Empower EHS&S Performance with Simple Tasks that Matter


Huco Consulting Feb. 10, 2021

EHS&S performance is now integral to companies’ long-term value.

The demand for businesses to demonstrate commendable EHS&S track record has never been higher, but many companies are struggling to achieve consistent regulatory compliance or make steady progress towards performance goals. In this article, we share how we work with clients to unlock reliable EHS&S results and build a stronger company by empowering frontline staff with simple tasks that matter.  

Relegating EHS&S to the specialists’ sphere of control limits what is possible. 

As regulators adapt to evolving policy priorities and broad stakeholder group(investors, media, suppliersconsumers, etc.) demand increased transparency into corporate environmental and social conductit has become abundantly clear that EHS&S performance is now integral to long-term corporate healthrisk management and value-creation across industries. So why is the responsibility for EHS&S activities still relegated to an isolated, specialized corner of organizations’ management and operations? 

Activating enduring EHS&S success requires unleashing ownership of organizational performance from the specialists’ sphere of control. While EHS experts track compliance, they do not control itand their time is too valuable to provide daily oversight for consistent performance on the ground. Placing the burden of responsibility for EHS&S activities exclusively on this small group of specialists not only results in process bottlenecks, inconsistent performance and a high cost to comply, it can also undermine an organization’s capacity to manage risk or set and achieve ambitious performance goals. It limits what is possible and leaves companies vulnerable to falling short of requirements and stakeholder expectations.

Industry leaders will mobilize their entire organization under a shared vision of EHS&S success.

Reliable risk management and steady progress towards EHS&S initiatives is a team effort and a daily process on the frontlines of a facility. In the new EHS&S landscape, industry leaders will be those who unite their organizations under a shared vision of success and mobilize their team with a clearmanageable plan to achieve it. With robust, reliable compliance plans in place, these organizations will free time and resources to pursue improvements, value creation or whatever the next frontier may be. 

Ultimate success, however, will depend on how companies break out of the EHS bottleneck and equip staff to drive consistent performanceNavigating this critical transition will require more than simply purchasing the latest EHS&S management software – there is a final, crucial step that must be taken.

Break out of the EHS bottleneck and empower your staff with simple tasks that matter. 

At Hucowe help companies achieve full team ownership of EHS&S performance by empowering staff with simple tasks that matterEHS&S software platforms are potent tools, and we work closely with clients to select and implement systems that fit their operations and objectives. But software tools are only as powerful as the content they contain – and breaking out of the EHS bottleneck is only possible when staff in control of EHS&S activities have access to clear information for achieving consistent performance on the ground. This is the last critical mile that must be completed for EHS&S success. 

We developed our HuComply Methodology to ensure our clients have the actionable content they need to take this final step, get the most out of their EHS systems and perform at their best. While regulatory content providers and AI solutions stop at identifying relevant content and isolated requirements, HuComply leverages our best-in-class task template library to organizeconsolidate and translate complex regulatory requirements into clear, meaningful compliance tasks for frontline workers in one streamlined process. Tasks are written in plain language, are fit for use by anyone at the facility and are ready to load into any EHS system and unleash teams’ full potential. That is the last critical mile – covered. 

Complete the last critical mile.  

The landscape of EHS&S has changed, but the opportunity to succeed there is already within reach. The only questions are: what do you want to achieve and how will you empower your team to get there? 

Learn more about how Huco can help you empower robust EHS&S performance with simple tasks that matter on our website, or contact us at info@hucoinc.com or +1 (844) 438-4826.  

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Simple Strategies for Managing Missing Emissions Data


Huco Consulting January 11, 2021

What do you do when you find you are missing data for an EI/GHG report that is due around the corner?

This blog reviews this common scenario and how to deal with it. Read about Huco’s best practices for preventing this situation in the first place by implementing streamlined report preparation processes and delegating data collection to operations throughout the year in our November 2020 post.

Are you missing data? 

If you are missing a piece of data for the year, don’t panic. The important thing is to identify these missing data points as soon as possible so you can select the best strategy for managing the situation. 

Assess alternative calculation methods 

First, review the different calculation methodologies for a given source. Required data is calculation-method specific, so if you are missing one piece of information, it is often possible to check an alternate method against the data you have available. For instance, there are 4 methods of calculation for amine units, dependent on the data you collect: 

  • Method 1: CEMS 
  • Method 2: CO2 composition in vent/stack gas 
  • Method 3: CO2 composition in inlet/residue gas and amine throughput volume 
  • Method 4: Simulation software 

If you have sufficient data to complete calculations using another method, try that first.  

