(Certified Best Practice by BMPCOE)
Sandia National Laboratories - Albuquerque, NM
Prior to initiating the present process, there existed no mechanism in place to address potential liability resulting from Environment, Safety, & Health (ES&H) regulatory compliance deficiencies of suppliers. Other companies used audits to manage this problem, but Sandia wanted to find an alternative to the adversarial nature of audits and manage exposure to liability in a positive and productive way. The process was also developed as a way to manage the risk of cost or schedule overruns due to regulatory compliance issues.
Sandia has developed a database/knowledge-based system to perform environment, safety, and health regulatory compliance assessments of manufacturing processes. It is part of Sandia's aggressive, proactive approach to managing the exposure to risk and liability resulting from supplier ES&H regulatory compliance deficiencies, particularly in hazardous waste management and disposal. The process investigates, identifies, and communicates all known or suspected hazards related to contracted activities. It also identifies ES&H technical assistance or other intervention strategies that result in win-win solutions for Sandia and its suppliers.
First, a process assessment methodology was developed, applied to contract specifications, and made available to suppliers. A database was established to link manufacturing processes and materials with regulatory issues. The database was enhanced to incorporate solutions to compliance issues including compliance program templates, environmentally conscious manufacturing technologies, pollution prevention and waste minimization and federal, state, and local resources. The database was called Interactive Technology Distribution System (ITDS). A front end smart questionnaire called Materials and Process Characterization (MPC) questionnaire was developed and interfaced with the database using a commercially available software package called Exsys®. The result was an expert database/knowledge-based system called ITDS/MPC.
ITDS/MPC, which differs from commercially available regulatory databases in several ways, is ideal for aiding small businesses. It is designed for users not familiar with ES&H regulatory compliance issues. Users need not have any knowledge of regulations because regulatory issues are linked to materials and processes. Hazard determinations are made for the user based on regulatory criteria. Going from materials and processes to regulatory compliance issues frequently requires some professional judgement and interpretation. This expertise is contained in the knowledge-base of the MPC. ITDS/MPC teaches the user about regulatory compliance issues. MPC may also be used to model changes in regulatory compliance issues with changes or additions of new materials and processes.
ITDS/MPC is a tool to assist the user in determining compliance requirements, prioritizing those issues, and solving compliance problems. It is also a training tool that is most useful to organizations without access to EH&S professionals.
The ITDS is built on a commercially available database platform (Paradox for Windows) which operates in a DOS/Windows environment and may be networked. The MPC is built on a commercially available expert system shell (Exsys) supporting both DOS/Windows and Macintosh operating systems. Minimum hardware requirements are IBM PC (or compatible), 4 MB RAM, 80 MB hard disk space.
Application of this process and automated tools have helped Sandia improve relationships with its suppliers, especially the small industrial manufacturers. The system identifies potential regulatory issues early, particularly those which vary from state to state, and avoids liability risks. It identifies cost effective solutions to regulatory problems and uses technology transfer to solve potential compliance problems.