The Importance of Recordkeeping
It’s officially summertime! We hope you all are staying happy, healthy, and busy during this time and gearing up for some summer fun! We are looking forward to seeing everyone this year for annual Indiana Certified Automotive Recyclers Exemplary Standards (INCARES) audits. With audit season in mind, we thought we would write about a very important item: recordkeeping. This is something that not only shows up on audits, but it is also important for the everyday function of your business.
From our experience working with auto recyclers, paperwork is often the aspect of business that is in need of the most tweaking when we are hired by a new client. There are a few exceptions, but all-in-all the recordkeeping systems are not complete, organized, or user-friendly. We have developed a system that seems to work well to help our folks keep track of the necessary information in a simple, user-friendly manner. The system we use applies specifically to your Storm Water Pollution Prevention Plan (SWPPP) and Spill Prevention Control and Countermeasure (SPCC) Plan. Inside the binders are all of the necessary forms along with space to store all of your pertinent documents. For example, if you sell a drum of used oil, you turn to the used oil tab of your SWPPP binder and store a copy of the receipt in that section. We keep redundant, electronic copies of the binders at our office so if something is lost or damaged we can recreate our clients’ system. We perform quarterly update checks to ensure that recordkeeping is up-to-date. We encourage you to keep records of all activities so that in the event you are asked you can produce documentation to support your processes.
There are often more requirements for internal tracking than there are requirements that are submitted to a regulatory agency. None of the requirements are particularly difficult. The difficulty is keeping up with the large number of requirements and developing a system that makes the compliance program run effectively. For sake of discussion, let’s talk about storm water. Storm water permits have several documents that are required to be submitted to the regulatory agency, such as the Notice of Intent, Storm Water Sampling, and Annual Reporting. However, items such as Quarterly Visual Wet Weather Inspections and Annual SWPPP Training documentation are not required to be submitted to a regulatory agency. Therefore, we often see that items required for submittal are completed while the other documentation falls to the wayside. So, what are some ways to ensure that your records are organized and required documentation is completed in a timely manner?
First, assign responsibility. Make it clear who is responsible for inspections, recordkeeping, and keeping these items organized. Provide proper training to ensure all documentation and inspections are completed accurately, thoroughly, and in a timely manner. Assigning specific duties to well-trained, trustworthy employees will help ensure your recordkeeping is in top shape.
Second, make sure that all documents are kept in a designated place. This will help you easily find documents when needed and keep different types of documentation separate. As we mentioned, binders are a great system. When using the binder system for storm water permitting, you know that all your applicable inspections, documentation, and forms are located in one central place. This is especially helpful in the case of a regulatory inspection. An organized recordkeeping system is one great way to instantly impress regulators. It shows that your care about your business and that you are committed to compliance.
A complete, organized, and user-friendly recordkeeping system can look many different ways. Different systems work for different people; keep this in mind as you work on improving systems at your facility. If you want additional information, have any questions, or want assistance with your facility’s recordkeeping practices, please do not hesitate to call VET at (812) 822-0400.
Got compliance?