According to the U.S. Bureau of Labor Statistics, more than 5,000 workers are killed on the job every year (a rate of 14 per day), and more than 3.6 million experience a serious job-related injury or illness.

OSHA’s Safe + Sound Week

Strong safety performance is a cornerstone of any business. Safe facilities, work practices, and training help to attract and retain employees and enable them to go home at the end of the shift without workplace injury or concerns.

For many companies, safety can also make the difference in being qualified to work with customers and successfully expand the business. Workers’ compensation rates and the ability to maintain adequate insurance both depend on an organization’s safety performance. On the other end of the spectrum, repeated safety accidents can lead to potential serious penalties and higher insurance rates for failing to comply with OSHA safety requirements.

Every year, OSHA encourages America’s workplaces to commit to workplace safety and health by participating in Safe + Sound Week, which falls August 10-16, 2020. This nationwide event recognizes the successes of workplace safety and health programs and offers information and ideas on how to keep America’s workers safe.

The Importance of Safety Programs

According to OSHA, implementing safety programs can improve businesses’ safety and health performance, save money, and improve competitiveness. Safety and health programs help businesses:

• Prevent workplace injuries and illnesses
• Improve compliance with laws and regulations
• Reduce costs, including significant reductions in workers’ compensation premiums
• Engage workers
• Enhance social responsibility goals
• Increase productivity and enhance overall business operations

Keeping Your Programs in Check

It is important for companies to regularly assess the level of existing OSHA programs against compliance issues and potential accidents. This requires both short- and longer-term actions. These actions should reveal what may need to change in your OSHA compliance programs to ensure their effectiveness. There will likely be a range of results depending on how well the initial programs were developed, implemented, and updated.

KTL recommends taking the following actions to help assess and improve OSHA programs, as needed:

• Develop a review plan. Schedule a meeting with key management and safety and health staff to develop a plan to review all OSHA programs for compliance to the standard. It is not uncommon for internal audits and insurance company audits to be based on confirmation of a compliance policy and not the level of detail required in the implementation of the policy. In the meeting, a complete review of programs should be delegated, including a review of the OSHA standards themselves. This should be based on criteria, including the level of detail, training, and updates and supporting logs/records.
• Review internal and loss prevention reports. This review should consist of the last three years of internal and loss prevention reports, including local fire. The findings of these should be compared against review findings to verify that necessary changes have been implemented.
• Review OSHA reporting and recordkeeping. Again, review should be based on the past three years of historical records. Not only should these records be verified as accurate and complete, but each accident should have resulted in either a documented corrective action of an unsafe situation or the retraining of an employee. This information should be checked, and any additional actions should be made to fully comply.
• Ensure proper closure of issues. Should you have had any past OSHA inspections at your facility(ies) that identified corrective actions, you need to ensure that proper actions were taken to close these issues. Again, it is very important to verify and assemble all related records.
• Conduct multiple physical walkthroughs for all work, personal, and administrative areas for compliance. Update or create a safety inspection checklist for each section, area, and department to confirm that there are no violations in manufacturing, lab, and/or office/administrative areas. Note that one area often missed is the adequate spacing and egress from office cubicles and file rooms.
• Document corrective actions. Your review should help to determine the corrective actions required for your programs to fully comply with OSHA standards and keep employees safe. These corrective actions should result in safety program updates that should be implemented immediately. Any updates need to be announced and included in employee training, which will also need to be scheduled and documented.
• Evaluate results. Concurrently, a qualified safety professional should compare the review findings, your accident statistics, and the top OSHA violations. If there are common links to programs, statistics, and OSHA violations report, an added level of scrutiny should be placed on this area and the resulting program updates.
• Meet requirements. Ensure that all the basic requirements are met and that the company is operating in compliance, including accident/injury records, training records, inspection logs, and a log for all program updates implemented.

Inspection Readiness

When the actions outlined above are done correctly—and on a regular basis—companies can greatly reduce their risk for compliance issues and create a safer work environment for employees. To fully verify safety program changes, a confirming review or audit should be completed within a 30-45-day strict timeframe, and any additional changes or training should be completed immediately. This will also put the company in a much better position for an OSHA inspection should it be required.

Throughout this process, owners and managers need to focus on prevention and on the overall culture of the company in terms of taking the necessary steps to reduce risk and make prevention part of daily operations. Good practice is to examine the workplace broadly, identify and assess hazards, and develop and implement appropriate controls. This helps ensure employees are protected in the workplace and regulatory compliance is achieved.

