Building a Compliance Regulatory Registry

Brenda ArmstrongEnvironmental Affairs ManagerEnvironmental Health & Safety OfficeYale University(203) 432- 3219Brenda.Armstrong@yale.edu

Recent Overview of Yale

EHS office appointed a new director in winter 07. Deputy Provost was interested in what regulatory

requirements EHS is responsible for on a detailed level.

EHS staff comprised of 45 staff members – Env Affairs– Rad Safety – Occ Health & Safety – Business & Support Section

Our Goal

Create one comprehensive system that tracks all compliance related on going projects or tasks.

Allow for automated notifications to all responsible parties

Track completion dates and one time projects

Typical University

Departmental disconnect Heavily regulated by OSHA, EPA,CT- DEP,

NRC, local POTW, Public Health etc. Everyone had their own system for keeping

track of their “to do list” Yale does not have a formal EMS Permits, reports, sampling, notifications, etc.

1st Steps

Simple spreadsheet– Ask EHS section managers to start compiling lists

for all the items they keep track of over time.– What permits, regulatory reports, samples, stack

tests, registrations, renewals, etc.– The list grew as the months went on through this

brain storming exercise to approximately 90 main tasks.

Fields in the Spreadsheet

Task name Media type Section responsible Due Date Frequency How much lead time for notification? Responsible person & their supervisor Regulatory Agency Regulatory Agency contact info Regulatory Citation

Next Step- Simple Process

Hired a programmer to put information into an Access database - $2K

Monthly business manager would then run reports by “responsible person” with a 3 month look ahead time line

Access Based Registry

Working ok but improvements needed

– Need to be able to track completion dates

– Would like to be able to include back up documents for each task for reference

– More efficient notifications needed

Next Step- EXPANSION

Deputy Provost Office is pleased with EHS’s database but wants a centralized repository for compliance units that report to Provost

Want to include IACUC, IRB, Conflict of Interest, HIPPA units.

Request for Proposal Written

Project Charter created

Official RFP sent out to bid

Expanded program will be accessible to each unit and by Office of Deputy Provost as needed with overall administration by Deputy Provost.

Key Deliverables of Single Database

Enable automated notifications to inform responsible parties of upcoming tasks

Capture history of completed tasks, along with notes and document links

Enable standard and ad hoc reporting of tasks

Deliverables con’t

Provide users with multiple views of tasks or by entire unit lists

Role based security access to certain tasks

Enable inter-departmental sharing of tasks that occur in conduct of university activities or operation of University facilities/equipment

Funding for a New EHS position

Information Specialist– Part of responsibilities in this area– Documentation manager for training and back up

documents for regulatory tasks– Administrative oversight for Project Charter

Benefits of SystemConclusion

Increased efficiency and productivity in EHS by eliminating current email reminders

Continued completion of expanding regulatory requirements by providing automated reminders to responsible parties

Development of a complete inventory of recurring regulatory events for certain University units

Maintenance of historical information and documents related to completed tasks

Timely reporting of info on tasks at unit level for Deputy Provost Flexibility to meet changes in regulatory requirements and in

University policies and procedures. Robust and secure web based database