Challenges and Solutions in Asbestos Notification Process
Various challenges exist in the asbestos notification process, such as complexity, tailored systems, and legal requirements like CROMERR certification. Solutions include digital signatures and electronic notifications to streamline the process. Key issues and common themes are identified, showcasing the need for efficient solutions tailored to each organization's needs.
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Asbestos Notification Process Observations on the AS-IS or Current State
What We Found - Common Themes Every system is complex and tailored to each organization s needs. The Regulated Community must navigate many different requirements for local, state and federal for one location. Much duplication, confusing and changing requirements. Paper is still a problem. CROMERR certification/ digital signature is legally necessary but not always affordable for small entities.
Summary Table of Key Issues ANFs Annually Recurring Acknowledgement of Receipt to Contractor Fees (e.g. permit fees) No-collected by WVDHHR "wet" signature required electronic notification via portal accepted along with "wet" signature on hardcopy digital signature accepted with electronic account set up "wet" signature requested, email accepted electronic notification via portal accepted along with "wet" signature on hardcopy Signature (CROMERR/digital signature, "wet" copy, scanned signature) Entity Contractors/Universe West Virginia 1,500 ~30/100s No Delaware District of Columbia Allegheny County 250 6/30 Yes No 400 30/30 Yes Yes 1,200 25/70 + some GCs Yes Yes Philadelphia County Yes, can verify submission via electronic system 1,500 500 Yes Pennsylvania 7,000 2200 No No, Contractor notified of permit only by Local permitting agency (e.g. Balt city) No* "wet" signature required Yes- local entity can issue permit Maryland 3,000 125 "wet" signature required "wet" signature requested, email accepted Virginia 1,300 30 Yes *fees probably in future
renovation. The information required in paragraph (b)(4) of this section must be reported using a form similar to that shown in EPA 40 CFR 61.145, Part M Standard for demolition and Figure 3.
LEAN- Value Added Analysis Value Added Analysis is a technique for improving a process by evaluating each process step to assess its importance to a customer. Process steps are sorted into three categories: Value Added (VA) Non-Value Added (NVA) Non-Value Added Necessary (NVAN) Value Added Non- Value Added Necessary Non- Value Added 5 Source: https://goleansixsigma.com/value-added-analysis
Value Added Value Added (VA) Task or action a customer is willing to pay for (or cares about) Value added actions transform materials and information into products and services, towards completion (something changes, e.g. form, fit, function) The action is done right the first time (no rework required) Example Approve and issue a final permit to an applicant Fund a task order for an Emergency Response Spill Removal Activity Value Added Goal Keep VA steps 6 Source: Identifying Waste and Value-added vs. Non-value added Activities, Yvonne Watson, EPA
Non-Value Added Necessary Non-Value Added Necessary (NVAN) These steps are necessary, although the step may not add value from the customer s perspective They could be necessary because of laws, regulations or other requirements for a business to function effectively Example Research Federal Acquisition Regulations (FAR) clauses that need to be included in a contract Non-Value Added Necessary Goal Reduce NVAN steps 7 Source: Identifying Waste and Value-added vs. Non-value added Activities, Yvonne Watson, EPA
Non-Value Added Non-Value Added (NVA) Consumes resources without creating value Requires more time, effort, or resources than necessary Can be removed to focus on VA steps Example Conducting a quality assurance inspection of a final product Require a second approval on a travel voucher Non-Value Added Goal Eliminate NVA steps 8 Source: Identifying Waste and Value-added vs. Non-value added Activities, Yvonne Watson, EPA
MICRO LEAN Exercise (5 min) Use dots to apply to process boards posted around the room (5 min) Value Added Non-Value Added Necessary Non Value Added Feel free to add your comments during the day
Towards Full Integration Fully integrated online Ensure Legal Signature requirements are met Connect fillable pdf to database
Where We Are Now Implementation DC (January 30) West Virginia (Jan-June) Pennsylvania DEP (March) Planning Maryland Testing Virginia Completion Delaware PA Philadelphia PA - Allegheny
