&EPA
United States
Environmental Protection
Agency
EPA 300-F-95-002
January 1995
Enforcement And Compliance Assurance (2225A)
The Office Of
Compliance
An Introductory Guide
COMPLIANCE
ASSISTANCE CENTERS
COMPLIANCE MONITORING
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OFFICE OF COMPLIANCE
Enforcement Planning,
Targeting and Data Division
Manufacturing, Energy
and Transportation Division
Chemical, Commercial Services
and Municipal Division
Agriculture and
Ecosystem Division
Planning Branch
Targeting and
Evaluation Branch
Manufacturing Branch
Energy and
Transportation Branch
Chemical Industry Branch
Commercial Services and
Municipal Branch
Agriculture Branch
Laboratory Data
Integrity Branch
Data Management
Branch
Resource Management
^— Team
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BACKGROUND
EPA Enforcement: The New Alignment
On June 8,1994, the Environmental Protection Agency established
a new Office of Enforcement and Compliance Assurance (OECA),
consolidating a number of functions formerly shared among sev-
eral different programs at EPA. This brochure introduces the Of-
fice of Compliance (OC), one of several offices established within
the new organization.
Office of Compliance Mission
The overriding mission of the Office of Compliance is to improve
compliance with environmental laws. OC will achieve this by:
• setting national compliance assurance and enforcement
priorities through strategic planning and targeting;
• collecting and integrating compliance data;
• developing effective compliance monitoring programs to
support inspections and self-reporting;
• building the capacity for more effective compliance assis-
tance to the regulated community;
• improving the quality of regulations;
• working with Regions, States, municipalities, citizens groups
and industry; and
• supporting enforcement activity.
Office of Compliance Organization
The Office of Compliance is comprised of four divisions. One Divi-
sion is responsible for strategic and annual planning to set compli-
ance assurance and enforcement priorities; State/tribal grant guid-
ance; targeting for inspection/enforcement activity; data man-
agement; and integration of compliance and enforcement data
from EPA program offices. Three Divisions organized by economic
sector will develop strategies to identify patterns of noncompli-
ance within the regulated community; support Federal enforce-
ment actions through inspection guidance and better compliance
monitoring techniques; and help the regulated community un-
derstand and comply with complex federal requirements.
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MAJOR OC FUNCTIONS/ACTIVITIES
STRATEGIC PLANNING
/ Develop short and long-term compliance monitoring and enforcement
priorities, including State/tribal grant ' '
grant guidance
RISK-BASED TARGETING
/ Focus compliance assurance/enforcement resources on
environmentally significant facilities through risk-based targeting
/ Develop targeting approaches that result in high compliance rates,
ecosystem protection and environmental justice
DATA INTEGRATION, MANAGEMENT AND ANALYSIS
/ Integrate geographic, corporate, pollutant, media, and industry-
specific data to support monitoring and targeting functions
/ Conduct detailed analyses of industry sectors to target compliance
and enforcement activities
/ Develop accurate measures of success for enforcement and
compliance activities
COMPLIANCE MONITORING
/ Develop inspection and monitoring guidance and training
/ Provide Regional, State and program office support on regulatory
matters and rulemakings relating to compliance monitoring
COMPLIANCE ASSISTANCE
/ Focus the presentation and communication of environmental
requiremenfs to the regulated community
/ Deliver clear, concise industry-specific technical and regulatory
information to States, Regions and the regulated community
ENVIRONMENTAL AUDITING/LEADERSHIP
/ Build partnerships with the regulated community to encourage facilities
to go beyond compliance
/ Recognize outstanding compliance records and pollution prevention
results
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MAJOR OC PROJECT CONTACTS
Common Sense Initiative - Printing Sector
Ginger Gotliffe
Ecosystems Management
Walter Brodtman
Enhanced Monitoring Rule
Scott Throwe
Electronic Data Interchange
Lucy Reed
Environmental Auditing
Geoff Garver
Environmental Justice
Pat Alberico
Environmental Leadership Program
Tai-Ming Chang
(202) 564-7072
(202)564-4181
(202)564-7013
(202) 564-5036
(202)564-5017
(202)564-5017
(202)564-5081
Expansion of C.A.A. Section 507 Enforcement Response Policy
Elliott Gilberg
IDEA Analyses
Bruce Rothrock
International GLP Agreements
David Dull
Sector Notebooks Project (industry profiles)
Mike Barrette
Small Town Compliance Assistance Strategy
Ken Harmon
Targeting Network
Rick Duffy
Worker Protection Strategy
Phyllis Flaherty
(202)564-2310
(202) 564-2375
(202) 564-7049
(202)564-7019
(202) 564-7049
(202) 564-2345
(202) 564-2355
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PLANNING, TARGETING AND DATA
Strategic Enforcement Planning
The Enforcement Planning, Targeting and Data Division (EPTDD)
develops the strategic plan for all compliance assurance and
enforcement functions at EPA. The ultimate goal of EPTDD is to
focus the Agency's compliance assurance and enforcement re-
sources on noncompliance problems that are pervasive and rep-
resent the greatest risk to human health and the environment. To
supplement single-media compliance indicators now used for tar-
geting, EPTDD is developing new measures of facility-level com-
pliance with all environmental laws. Compliance data analysis is
being used extensively to establish targeting priorities, and mea-
sure the success of national and State enforcement programs.
