EHS Digital Solution Evergreening 101: Use Case Compliance Tasks

What is Evergreening? Why is it Important?

Evergreening, as you might imagine, is keeping things fresh. In a digital system, evergreening is the process of updating content in a compliance tool to keep it accurate and useful. When a new digital tool is implemented, the content should not remain static. Master data, such as permit conditions, must be updated to keep the system accurate and useful. This task is typically an administrator or “super user” task to maintain the system rather than normal usage. The process of evergreening applies to all types of content such as regulatory requirements, emission calculations, procedure versions, or waste transporters.

This article will focus on keeping your compliance tasks evergreen, as these are often driven by regulations and permits that are routinely updated, requiring changes in either task language, task frequency, or referenced regulatory citation to keep content evergreen. However, similar principles apply to all types of content.

Evergreening Best Practices

When Should Evergreening Be Done?

Compliance evergreening should start as soon as possible after a renewed or revised permit is issued or after regulatory changes are final. The goal is to have the updated and accurate content in the system as quickly as reasonably possible to minimize risk and the amount of time that the information in the digital system does not match the compliance requirements. It may be worth trying to streamline the evergreening process where possible or to allocate resources to support evergreening. Below we discuss some best practices to optimize evergreening.

Who Should be Involved in Evergreening?

A collaborative effort is key for compliance task evergreening. The following stakeholders should be involved:

• The EHS professional responsible for the site must be involved.
• Operations or maintenance personnel who will be interacting with the finished content in the solution should be involved in a review of the content before it is final.
• External subject matter experts may be contributors, particularly if site-specific resources do not have time to be involved with every step of the process and are instead serving as reviewers.
• Corporate EHS staff may be helpful with evergreening if they support permitting and are familiar with site methods of demonstrating compliance.

To maintain consistency and promote efficiency, it is important to both understand and implement the business rules used for due dates and other content in the system. In addition to understanding the required changes driving regulatory, permit, or site changes, a refresher on the business rules is recommended.

How Should Evergreening be Accomplished? Simple tools to support Evergreening

It may be helpful to use a tool to identify changes in the permit to increase accuracy, to eliminate human errors, and to increase transparency of the evergreening process. This can range from a spreadsheet comparing the data to a technology tool that automates identification of changes. A copy of the comparison can be part of a strong quality assurance review process and a resource if any questions arise later related to how certain permit requirements changed and how those changes were captured.

For efficient reviews a recommended part of the evergreening process is flagging which conditions or requirements have been updated.  Additional review can then be directed to conditions or other content that has been updated. It may be helpful to have specific flags for content that is new, updated, unchanged, or is being deleted as part of the evergreening process. A deleted flag in particular gives a reviewer a chance to consider whether the deletion is accurate. It is much easier for a reviewer to object to a noted change than it is to notice something is missing and comment on it as part of a review.

Evergreening should be performed with a standardized process and quality assurance procedure checklist to ensure consistency. Using a set process can avoid skipping critical steps or spending time on tasks that are not valuable to the process. Reviewers may be new or have months of time between reviews, so a standardized checklist for quality reviews can focus their efforts. Examples of correct content or brief descriptions of business rules can be included as part of the checklist. The checklist should be refined over time as new issues are encountered. Just like the content, quality tools like checklists should be refreshed.

Summary

Evergreening is a critical administrative task to revise and update data in a digital solution. An effective evergreening process supports companies EHS programs. An effective evergreening process includes evergreening as soon as possible, involving all key stakeholders, and structuring the process to increase accuracy, efficiency, and consistency.

This blog has provided a brief discussion of evergreening your EHS compliance tool content.  ALL4’s Digital Solutions Practice has extensive experience helping clients scope, select, implement, maintain, and upgrade various types of digital tools. If you would like to discuss a digital solution for your company, please contact Julie Taccino at jtaccino@all4inc.com or 281-201-1247.