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Measuring Environmental Performance: Beyond the Beans – San Diego County’s EPIC Pilot Project. 16 th ANNUAL CIHC CONFERENCE December 4, 2006 presented by: Michael Dorsey, Chief Hazardous Materials Division County of San Diego Department of Environmental Health.
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Measuring Environmental Performance: Beyond the Beans – San Diego County’s EPIC Pilot Project 16th ANNUAL CIHC CONFERENCE December 4,2006 presented by: Michael Dorsey, Chief Hazardous Materials Division County of San Diego Department of Environmental Health
DECLINING ENFORCEMENT LEVELS: A SIGN OF SUCCESS OR AN INDICATOR OF PROBLEMS? • Environmental agencies are commonly criticized when the number of enforcement cases decline. • The number of enforcement actions may decrease for a number of reasons, some positive and others negative. • It may reflect lax government follow-up or a reduced number of inspections. • It may reflect improved compliance by the regulated community. • Without more information and better outcome measures, enforcement levels alone don’t provide a complete picture of performance.
ARE THERE BETTER WAYS TO MEASURE PERFORMANCE? • Find and target environmental and non-compliance problems; • Motivate regulated parties to reduce their negative impacts on the environment; • Assess and depict program effectiveness more accurately; and • Communicate program effectiveness to EPA, Cal/EPA, federal and state legislatures, and the public.
Directive: OEHHA to collaboratively develop and maintain environmental indicators Project’s initial goals: • a process for identifying and selecting environmental indicators; and, • an initial set of indicators The Environmental Protection Indicators for California (EPIC) Project
Results-Based Managementrelies on…. • Measurements of outcomes/results as part of a system that tracks resources and activities; • A structure for reporting and analyzing the measurements; • Adjustments to planning and implementation efforts to meet our mission.
UNIFIED PROGRAM EPIC PILOT PROJECT • Measuring Unified Program Compliance Through Education • Hazardous Waste Generator Program; Hazardous Materials Business Plan Program; and Medical Waste Management Program (San Diego County Department of Environmental Health). • Underground Storage Tank Program (Sacramento County Department of Environmental Health).
UNIFIED PROGRAM EPIC PILOT PROJECT (Cont.) • Project Description: • Focus on a narrow set of indicators (selected violations) in an industry sector • Establish a baseline • Measure impact of educational outreach on compliance
GOALS AND OBJECTIVES • Goal: Reduce non-compliance of Unified Program Agency violations through education and outreach. • Objectives: (1) Demonstrate that education and outreach can be effective tools in obtaining compliance from the regulated community; and (2) Establish a risk-based inspection process that can be used to assist in directing resources to areas of high risk and non-compliance.
PERFORMANCE MEASURES • Reduce by 25% the top ten most common violations combined from the following categories by July 1, 2006: • Hazardous Waste/Tiered Permitting • Hazardous Materials Business Plans • Medical Waste • Reduce the top ten most common violations combined from the following categories by an additional 25% by July 1, 2007: • Hazardous Waste/Tiered Permitting • Hazardous Materials Business Plans • Medical Waste
INCENTIVES • Reduce inspection frequency for R&D Laboratories and Biotechnology businesses from 18 to 36 months for FY 07-08. • Institute a flat fee for Biological R&D laboratories and Biotechs to reflect 36-month inspection frequencies for FY 07-08. • UST & Med Waste LQGs retain 12-month statutory inspection interval. SNC status would trigger return to the 18-month inspection interval and a comparable fee schedule.
SNC STATUS • Significant non-compliance (SNC) for this project is either: • One significant violation, or • Three violations that cannot be corrected during an inspection. • A combination of repeat minor violations and other violations. • A facility in a SNC status will be inspected every 18 months instead of 36 months, and • Permit fees will return to original fee schedule
FUTURE TASKS • Determine who qualifies for reduced inspection frequency • Develop the flat fee structure • Continually update the most common violation list and adjust outreach process • Develop an continued education/certification process • Publish the results of the project in an environmental journal • Develop new topics for education and training • Refine performance measures as needed.
Building a Results-Based Management System Plan Setting goals and objectives Formulating strategies Adapt Modifying plans or actions to improve performance Do Carrying out actions to accomplish objectives Check Implementing the evaluation system