Employ missing data procedures 

When the greenhouse gas rules were first released, facilities and suppliers had the option to use the Best Available Monitoring Method (BAMM) to determine emissions from specific sources because it was not always feasible for a facility to acquire, install and operate all of the required monitoring equipment by the required date. 

This changed in 2017, however, and BAMM is no longer an accepted method. Instead, missing data procedures must be utilized for all sources moving forward. This requires you to communicate the following within the Subpart W Spreadsheet: 

  • What piece of data was estimated? 
  • At what frequency is the data usually measured? 
  • How many times were measurements missed? 
  • What procedure was used to estimate the missing data? 

If there is still a lack of data after assessing alternative calculation methods, you will need to employ missing data procedures. These procedures include: 

  1. Standards set by the rule, such as using an emission factor,
  2. The average of other measurements, 
  3. Best engineering estimates, or 
  4. A value that was used in the previous year. 

Verify recordkeeping procedures 

Beyond resolving instances of missing data, it is critical to ensure your data is being properly recorded. 

Operations are required to maintain records on site that document how the data provided in their annual GHG reports were developed. These records include a monitoring plan describing where and when samples were collected, methods used to analyze samples and the procedures used for quality assurance and quality control. 

 Verifying data is collected and maintained as required (for example, records must be kept for at least 3 years following the respective reporting period in a format that is readily available for inspection and review) improves the quality of your reports and will help prevent future data gaps.  

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Are You Ready for Reporting Season?


Huco Consulting Nov. 20, 2020

Best practices and proven processes to streamline reporting

Greenhouse gas (GHG) and state emissions inventory reporting season is a stressful time for many EHS professionals, who often take on most, if not all, of the heavy lifting. The concentration of responsibility on Environmental Managers can lead to time-crunched and frenzied processes – but there’s another way.

In this post, we share best practices for harnessing efficiencies and mobilizing full-team ownership to streamline and simplify seasonal reporting.

Step 1: Start early

While reporting season does not kick off in earnest until January or February, we believe preparation should begin as early as possible. As the following steps demonstrate, looking ahead and managing reporting as an ongoing endeavor distributes the workload across the year and paves the road for an organized, accurate process in the spring.  

Step 2: Check for updates

Checking for regulatory and process updates is the launching point for any reporting plan. These updates fall into 2 categories:

  1. Regulatory changes, which are changes to the rules themselves, and
  2. Report format changes, which are changes that have been made to the excel spreadsheets or xml schema that will be submitted to the agency.

Regulatory changes are usually available at the beginning of the year. Because these may affect how data is collected, the applicability of certain emission sources or how emission calculations are performed, we recommend reviewing these changes as soon as they are available to provide ample time for both configuring necessary changes into the environmental management systems (EMS) and communicating new data needs to operations personnel.

Report format changes can be assessed when the reporting forms are made available, typically in the end of December – though they are occasionally released earlier. Changes to these forms affect how data will be integrated into reports, which, in turn, may require adjustments to your data collection procedures or EMS. Promptly reviewing changes and implementing necessary updates will ensure your processes are calibrated to your requirements, saving you considerable time and potential headaches in March.

After you have reviewed the changes, compare your latest reporting tool (e.g., your eGGRT reporting spreadsheet) to the previous year’s and identify any updates in the formatting or content. You can then compile the changes into a new spreadsheet, compare the new XML reporting schema to the previous year’s, and implement any updates that need to be made.

Step 3: Review changes to your business

Employee turnover, mergers, acquisitions and divestitures are business realities that will impact your reporting requirements to varying degrees each year. Updating asset status changes as soon as they occur, whether this entails updating your entire EMS or simply updating procedures, will streamline your reporting process during the spring time-crunch by clarifying the sources for which you must collect data, as well as from whom you must collect that data.

Step 4: Empower efficient data management

All too often, the bulk of the data collection burden is placed on EHS professionals during reporting season. This not only results in unnecessary process bottlenecks, but in an inefficient allocation of EHS time and expertise as well. We encourage Environmental Managers to break out of this cycle by delegating responsibility to operations personnel, who are advantageously positioned and uniquely qualified to drive efficient data management systems on the ground.

