Elise Rothschild, REHS Division Chief Environmental Management Department

1. HELP... Everyone wants my Data! A Look at Streamlining Environmental Health Programs Elise Rothschild, REHS Division Chief Environmental Management Department

2. Digital World

3. Impacts to Government

4. Mandated Electronic ReportingAB 2286 (2009) • Businesses and CUPAs must use the internet to file required program information into statewide electronic reporting system CERS (California Environmental Reporting System) in by Jan 1, 2013. • Businesses can opt to use the CUPA’s local reporting web portal. • Hazardous materials regulatory activities which include: • Filed chemical inventories , underground and aboveground storage tanks, and hazardous waste generation program information. • Includes inspection , violation and enforcement data. • 3 year electronic reporting fee of $25.00 for regulated businesses. This was collected by the CUPA and forwarded to CAL EPA. CAL EPA provided funds to CUPAs as grants to help pay for costs associated with this transition.

5. State of California • Sacramento is one of 58 Counties in California • 62 Environmental Health Departments • 200,000+ businesses • 83 CUPAs – Certified Unified Program Agencies (Regulate Hazardous Materials and Wastes Storage) • 146,000+ businesses

6. Environmental Compliance Division • Hazardous Materials Business Plans and Storage • Hazardous Waste Storage and Generation • Underground Storage Tanks • Above Ground Storage Tanks • California Accidental Release Prevention Program/Risk Management Plans (CAL-ARP) • Incident Response • Industrial/Commercial Storm Water Inspection • Septic Systems • Land Use Evaluations (Water/Waste) • HazMatLand Use • Cross Connection Control Program • Public/Private Small Water Systems • Solid Waste Facilities • Medical Waste • Business Recycling • Multi-Family Recycling • Recycled Water • Wells • Abandoned Wells ID Program • Toxic Site Cleanup Program

7. Cross-Connection Control Program (CCCP)

8. Regulatory Background • Federal Safe Drinking Water Act (SDWA) • Authorized national regulations to ensure safe drinking water served by public water systems. • States must adopt drinking water regulations that are as stringent as the federal rules. • State of California • California Health and Safety Code (CHSC) and Title 17 of the California Code of Regulations (17 CCR) were adopted in 1987.

9. Requirements • 17 CCR Section 7584 requires public water suppliers to adopt operating rules or ordinances to implement their CCCPs. • Conduct surveys of premises to identify hazards • Include provisions detailing backflow protection • Have staff trained in cross connection control to oversee CCCP • Maintain records of locations, tests and repairs of devices • Report to the California Department of Public Health (CDPH) a summary of their program data. • May delegate their program to the representative of the local health officer.

10. What is Backflow?

11. Delegation of Cross Connection Program - EMD • Work with 10 Public Water Agencies • 1987 – less than 1,000 backflow devices • 15,000 devices now managed • How can we create better efficiencies using technology?

12. Old Paper-Based Workflow

13. Challenge Before the Portal… • Over 4,000 annual staff hours spent on paper – based processes • Several thousands of printed pieces of paper for operators, water agencies and internal recordkeeping • Program cost recovery becoming difficult

14. How Does A Web Portal Work?

15. Advantages of A Web Portal • Eliminates the transfer of information from paper into a database. • Portal guides regulated community to submit information directly through portal which is then transferred into a database. • Regulated community can review their own submitted information and make updates or changes directly.

16. Developed New Web Portal

17. Test Report Entries Online Backflow Test Assembly Report Backflow Test Assembly Report Online Test Result Entry Proof of Test Result Submittal

18. Tester Certification Records Certification Management View Records

19. Pay fees online Online Tester Registration Purchase Annual Testing Tags

20. Streamlined Testing Letter Process • Simplified letter format • Reminder Letters and Test Reports are “auto-imaged” • Improves owners’ ability to track and manage testing compliance

21. Benefits Testers • “One stop shop” – registration, test reports and program fee payment all online • Proof of electronic test report submittal Water Agencies • Access to real-time testing information • Online recordkeeping for California Department of Public Health (CDPH) reporting

22. Cost Savings 9 Trees Saved Annually 7,800 gals of water saved annually

23. Hazardous Materials Business Plans California’s Conversion from Paper to Electronic Reporting

24. Federal Emergency Planning and Community Right To Know ActEPCRA 1986 California Community Right To Know Law 1986 Hazardous Materials Reporting Sara Title III US 42 CHP 116 subchapter 11§11021 and §11022 (§311 and §312) 29 CFR Section 1910.1200 (c) definition of a hazardous chemical (Fed Hazard Communication) • California Health and Safety Code (H&SC) Chapter 6.95 §25500 • California Health and Safety Code (H&SC) §25501 • definition of a hazardous material

25. FED EPCRA Reporting Requirements California Reporting Requirements Must file SDS (MSDS) with LEPC, SERC, and local Fire Department. SDS(MSDS) must identify the hazard categories for each substance: Acute , delayed and chronic health hazards, fire, reactive or sudden release. Stores 10,000 lbs of hazardous chemical or 500 lbs of an extremely hazardous chemical must file a Tier II Report with the LEPC, SERC, and local Fire Department • Must file a hazardous materials businesses plan with the local CUPA. • SDS(MSDS) must be available to the employees of the businesses. • Reportable quantities of 55 gallons, 500 lbs of a solid or 200 ft3of a compressed gas.

