Gas Compliance: How accurate is the data you use to make informed decisions?
In a regulated environment it is absolutely vital that the data used to make informed decisions is wholly accurate, up to date, robust, open and transparent. Poor quality data, or worse still, a lack of data, leaves the organisation critically exposed. This can ultimately lead to reputational damage, fines, downgrades, or worse.
Despite recognising this, research has shown many Housing Associations are still operating with data that is typically static in nature, spreadsheet driven and prone to human error. This approach, it is argued, is delivering “reassurance” as it takes a retrospective view of works undertaken. It does not provide true “assurance” via real time, dynamic data management.
Furthermore, the data that is relied upon to demonstrate compliance comes from a source who can have a vested interest in presenting a positive case, so is this data truly independent and impartial?
The good news is that the advancement of technology can now deliver a real time, dynamically verified data solution that is not only robust, but is also transparent, completely impartial and can provide true assurance.
This paper therefore serves to reflect on current approaches to data management within gas compliance and how risk is managed out of the process through technology enablement.
Data Management within gas compliance
According to Forbes Insights and KPMG “2016 Global CEO Outlook,” 84% of CEO’s are concerned about the quality of the data they are basing their decisions on. It is therefore no surprise that CEO’s are challenging the veracity of the data they are presented. Let’s face it, has anyone ever presented a case for investment to a CEO with a spreadsheet that doesn’t provide a positive payback!
When operating in a regulated environment, and specifically when it comes to gas compliance, the reliance upon accurate data is absolutely critical to avoid the “red face challenge!” With the CEO’s of organisations being ultimately accountable for gas compliance, expect the data presented to be rigorously challenged along with the methods deployed to assure data quality and ultimately the validity.
Despite this, in gas compliance many social landlords still operate or accept from their contractor traditional methods of data capture (paper returns, spreadsheets, legacy systems) which are not only labour intensive to operate but prone to human error. The data is static in nature, reports tend to be “clunky,” take an inordinate amount of time to produce, and information most certainly isn’t presented in real time.
There are admissions that more can be done to improve data. There are significant gaps in the data assimilated, and alarmingly a lack of awareness of accountability, especially where data is provided by the contractor. Whilst you can devolve responsibility [to get the job done], you can’t devolve accountability [ultimate responsibility] – a point which is often overlooked, or misunderstood.
The speed of change in the digital age is enabling a seismic shift in the data arena. Interoperability between systems, processing power, cloud computing, mobile technology, data science, etc are driving the digitalisation of information and allowing for real time, dynamic verified data to replace the traditional “static” models.
Against this background the pertinent question to ask about your data management strategy should be “does your current approach deliver true assurance, or just a level of retrospective reassurance……?”
Below are examples of opportunities to engineer out the risk, cost and human error factors associated with traditional methods.
- Gas Engineer Checks
How do you know that the Engineer turning up to a property is Gas Safe registered and actually the individual who is undertaking the work?
Engineers visiting properties will display a Gas Safe card and show this to a resident. But who is checking the credentials of the engineer, the work they are accredited to undertake, whether their Gas Safe registration details are up to date and as an extreme, whether the Gas Safe card belongs to that individual! It is unfair to expect the resident to do this and they will typically be more concerned with whether the engineer would like a brew. Having met with a number of RSL’s, there is a significant variance in approach. Where checks take place, these are typically being undertaken on a manual spreadsheet usually on a weekly / monthly basis. It was acknowledged that this was not only resource intensive but the information dated as soon as the information was inputted on the spreadsheet, so administratively they were constantly chasing their tails. Some organisations who use contractors simply expect the contractor to ensure engineers registration with the Gas Safe Register is up to date, with no checks being completed by the RSL and the contractor not being asked to evidence competency of their engineers / sub-contractors.
Fundamentally best practice would dictate that there is a process to assure the organisation that the Engineer is fully competent and has an up to date registration with the Gas Safe Register at the point he / she undertakes the work. In an ideal world, this would mean keeping a list of all engineers and checking before each job their competency based on the Gas Safe Register. Based on traditional methods this would be impractical to administer. However, due to technological advancements this is now achievable.
The Gas Tag system has a direct link to the Gas Safe Register database and not only checks that the engineer is a valid Gas Safe registered engineer in real time at the point they commence the work but also verifies the categories of work. As a fail safe, If they aren’t registered then they can’t access the Gas Tag system. If they are, then their registered categories of work are pulled through from the Gas Safe Register so the engineer can only undertake work that they are suitably qualified to do at that point in time. This not only mitigates a significant amount of risk, but this real time data feed also saves a significant amount of back office administration and time at a hidden cost to the organisation.