A wider reaching global supply chain exposes our food—and those companies within the food supply chain—to increased risk. As a result, food companies are operating in an increasingly complex world with changing regulations and requirements that require careful monitoring and review. Like many industries, the global pandemic not only complicates many facets of operations, it has also impacted many regulatory and certification requirements.

The following websites provide excellent resources for companies within the food industry to stay on top of the latest regulatory and certification changes. Our advice? Bookmark these sites, sign up for automated emails, and take advantage of the resources available to companies to help navigate the ongoing changes.

U.S. Department of Agriculture (USDA): Food Safety and Inspection Service (FSIS)

This USDA FSIS Regulations, Directives & Notices site gives users access to the Code of Federal Regulations (CFR)), Federal Register (FR), FSIS Directives, and FSIS Notices. Users can sign up with an email address to receive the latest news from USDA and FSIS. These email updates include recall alerts and FSIS directives and notices. This allows users to be “in the know” instantly and to keep ahead of changing regulations. 

The “AskUSDA” and “AskFSIS” features, located on the USDA FSIS homepage, further allow users to look up common questions or submit any question to USDA or FSIS for answers. These features offer a quick turnaround, with responses provided by specialized USDA/FSIS employees.

• AskFSIS: Find answers or ask questions on inspection-related polices, programs, systems, and procedures.
• AskUSDA: Find answers or ask questions about safe food handling at home or food safety in general.

The USDA’s dedicated COVID-19 site breaks down information by topic area, including food supply chain, to answer frequently asked questions about COVID-19.  

U.S. Food and Drug Administration (FDA)

The FDA’s Food Safety Modernization Act (FSMA) impacts every aspect of the U.S. food system, from farmers to manufacturers to importers. Keeping up with changes to the FSMA rules is vital. Users can sign up for automatic emails from the Center for Food Safety and Applied Nutrition (CFSAN) to receive updates, including regulatory changes and recalls. Users can select settings for what product(s) they would like to receive notifications. 

Users can also research and submit questions related to FSMA to the Technical Assistance Network (TAN). Inquiries are answered by FDA Information Specialists or Subject Matter Experts, based on the complexity of the question. Responses are usually timely, based on the complexity of the question. 

In addition, FDA has a dedicated COVID-19 site. To see the latest COVID-19 information from FDA related to the food industry, select “Food & Beverages” from the drop-down “Topic” menu.

Electronic Code of Federal Regulations (e-CFR)

The e-CRF is a currently updated version of the Code of Federal Regulations (CFR). It allows users to look up all sections of the CFR. CFR is the codification of the general and permanent rules published in the Federal Register by the departments and agencies of the Federal Government produced by the Office of the Federal Register (OFR) and the Government Publishing Office (GPO). 

Regulations.gov

Regulations.gov provides an online resource for users to find, review, and submit comments on federal rules that are open for comment and published in the Federal Register.

Global Food Safety Initiative (GFSI)

The GFSI News & Resources section directs users to articles, publications, videos, and news releases on topics related to GFSI and certification.

Beyond that, as GFSI states on their website, “the pandemic has fundamentally affected the management and assurance of food safety in all retailers and manufacturers, globally. We recognise the COVID-19 outbreak continues to create audit restrictions, which has an impact on the certification status of certain sites.” As such, GFSI has created a COVID-19 site to keep companies abreast of certification requirements in light of changing needs and demands. Users can also enroll to receive the GFSI newsletter to stay updated on the latest updates from GFSI.

For resources related to each of the GFSI-benchmarked standards, users can visit the following sites:

• BRCGS
• FSSC22000
• IFS
• SQF

Managing Requirements

There are many great resources available to stay current on the latest regulatory changes and requirements. However, just knowing the requirements is not enough—companies need to be able to manage them to ensure compliance.

Technology-enabled business solutions can help simplify this task. Compliance efficiency tools and document management systems allow companies to:

• Maintain standards, programs, and regulatory requirements in one place
• Outline a plan for meeting each requirement
• Create alignment and consistency between different standards and requirements
• Update requirements as regulations—or company operations—change
• Provide a compliance calendar and tracking to manage and monitor compliance activities

Technology solutions can be instrumental in establishing or improving a company’s capability to efficiently and effectively manage compliance and business processes.  

Over the past several months, many companies have had to prioritize business activities given restrictions on travel and social distancing guidelines. Despite these restrictions, however, certain compliance activities are still required, including training.

