Two Lessons in Compliance

• By Arlene Davidson
• Sep 01, 2003

IN 2002, Moline, Ill.-based Deere & Company resolved 95 percent of its environmental compliance issues in North America within 90 days. It was able to build a "Top Ten" list from more than 1,000 regulatory line items. Corporate officials and site managers can determine the status of each issue at each facility, whenever they want.

The compliance challenges are different for Seattle-based Holland America Line and its fleet of 14 cruise ships. Holland America's reputation for maintaining safety is essential to customer credibility and is an integral part of its product, while its ability to comply with regulations is essential to corporate profitability.

A key to both companies' success is Web-based Dakota Tracer, a management tool from Dakota Software Corporation that documents and tracks recommendations/deficiencies and verifies compliance.

A Better Way at Deere
At Deere, a $14 billion entity with some 40,000 employees worldwide, it was not always so easy. The company started environmental auditing back in 1994. As Deere grew, regulations became more complex, and the process to audit, manage, and correct findings became increasingly challenging.

Just in North America, Deere has 31 manufacturing facilities operating in 13 U.S. states, four Canadian provinces, and Mexico. Follow-up on corrective actions was tedious and slow. Units were submitting updated spreadsheets on their corrective action items every six months or so until completed. The system was static, but the problems were dynamic. The company's culture demands operations run as smoothly as the machinery it manufactures; they needed a better way.

Joanne Howard is staff engineer in the Environmental Control Department at Deere's world headquarters in Moline. She's responsible for corporate environmental audits for Deere facilities, including tracking progress being made on corrections and encouraging sites to be vigilant in environmental compliance. Tracer, developed from extensive input from Dakota's Fortune 2000 customers, was designed for multiple-site situations such as Deere's.

In 2000, Deere subscribed to Tracer to automate the process, offering it on a voluntary basis to North American facilities. By 2002, the use of Tracer became mandatory in North American facilities that had corrective action plans. Tracer enables Howard to measure over 30-day intervals what percentage of closure is being achieved on open items. She sees Dakota Tracer as one of their primary corrective action process tools.

According to Howard, Tracer has brought Deere's corrective action process to new levels of speed and accuracy. Corrective action plans are tracked in real time, ensuring a more comprehensive review. Compliance checks are completed and reported every 30 days, and all data is online and available to those granted access. To reach the 95 percent level, she credits three Tracer features: (1) e-mail alerts, which send reminders that an item is due, (2) Tracer Journal, which provides an always-current history of corrective action updates, and (3) Real-time Monitoring, which lets the appropriate people within the company assess any situation at any location at any given time.

"We have seen vast improvements in our programs with Tracer's support," Howard says. "It would be very difficult for us to review over 1,000 line items to find the top items, which Tracer gives us in just minutes. We can examine water, waste, air, etc. on an enterprise-wide basis. The company can then examine the same categories by facility, or dig a level deeper to look just at wastewater, for example. Without Tracer, creating a snapshot of our status for management would require numerous e-mails and spreadsheets, and then it still would not be current. Tracer has brought consistency to our compliance process and efficiency to follow up reporting. Because of the speed and ease, higher levels of management have become involved with Tracer. Now, they know where we stand."

These processes can be attributed to Tracer's patent-pending Parametric Filters, which enable Deere to determine problems throughout the corporate network, slicing data into whatever categories it wishes and drilling deeper when needed. "Multiple filters now give us information we could not previously obtain," Howard says.

Holland America Steams Ahead
Complying with government safety and environmental regulations is a daunting task. Consider the complexity of operating a fleet of luxury liners--perpetually steaming, sailing or mooring on each of the seven seas, visiting all seven continents, often visiting scores of countries by the day. While all global corporations need to manage remote sites, Holland America's are perpetually moving around, often visiting several countries in a day. Each nation and port applies its own regulations. Between ports, you're subject to international maritime law, not to mention the requirements of the country whose flag you fly.

As Holland America's Compliance Program Manager, Michiel Versteeg ensures all vessels comply with company, local, national, international, and industry safety and environmental regulations--at all times in all locales. Holding a bachelor's degree in nautical and engineering studies, he understands the logistical challenges of managing ships in motion, while his four years' experience as a Deck Officer gave him insight into the operational challenges aboard luxury passenger vessels. When he took the headquarters-based position two years ago, Holland America was making its best effort to track, manage, and comply with global environmental and safety regulations using a Microsoft Access relational database. Information was transmitted from each ship to the Seattle headquarters via e-mail file transfers. A system administrator who served as corporate gatekeeper for all safety and environmental-related data manually populated the database.

The ship's staff officers did not have direct access to this database. "They were unable to instantly generate reports they needed at a specific moment in time," Versteeg recalls. "This scenario was not compatible with the company's needs."

Versteeg sought out a better solution to help corporate staff and ship staff officers effectively communicate. There was a need for real-time tracking to allow Holland America to manage the process of regulatory compliance. Management needed a tool that would globally track regulatory deficiencies and provide current data for analysis. Another challenge was the change of staff officers, who are frequently rotated in a work/leave system. Holland America, Versteeg felt, needed to give ships' officers the ability to step aboard any vessel and immediately determine the ship's compliance status.

This is a tall order, but Holland America is confident that Dakota Tracer is fulfilling these requirements. It allows real-time analysis of data from any location, shipboard or onshore. Dakota Tracer maintains a running history that lets newly installed officers know which actions are required to ensure compliance.

"Dakota Tracer makes it a lot easier for our personnel, letting us see who is responsible for a certain requirement and the real-time status regarding compliance," Versteeg says. "For example, a Chief Engineer just assuming responsibilities on a vessel can use Tracer to determine outstanding corrections that need to be completed within the next month."

Holland America uses Tracer as part of its Safety Management System, which is a company self-improvement program. Tracer tracks the regulatory compliance items that are generated from the various inspections/audits, such as Coast Guard inspections, so it can more easily identify where emphasis should be placed in changing operational environments. "With Tracer's Parametric Filtering feature, each member of our team can display precisely the data he or she needs, at the moment it is needed. When one piece of data is updated, all the related data gets automatically adjusted accordingly. The organizational structure in Tracer enables each vessel to have its own folder, containing subfolders for each regulatory inspection group (e.g. Coast Guard, Flag State, etc.) with the tracking items in them, including due dates, personnel responsible," Versteeg adds. "We have about 500 seagoing deck and engine officers assigned over the fleet. Dakota Tracer makes us more efficient in managing this volume and with organizing and planning."

"Tracer is a tool that ensures you will always know at a glance who's responsible, what has been accomplished, and what still needs to be done to ensure that a vessel is in compliance," he says.

This article originally appeared in the September 2003 issue of Occupational Health & Safety.