To get the greatest possible value from this full-team approach, data collection should be centralized to allow for the review, analysis and assessment of data from a high level. Centralization optimizes validation processes by enabling EHS managers to reference one source with all the data rather than an array of separate sources. Importantly, centralized systems also reduce instances of data loss, miscommunication and other inefficiencies that are common when coordinating data collection and validation through lengthy email chains or other ad-hoc systems.

There are 3 principal approaches to mobilizing operations for data centralization:

1. Provide operations with a pre-formatted spreadsheet of all the equipment at a given facility and the data that must be collected for that equipment. This approach can be leveraged to increase the consistency of data collection across facilities and to aggregate data from those facilities into a master spreadsheet.

When using spreadsheets to collect data, it may be useful to denote which data will remain the same next year and to pre-populate these fields with default values. Additionally, including data from last year into the spreadsheet may serve as a valuable reference of what the operator filling out the data should expect.

2. Have operations enter data directly into an EMS. EHS personnel can then run reports from the EMS to verify that data is accurate and complete. Note: operators tend to be intimately familiar with the data output. Therefore, the people most familiar with the data are collecting and formatting it, providing initial quality control. In this approach, EHS primarily serves a validation role.

3. Integrate your EMS system with upstream data historians. If the data is already entered in another system or measured directly from electronic instruments, push this data to your reporting system.

Step 5: Validate and submit reports

With more data management responsibility shifted to operations personnel, EHS managers can focus on validating data accuracy. At this point, the centralized data management system helps ensure EHS can include all relevant sites in the validation process, reducing effort and expediting the identification of outliers. An EMS may assist in this process by highlighting missing data or other outliers before submission – similar to how tax software suggests double checking values for accuracy.

Robust report validation is critical before uploading reporting spreadsheets to agency online submission systems. These systems often reject uploads due to invalid picklist options or inaccurate data, using logic and statistical checks against similar facilities as well as algorithm checks – for example, verifying whether quarterly data adds up to the annual total.

Step 6: Jumpstart next year’s process

Reporting is an ongoing endeavor – the job isn’t done when your annual submissions are complete. There are several things you can address now to jumpstart a smooth reporting process next year:

  • Integrate current procedures, roles/responsibilities and work practices into your EHS management system and seize opportunities to streamline your process.
  • If you are still conducting spreadsheet-based reporting, document your procedures and save them to a common location to help share your facility-wide knowledge. This includes identifying which data needs to be gathered and who is responsible for collecting it.
  • Update your data collection procedure or take advantage of any new features to your EMS you may not have been aware of.

By looking ahead, implementing manageable processes, and empowering streamlined systems that leverage your team’s full capacity, you can eliminate bottlenecks and inconsistencies for a smooth and accurate reporting process. Learn more about how Huco can help you tackle reporting season here.


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Press Release: Gensuite Partners with Huco Consulting to Offer Turnkey Permit Compliance Solution

Huco Square Logo option 3

Huco Consulting Sept. 5, 2020

Press Release: Gensuite Partners with Huco Consulting to Offer Turnkey Permit Compliance Solution

We‘re excited to share the announcement of our partnership with Gensuite on our HuComply offering.  

Together, Huco and Gensuite leverage proven systems and powerful software to strengthen businessesempowering staff with a clear vision of EHS success and anaction-ready plan to achieve it 

This partnership exemplifies Huco’s commitment to improving compliance and risk management through teamwork, and we look forward to working with Gensuite to equip frontline workers with the information and tools they need to achieve consistent compliance on the ground. 

Read the press release here. 

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Activate Nimble Compliance Assurance with Virtual Audits

Alice Harman P.E.

Alice Harman July 28, 2020

Keep your company on the path to successful compliance.

In our Don’t Fear the Audit post, we highlighted the importance of conducting an audit to keep your workers safe, protect the public from environmental incidents and shield your company from fines, penalties or injuries. In this article, we share how we are helping clients respond nimbly to the challenges posed by COVID-19 and stay on the path to successful compliance with virtual audits.

Take stock of your compliance assurance status.

We trust that you have reviewed your management system, permits, checklists, facility inspection reports and focused on areas of concern at your sites. But with the COVID-19 pandemic, have you been able to get out to your facilities to check on records or the physical condition of the site? Have you been able to pull sample records and documents to verify they are filled in completely and accurately? Do you have the resources and subject matter experts (SMEs) available to assist and provide external insight?

The Huco audit team can help you plan and conduct virtual audits of your EHS management system and assure continual compliance. Below we outline the two key elements of our approach – the virtual site inspection and the desktop document review – and share best practices for equipping your organization to manage evolving compliance challenges with robust tools, nimble systems and expert insight.

