Permitting: tl;dr

(Yes, another work related post.  You have been warned.)

At work, I write and issue permits operational permits to businesses.  To an extent these are negotiated permits.  What that means is that after we receive an application and draft an initial permit, the applicant gets a chance to review the permit, make comments, and request changes if necessary.

The goal is to end up with a permit that achieves our goal of having a permit that shows the applicant how to operate in compliance with the regulations and at the same time having a permit the applicant can live with.

This doesn't happen if nobody reads the draft permits.

Ideally, a permit condition will meet three criteria: it will have a purpose, it will be clear, and it will be enforceable.

Purpose:  There should be a reason that a condition exists.  Usually this will be a regulatory requirement of some type or it could be a means to achieve a policy goal.  One condition I ran into many years ago was a requirement for a trash handling facility to have a SCBA ( self contained breathing apparatus) on site - I still can't figure out why that was required.

Clarity:  Conditions should be clear as to what the requirements are.  If a condition confuses you or puts you to sleep before you can finish reading it, that's something that needs to be addressed before the permit is finalized.

Enforceable:  This is twofold: compliance with the condition should lead to compliance with the regulation, and non-compliance with the condition should clearly show non-compliance with the regulation.

As an applicant, it's important to focus on the purpose and clarity of any drafts you are sent.  If you don't understand why a requirement is in the permit or you are confused as to what you are being asked to do.... ask questions.  This is your chance, once a permit is final, it may be too late.

tl;dr:  Read!

Going Paperless at the Office

Well, sort of paperless.

A few years ago we saw that we would soon be running out of space to store paper records.

What we had was a storage room full of archive boxes and bulging file cabinets.  This wouldn't have been too bad except there was no uniform document management system.  Most of the files in the cabinets used an old record ID system that had been retired in 1995; the rest of the material had just been randomly dumped wherever anyone found an empty drawer.  All in all, every former employee's document system was memorialized in our records. (This is being dealt with ... slowly.)

In the mean time, we were generating a ton of new paper records; and there was (is?) no hope of a enterprise-wide document management system (DMS) appearing any time soon.

Luckily we had the ability to create PDF files.  The decision was to go with three basic identifiers: client ID, document date, and subject/summary.  These could all be easily incorporated into the file name.

We haven't achieved 100% buy-in, as some people are still not comfortable without paper;  but we have severely cut down on printing costs and the record storage issues are at least manageable.

We did have to ask IT for more disk space (to be expected); which we were granted - along with a side-note which showed that IT was not in tune with the rest of the organization.

It will be interesting to see what happens when an enterprise DMS gets introduced; but that's not for another day, month, year, decade...