Adopting Digital Solutions is Becoming Imperative for Meeting Market and Regulator Expectations

Expectations both internally and externally (public, regulatory agencies) are continually increasing around availability, quality, and transparency of environmental and health and safety (EHS) data. An emerging trend is a focus on auditability with some very stringent interpretations of this requirement appearing in recently approved regulations.  

In 2024 and beyond, there will be more need and opportunity to leverage digital solutions to tackle ever-increasing demand for more auditability of compliance data, and in particular air emissions data. Implementing digital solutions will support these objectives.  Take for example the New Mexico Ozone Precursor Rule: all records required by the rule must be 1) stored in a data system, 2) available to the agency in a report within three days of request, and 3) imported into the data system within three days of data collection or report finalization.  Further, they are requiring inputs and methodologies for calculating emissions to be included in the reports.  Requiring this level of accessibility to all compliance monitoring, recordkeeping and reporting is unprecedented and likely a harbinger of what is to come in other regulations. Another imminent opportunity for management of more data than ever before will be upcoming additional requirements under U.S. EPA’s Air Emissions Reporting Requirements (AERR) Rule. U.S. EPA proposed to add reporting requirements for hazardous air pollutants (HAPs) emitted over certain thresholds (many of which are very low) for thousands of facilities in various sectors. Essentially, facilities will need to use best available methods to quantify and report HAP emissions from all temporary, mobile, and stationary sources onsite to U.S. EPA electronically. 

Not all operations will encounter the level of requirements in the New Mexico rule, but when this regulatory trend is combined with growing pressures around ESG reporting and Net Zero initiatives, most operations should be considering going digital.  Digital solutions can be scaled to the current set of requirements and matured when/if requirements become more stringent.  Even if you outgrow the functionality of your current system, it is easier to move from one digital solution to another than it is to go from spreadsheets, paper forms, and other such tools to your first digital tool.  For those considering the move into a digital system for data management we’ve outlined some tiers of support to help identify what might be a match to your current needs. 

Option 1:  Facility Level Deployments of Digital Solutions 

If consulting support is a key part of your current approach, then the most straightforward path to implementing a digital solution will be to enhance your consulting support with an embedded digital solution offering.  This can look like having your consultant stand up a digital solution to support your facility level air emissions calculations.  Like with any engagement, there are tiers of support levels.  At the most basic level, you just get the outputs from the system, but the digital solution is there if you get agency requests that require an audit of the solution.  Alternatively, you can be provided with access to the system for adding data, running reports, etc.   

• The benefit of this approach is it allows you the power of a digital solution without the IT headache of owning and maintaining software.   
• The downside is you typically have fewer options to tailor the solution to your needs and have less (sometimes much less) access.  

Option 2:  Leveraging Operations Systems, Data Lakes, and PowerBI 

If the bulk of your required data exists in operational systems and the EHS-specific business logic is minimal, then using Data Lakes and a BI reporting tool to pull all the required data together and enhance it with simple calculated values might be the way to go.  A good example of the kind of operation where this would work is an upstream oil and gas (O&G) field that is dominated by unpermitted well pads.  In this type of operation, the majority of the data required for tracking air compliance, including calculating emissions, is stored in operational systems such as the asset management and work order system.   In the case of a relatively mature data lake system, this can be the most efficient place to store all the air quality (AQ) compliance recordkeeping and emissions data.     

• The benefit of this approach is it does not introduce the complexity of mirroring your complex and voluminous facility and asset hierarchy in your EMIS tool. 
• The downside is you must architect the whole solution and make sure that basic features included in all EMIS such as data audit tracking are considered and addressed in your solution. 

 Option 3:  Low-Configuration EMIS Solution 

The degree of configurability supported in EMIS solutions is on a continuum. The move to cloud-based software as a service (SAAS) offerings has supported the emergence of several vendors that are focused on a higher degree of standardization. Standardization supports quicker implementations, ease of upgrade, and less required decision making.  These solutions are a great fit for organizations that are willing to be flexible and have strong change management programs or are standing up a new business process and willing to conform to the solution. 

• The benefit of this approach is ease of implementation and solution maintenance. 
• The downside is you have to adjust your business process to match the solution or risk building many undesirable workarounds or low user adoption because it doesn’t fully support requirements. 

Option 4: Highly-Tailored EMIS Solution 

On the other end of the continuum are the solutions that support a high degree of configuration and even limited customization.  These are a great fit for organizations that are heavily regulated, resulting in requirements that are not supported with typical best practice implementations, or have an existing business process that they want to keep.   

• The benefit of this approach is having a solution that can scale to the complexities of your organization. 
• The downside is higher effort and cost to design, implement and maintain the highly tailored solution. 

Conclusion

It will be increasingly difficult to manage data, document data quality, maintain compliance, and meet investor expectations without adopting digital solutions to support your EHS business processes. The market has diversified, and a variety of approaches to implement these solutions exist.  ALL4 can help you select a strategy that is aligned with your requirements. For more information about how ALL4 can help you understand your options for a new or updated digital solution, contact Linsey DeBell at ldebell@all4inc.com or (970) 217-7436.