Training is a key component for maintaining ongoing compliance—whether with regulatory requirements, supply chain mandates, or internal policies. While some training can be postponed, putting training on the backburner can have its consequences, ranging from unprepared employees, to noncompliance, to preventable injuries or worse.

Much like with audits, there are alternatives to meeting training requirements and ensuring employees are well-instructed and prepared to do their jobs, even with current government and/or company restrictions. Online and virtual training are not necessarily new options, but their popularity is most certainly on the rise. In-person, online, and virtual training can all provide quality options if you understand your training needs and understand what type of training works best in different scenarios.

Face-to-Face

As we have experienced, sometimes there is no substitute for doing things face-to-face. For certain types of training, in-person is clearly the best alternative for a number of reasons:

• It is designed for people who need to genuinely know the material inside and out and for those who would benefit from a more tailored, interactive learning experience.
• With in-person training, learners are able to ask specific questions and get them answered immediately.
• In-person training provides a focused, immersive learning experience, where attendees can have interaction, discussion, and live input.
• Trainers get to know attendees and can adjust training (e.g., material, learning speed, examples) to the group’s learning style.
• In-person training allows attendees to develop relationships with the trainer and other attendees, which can prove beneficial on future projects.

As many organizations have discovered, particularly lately, while in-person training may offer a great alternative, it is not always possible. Beyond travel and social distancing restrictions, in-person training can also be cost-prohibitive. In addition, scheduling of in-person training can present more challenges, as timing is based on the instructor and is not flexible.

Best suited for: Multi-day classes where demonstration of competency is needed, and participants are building skills they will use frequently; introductory classes where participants need to understand new material.

The Online Option

At the other end of the spectrum, we have online training (not to be confused with virtual, which is discussed below). Online training involves an online module that allows participants to watch and/or listen to a pre-recorded class. Generally speaking, online training works best when individuals already know the material (e.g., refresher training) and is most appropriate when the attendee does not have to be an expert in the subject matter (i.e., awareness level vs. functional expertise).

In addition, online training is generally cheaper since it is not customized and does not require travel or an onsite trainer. It can also be faster and more flexible, as attendees can work at their own pace and have the ability to pick their own schedule.

While there are certain benefits to online training, it is not suitable for all types of training. Because online training does not involve a live instructor, attendees are generally unable to ask questions effectively and there is little opportunity for follow-up input on areas covered. This is no opportunity for hands-on learning and interaction. For example, something like 24-hour HAZWOPER training would be difficult to do as an online course, as a hands-on component is valuable in helping participants demonstrate competency, as required. Finally, because of a potentially diverse audience, online training tends to be generic and not tailored to the specific needs.

Best suited for: Courses where participants have had many, many years of experience and just need refreshers, such as HAZWOPER 8-hour, DOT General Awareness, or RCRA refresher training.

Taking It Virtual

Finally, virtual training provides a bridge between online and in-person training. Like online training, virtual training is done via technology (e.g., Zoom, WebEx); however, it takes place live with instructors engaged in the training as it is occurring. Virtual has many of the same advantages as in-person training since it is being done live. Learners can get more in-depth training and benefit from live interaction, questions, and discussion to help develop specialized expertise. Virtual training works best when travel is limited but students still need to have real-time input from the instructor.

That being said, virtual training cannot completely replace in-person training. With screens, it may be difficult for the trainer to read the crowd and accurately interpret learning needs. Hands-on opportunities become more limited—though not impossible—and require cooperation, coordination, and open-mindedness from all attendees. Finally, technology and logistics are critical for this type of training. A computer with good internet access is critical. If internet connections are slow or sound quality is poor, training can quickly become ineffective.

Best suited for: Refresher training (as with online options), more detailed training that can be customized to the specifics of the class (i.e., site-specific, industry-specific), or training for those with less experience who may need to ask questions.

Consider Learning Styles

People learn very differently. Some people are aural learners and can hear material and develop understanding. Others are visual learners so just reading material on a screen “sticks.” Others are tactile learners and need to participate in physical interaction to understand content. It is important to keep this in mind when choosing the best platform, as well:

• With in-person classes, all learner types can be addressed. 
• With online classes, typically only visual learners retain the information unless there is audible training coordinated with the material. 
• With virtual learning and coordination with the site prior to the training program, all three learner types can be addressed. 

