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POST INSPECTION LETTER REINFORCES THE INSPECTION AND ENCOURAGES COMPLIANCE

The post-inspection letter by EPA New England aims to encourage compliance and provide valuable environmental resources to inspected facilities. This comprehensive document includes information on compliance, pollution prevention, and more, maximizing the impact of inspections. The letter has been well-received and has led to improvements in environmental performance. It also addresses enforcement issues and can be customized by states to suit specific sectors.

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POST INSPECTION LETTER REINFORCES THE INSPECTION AND ENCOURAGES COMPLIANCE

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  1. POST INSPECTION LETTER REINFORCES THE INSPECTION AND ENCOURAGES COMPLIANCE September 29, 2005 Maggie Theroux 617-918-1613 theroux.maggie@epa.gov EPA New England

  2. What is the Purpose? • Reach every facility that we inspect • Provide compliance and “beyond compliance” info via the Attachment or the Region’s "Solutions" web site • Help facilities to improve their environmental performance at a time when they have an incentive to listen • Maximize the environmental impact of our inspections with .10 FTE Please note: It is not a “close out” letter.

  3. What type of Information is included in the Attachment? • Access to web resources for: • Compliance assistance • Sector specific information • Pollution prevention • Energy efficiency • Green buildings • Environmentally-preferable purchasing • Technology Connection • Environmental Management Systems • Recycling • Enhanced security

  4. EPA Internal Approval Process • Text of letter & attachment reviewed in FY’02 by: • Region 1 Assistance & P2 manager & staff • Region 1 Enforcement management, attorneys, & inspectors • Regional Administrator • OECA

  5. What is the Process? • Enter the facility inspection data & contact information into ICIS • Create an ICIS report & eliminate duplicates • Review the list of facilities

  6. What is the Process? • Use the report to create the Letters which are signed by the A&P2 manager • Send the Letter & Attachment to recently inspected facilities • Update the Attachment & web site every 6 months

  7. Results • Sent 432 letters since November, 2002 • Received 3,221 page requests on the “Solutions” web site • Most popular information: P2, Compliance Assistance, Sector Specific, & Recycling • Measurement survey – 8/03 • Received OECA Best Practice Award – ’04 • Now being considered by other Regions

  8. Measurement Survey – 8/03 • 7 out of 9 remember receiving the letter & reviewing the attachment • Some remembered visiting the web sites for CA info & regulations, & Sector Specific • 5 out of 9 knew they needed to make improvements & 4 of these were already making the changes

  9. Measurement Survey – 8/03 • Overall, the results emphasized the importance of getting back in touch with inspected facilities.

  10. Enforcement Issues Addressed • Limiting use of Enforcement resources • Avoiding impression that we are pressuring facilities into making environmental improvements • Complicating penalty negotiations if companies argue that they are owed reductions due to actions taken

  11. How can it be used by the States? • Customize the Letter & Attachment • Copy the "Solutions" web site • Make sure your inspection data entry system includes facility contact information • Add topics for specific sectors • UST example – 1,689 page requests from 12/02-6/04

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