whenthey have a lean leadership team
.
Speaker 1 (12:03):
I know you had mentioned one symptom of lacking
a healthier jointaccountability for record
keeping is when someone stepsout on vacation and no one else
knows how to step in place forthem or fill in that gap.
Are there any other symptomsthat we can watch out for?
Speaker 2 (12:23):
Yeah, I mean, some of the symptoms are just records
not being kept because nobody'sgiven feedback or held the
terminal manager accountable forcompleting that record.
One of the other symptoms weoften see if you don't have
healthy accountability in place.
Joint accountability how theserecords are filed means that
(12:43):
nobody else can access them oraudit them or investigate them
without spending hundreds ofhours.
And so one of those systemsthat I see is that they're all
on the hard drive of theterminal manager or they're in
hard copy in a filing system andauditing them is very difficult
(13:04):
.
Or my favorite one is I emailedit to you every day.
I emailed you the dailies, Iemailed you the monthlies, I
emailed you the everythingsright.
If you've got somebody who's anenvironmental manager and
they're getting several hundredemails a year related to dailies
monthly, so I just and they'renot in one place and they're not
organized and they're not namedin a way that you could like
(13:25):
save them all in a folder andhave them all sort themselves
out.
That system's not healthybecause you can't audit it
easily, you can't see the gaps,you can't go in and easily see
that only 17 dailies gotperformed in this month and it
should have been 24 or something.
So, like I've said before andthroughout this series on record
keeping, it's a three-partstool.
You've got to have all of theparts in place, but if there's
(13:47):
no accountability, you see drift.
You see, like maybe you had thebest record in the world, you
had the best training, and thena terminal manager turned over
and it's a new terminal manager,and if there's not
accountability from anenvironmental manager, they may
not ensure that the new one getsthe right training and then
maybe the context goes away.
When accountability is notworking, you're going to see
(14:08):
drift or shifting in the otheraspects of the record keeping
system.
You're going to see that thecontext maybe gets dropped or
the records are not as quality,or maybe they were quality five
years ago but they haven't beenupdated and managed and so now
they are out of date and theyare not quality anymore.
They're not working for theterminal manager because so many
(14:29):
things have changed.
Speaker 1 (14:30):
Do you have any resources for our listeners to
get better at accountability?
Hmm?
Speaker 2 (14:36):
yes, I do.
We have a naming guidance fornaming these digital files, and
it really helps organize them.
Even if they're all dumped intoa folder, they'll at least be
in date order, and almost anytime that we have done work to
respond to a federal or stateinspector's request for records,
(14:58):
or records requested by legalteams as part of Notice of
Violation negotiations, thelegal team will need all of
these records sorted by contextand by date order, and so, if
you are interested in creatingthe best record keeping system
on earth, I would recommendusing our naming guidance,
because it'll help.
Starting from the beginning,you will be able to create a
(15:21):
record that's ready for anythingyou may need it for, and so
we'll include that in the shownotes.
You, of course, can adapt it inany way you need to for your
own company.
The big key, though, is, onceyou do select a record naming
protocol, you have to beconsistent with it, and that
consistency can be difficultbecause of human nature.
(15:42):
But yeah, if you've got anaming guidance and you're using
it, and the terminal manager isusing it, and you're performing
a monthly audit and you'resaying hey, I noticed that all
of your dailies came throughwith the scanner name.
You know, scanner ZYZ1001529,.
I renamed them for you thismonth, but you need to do it
next month, right?
(16:02):
Those are much better files foryour digital record keeping
than all the files that have thescanner name and an individual
number on it.
If you've got a date, alocation, a record type, context
, anything like that, it'll makefor a better record.
So we'll provide that resourceto the listeners because I think
(16:23):
that that is a really bighurdle for a lot of records as
we move into the digital age.
As you know, before we had filefolders and the record was in
the folder and you could tellwhat it was clearly by looking
at it.
Digital files are numerous.
You can't really look at themwithout like opening them, and
they do need to be sorted intotheir own digital files.
(16:45):
It gets a little morecomplicated with digital and so
having context in the name ofthe file means you can search
for it independently of whereit's located, and we find that
really helpful.
When there's misfilings, likethey file it in the wrong folder
, you can still find that file.
Is there an annual for 2022?
