Compliance Assistance Program at the US
Environmental Protection Agency
Michael M. StahlDirector, Office of Compliance
U.S. EPA
Presentation at
The Regulatory Craft in Nova Scotia 2007
November 20, 2007
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Presentation Outline Enforcement and compliance program
overview Role and benefits of compliance
assistance Examples of EPA’s compliance
assistance tools Measuring results of assistance Integrating assistance with other tools Lessons learned
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EPA Enforcement and Compliance Program
Compliance Assistance is one “tool” used to address environmental problems. The other tools are:
Compliance monitoring (e.g., inspections) Compliance Incentives Enforcement
Often used together as part of integrated strategies or approaches to solving problems
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Compliance Assistance - Definition
Activities, tools or technical assistance which provide clear and consistent information for:
The regulated community – to help them understand, meet obligations under environmental regulations
Compliance assistance providers - state and local governments, trade associations, nonprofits - to aid the regulated community in complying with environmental regulations
Includes web sites, plain-language guides, fact sheets, onsite visits, training etc.
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Compliance Assistance Providers
EPA partners with other providers of assistance, including:
State and Tribal governments Local governments Trade associations Nonprofit organizations Academia
EPA works with these organizations to: Develop and deliver assistance resources Maintain a repository of information on assistance
resources Consistently measure results of assistance
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Benefits of Compliance Assistance Prevents violations from occurring Simplifies compliance requirements
for regulated facilities and companies
Aimed at small and medium-sized businesses
Reaches large audiences (as compared with case-by-case approach of enforcement)
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CA Activities – Entities Reached
590673 721
870731
1,164
612
1,443
878
1,879
0200
400600
800
10001200
14001600
1800
2000
To
tal
En
titi
es R
each
in
T
ho
usa
nd
s
2002 2003 2004 2005 2006
Fiscal Year (FY)
Number of Entities Reached with Compliance Assistance (exceptCenter Users)
Number of Users of EPA-Sponsored Web-Based ComplianceAssistance Centers
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CA Tools - Examples Industry Sector Notebooks - Profiles on 36 specific industries and governments that describe
processes and applicable regulations.• http://epa.gov/compliance/sectornotebooks.html
Environmental Audit Protocols - Assists the regulated community in developing programs at
individual facilities to evaluate their compliance with environmental requirements under federal law.
- provide detailed regulatory checklists that you can be customized to meet specific needs.
- http://www.epa.gov/compliance/incentives/auditing/protocol.html Managing Your Environmental Responsibilities: A Guide
for the Construction Industry - Information on environmental requirements for the
construction and development industries with a checklist to help assign environmental responsibilities. http://ww.epa.gov/compliance/resources/publications/assistance/sectors/constructmyer/index.html
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Compliance Assistance Centers
Fifteen web-based, sector-specific compliance assistance centers
First-stop information source for industry sector Identifies the federal environmental regulations
that apply to them Provides guidance on how to comply with
regulations Identifies pollution prevention approaches that can
save them money
Since 1998, the Centers have had over 8 million user sessions through the end of FY2006.
www.assistancecenters.net
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Compliance Assistance Centers www.assistancecenters.net
Services
Automotive Service and Repair
Automotive Recycling
Health Care
Paints and Coatings
Printing
Transportation
Border Center
Education Sector (pending)
Manufacturing
Metal Finishing
Agriculture Printed Wiring Board
Construction
Chemical Manufacturing
Government
Local Government
Federal Facilities
Tribal
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Virtual Tours
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On-Line Tools
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Border CA Center
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National Compliance Assistance Clearinghouse
Web-based tool for assistance providers to share information on their projects Find assistance information quickly Share latest assistance tools Learn what others are working on Share success stories with other providers Tell EPA what assistance tools are needed Share information to boost providers’ web
content
www.epa.gov/clearinghouse
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Outcomes of FY2006 Direct Compliance Assistance Activities In FY2006, EPA provided direct CA
(workshops, trainings, onsite visits, response to public inquires, etc.) to over 74,000 regulated entities.
