Ireland, land of green pastures, great beer and complicated regulatory information.
I once heard a story that Ireland only introduced postal codes in 2014. Prior to that, the only people who knew all the addresses were local postal offices. These local offices did not want postal codes as it would allow more mail to be centrally managed and would reduce the country’s reliance on local offices. If true, perhaps this is why Ireland still has such a difficult and complex web of regulations that the average business will have trouble navigating.
In 2020, Nimonik undertook a project to improve its Irish regulatory tracking. This project has been uniquely challenging. The main obstacle was the size of the project, as over 38,000 documents were identified on Ireland’s legislative archive (http://www.irishstatutebook.ie/). Manually locating all General Industry EHS (Environmental Health & Safety) documents in this immense list would require a huge investment of time and manpower, so the process was divided into phases:
Phase 1: Identify, Review and Upload all “Principal Documents”.
Phase 2: Identify, Review and Upload all “Amending-only Documents”.
Phase 3: Review all Document excluded (by Title) from Phase 1.
Phase 4: Upload the “Oh Hold” Documents (ex: Animal Habitats, Wildlife Sanctuaries).
An initial assessment was completed by running a series of formulas to identify keywords that would determine if a Document would be entered in Phase 1 (ex: Health, Water, Waste, Safety, and other Nimonik EHS Topics.) or Phase 2 (Amendment, Commencement) or Excluded entirely.
Phase 1: Wait how many are there?
The challenge in phase 1 was mainly an issue of time management. The initial keyword filter produced a general list of ~ 2850 Primary EHS Documents (Acts and Regulations)to be included in the manual verification process. The evaluators would first have to check the Amendment tab on each document’s webpage to determine if it had been removed, repealed or otherwise changed in a manner that rendered it irrelevant in Phase 1. The remaining entries that were still in-force were then evaluated to verify that the contents met the ‘General Industry” and EHS definitions. One interesting note is that the date-range for active documents went as far back as the 19th century. The terms, wording and definitions in these older pages required more liberal interpretations when determining their categorization. This evaluation process took several weeks to complete, resulting in a final upload list of 133 entries.
Phase 2: How do Amendments work?
The second phase proved more challenging as Ireland is an unconsolidated jurisdiction (amendments are not incorporated into the primary documents). The first step was to determine which amendments would be required for each principal document added in phase 1 (extract list from the Amendments tab and evaluate) and to evaluate each document identified as an amendments/commencement in the initial text filter. The primary challenge with Ireland is that many amending documents contain links to supplementary amendments (amendments for the amendments), creating multiple document chains. A large amount of analysis and research was required to organize the relationships between the amendments to allow for the import to NimonikApp. The final validation check required Nimonik staff to review each amendment to determine if the amending passage is valid (content addition, replacement or repeal) or invalid (reference, ‘utilizing powers’, etc.).
In short, Ireland has a vast and complex web of regulatory documents. For a country of five million people it is surprising how difficult it is to navigate through the legislation. Now that Nimonik has organized all the Irish environmental, health and safety regulations it will be much easier for our customers to work towards Comprehensive Compliance in Ireland.