If you've named your filesconsistently, you can search for
(17:07):
that ANL for annual and see allof the files and you'll be able
to find it.
And oh look, someone put it in2019 on accident.
That's where it is, so I thinkthat'll be helpful.
Speaker 1 (17:17):
Well, thank you so much, Shannon.
I learned so much from thesethree legs of the stool record
keeping.
I look forward to learning morewith you in future episodes.
Speaker 2 (17:27):
Yeah, thanks so much for having me again, amanda.
I really appreciate your good,thoughtful questions and I was
really excited to talk aboutrecord keeping.
Our firm handles a lot and ifwe can help make it better for
others, I would really like tosee that happen.
Speaker 1 (17:41):
Absolutely.
Welcome back, shannon .
It sounds like we finally hitthe caboose on the record
keeping train.
Yes, so today we'll bediscussing accountability.
Speaker 2 (00:08):
Yes, my favorite leg of the record keeping stool.
Speaker 1 (00:11):
What is accountability?
Speaker 2 (00:13):
Ah, accountability is this vague sort of large term
for a whole lot of differentthings, specifically human
behavior.
I think it's really heavilymisunderstood.
A lot of people.
If you ask them what'saccountability, they'll say
things like oh, it's ownership,one person taking responsibility
, and that responsibility comeswith rewards and consequences,
(00:37):
and that is one definition ofaccountability.
But in the context ofindustrial record keeping, that
kind of definition, which isvery prevalent in a lot of
business models, that sort ofmindset results in some unwanted
consequences or unwantedresults.
The two that we see the most isinformation siloing.
(00:57):
Someone was responsible fordoing something like the storm
water monitoring right, and theywere the one person responsible
for it.
It was their job, all theconsequences were theirs and
they did it and then they left.
There was staff turnover andnobody else knows how to do it.
Nobody else knows where thefiles are located.
It's very difficult for theincoming person to access
(01:21):
historical records or continuedoing it the way it was done,
and that information silocreates problems for a company
with turnover.
The other thing that we seethat's really common with that
specific mis like accountabilitydefinition is we see
consequences that are so heavythat they're insurmountable or
uncorrectable from thesupervisory level.
(01:42):
And the biggest example of thisis a terminal manager is told
that record keeping is hisresponsibility and he is
supposed to do it, which heaccepts when he takes the job.
But after five years nobody'sever checked in with him or
verified that these records arebeing kept or given him any
feedback whatsoever.
And they have a state orfederal inspection and the
(02:06):
inspector comes in and says weneed to see your records and
they aren't any.
So you get a nice potentialnotice of violation letter from
the state or the EPA saying weneed to see all your records for
the last five years.
Terminal manager was unable toprovide them at our onsite site
visit.
Whoever the terminal managersupervisor is, there's no way to
supervise your way out of afive-year record gap.
(02:28):
It's so insurmountable and it'ssuch a huge risk.
And yes, the terminal managerwas accountable and it was his
responsibility.
But if it didn't happen andit's a big gap the risk and the
potential damage to the companypretty huge.
That's why I like to talk aboutaccountability in a different
way.
Speaker 1 (02:47):
Then how should we be looking at accountability?
Speaker 2 (02:50):
We prefer talking about it more as a joint
responsibility, and I actuallycall it joint accountability
when we're setting clients upwith this system.
But the idea is is that forsomething so critical like
record keeping, especially forrisk management, there's two
people that have accountabilityfor something like record
(03:10):
keeping at least.
Sometimes there's more, but atthe simplest way to look at it
is that someone like a terminalmanager has the responsible for
creating and filing the recordor maintaining the record, and
these days it's very often adigital record that's being
created, but there are stillplenty of people that do it hard
copy and have it in a filefolder in the office.
And there's another person, andthat person may or may not
(03:34):
actually be the supervisor ofthe terminal manager, it may be
an environmental managementstaff member and that person has
the responsibility to check thefiled records on a routine
basis and sort of audit forcompleteness, errors in context,
etc.
And what that system does.
It allows the business toensure that you're creating this
(03:58):
record keeping record.
If there's incomplete records,they're corrected in real time.
It's not five years later whenit becomes a problem, it's at
the end of the month.
We noticed that you, like a realcommon example is looking at
dailies right.