While some training can be rescheduled with minimal impacts to the business, many training requirements cannot. Companies need to know their workers are retaining the information, particularly given OSHA requirements that employees must demonstrate understanding and competency. To ensure that training not only “checks the box” but is also effective, it is important to evaluate not just the training, but the delivery options. In-person, online, and virtual all have their strengths based on the training needs and individual learning styles.

Checklists are a common way to collect information. From inspections and maintenance checks to near-miss and behavior-based safety reporting, most companies regularly use some form of checklist to gather information that should help inform operational decisions. Checklists are important. They establish good employee practices for regularly reviewing operational areas. But the information gathered in checklists only adds value to the organization if the data collected is used.

What happens to your checklists once they are filled out? Are they submitted? Is the data reviewed? And importantly, how are you leveraging the data gathered to better understand and improve your organization

Gathering Data

There are dozens of options available for gathering data through checklists. Paper checklists are largely becoming a thing of the past—and for good reason. Mobile forms and technology (e.g., Microsoft Forms, Google Forms) make completing checklists of almost any type easier and faster in the field. Mobile forms allow employees to quickly and easily complete forms from a mobile device—without logging in—from daily inspections to near-miss information as it is happening. Any daily, weekly, monthly form/checklist can be turned into a mobile form (e.g., Powered Industrial Truck inspection checklists, monthly tank inspection checklists, incident reports, non-conformance reports). Questions can be multiple choice, yes/no, text, numerical, rating scales, and several others.

Storing Data

Not only is completing an electronic form easy for employees, one of the largest benefits of gathering data via a mobile checklist is that the resulting data is already in digital format—and much more usable than a binder filled with paper checklists.

Checklists can be designed to move the data gathered from the form directly into a database, such as Microsoft SharePoint or a SQL database. Digital data from all electronic forms can then be stored in a centralized system; categorized for searchability; and easily accessed for review, comparison, and analysis.

Displaying Data

With all data that is collected being stored in a central database, it then becomes possible to leverage and manipulate that data to graphically display high-level information on a dashboard through the use of technology like Microsoft Power BI. Google dashboards offer another user-friendly alternative for analyzing the resulting data. Dashboards serve as a user interface to display/highlight key information. When companies amass a lot of data in many different areas, the dashboard can provide an integrated view of data pulled from multiple checklists/modules in an easy-to-read display. Dashboards such as this:

• Provide greater visibility and alert to issues that need attention/resolution across the entire organization.

• Allow management to view outstanding issues under their responsibility.

• Display up-to-date graphics of how the organization is performing compared to goals.

• Generate graphs and charts from the data collected based on what information needs to be reported.

• Allow for the use of advanced data analytics to help identify patterns and trends, inform business decisions, and guide resources.

Many companies have a lot of great data at their fingertips but knowing to how access and leverage it can be a challenge. Checklists and forms provide a relatively simple and straightforward method for gathering electronic data and turning it into valuable information that can improve operations and help inform business decision-making.

KTL is pleased to announce that we have renewed our agreement with the Construction Engineering Research Laboratory (CERL) of the U.S. Army Corp of Engineers, which provides access to the following regulatory question modules:

• The Environmental Assessment and Management (TEAM) Guide and the related state supplements address environmental compliance in the areas of air quality, cultural and natural resources, hazardous materials and waste, pesticide management, pollution prevention, energy conservation, petroleum, oils and lubricants, storage tanks, solid waste management, toxic substances, water quality, and more.
• The Occupational Safety and Health (OSH) Guide is used in assessing compliance with the standards of the Occupational Safety and Health Administration (OSHA). It may also be used in combination with an agency-specific safety and occupational health manual. The OSH Guide is based on OSHA regulations from Title 29 of the Code of Federal Regulations.

KTL originally entered into this agreement with CERL in 2015. CERL’s experts are dedicated to conducting ongoing research, updating federal and state environmental and federal safety regulatory requirements, and developing and maintaining standardized audit checklists for those regulations. These checklists are very comprehensive; are used by auditors for DOD, DOE, DOI, and other federal agencies; are updated regularly to reflect any regulatory changes; and cover virtually all of the functions that would be present in a broad mix of industrial companies.

Our agreement allows KTL to make the TEAM Guide and OSH Guide available through an electronic format (i.e. dynaQ™). KTL staff can use these modules to stay current on changing federal regulations. The question modules bring a basis of significant credibility related to the reliability and completeness of audit content via a software tool that manages audit data and makes finding information more efficient. With this agreement, KTL remains one of the only professional service firms in the country to offer access to the following regulatory question modules.