Put virtual boots on the ground for a physical site inspection.

The COVID-19 pandemic and subsequent travel restrictions and social distancing protocols have decreased the on-site time for many EHS staff and Regional Management. Our team assessed opportunities for companies to leverage technology in response to this challenge, and after an in-depth market review, we identified a range of robust options for giving EHS an eye in the field from afar. Most notable among these options are hardware such as drones, RealWear™ headsets and Apple and Android tablets and smart phones that are easily paired with software solutions like Zoom, Teams, SmartTECHS.io, XpertEye, Vital Enterprises and Upskill to place you virtually side-by-side with your team on-site.

These tools provide mobile capabilities (either with or without internet access) including hands-free, voice-activated commands that are easy to use and safe for industrial environments, and many vendors offer integrated software and hardware solutions that will improve lead time on supply chain approvals. We recommend leveraging these out-of-the-box configurations to keep the learning curve short – the more comfortable and confident your team is working with the equipment, the better positioned you are to launch a thorough remote compliance assurance process that fits seamlessly into your operations.

Once your virtual audit toolkit is assembled, the next step is to tie in one of our SMEs to participate in the facility walk through. Whether joining the inspection live or by reviewing videos and photos taken by on-site personnel, the SME ensures the audit’s success by pointing out what looks good, identifying areas for additional follow-up and ensuring the security of the facility’s data at every stage of the process.

Dive into the details with a desktop document review.

While the site inspection provides an essential snapshot of a facility’s compliance status on the ground, operational records often paint a more detailed picture of compliance activities over time.

Many companies have implemented EHS management systems to schedule and track regulatory compliance tasks such as inspections, maintenance, throughput documentation, reporting, etc. Throughout the month and year, staff may review task descriptions and verify that tasks were completed as required to ensure compliance based on personal knowledge or documentation on file at the facility.

Take a moment to think about how many pieces of paper are documented or the number of electronic checklists that are completed by staff each year. How do you ensure these records are in order? When a new permit was issued or a plan was revised, were the associated checklists updated? Are the documents scanned, uploaded and organized within your EHS management system, or are they filed in a cabinet?

Let’s use a small petroleum tank farm as an example. With 5 tanks and a loading rack with controls, this facility would be expected to generate, at a minimum, the following records annually:

  • Monthly air emission tank inspections (60);
  • Monthly and annual SPCC inspections (13);
  • Monthly rack inspections (12);
  • Daily control equipment monitoring (365);
  • Monthly and quarterly control equipment calibration, plus annual test (17);
  • Emergency engine maintenance records (2);
  • Water sampling and drainage logs (16);
  • Waste inspection and manifest (12);
  • Fire equipment (14);
  • Safety equipment (14);
  • Training (25); and
  • Company and permit-specific documentation or reporting requirements (25+).
  • Total records generated each year: 575+

Reviewing these documents might appear to be an overwhelming task, but our staff has years of experience in environmental audits and are able to aide in simplifying the process – and if you’ve been keeping your files in a cabinet, we can work with you to use the desktop review preparation process as an opportunity to unlock efficiencies and streamline compliance management through EHS digitization.

Huco’s team of SMEs are seasoned reviewers of permits and regulatory requirements who know which sample sets to pull and which records must be completed. During the desktop review, we will identify any gaps in checklists or reports that could lead to environmental non-compliance or safety concerns. Our goal is to provide the information and clarity to assure consistent compliance year after year, and that aim informs every aspect of our virtual audit approach – empowering your facility’s best performance.

Ready to take the next step for nimble, insightful compliance assurance?

We believe in the power of external review to reveal risks and illuminate opportunities, and we are committed to applying our market expertise to help organizations in any industry take the next step for resilient compliance assurance. Whatever the next step may be –  evaluating  hardware and software vendors, planning an annual audit or launching a new compliance assurance program – our team knows the landscape and is prepared to guide, support and keep your organization on the path to successful compliance. Contact us at info@hucoinc.com or +1 (844) 438-4826 to learn more. 

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Don’t Fear the Audit

Alice Harman P.E.

Alice Harman May 27, 2020

Don't Fear the Audit

This is the first article of a two-part series on audits. In this post, we discuss creating value for your organization through a robust third-party audit program and an effective management system. In the second post of the series, we’ll look more closely at delivering nimble compliance support and expertise through virtual audits. 