Most facilities have dailyrecords and they perform them
every day that they'reoperational.
So if they're closed Saturday,sunday, there's not a record
(04:19):
right.
So most months you have I don'tknow 24 daily records.
If you open up the file andyou're auditing it, like we have
done for clients, and there'sonly 16 records in there, and
you look and you realize thatthere's an entire week where
nobody did a daily and you'relike what happened here?
So you call the terminalmanager and she's like oh,
that's the week I took personalleave and I went to Vegas and my
(04:43):
yard foreman was working for me.
However, I failed to tell himhe had to do the daily.
You can correct that for thefuture.
You can't, of course, go backin time and fill in the record
gap, but recognizing the problem, coming up with a solution,
providing training, support andresources happens in real time,
and it's not just something thathappens every time the terminal
(05:03):
manager leaves and they justdon't, you know, never correct
it.
The other thing that we see withroutine monitoring is if the
terminal manager is not gettingsupport from the company, he'll
notice like oh, I'm uploadingall these records and I've told
them multiple times that thesecondary containment three inch
log doesn't match right whatwe're doing or we need this
(05:25):
thing repaired and I'm having toput it on every record that
it's broken, like every day onour dailies.
It can also highlight abreakdown in the environmental
or record keeping managementportion of a company and that
can be brought up during allhand meetings with senior
personnel and they can saythings like and I've heard this
before from companies where, hey, when it's safety, we get it
(05:46):
resolved immediately and we geteverything we need, but when
it's environmental, it takesmonths and months, and months,
and that's that's one of thesymptoms that we see when
there's not a goodaccountability system set up is
that the environmental manageris not being held accountable
for their responsibilities, formaking sure that the system is
creating and producing recordsthat are measurable, complete,
(06:11):
have all the right context, arefilled out correctly, all of
those things.
Speaker 1 (06:15):
So how does joint accountability work, how would
we set it up correctly and howwould we avoid bad consequences?
Speaker 2 (06:22):
That's a really great question, and it's one we
answer for our clients.
Many of our clients start withthe terminal manager is solely
responsible.
As I mentioned before, recordkeeping is a three part stool,
and so if they also had problemswith context, they also had
problems with quality in andquality out.
Accountability is often alsoaffected.
It's hard to keep good,complete records when the record
(06:45):
that you're filling out isn'tset up for the way you need to
do it and it's also notsomething that you've been
trained on, so you don't fullyunderstand what you're filling
out, and then there's nobodytelling you or giving you
feedback about how complete orwell done the record is right.
And so we set this jointaccountability up to provide
that mechanism for feedback,training, support when they need
(07:06):
it in real time, and what wetypically do.
Because we're moving into thedigital world.
They're like I said, there arestill hard copies, but those are
the exception at this point.
Digital copies they have a.
They have quite a few benefitsthat, in my mind, ensure that
they are the future of recordkeeping one.
They create time stamped anddate stamped records that show
(07:27):
they got completed on a specificdate.
They're easily accessible bystaff or personnel and other
locations, like the mainleadership group and Anchorage,
can drop in and look and see athow record keeping is being
performed at a satellitefacility or a facility in a
different community.
And so when we set up thisjoint accountability, we set up
(07:50):
a filing system that makes itpretty easy to see where things
go and it matches our recordkeeping organizer right.
So if there's daily records andmonthly records, there's
folders that say daily andmonthly and there's one for each
month of each year and theterminal manager is supposed to
upload these to the folders.
And then it makes it real easyfor whoever's auditing them from
(08:12):
the environment, like anenvironmental manager or
sometimes the terminal managersupervisor, whoever that is a
general manager.
Maybe they can go in and lookand say, okay, there's supposed
to be four monthly records inhere, one for the facility, one
for the tank truck and a fewothers secondary containment,
drainout, jog, whatever.
And if he opens up the folderand there's only three records
(08:35):
in there, he knows right awayyou've got a master list of all
the records you're supposed tobe keeping that one is missing
and he can follow up with anemail to the terminal manager
and say hey, rosie, could youget me this record that seems to
be missing and if it occurs inreal time, it's small amounts of
time, a 30 minute meeting oncea month maybe.