Get to know our KTL team! This month, we are catching up with Senior Consultant and Partner Roberto Bellavia. Roberto has been with KTL for three and a half years and is based in the Chicagoland area.

Tell us a little bit about your background—what are your areas of expertise?

I was born and raised in Rome, Italy. I have a master’s degree in animal production science and started my career in Italy working on the farming side of the food supply chain. I was working with farmers that had small manufacturing operations for cheese, salami, meat, and I was doing food safety (HACCP) plans for them. I also worked in a couple of dairy farms.

I first came to the U.S. in 1999 for a genetic research project at the University of Minnesota on mapping of chromosome 29 in bovine. I moved to the U.S. permanently in 2001, when I got married. I worked at the Italian Chamber of Commerce, made connections, and started working for Turano Pastry Shop as Production Manager. I learned Spanish before I learned English! I wanted to move back into the meat industry, so I began working at Chiappetti Lamb and Veal in the Stockyards District in Chicago, the last federal-inspected plant in the city. When they closed, I moved to U.S. Foods as the Director of Food Safety for the Stockyards brand.

I joined the consulting world at KTL in January 2017. My areas of expertise revolve around food safety, quality, and regulatory compliance. I am well-versed on all the GFSI schemes (i.e., FSSC22000, SQF, BRC, IFS) and the USDA – FSIS and FDA requirements. In this role, I really enjoy working with different people. There is no reporting structure in my team; rather, it is about people working together to achieve the same objectives. I am in the business of food safety. I believe that people always want to do the right thing, but sometimes they need someone to tell them what the right thing is or to show them how to get there.

What types of clients do you work with? What are the biggest issues you see them facing right now?

All my clients are in the food supply chain—from food manufacturing, to food additives and food packaging, to distributors and importers. I also work with a company in the dietary supplement arena, which is an area with growing food safety requirements.

 Data management is one of the biggest challenges facing my clients right now. How do you collect and use data, while also protecting information? Every company needs to fulfill someone else’s requirements (e.g., regulatory, standards, customers, supply chain) by submitting information, auditing, reviewing, and assessing and allocating levels of risk. Our clients look to KTL to help them meet those needs.

Training and culture change are two other large areas where food companies rely on KTL’s expertise. When a company decides to pursue a major change in their food safety program, they also need help in culture change and much of that starts with training.

Lastly, the new rules of the FDA – FSMA have been a challenge, including implementing allergen control, environmental, and food defense/intentional adulteration programs.

What would you say is a highlight of your job?

I get to be 100% involved in what I do. I always seek the highest results and take pride in everything I do. It is important to me to show my clients the value they get from working with KTL, and what we have accomplished once our project is done. We are currently focusing a lot of our expertise on data management and predictive analytics, developing dashboards that allow our clients to see in real time the performance of the food safety programs we are developing. It is very satisfying to see those results.

What do you like to do in your free time?

My free time is about my wife, my three kids, and my dog. When I don’t work, I enjoy spending time home. I like to coach soccer and have been a coach for over eight years. I enjoy a home-cooked meal (because I travel and eat out a lot), spending time at the beach (but that never seems to happen), and playing cornhole (a/k/a bean bags). I also like motorsports, so when I can (and when COVID is not cancelling half of the season), I enjoy watching Formula 1 racing (there is something about technology, courage, and teamwork that is fascinating) and European football (a/k/a soccer).

Finally, I enjoy road tripping with the family—or just driving alone—and discovering and seeing something new. I have been in three different Portlands in the U.S.! I feel that every place I go, no matter how remote or rural it is, has something interesting for me to see.

Read Roberto’s full bio.

The second annual World Food Safety Day (WFSD) returns on June 7, 2020 under the theme “Food safety, everyone’s business.”

WFSD was originally declared by the United Nations on June 7, 2019, to draw global attention and inspire action to help prevent, detect and manage foodborne risks, contributing to food security, human health, economic prosperity, agriculture, market access, tourism and sustainable development. 

This year’s celebration focuses on food safety being a shared responsibility—from farm to table—including governments, to producers, to consumers.

A wider reaching global supply chain exposes our food and those companies within the food supply chain to increased risk. KTL is committed to supporting companies in our increasingly complex world with effectively operating across the food supply chain, while managing food safety and quality risks.  

Both the U.S. Food and Drug Administration (FDA) and World Health Organization (WHO) offer a number of resources for companies and individuals to participate in World Food Safety Day and help reduce food safety risks.

