A program still run on paper
Two offices behind Zach Foster’s desk at the City of Eugene, Oregon, there is a records room about twice the size of his office. It is full of binders.
They hold the last 5 years of records, which he audits once a year.
“But all of that still takes an entire room,” he says.
“We’re worlds better than we were five, 10 years ago already,” Zach says. “That being said, 95% of what I do still lives on paper documents.”
Each month, almost every permitted industry sends a self-monitoring report. Zach types the data into a spreadsheet, then again into SwiftComply while the program makes the move.
“Right now I’m duplicating all of our data entry,” he says. The goal is to drop the spreadsheet and have industries report through a portal.
More responsibility, fewer hands
Zach’s official title is Environmental Compliance Specialist. His unofficial one is pretreatment manager, “but that’s only because I am the only person doing pretreatment full time.”
Eugene’s Regulatory Services program covers Industrial Pretreatment, FOG, Mobile Waste Hauling, and Industrial & Commercial Stormwater, with a current total of 4 full-time employees.
The program covers 16 permitted wastewater facilities, 10 non-discharging categorical users, 16 permitted mobile waste haulers, and 62 permitted Industrial Stormwater sites.
Eugene once had 3 full-time employees on pretreatment permitting. That number, he says, “got pared away as we had more responsibility come into the program.”
“We are technically down two full-time positions right now,” Zach says. “Hopefully in the next couple years we’ll be able to rehire and fill those positions.”
From brewery floor to city regulator
Zach came from the other side of the permit: almost 10 years at a Eugene brewery, where he worked his way from forklift driver to quality manager.
“I didn’t go to college. I don’t have a background in any of this, so I had to teach myself microbiology and plating and all this stuff,” he says. That meant “literally watching chemistry and microbiology YouTube series.”
He also ran the brewery’s wastewater treatment system, “because nobody else wanted to do it,” and wrote the automation that let it run on its own.
When a city position opened, he “pretty much just changed sides.” For a couple of years, he administered the brewery’s permit as its regulator.
When the tool does not match the work
Before Zach joined the city, Eugene had already tried software for its FOG and pretreatment inspections.
“Think of it like an automated spreadsheet that you would try to put data into on your phone while you’re doing an inspection,” he says. “We couldn’t even get the files to save properly.”
After about 2 years, the city scrapped it and went back to paper.
“It was something that I think was purpose-built, but not for this purpose,” Zach says. “I think it probably works pretty well for what it was explicitly built for.”
“My blank inspection sheet is 14 pages, which is ridiculous,” he says. “But trying to do all of that in a program that is not built to do that just didn’t work.”
Why Eugene chose to help shape the solution
Much of Eugene’s early involvement in SwiftComply’s pretreatment module came out of those hard lessons, Zach says.
“Part of it was the knowledge and understanding that an out-of-the-box program sometimes does not do exactly what they say it’s going to do.”
Eugene also had experience with SwiftComply’s FOG product.
“My coworker Deustin manages the FOG program. He operates almost exclusively in the FOG module of SwiftComply. It’s going really well. We’re really happy with it,” Zach says. Eugene’s FOG program oversees nearly 900 food service establishments.
When Eugene weighed its options, it chose to “invest and know that this is being built by industry professionals who not only know what they’re doing and what we need out of the program, but are also actively seeking our input because we’re the ones who are using it every day.”
Underneath it all was a simpler need.
“We needed to get out of the pen and paper era,” he says. “We needed to start digitizing our documents. We really wanted CROMERR.”
Making digital reporting possible: CROMERR
For Eugene, replacing paper is not only a software question. It also depends on CROMERR, the EPA’s Cross-Media Electronic Reporting Rule.
“Legally, until a program receives CROMERR approval, the only way we can accept program-required documents is wet signature, pen and paper,” Zach says.
The documents, he says, have to be physically in the city’s possession. “I can’t take a scanned copy over email.”
Already writing a new sewer use ordinance, Eugene put CROMERR language in early. The state approved it 2 years ago, he says, “long before we had even filed for [CROMERR] approval.”
“We figured, why not just put it in there now? We know we’re going to get it eventually. And so we did,” Zach says.
“We actually technically have CROMERR approval already. We’re working on some back-end stuff,” he said.
Starting with the industries ready to go digital
Zach wants to issue permits through SwiftComply and have industries submit their monitoring data digitally.
“It’s probably 10 to 14 hours of the month just sitting down and manually typing in data,” he says.
The harder part will be the industries.
“I know I have a handful of industries that I will have to sit down and teach them how to do data entry,” he says.
He is picking a few that are “already pretty tech-savvy” to go first.
“So I’ve got a game plan.”
More time for the work that needs a person
Zach wants the program to have time for “doing deep quality inspections and working more with the industry on constant improvement instead of cleaning up problems.”
“Sometimes we don’t even know about a violation until a month later when we get a report,” he says.
His ideal is a dashboard where he can “see who’s got a violation, who’s ready to get their permit renewed, who’s ready for their next inspection.”
“And I just go do it.”