(08:55):
At the most it avoids panickedmeetings three years in the
future when all these recordsare missing and there's huge
data gaps and a firm like ourshas to be brought in to audit,
summarize, identify and prepareall this stuff to be submitted.
Because all of these records areauditable to all these
different regulatory agencies.
(09:16):
They can be asked for at anytime and they are almost always
asked for after some sort ofevent, like a spill or
infrastructure failure or a nearmiss or something, and
sometimes it's just part of theregular inspection schedule.
They just want to know all therecords for the last three years
.
So creating an auditable recordis pretty important, as
important as your accountingrecords, and I'm still working
(09:41):
on changing everybody's mindabout the importance of all of
that.
That's generally how we set itup as we use the quality and
quality out to create the masterlist.
We have training for everybodyenvironmental manager and the
terminal manager.
So everyone's got context aboutwhat needs to be filled out
completely and why, and then wehave this accountability where
(10:01):
the terminal manager isuploading the required records
and somebody an environmentalmanager, we'll say, for
argument's sake is reviewingthese on a monthly basis and
giving feedback, requestingmissing and just sort of helping
and supporting that terminalmanager and making sure that the
record is created and then thatwhat is created is quality, and
then that environmental manageris creating an auditable record
(10:22):
for the company that reducesrisk and allows the company to
operate safely, securely andalso have all of the information
it needs if it ever does getaudited or inspected or whatever
from the state or the feds.
That's how we look ataccountability and it's a very
effective system, but it doesrequire some resources.
(10:43):
You have to have somebody who'sgoing to look at those records
on a routine basis.
Some of our clients don't havethose resources.
They're real lean at theleadership level, and so our
firm also offers somethingcalled Shield Record Keeping
Services and we actually dothose audits.
We set up the list of, you know, the master list of record
keeping.
We provide the training for theterminal manager and then we
(11:06):
audit all of those files eachmonth and we provide reports to
the manager on a monthly,quarterly, semi-annual and
annual basis.
And what that allows the personlike a general manager, who has
a lot more responsibilities thanjust environmental management
what it allows that person to dois look at the holes or gaps
that our team has identified andhave a very targeted, specific
(11:28):
conversation with the terminalmanager about the things that
need to be fixed or that mayneed more support, or that you
know or that are not workingquite right, instead of
reviewing all 26 dailies to makesure that they're correct,
right, our team does that andthen they can focus on the fact
that we identified that theywere all filled out but they
never noted any maintenance.
And he can say you know, look,rosie, you have got to get the
(11:50):
maintenance onto these dailies.
You've got to show when youfound a weep and corrected the
weep.
And it makes for a much moreefficient use of some of our
senior leadership's time whenthey have a lean leadership team
.
Speaker 1 (12:03):
I know you had mentioned one symptom of lacking
a healthier jointaccountability for record
keeping is when someone stepsout on vacation and no one else
knows how to step in place forthem or fill in that gap.
Are there any other symptomsthat we can watch out for?
Speaker 2 (12:23):
Yeah, I mean, some of the symptoms are just records
not being kept because nobody'sgiven feedback or held the
terminal manager accountable forcompleting that record.
One of the other symptoms weoften see if you don't have
healthy accountability in place.
Joint accountability how theserecords are filed means that
(12:43):
nobody else can access them oraudit them or investigate them
without spending hundreds ofhours.
And so one of those systemsthat I see is that they're all
on the hard drive of theterminal manager or they're in
hard copy in a filing system andauditing them is very difficult
(13:04):
.
Or my favorite one is I emailedit to you every day.
I emailed you the dailies, Iemailed you the monthlies, I
emailed you the everythingsright.
If you've got somebody who's anenvironmental manager and
they're getting several hundredemails a year related to dailies
monthly, so I just and they'renot in one place and they're not
organized and they're not namedin a way that you could like
(13:25):
save them all in a folder andhave them all sort themselves
out.
That system's not healthybecause you can't audit it
easily, you can't see the gaps,you can't go in and easily see
that only 17 dailies gotperformed in this month and it
should have been 24 or something.
So, like I've said before andthroughout this series on record
keeping, it's a three-partstool.
You've got to have all of theparts in place, but if there's
(13:47):
no accountability, you see drift.
You see, like maybe you had thebest record in the world, you
had the best training, and thena terminal manager turned over
and it's a new terminal manager,and if there's not
accountability from anenvironmental manager, they may
not ensure that the new one getsthe right training and then
maybe the context goes away.
