Regulatory enforcement, customer and supply chain audits, and internal risk management initiatives are all driving requirements for managing regulatory obligations. Many companies—especially those that are not large enough for a dedicated team of full-time EHS&S staff—struggle with how to effectively resource their regulatory compliance needs.

The following case study talks about how The C.I. Thornburg Co., Inc. (C.I. Thornburg) is using a technology tool to efficiently meet National Association of Chemical Distributors (NACD) and a number of other regulatory requirements.

The Challenge of Compliance

C.I. Thornburg joined NACD in January 2015. As a condition of membership, the company started the process of developing and implementing Responsible Distribution in April 2015. Responsible Distribution showcases member companies’ commitment to continuous improvement in every business process of chemical distribution—and it requires rigorous management activities to develop and maintain.

With an EHS&S department of one, managing all of those activities was a challenge for C.I. Thornburg. The company was looking for a way to streamline the process and more effectively manage Responsible Distribution requirements and regulatory compliance obligations.

Code & Compliance Elite™

C.I. Thornburg brought on Kestrel to initially help the company achieve Responsible Distribution verification. Kestrel worked with C.I. Thornburg to customize and implement Code & Compliance Elite (CCE™), an easy-to-use technology tool designed to effectively manage management system and verification requirements. Kestrel tailored the CCE™ application specifically for C.I. Thornburg to provide:

• Document management – storage, access, and version control
• Mobile device access
• Regulatory compliance management and compliance obligation calendaring
• Internal audit capabilities
• Corrective and preventive action (CAPA/CPAR) tracking and management
• Task and action management

CCE™ played a large role toward the end of C.I. Thornburg’s Responsible Distribution implementation, particularly with document control and organization, and in the verification audit. During verification, documents could be quickly referenced because of how they are organized in CCE™, making the process very efficient. According to C.I. Thornburg Director of Regulatory Compliance and EHS&S Richard Parks, “The verifier was blown away by how well we were organized and how the tool linked many documents from different regulatory policies.” The company achieved verification in May 2016.

Broadening to Other Regulatory Requirements

CCE™ is still being used to manage Responsible Distribution requirements, but C.I. Thornburg is now working with Kestrel to expand it to all regulatory branches that govern the business. Regulatory requirements function similarly—for example, Responsible Distribution has 13 codes, Department of Homeland Security (DHS) has 18 performance standards (RBPS), and OSHA PSM has 14 elements. All require internal audits and corrective action tracking—things that can be easily and effectively managed through CCE™ to create a one-stop shop for regulatory compliance. Kestrel is currently developing the DHS and PSM modules in CCE™ for C.I. Thornburg.

Valuable Management Tool

CCE™ is providing C.I. Thornburg with a valuable management tool that automates the regulatory landscape. According to Parks, as a small organization that depends on using efficient tools to manage compliance rather than adding more manpower, CCE™ has provided huge cost savings and tremendous value for the organization, including the following:

• CCE™ has become the ultimate tool inefficiency. Tasks that used to take hours to complete are now easily done in just minutes.
• The internal audit function of CCE™ makes audits seamless and tracking and follow-up easy.
• The CAPA tool ensures that the company is managing corrective actions and completing follow-up activities and tasks.
• The functionality of CCE™ allows for managing multiple regulatory dashboards, providing a one-stop shop for managing regulatory compliance obligations.
• CCE™ creates an organized document structure that enables easy access to information and quick response to auditors.
• During Senior Management Review, senior managers see the benefit of being able to reference the history of corrective actions and audits through CCE™.

“A lot of NACD member companies are small organizations that have limited resources to effectively manage all EHS&S needs,” said Parks. “CCE™ really creates the department and is a huge value to small businesses. With the CCE™ technology and a company’s clearly defined goal, Kestrel can provide an efficient solution to most any need.”