- Assurance that the Gas Safe Engineer is physically at the property
It is widely accepted that due to human nature, there will always be a possibility of a “drive by” service. Operating under the pressures of a target culture driving volume of daily services, through to there being a large dog which looks somewhat intimidating, the engineer may be persuaded to complete his inspection from his van! Most organisations recognise this and attempt to mitigate the risk by utilising GPS trackers on vans, but also acknowledge that this will only confirm that the engineer was parked up near the property and is therefore at best just a partial solution.
With technological advancements, it is now possible to install a “Gas Tag” at a property which takes literally seconds to do. Engineers firstly tap their mobile device against the Gas Tag to “sign in” to the property. They are then accountable for all work carried out at the property. Each element of the work is then Geo-tagged and Time/Date stamped to independently prove that the engineer is on site when the work is carried out and that it is carried out when and where it should have been. Furthermore, the “time on site” for engineers is also automatically captured by the Gas Tag system. All this data is available at the click of a button and, as Gas Tag is impartial, the data is not only impartial but also independently verified.
- Information collation from the Gas Engineer’s visit
Again, the traditional methods for data capture range from paper based systems prone to error, through to electronic repositories of information which are ordinarily difficult to analyse, interrogate and report on. What is alarming is that it is this information that is used to report on gas compliance and to make informed decisions on repairs and maintenance.
Where contractors are engaged, important questions to consider are who owns the data, how open and transparent is the data (noting it will most probably be eye balled by the contractor before being shared) and how granular is the data?
Should there be an incident which requires an investigation, how quickly and comprehensive can a response be given? Would an in-date LGSR suffice or could the whole workflow from a particular visit be provided at the click of a button?
The Gas Tag system provides an intuitive workflow which not only time/date stamps the engineer’s work, but prompts the engineer to take photographs of particular elements of the work. All photographs are geo-tagged and time/date stamped. The photographs are uploaded to the Gas Tag portal in real time and attached to the work record. A Landlord can access all this data via their Gas Tag Dashboard. This provides a data rich picture in real-time, and enables desk based audits of engineers’ work. Furthermore, the data can be utilised to make informed decision, or in the event of an incident provide at the click of a button an impartial view of the work undertaken at a particular property.
- Is the claim of gas compliance supported by the data
Clearly every organisation aspires to be 100% compliant and sets up their processes and approach to deliver this. However, how many organisations have a real-time view on compliance, by the minute? How accurate is the claimed percentage compliance and what assumptions have been factored in?
Where contractors are engaged is there full transparency? Does the contractor have a vested interest in providing data to support their performance on a contract which ultimately is measured by compliance rates? How often does the data and compliance get challenged!
Gas Tag provides a real-time picture of compliance based on independent and impartial data; no assumptions are necessary. The overarching compliance position stems from information collated from every engineer visit. This data is presented on an informative Dashboard which allows for drilling down to the micro level. At any time a Landlord can view compliance statistics, they can analyse risk / exposure, and can interrogate the work undertaken by any engineer across any property within their portfolio.
- No Access
Another headache for RSL’s is No Access attempts, plus the associated time and cost of intervening to manage access and disputes where initial attempts have failed. Reliable and robust data is required to categorically prove attempts were legitimate.
The Gas Tag system geo-tags the engineer and time/date stamps them to prove they are at the property. Furthermore, the Gas Tag App forces them to take a photo of the front door as proof they were there. A reporting dashboard then allows the landlord to analyse No Access trends, and could identify, as an example, that No Access attempts appear to peak at 3:30 on a Friday afternoon for a particular engineer. Furthermore, as Gas Tag is impartial, an unbiased view can be presented as required.
It is critical that the data used to make informed decisions on Gas Compliance is wholly accurate, up to date, robust, open and transparent.
Operating in a regulated environment it can be argued that whilst you can devolve responsibility to get the job done, you can not ultimately devolve accountability. As such Landlords are recognising more needs to be done; 54% in a recent service stated they believe gas compliance systems could be improved.
Within the gas compliance environment there is the technological capability to provide real-time dynamic data very cost effectively. This data is impartial, independent and delivers a true insight across your property portfolio. The benefits of adoption are compelling as the output will allow for informed management decisions, complete assurance on the true position of gas compliance, and provide demonstrable cost savings – including significant reduction in intensive back office processes.
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