When accountability is notworking, you're going to see
(14:08):
drift or shifting in the otheraspects of the record keeping
system.
You're going to see that thecontext maybe gets dropped or
the records are not as quality,or maybe they were quality five
years ago but they haven't beenupdated and managed and so now
they are out of date and theyare not quality anymore.
They're not working for theterminal manager because so many
(14:29):
things have changed.
Speaker 1 (14:30):
Do you have any resources for our listeners to
get better at accountability?
Hmm?
Speaker 2 (14:36):
yes, I do.
We have a naming guidance fornaming these digital files, and
it really helps organize them.
Even if they're all dumped intoa folder, they'll at least be
in date order, and almost anytime that we have done work to
respond to a federal or stateinspector's request for records,
(14:58):
or records requested by legalteams as part of Notice of
Violation negotiations, thelegal team will need all of
these records sorted by contextand by date order, and so, if
you are interested in creatingthe best record keeping system
on earth, I would recommendusing our naming guidance,
because it'll help.
Starting from the beginning,you will be able to create a
(15:21):
record that's ready for anythingyou may need it for, and so
we'll include that in the shownotes.
You, of course, can adapt it inany way you need to for your
own company.
The big key, though, is, onceyou do select a record naming
protocol, you have to beconsistent with it, and that
consistency can be difficultbecause of human nature.
(15:42):
But yeah, if you've got anaming guidance and you're using
it, and the terminal manager isusing it, and you're performing
a monthly audit and you'resaying hey, I noticed that all
of your dailies came throughwith the scanner name.
You know, scanner ZYZ1001529,.
I renamed them for you thismonth, but you need to do it
next month, right?
(16:02):
Those are much better files foryour digital record keeping
than all the files that have thescanner name and an individual
number on it.
If you've got a date, alocation, a record type, context
, anything like that, it'll makefor a better record.
So we'll provide that resourceto the listeners because I think
(16:23):
that that is a really bighurdle for a lot of records as
we move into the digital age.
As you know, before we had filefolders and the record was in
the folder and you could tellwhat it was clearly by looking
at it.
Digital files are numerous.
You can't really look at themwithout like opening them, and
they do need to be sorted intotheir own digital files.
(16:45):
It gets a little morecomplicated with digital and so
having context in the name ofthe file means you can search
for it independently of whereit's located, and we find that
really helpful.
When there's misfilings, likethey file it in the wrong folder
, you can still find that file.
Is there an annual for 2022?
If you've named your filesconsistently, you can search for
(17:07):
that ANL for annual and see allof the files and you'll be able
to find it.
And oh look, someone put it in2019 on accident.
That's where it is, so I thinkthat'll be helpful.
Speaker 1 (17:17):
Well, thank you so much, Shannon.
I learned so much from thesethree legs of the stool record
keeping.
I look forward to learning morewith you in future episodes.
Speaker 2 (17:27):
Yeah, thanks so much for having me again, amanda.
I really appreciate your good,thoughtful questions and I was
really excited to talk aboutrecord keeping.
Our firm handles a lot and ifwe can help make it better for
others, I would really like tosee that happen.
Speaker 1 (17:41):
Absolutely.
Popular Podcasts
Dateline NBC
Current and classic episodes, featuring compelling true-crime mysteries, powerful documentaries and in-depth investigations. Follow now to get the latest episodes of Dateline NBC completely free, or subscribe to Dateline Premium for ad-free listening and exclusive bonus content: DatelinePremium.com
Stuff You Should Know
If you've ever wanted to know about champagne, satanism, the Stonewall Uprising, chaos theory, LSD, El Nino, true crime and Rosa Parks, then look no further. Josh and Chuck have you covered.
Intentionally Disturbing
Join me on this podcast as I navigate the murky waters of human behavior, current events, and personal anecdotes through in-depth interviews with incredible people—all served with a generous helping of sarcasm and satire. After years as a forensic and clinical psychologist, I offer a unique interview style and a low tolerance for bullshit, quickly steering conversations toward depth and darkness. I honor the seriousness while also appreciating wit. I’m your guide through the twisted labyrinth of the human psyche, armed with dark humor and biting wit.