Key performance indicator (KPI) is, arguably, one of the biggest buzzwords of the decade. If you want someone’s attention, mention KPIs. According to Investopedia, KPIs are “a set of quantifiable measures that a company or industry uses to gauge or compare performance in terms of meeting their strategic and operational goals.”

For some individual practices—financials, inventory, sales—KPIs are relatively standard. For example, a company may measure revenue growth year after year as a standard KPI. As we bridge into operational practices with varying numbers of employees and levels of risk, however, it can become more difficult to understand not only how to establish KPIs but also where to get the data.

Technology can help to create a pull-to-push methodology that puts site-specific leading KPIs at stakeholders’ fingertips.

Leading vs. Lagging Indicators

In order to understand how to use this pull-to-push methodology to create leading KPIs, it is important to first understand the concept of leading versus lagging indicators.

• Lagging indicators measure and help track how the company is performing in comparison to its goals. Lagging indicators are usually fairly easy to measure—but they can be hard to influence because what they are measuring has already happened or performance data already captured. In this way, lagging indicators are backward-focused. Many standard performance metrics are lagging. In safety, for example, the Recordable Incident Rate is a lagging indicator. Important information to know but hard to change.
• Leading indicators signify the direction performance is going. Because leading indicators come before a trend, they are often seen as business drivers and should be incorporated into the business strategy. The forward-looking nature of leading indicators may make them harder to measure and they may change quickly; however, leading indicators are generally easier to influence. A good example of a leading indicator in determining the most common causes of an incident before it happens to prevent future recurrence, thereby impacting performance.

Pull vs. Push Metrics

That brings us back to the pull-to-push methodology. Or, in essence, digging for metrics versus having KPIs sent directly to the appropriate stakeholders.

With a push approach, metrics are literally “pushed” to end-users, who then extract meaningful insights and take appropriate actions for themselves. Push metrics can have a number of components that trigger when (and who) metrics are sent to, including threshold, capacity, severity, and timing.

Conversely, with a pull approach, data is pulled in order to answer specific business questions. Pull metrics generally require someone with analytical skills to dig deeper into the data to identify the desired metrics.

While pull metrics may be more time consuming to identify and obtain, that doesn’t mean pull metrics aren’t important to have. In fact, organizations often need to pull data in order to create the push metrics that provide for standard KPIs. And push metrics may demand you circle back and pull further information. In reality, the process is cyclical: pull produces what should be pushed; push cycles back to pull in order to dig deeper into the details.

Creating Standard KPIs

How does an organization, then, get to the point of having standard KPIs that can be pushed when needed and that don’t require the time and investment associated with digging for information?

Technology can help to create that pull-to-push methodology for creating standard KPIs. This requires a number of things:

1. The program must be well-established and designed with the operational requirements, capacity, tools, and skills to effectively integrate the program itself and associated data with technology.
2. Assuming a program such as this is developed, initial reports can be pulled to check the program’s effectiveness based on a number of key attributes/metrics. This yields analyzable data.
3. This data should be explored in many different ways. This allows the company to start seeing the interaction between stakeholders and the data and, eventually, creates the “a-ha” moment of understanding as to what metrics are important and meaningful.
4. At this point, it becomes possible to begin comparing data and metrics on a periodic basis, while continuing to pull information from technology. Remembering what queries are effective will aid in establishing initial leading KPIs. This process also will yield improved understanding of how the data gathering process (e.g., incident investigation) needs to be improved and standardized for a more reliable pull of information.
5. This comparison of data should then be used to discover what data is beneficial and what information needs to be more granular to really hone in on the standard KPI.

Walking through this process and leveraging available technology makes it possible to effectively transition from pull methodology to push reporting—putting leading KPIs in the hands of decision-makers and identified stakeholders.

In simplest terms, a “database” is a collection of records. To many, databases are simply a technological representation of linear tasks that provide the benefits of electronic storage, security, time savings, etc. Linear databases basically replicate a standard file folder structure that we are familiar with when working in a program like Windows Explorer. These are all great benefits to any organization.