What is your first reaction when you hear: “Your facility is going to be audited”? I used to work for a midstream and terminals company, and many of my colleagues expressed dread when they learned that one of our facilities was facing an internal audit.

Conversations began to center on concerns such as:
  • Are we prepared for someone to come take a look around our facility?
  • The audit will distract from daily operations. Between the time needed to prep, pull information during the audit and inspect the site, this is going to hold up our other work.
  • Our dirty laundry will be aired out and mistakes will be identified — is that inspection form completed fully and accurately? Does it have all the required information?
  • Fixing any issues identified in the audit will require additional work, training, or capital expenditures.

At Huco, we have a more positive and proactive perspective on audits. Wherobust third-party audits are combined with an effective management system, they create opportunities for the EHS department to generate value for the organization. Bear in mind, though, that the audit alone does not create value — it’s what you do with the findings and how you track the resulting improvements that make the differenceI believe audits should empower you to continuously improve compliance and effectively manage risk for a stronger company. Here’s why: 

Why shouldn’t I fear an audit? 

  • I am a glasshalffull kind of person, so I appreciate a fresh set of eyes looking at my compliance documentation. After seeing the same site every day, I may begin to unintentionally overlook things  it is human nature to become comfortable and even a bit complacent. Audits provide a new perspective for assessing on-site compliance activities.  
  • Working with an auditor can help me prepare for inspections and provide an opportunity to identify and resolve any gaps before the agency finds themThis enables me to improve performance and maintain the trust of both the agency and the general public. 
  • An audit is a chance to minimizes risk by identifying preventable issues. 
  • Audits enable me to leverage lessons learned from other sites and share best management practices across industry. 
  • It is an opportunity to cross train site-level teamon what to look for during audits. They can then use their experience at other sites.

Audits are an investment, but they can save longterm costs; there is significant ROI when it comes to preventing fines, penalties, injuries and workers comp claims, and through advanced scheduling, operations can plan ahead and avoid losing time for daily tasks to the audit process.

What constitutes a robust third-party auditing program? 

We use the 7-element program outlined below when we conduct audits for our clients to ensure they get the most benefit possible from the experience: 

Internally Driven Process

Management buy-in is critical to any project. If you need to get funding, we suggest tapping into the cost-benefit mindset.


Once your project is approved, we will work with EHS and Operations to create a schedule.  

Preparation in Advance

The Audit Team Leader coordinates with the site to develop the agenda, scope and responsibilities for the SMEs. We will need permits, plans, and policies ahead of time. This is where time spent setting up your management system will come in handy!

Site Visit 

Once all the prep work and scheduling are completed, we have the big day on site. While inspecting your site, the Audit Team will want to verify compliance on the ground. They will look at signage, labels, the condition of equipment and whether permit language lines up with actual operations. 


You will typically receive the Lead Auditor’s draft report with input from the SMEs within two weeks. There will then be an opportunity to make comments and adjustments. Sometimes corrections are also made during the draft period and resolved before the final report. 

Tracked Findings

The final report includes photos, the basis of findings (regulatory, permit or policy), details of each finding, a corrective action plan for each finding, a person assigned to ensure the finding is corrected and a timeline to resolve the findings. 

Attorney Client Privilege 

After the audit, the attorney reviews the compliance findings, and a determination can be made of whether self-reporting to the agency is needed and, if so, how to protect confidential information. 

The power of your management system 

A successful audit is not completed with receipt of the final report. After the findings are identified, you need to track them for correction and completion. Using an information management system with action plan or compliance calendar features is the best way to ensure that any assigned corrective actions are completed. 

Information is only useful when it’s available to the people who need it. Every software tool has different features and best practices for sharing information.  Whichever system you use be sure to leverage it to share audit findings across your facility and even with other sites within your organization. Some tools offer weekly email reminders, others have push notifications or safety bulletins that go out to pre-configured lists or certain roles. If you are unsure how you can spread information and learnings from your audit, ask your system admin, or contact us for help with system sustainment planning. 

Conclusion: A small investment can reduce operational risk 

The mission of EHS is to ensure your workers go home safe each night, the public is protected from environmental incidents and your organization is not exposed to risk. 

Some say audits burn time that could be used on daily operations. However, audits are a small investment in time and money that can save costs in the long run, particularly when it comes to fines, penalties or injuries – and the lessons learned are invaluable when it comes to protecting your stakeholders.

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