The COVID-19 pandemic has had tremendous impacts on various industries and sectors—most have had to adjust business practices (in small or large ways) to meet new guidelines for safe operations. At times, it may seem impossible to keep up with the latest developments/recommendations and their impacts on day-to-day operations.

A cross-cutting issue for almost every business (and every household) is the safe and proper management of waste. Almost all our activities generate some form of waste. During an infectious disease outbreak such as COVID-19, it becomes increasingly important to ensure the provision of safe water, sanitation, and hygienic conditions to help prevent human-to-human transmission of the virus.

Updated Guidance

State and federal agencies throughout the U.S. and abroad, as well as international organizations, have begun to issue new and/or update existing guidance regarding proper waste management practices as experts learn more about the COVID-19 virus (SARS-CoV-2). The U.S. Occupational Safety and Health Administration (OSHA), for example, recently issued guidance stating that, “Generally, management of waste that is suspected or known to contain or be contaminated with COVID-19 does not require special precautions beyond those already used to protect workers from the hazards they encounter during their routine job tasks in solid waste and wastewater management.” However, state, tribal, and local governments may follow stricter guidance.

Similarly, the World Health Organization (WHO), in its April 2020 revised Interim Guidance, noted that there is “no evidence that direct, unprotected human contact during the handling of healthcare waste has resulted in the transmission of the COVID-19 virus.” The WHO further states that the usual best practices for the safe management of infectious waste should be exercised.

Best Practices to Minimize Risk

The OSHA and WHO guidance highlight an important point—where existing processes and systems can safely be relied upon for the proper management of waste during this pandemic, organizations should avoid making changes. Where the nature of COVID-19 requires adjustments, that is where organizations should focus their efforts.

Outlined below are some general best practices that organizations should consider implementing to minimize risks associated with waste management during COVID-19 and beyond:

• Municipal Waste: Workers and employers should manage municipal (e.g., household, business) solid waste with potential or known COVID-19 contamination like any other non-contaminated municipal waste. Workers should prevent exposure to waste through safe work practices and approved Personal Protective Equipment (PPE), such as puncture-resistant gloves and face and eye protection. To help protect sanitation workers, the Idaho Department of Environmental Quality (DEQ) advises households with waste suspected to be infected with COVID-19 tightly enclose waste in heavy-duty bags, double-bag the waste, and ensure that curbside containers can close completely. As always, anyone handling waste should wash hands thoroughly.
• Healthcare Waste: Healthcare waste with potential or known COVID-19 contamination should be managed like any other regulated medical waste. In the U.S., COVID-19 is not a Category A infectious substance. Again, use typical engineering and administrative controls, safe work practices, and PPE to prevent worker exposure. Although not required, the Healthcare Waste Institute (HWI) recommends COVID-19 waste be identified to protect workers in the event a bag needs to be re-opened. Only grossly contaminated PPE should be placed into sealed bags (red bags in the U.S.). Tissues or similar materials used by patients when coughing or sneezing should be immediately disposed of in a lined waste receptacle, and then correct hand hygiene should be performed. Such waste may be disposed as regular trash (i.e., municipal solid waste), unless otherwise directed by local health departments. Public Health England, for example, advises that such waste be double-bagged, tied securely, stored separately from other waste, and left for 72 hours before sending for disposal as standard municipal solid waste.
• Recycling: As with municipal waste, employers and workers in the recycling industry should continue to use typical engineering and administrative controls, safe work practices, and PPE to prevent exposure to recyclable materials they manage, including any contaminants in the materials. Organizations and households should always refer to their local recycling hauler’s guidelines to determine if and what products can be recycled. The U.S. Environmental Protection Agency (EPA) is advising individuals to treat recyclables as trash if anyone in their home has COVID-19.
• Wastewater: Coronaviruses are susceptible to the same disinfection conditions as other viruses, so current disinfection processes in wastewater treatment facilities are expected to be sufficient, per OSHA and the Centers for Disease Control and Prevention (CDC). This includes practices such as oxidation with hypochlorite (i.e., chlorine bleach) and peracetic acid, as well as inactivation using ultraviolet irradiation. There is no evidence to suggest that additional, COVID-19-specific protections are needed for employees involved in wastewater treatment operations.
• General Hygiene and PPE: As currently recommended by all agencies, improved personal hygiene, particularly adequate handwashing and the use of adequate PPE (e.g., masks, gloves, eye protection), offers the greatest protection against COVID-19, including transmission through waste. Staff handling waste should be properly trained, use approved PPE, and maintain good hygiene.