As our desire and ability to access information has changed, however, the linear database model has its shortcomings.

The Birth of Relational Databases

Databases really began to evolve and provide the ability to extract desired information with the birth of the relational database model, as first proposed by E.F. Codd in 1970.

A relational database stores records according to how they relate to each other, making it multi-dimensional. With a relational database, you can quickly compare information because of the arrangement of data. Using the relationship of similar data increases the speed and versatility of the database.

The benefits of a relational database become very apparent when applied on a larger scale. Take Amazon as a prime example of a relational database. If you were buying socks from Amazon, sorting through a linear file structure to find the pair you want would take an exceedingly long time. There would be folders filled with different options based on size, color, pattern, etc. With a relational database, you are able to search on multiple dimensions and effectively filter your results. Relational databases help the user find what they want and the owner better understands user behavior.

Keeping Up with Operational Tempo

As relational database technology is being applied more and more in every facet of life, the expectation for all software to perform as a relational database is starting to overstep most current business practices and legacy IT systems.

The majority of business applications fall into a linear (i.e., folder, Excel spreadsheet) system because this is easily understood. In essence, these linear systems are an electronic replication of the typical management system three-ring binder. Pertinent information is there but is not easily usable. Unfortunately, systems such as these don’t often align with operational tempo, which, in reality, requires a relational model to create better access and utilization, as well as ease of use.

Case Study: Code &Compliance Elite

Code & Compliance Elite (CCE) is one example of a relational database that Kestrel recently developed and is deploying to help chemical distributors meet and manage Responsible Distribution management system requirements. The Responsible Distribution Codes of Management Practice, compliance programs, and related documents are all housed in CCE to allow for efficient tracking and documentation.

To enable ongoing compliance management, Kestrel also develops and maintains a number of tools tailored to Responsible Distribution in CCE, including:

• Document management – storage, access, and control
• Internal audit
• Corrective and Preventive Action (CPAR/CAPA)
• Task and action management

CCE employs a relational database structure with linear attributes (such as folders), where necessary. Even these folders, however, link to associated documents and owners to connect all applicable parts and procedures without requiring the user to dig through files.

Understanding and being able to evaluate components of an existing management system is key to extracting those pieces that lend themselves to relational use. When companies are able to do this, the end product is an operational management system that integrates technology with operations and meets the operational tempo of the business.

A decade ago, when handheld computers first became popular, storing appointments and contact information on a portable electronic device was a convenient way to avoid lugging around your appointment calendar. Mobile technology has come a long way in the last few years; today’s smartphones are capable of much more.

Many mobile devices are as powerful as a desktop computer. They have processors that handle internet access, photos, voice recordings, and database applications. They allow viewing of documents, reports, presentations, and video files. They integrate cellular technology, digital networks, email, scanners, a world of Bluetooth devices, and global positioning systems (GPS).

As mighty as they may be, mobile devices have not replaced laptop computers because of their limited keyboards, screen sizes, and computing power. But the line between laptops and smartphones has blurred substantially. Mobile technology offers ways to become more efficient and provides more value to company operations and management systems.

Find & Fix

Traditional processes tend to produce traditional results. One cannot expect technological innovation without technological integration. Integration allows companies to stretch and empower every limited resource. The key is identifying those traditional processes that will realize benefit (mostly likely cost or time savings) from technological integration.

Take the business practice of internal auditing for example. The most traditional practice for internal auditing an aspect of a company (e.g., general safe practices, OSHA compliance, OHSAS 18001) is a “find it & fix it” cycle, where the internal inspector goes into a facility and inspects operations as they exist. The inspector typically walks a facility with a notepad and pencil, taking notes of field observations that are not in compliance with the defined protocol.

Following the audit, the inspector creates a report and shares the findings with a responsible party. Sometimes the process of creating a report and communicating findings can take weeks or even months. The cycle is repeated when the inspector comes back to check the site at a later time.

The “find & fix” inspection cycle works—but only to a point.