Outcome results from direct assistance continue to be high in FY06: 94% increased understanding 74% improved environmental management
practices 28% reduced or eliminated pollution
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CA Centers Outcomes90%
72%
48%
84%77%
46%
88%82%
55%
0%
20%
40%
60%
80%
100%
IncreasedUnderstanding of
Regulations
Action Taken Pollutant Reductions
Outcomes Reported from Regulated Entities Responding to OnLine Survey
To
tal P
erc
en
tag
e 2004
2005
2006
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Integrating Assistance with Other Tools Maximize outcomes by using a
combination of: Compliance assistance Monitoring Incentives Enforcement Other Tools
Sequence of these activities is critical to success
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Inspectors Often Provide CA During Compliance Inspections EPA policy allows inspectors to provide
compliance assistance during inspections.
Inspections offer a “teachable moment” for assistance.
In FY2006, 58% of the facilities EPA inspected received compliance assistance (over 11,00 facilities).
www.epa.gov/oeca/inspector/
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Integrating Assistance with Other Tools: Healthcare
Environmental Problems Identified: Hazardous Waste Identification,
Labeling and Manifest Violations. HW Container Management and
Storage CFC and UST Leak Detection. Oil Spill Contingency Plans Personnel Training Requirements.
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Integrating Assistance with Other Tools: Healthcare
Goals of Regional Initiative: Improve environmental compliance
and safety at healthcare facilities. Ensure compliance of entire sector;
not just those reached through inspections.
Ensure continued compliance by implementing permanent changes.
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Hospital Wastes
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Integrating Assistance with Other Tools: HealthcareRegion combined the following strategies to address
compliance issues in this sector:
Provide environmental assistance to healthcare facilities
Encourage healthcare facilities to perform voluntary compliance audits and enter into audit agreements
Conduct inspections and undertake enforcement
Identify pollution prevention opportunities and encourage use of Environmental Management Systems
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Integrating Assistance with Other Tools: Healthcare
Compliance Assistance Results Held 11 “Environmental Compliance 101”
Workshops and a series of hazardous waste identification and management seminars
Develop 118 CA Tools (e.g., CD-ROMS, websites, checklists, etc.)
Entities reached through workshops: 5,000
Entities Reached via other CA: 25,290
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Integrating Assistance with Other Tools: Healthcare
Results from Other Tools: 58 Inspections resulting in 39
enforcement actions Over $1.5 Million in Assessed Penalties 42 Audit Agreements with 189
Voluntary Disclosures covering 688 facilities
Almost 4,000 violations corrected
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Changes in Understanding – Very High Responses
PROGRAM BEFORE AFTER
RCRA 40 98
AST 9 75
UST 34 88
CAA 27 76
CWA 24 70
SPCC 14 83
TSCA 14 61
Pesticides 36 76
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Top Five Pollutant Reductions
Battery Recycling 15 tonsMedical Waste Segregation 475 tonsElectronics equipment recycling 75 tonsSharps containers 10,500 unitsIntegrated pest management 80%
reduction in pesticides
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Integrating Assistance with Other Tools Similar projects in other sectors:
Concentrated Animal Feeding Operations
Construction Auto Salvage Yards Marinas Colleges/Universities
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Guide for Addressing Environmental Problems: Using an Integrated Strategic Approach
Explains a 9-element strategic approach to address environmental problems
Promotes consistency in planning, implementing and measuring strategic approaches
Provides a means for documenting the decision-making process
www.epa.gov/compliance/resources/ policies/assistance/strategicguide.pdf
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Lessons Learned Consult stakeholders during
development of assistance tools Assistance can have a broader
“reach” than other tools Consider needs of small businesses Inspections offer “teachable
moment” for assistance
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Lessons Learned Strong enforcement program helps
assistance
Use assistance with other tools to maximize results
Measure outcomes of assistance
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EPA Compliance Assistance Resources
www.epa.gov/compliance/assistance
www.epa.gov/clearinghouse
www.assistancecenters.net
