How to identify your regulatory requirements or variability in regulatory document formats!

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Regulatory documents are designed to be read by humans. To help people better understand their obligations and ensure compliance to every element of the regulations. At Nimonik, we take these documents apart for the computer. The computer then reads, understands and compares the documents. 

But this task is challenging (read costly) due to the variability in the digital format and the layout of the documents. Lets see three simple examples from the Air Energy Regulator in Alberta, Canada.

Directive 38 : Noise Control

Directive 38 (57 pages) contains requirements that are numbered in parallel to the normal numbering of the document. Take a look at the section 2.1. Within that, you can see three requirements labeled as “1)”, “2)” and “3)” on page number 7.

Then the next requirement is on page 8. So far, so good. However, item”4)” should logically be within the same 2.1 section of the document. Wrong! They have placed the”4)” in a deeper level, 2.1.2.2. How do we know they go together or should be grouped in any way? This is just poor organization and increases the cost of compliance.


Directive 77: Pipelines – Requirements and Reference Tools

Directive 77 (68 pages) has titles specifically made for containing requirements.

This one contains many attachments which you technically need to comply to too, but you have to buy the standards and they are in a format that is difficult to analyze with software.

What is really amazing is that the variability mentioned above is for documents coming from the same regulating body in the same jurisdiction!

Directive 58: Oilfield Waste Management Requirements for the Upstream Petroleum Industry

Directive 58 (233 pages) is based on images of the directives on which an Optical character recognition (OCR) has been used. When copy-pasting, there are many spelling errors and spaces missing. This is literally as if the regulator printed out the Directive, then scanned it, then ran a software recognition on it and posted it with errors and mistakes. Something seems wrong and unprofessional.

What is really amazing is that the variability mentioned above is for documents coming from the same regulating body in the same jurisdiction! If we expand the scope to multiple jurisdictions and multiple regulators, you can imagine how difficult it is to compare your compliance obligations (your requirements) across your operations. Then try comparing your requirements over time!

Nimonik has been working with companies around the world to streamline and organize the regulatory requirements they must meet. Part of this work has been building out 150 Environmental, Health and Safety Topics and part of this work is related to breaking apart the regulatory documents to make them comparable.

However, to standardize the legal requirements, you need to break up the variable documents into their constituent parts and then try to rebuild them. This can be done, the immense challenge comes along when you want to keep all of this information up-to-date across multiple jurisdictions and multiple languages. Our end product, simple as it might seem, is based on very complex software. We present users with a clear before and after of an individual regulatory requirement:

It may be wishful thinking that government would organize itself to standardize the format of legislation, but it would certainly help industry (and citizens) comply more easily. For example, financial information published to stock markets is standardized, making it easy to compare financial information by company, industry, and location.

If government regulatory data were standardized we could more easily consume that data in monitoring stations, apps and other services. This would allow companies to comply and it would help ensure the regulations we spend so much time writing are actually respected! Unsexy as it might be, standardization is a linchpin of efficiency. Contact us today if you would like help standardize your EHS requirements!