Same Old Methods: Same Old Problems

The difficult part comes next. What happens to that inspection form or accident investigation report after it is completed? It is likely reviewed by a few people, perhaps transcribed into electronic form by a data entry clerk (where data entry errors may enter the equation), and filed away for legal and compliance reasons, rarely (if ever) to be seen again.

Filing data away in a drawer is better than nothing—it at least shows some documentation of findings— but what happens when the inspector is asked to compile annual data from the findings? And how are trends and patterns evaluated to best allocate resources for improvement initiatives? The paper method of recordkeeping makes compiling field data into a report an enormous task consuming resources and money.

Electronic Data Capture and Reporting

When the inspector captures all field data electronically, the task of generating a report to analyze trends becomes much easier. Mobile technology allows the inspector to capture data electronically—in the field, at the point of discovery—and can eliminate the problems associated with manual data entry and manipulation.

And when data is collected, uploaded, and stored in a database, accessing and reporting on the data becomes as easy as simply requesting the desired information—from questions like, “How many deficient issues were there at the warehouse last year?” to “How many overdue action items does Bruce have in repackaging?”

Reports generated can include photos and reference information, along with field comments. These reports support the inspector’s findings and eliminate many questions about whether a situation is accurately described and/or in violation of the defined protocol. With this information, reports also become a valuable learning tool for employees in the field.

Once uploaded, data are stored in a database for later reference. Assessments continue to be added as inspections are performed and a large bank of data is amassed. That data in electronic format, unlike hand-written notes that are filed away, can be easily arranged for future analysis. Reports can be generated using a large menu of criteria that address specific business needs, such as running statistics on a site over a period time or reviewing instances of a particular violation.

Not only is reporting easier, it can serve more needs:

• Certain reports provide a means of internal communication, enabling transparency and creating clear accountability.
• Automated notifications provide real-time improvements.
• Follow-up actions can be assigned and sent to those who need them.
• Reports on action status can be sent as reminders to each assignee.
• Follow-up reports can show photo evidence from the point of discovery, cite the relevant regulatory reference, and encourage continued improvement.
• Positive observations can be used to provide positive feedback to those employees who have met or exceeded expectations.
• Mining data in different ways can help to identify root causes and end harmful trends so that real improvement can occur.

Value of Good Software

Even with all of the power and functionality that mobile devices offer, they are of limited value without good software. Software applications use the mobile device’s power, synchronize with web and network applications, and use new programming languages.

A number of management efficiencies are realized when auditing/inspection software offers:

• Consistency: Pre-defined answers allow users to answer consistently to like situations, lessening the potential for inconsistent interpretation of the responses from one inspector to the next.
• Standardization: Providing a centrally located database with standard criteria helps ensure that all facilities are on the same page.
• Consensus: On priority rating of inspection findings.
• Tracking: The ability to assign and check status of fixes and corrective/preventive actions helps ensure compliance.
• Analysis: Results can be analyzed for relative importance, statistics, comparisons, patterns, trends, and, ultimately, to identify root causes.

Looking Forward

Our world continues to demand faster response times, constant internet connectivity, and immediate access to information. Technology manufacturers have responded, as we continue to see the emergence of hybrid devices that incorporate laptop computer capability with cellular technology.

The growth of mobile devices has accelerated to the point where they can be a huge asset to company operations:

• Provide electronic data collection
• Integrate data from different types of media
• Offer data management to organize reference materials, inspection protocols, and field data
• Immediately generate reports
• Easily assign and track follow-up actions
• Educate employees and eliminate confusion
• Query and organize data for analysis to discover trends and identify root causes

Ultimately, the goal is to continually improve the company’s overall performance—health & safety, environmental, quality, overall business. Fortunately, technology can enhance traditional business practices, such as the “find & fix it” inspection cycle, to create greater efficiencies and enhanced business value. Integrating technology with current business practices not only allows for continual improvement, it helps create the next level of competitive advantage.