Developing Targeting Priorities
Data integration efforts by the EPTDD will improve the targeting
of compliance and enforcement activities at EPA. Compliance
profiles will be developed from historical records, pollution release
data, corporate compliance rates, and geographic/demo-
graphic characteristics. The IDEA (Integrated Data for Enforce-
ment Analysis) system, managed by EPTDD, has the capability to
integrate these data elements from other EPA single- media da-
tabases. Based upon data analysis results, initiatives will be de-
veloped by EPTDD, the Sector Divisions, and other offices within
OECA to address concerns arising within industrial sectors, sensi-
tive ecosystems, and environmental justice areas.
Improving Environmental Success Measures
Risk-based measures of enforcement activities and compliance
results are being developed by EPTDD to gauge the environmen-
tal impact of national and State enforcement programs. As these
measures are refined, EPTDD will continue to work with Regional,
State and tribal groups to promote effective enforcement strate-
gies and ensure consistency of compliance and inspection data.
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DEVELOPING SECTOR STRATEGIES
Using the "Sector" Approach to Improve Compliance
Traditionally at EPA, work has been divided along single-media
statutory lines - air, water, waste and toxic substances. Within the
Office of Compliance, all compliance issues related to a specific
economic category (or industrial group) are handled by staff units
specializing in that particular sector. This multi-media orientation is
expected to improve compliance rates in several ways.
Identification and Targeting of Noncompliance Patterns: The Sec-
tor Divisions will identify patterns of noncompliance within specific
economic sectors, and devise appropriate compliance assurance
and enforcement strategies to correct violations. That effort will
include publishing periodic compliance profiles for specific indus-
tries.
Support for the Enforcement and Compliance Assurance Program:
The Sector Divisions will support the enforcement and compliance
assurance program through inspection guidance, by improving
compliance monitoring, and by providing technical advice where
needed to support major enforcement actions. The specific in-
dustry expertise in the Office of Compliance will be critical to these
functions.
Development of Compliance Assistance Programs: The Sector Di-
visions will develop programs that help to organize and better ex-
plain different environmental requirements that affect the same
industry. As a first step, the Office of Compliance is developing
"compliance service centers" to help those small business sectors
with significant regulatory requirements.
Media Programs
The Sector Divisions are also responsible for those compliance ac-
tivities (e.g., regulatory development, inspection guidance) that
OECA performs for media programs. See page 12 for information
on these responsibilities.
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OC DIRECTORY
OFFICE OF COMPLIANCE Mail Code - 2221 -A
Elaine Stanley, Director 202-564-2280
Eric Schaeffer, Deputy Director 202-564-2280
ENFORCEMENT PLANNING, TARGETING AND DATA DIVISION (2222-A)
Frederick Stiehl, Director 202-564-2290
Pat Alberico, Deputy Director 202-564-2290
Bob Heiss, Senior Legal Advisor 202-564-2290
Planning Branch
Responsibilities: Strategic planning, OECA priority setting, state grant and
operating plan coordination, and inter-agency Memoranda of Under-
standing with other Federal agencies
Jack Neylan, Branch Chief 202-564-2385
Rita Smith, MOA Team 202-564-5044
Phil Milton, Strategic Planning Team 202-564-5029
Karen Milne, RCRA Import/Export Team 202-564-5028
Data Management Branch
Responsibilities: Compliance data system management (e.g., AIRS,
NCDB, PCS, RCRIS, SETS, Enforcement Dockets), data integration (IDEA),
training and user support
Carol Galloway, Branch Chief 202-564-2375
Bob Zisa, Program Regional Liaison Team 202-564-5048
Chris Nugent, System Support and Analysis Team 202-564-7051
Bruce Rothrock, Integration Team 202-564-5038
Mike Mundell, Systems Operations Team 202-564-5031
Bob Small, Import/Export Team 202-564-5043
Resource Management Team
Responsibilities: Contracts management, budget formulation, financial
management, OC administrative activities, and Freedom of Informa-
tion Act tracking
Roberta Miller, Team Leader 202-260-7691
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OC DIRECTORY