26. Definition of CHSC Division 20 Chapter 6.95 Article 1 §25503.5 Business that handles a hazardous material or mixture containing a hazardous material that has a quantity at any one time (during the reporting year) equal to or greater than • Total weight of 500 lbs • Total volume of 55 gallons • 200 cubic feet of a compressed gas • Shall submit its business plan to the local CUPA .

27. Is California the first State to enact Electronic Reporting? The federal reporting requirement applies to larger facilities with dedicated staff to manage regulatory requirements. In California, many “mom and pop” businesses that would fall under federal reporting requirements are regulated under California requirements.

28. California Hazardous Materials Regulatory Structure • Cal-EPA • DTSC • SFM • SWRCB • Cal-OES • Hazardous Waste • Tiered Permitting • (Treatment of Hazardous Waste) • Aboveground Tanks • Underground Tanks • Hazardous Materials Business Plan (EPCRA) • Cal-ARP (RMP) • CUPA

29. California Businesses Affected Total Regulated Businesses 146,000 Business Plan Program 123,983 Cal ARP Program 2,166 UST Program 14,513 AST Program 11,993 Hazardous Waste Program 87,689 Source Data: Cal EPA 2012 Annual Summary Reports

30. 4,328 annual submissions Paper Review… Plans had to be logged... And sent to Imaging. CDs of HMPs sent to Fire

31. New Workflow

32. CUPAs Collect Electronic Data CERS Multijurisdictional Businesses (i.e. AT&T) CUPA Database EMD Portal Local Businesses

33. Business Activities Information • Regulatory Program Status • Identifies which regulatory programs the business falls under

34. Business Owner/Operator Information • Identifies business owner, business operator, environmental contact, and emergency contact

35. Chemical Inventory Information • One form for each hazardous material or hazardous waste on site in reportable quantities (55 gal, 200 ft3, 500 lb). • Some materials are exempt or have higher reporting thresholds

36. Emergency Response Plan –Training Information • Local agency reporting phone numbers • Contingencies for an emergency or a release • List of emergency equipment onsite • Employee training

37. Site Map

38. California Environmental Reporting System (CERS) • HMBP data and inspection and enforcement data from CUPAs will be consolidated into the statewide database CERS

39. HMBP Portal Generates printable PDF version of familiar paper forms. Forms filled out online.

40. Accept / Decline a Plan • Business receives an email letting them know the status of their plan and a list of corrections required, if any.

41. Sacramento County’s Outreach and Education Efforts • Step by step user guide created. Available online for businesses to use as needed

43. Compliance Rates in Sacramento County Total regulated businesses: ~5,000 • ~4,000 businesses have submitted a complete HMBP • ~400 HMBPs in pending status awaiting review • ~400 HMBPs submitted, reviewed, sent back for corrections • ~200 facilities have made no effort to make an electronic submission

44. Consequences of Non-Compliance • The 200 current facilities with no attempt at electronic submission are receiving phone calls or inspections in an attempt to attain compliance • Enforcement action and penalties are the final step

45. Benefits of E-Reporting • Database with chemical inventory information, etc • Ease of use for businesses and regulators • Statewide consolidation of data • Consultants and Operators can access from anywhere • Easier to update / annually re-certify HMBP • Review of plan is done online, and business gets an email notification of submission status, or can log on to check status at any time • Sharing of information with other regulatory departments • Goal - Fire Responders can access actual data

46. Start Ups Project Management – Strategic Planning/Implementation Software Vendor – Decade Software IT Staff’s understanding of programs Staff Resources Student Interns Collaboration CUPA Forum Board CAL-EPA Unified Program Steering Groups TAG Groups Outreach/Training – Mom and Pop Businesses

47. Challenges • Back log of electronic submittals vs staff resources. • Staff ability to adapt to use of technology. • Network may not support newest version of software. • IT capability and program knowledge. • Legislative changes impact design of portal.

48. Leveraging Technology Other Implemented Technologies • Field Inspection Tablets • Smart Phones ( Data / Video / Pictures ) • Mobile Apps – Restaurant Inspections, Incident Response • Voice Over IP • Document Imaging, Indexing & Distribution • Electronic Public Access (Public Website) • Web Portal – streamline other EH Programs • Online Payments Now Available • Facebook Costs Time/Effort Regulatory Fees

49. Technology Partner