As with many facets of this pandemic, regulatory requirements and best practices are subject to change as we continue to learn about the virus and its transmission. KTL can help you monitor these developments and understand which requirements and guidance apply to your operations—both in the U.S. and abroad.

Audits provide an essential tool for improving and verifying compliance performance. Audits may be used to capture regulatory compliance status, management system conformance, adequacy of internal controls, potential risks, and best practices.

Most regulations, standards, and guidance require audits to be conducted with some established frequency. For many companies, figuring out how to meet these audit requirements amongst travel restrictions, new company safety protocol, and government quarantines related to COVID-19 presents a significant new challenge.

The Online Alternative

Companies come in a variety of sizes with a range of different needs. Because of this, auditing standards remain fairly flexible by design. Fortunately, this allows for online/remote/virtual audits as a viable alternative to onsite audits—provided the audits:

• Are planned well;
• Appropriately leverage technology; and
• Are executed by a team who understands the facility and the requirements.

The ultimate objective of a virtual audit remains the same as an in-person audit: To obtain credible audit evidence to accurately assess compliance/conformance with identified requirements/specifications. The difference lies in the means in which that evidence is collected (i.e., live stream video, surveillance cameras, group web meetings, electronic document review).

Weighing Risks vs. Rewards

Audits can be conducted onsite, remotely, or a combination of the two. In many cases, companies may already be having portions of the audit (e.g., document review) done remotely. Moving the entire audit to the virtual world allows credible evidence to be obtained in unique ways that can offer significant benefits to a company when onsite audits aren’t possible—and even when they are:

• Reduced cost – Online audits eliminate the expenses associated with travel (i.e., mileage, flights, hotels, meals), which can add up depending on the location and duration of the audit.
• Flexible schedule – Remote audits can be conducted on a more flexible time schedule. Auditors do not have to complete work onsite in a set number of days, as is required when traveling to a facility. The auditor can also review areas in question remotely after the audit is technically over. Note that a more flexible time schedule does not necessarily mean less time involved to conduct the audit.
• Social distancing – As CDC guidelines have recommended, it is currently safest to work remotely, when possible, or to remain six feet of social distance to avoid potential transmission of COVID-19. Through the use of technology, virtual audits provide a social distancing extreme.
• Improved systems – Preparing for a virtual audit provides the “push” some organizations need to improve electronic storage systems. To conduct a virtual audit, documents and records must be retained in an organized manner that facilitates easy/quick access. Being able to access all documents remotely is necessary—paper records or documents stored on individual computers/network drives no longer cut it.

At the same time, there are some potential risks to conducting a completely virtual audit, particularly since this practice is relatively new to many organizations:

• Observation/technology limits – Observation of site conditions is limited by the ability to direct live stream video remotely. Technology can create limitations. If the camera can’t see it, neither can the auditor. Poor video quality can impede visual clarity. You don’t know what you don’t know.
• Communication confusion – It can be difficult to read body language and/or interpret emails and phone conversations to make sure communication is clear. This can require revisiting topics/findings several times to ensure accurate evidence is collected.
• Time barriers – There may be time zone and associated scheduling barriers depending on the location of the auditor and the facility.

Considerations and Best Practices

Regardless of the type of audit a facility conducts (i.e., remote, onsite, combination), standard audit best practices should be followed to ensure that audit results are comprehensive and credible. If the company opts for a virtual audit—for any reason—there are a number of considerations and best practices to ensure that the audit effectively fulfills its objectives and alleviates the risks outlined above to the extent possible:

• Site Familiarity – Virtual audits work best if auditors are familiar with the industry and/or operations. While it is not necessary for the auditor to have visited the site before, that type of familiarity with the facility provides the best-case scenario, especially for compliance audits, as it prepares the auditor to know what to look for (and where) and what questions to ask.
• Careful Planning – Much like onsite audits, virtual audits require careful upfront planning on the part of the auditor and the facility—and perhaps to an elevated degree.
  • The facility needs to collect all documents and records prior to the audit and determine best way to present that information remotely (e.g., email/transfer ahead of time, allow access to company Intranet/shared directory space, share during a web meeting).
  • Interviews are best scheduled in advance to ensure availability; however, they can be conducted on an ad hoc basis as need arises.
  • It is best to plot out route and areas of specific focus for the audit ahead of time using a site map as a guide to ensure that all areas are covered and that the audit can be conducted as efficiently as possible using the allocated facility resources. An audit site guide must be assigned who is familiar with the entire facility.
  • Technology needs and requirements must be evaluated, and logistics and access should be tested prior to the audit. It is vital that all cameras, web meetings, shared document space, WiFi, and other technology is working appropriately prior to the audit or a lot of time can be wasted troubleshooting issues.
• Video – Videos should be live. Site walks should be led by a site guide/employee along the planned route with smart phones, iPads, etc., with live streaming capabilities. It is important to ensure that live streaming works within the facility being audited so auditors have a clear view of site conditions. Auditors can also take advantage of any in-house surveillance cameras (e.g., security or quality systems) to provide additional footage of operations, when necessary. In most cases, surveillance footage cannot replace live video.
• Web Meetings – Opening, closing, and daily briefings can be conducted via web meeting. Remote audits provide the flexibility to conduct the audit in segments, with briefings following each segment. This allows the auditor to review video footage, evaluate records, and generate questions to ensure the information collected is accurate and complete.

Companies all over the world are working through a transition period right now, where they are trying to establish what a new “normal” looks like when it comes to operating practices, employee health and safety, business continuity, and compliance. Audits are one piece of the overall puzzle that can be transitioned somewhat seamlessly with the right planning and technology in place to ensure ongoing compliance.

How many permits does your operating system (e.g., facilities, production, storage, transportation, distribution) have? What kinds of requirements are associated with each of those permits? Who is responsible for making sure requirements are fulfilled? Are there key/critical dates? How many contractors/vendors do you have carrying out activities pertaining to the many diverse permit requirements? How do you manage all that information? And, importantly, how do you verify compliance?

Depending on the breadth and locations of your operations, managing permits and their associated requirements and due dates without a centralized system in place can be an insurmountable challenge. This was certainly true for a large transportation company managing over 3,600 permits for over 1,600 projects across more than 20 states. Finding a better way to track and manage permits wasn’t just a matter of convenience, it was a necessity.

Web-based Tracking System

After a series of washout incidents, the company’s Engineering Department stepped up its efforts to develop a program to ensure engineering and maintenance activities were meeting applicable construction and environmental permit requirements. With so many activities, responsible parties, and deadlines, the Department retained Kestrel Tellevate LLC (KTL) to develop a web-based project tracking system to help:

• Track permit requirements and construction restriction timeframes
• Produce project-specific All Permits Issued (API) documents
• Track post-activity mitigation requirements
• Manage change information
• Report actual-to-budget performance

While the Engineering Department remains responsible for the permitting activities associated with all construction, maintenance, and emergency response activities, KTL’s Permit Tracking System (PTS) offers a cloud-based project management solution to facilitate permit tracking across a variety of data points.

How It Works

The PTS serves as a communication conduit by providing a standardized approach to project/permit activity tracking, while distributing periodic, tailored reports that allow the Engineering Department to manage project activities, as needed. Integrating with internal databases, PTS provides a means to supplement project data with ongoing contractor/consultant input. This enables comprehensive program oversight on the timeliness of the permitting effort and project details, which, in turn, offers preemptive visibility on issues that may affect project construction and permit compliance.

In short, PTS allows the company to:

• Catalog and track permits in one database
• Document and track project conditions, impacts, construction timeframe restrictions, sensitive resources, etc.
• Send and receive notifications of permits about to expire
• Coordinate and communicate with project contractors
• Establish accountability and a standardized approach for reporting and performance measurement
• Effectively manage project process from permitting through handover to construction
• Monitor financial performance

Business Benefits

The Engineering Department has managed nearly 1,600 projects with more than 3,600 associated permits through PTS. Permits in the system include 404 (most common), 401, Floodplain, NESHAPS, FAA, 402, Air, Coast, Air Emissions, 408 Levee, Coast Guard Bridge, Heritage Tree, Tank, Well, Excavated Materials, NPDES, and others.

With this many projects and permits being managed through a consolidated system, PTS is providing many business benefits, including the following:

• Improved program efficiency, consistency, and coherence by fostering a standardized approach to all permitting data management and input by third-party users
• Customized, automated reporting that allows for enhanced progress monitoring, project accountability, and detailed oversight
• Flexible, cloud-based approach to accommodate a variety of program management aspects into a single tool for real-time, comprehensive visibility
• Sole repository for all project management data to help foster communication and coordination both internally and with contractors/consultants
• Improved permit compliance assurance reliability