ENFORCEMENT TARGETING, PLANNING AND DATA DIVISION (continued)
Targeting and Evaluation Branch
Responsibilities: Risk-based targeting, compliance rate analysis, regional/
state program evaluation, success/performance measures, and accom-
plishment reports
Rick Duffy, Branch Chief 202-564-2345
Joseph Acton, Measures of Success 202-564-5002
Gerald Lappan, Targeting Network 202-564-5024
Daniel Palmer, Regional Reviews 202-564-5034
AGRICULTURE AND ECOSYSTEM DIVISION (2225-A)
Rick Colbert, Director 202-564-2320
David Dull, Associate Director 202-564-2320
Agriculture Branch (AB)
Regulated sectors: Agricultural production (crops/livestock), forestry, fish-
ing, hunting, agricultural chemicals, irrigation systems, farm, lawn sup-
ply, pest control, public lands, wildlife and forests
Phyllis Flaherty, Branch Chief 202-564-2355
Walter Brodtman, Ecosystems Team 202-564-4181
David Stangel, Agriculture, FIFRA Issues Team 202-564-4162
Steve Howie, Agriculture, FIFRA Issues Team 202-564-4146
Laboratory Data Integrity Branch (LDIB)
Responsibilities: Implementation of the Laboratory Data Integrity Assur-
ance and Good Laboratory Practice (GLP) programs
Francisco Liem, Chief 202-564-2365
Fred Siegelman, Non-GLP Issues Team 202-564-4159
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OC DIRECTORY
MANUFACTURING, ENERGY AND TRANSPORTATION DIVISION (2223-A)
John Rasnic, Director 202-564-2300
Richard Biondi, Associate Director 202-564-2300
Manufacturing Branch (MB)
Regulated sectors: Mining, textile mills, lumber, wood, furniture, paper &
allied products, rubber, leather, stone, clay, glass, concrete, primary
metals, fabricated metal, electronic equipment, manufacture of trans-
portation equipment and machinery, computers, and woodstoves
Mamie Miller, Branch Chief
Scott Throwe, Enhanced Monitoring Team
Greg Waldrip, Metals Team
Seth Heminway, Wood Products Team
Robert Marshall, Woodstoves Team
202-564-2395
202-564-7013
202-564-7024
202-564-7017
202-564-7021
Energy and Transportation Branch (ETB)
Regulated sectors: Coal mining, oil/gas extraction, petroleum refining,
transit, USPS, transportation (air, land, rail, water), pipelines, communi-
cations, electric & gas utilities, steam production, petroleum bulk stor-
age & terminals, and auto repair/dealers/services
David Lyons, Branch Chief 202-564-2405
Tom Ripp, Petroleum Refining Team 202-564-7003
Ted Coopwood, Power Generation Team 202-564-7058
Virginia Lathrop, Transportation Team 202-564-7057
Everett Bishop, Auto Services and Repair Team 202-564-7032
Gary Polvi, Inpections and Inspector Training Team 202-564-7056
Joanne Callahan, Radionuclies Team 202-564-5009
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OC DIRECTORY
CHEMICAL, COMMERCIAL SERVICES AND MUNICIPAL DIVISION (2224-A)
Susan Bromm, Director 202-564-2310
Elliott Gilberg, Associate Director 202-564-2310
Chemical Industry Branch (CIB)
Regulated sectors: Manufacture and formulation of chemicals and al-
lied products including plastics, synthetic resins, synthetic rubber, phar-
maceuticals, detergents, cleaning agents, soaps, cosmetics, paints,
varnishes, lacquers, enamels, wood chemicals, dyes, explosives, inks, ad-
hesives, and sealants
Ken Gigliello, Branch Chief
Emily Chow, Combustion & CFC Compliance Team
Commercial Services and Municipal Branch (CSMB)
202-564-2524
202-564-7071
Regulated sectors: Building construction, food products, tobacco, print-
ing and publishing, sewers and wastewater treatment, municipalities,
hazardous/solid waste facilities, wholesale trade, building materials, food
stores, furniture stores, restaurants, retail, real estate, medical waste,
health service, and dry cleaners
Mimi Guernica, Branch Chief
George Gray, Municipal Issues Team
Karen Leff, Commercial Services Issues Team
202-564-2415
202-564-7069
202-564-7068
'To be most effective in measuring compliance and im-
proving targeting of enforcement resources, national en-
forcement strategies should increasingly be organized
around 'sectors' of the economy."
- EPA Administrator Carol Browner
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REGULATED SECTOR INDEX
Below is an index of regulated sectors with the appropriate
Branch-level contacts. Phone listings appear on the previous
pages. Questions pertaining to sectors not listed below should
be directed to the Branch handling similar types of industries. *&•
Agricultural - (General - livestock, crops)
Agricultural chemicals - pesticides/fertilizers...
Air transportation
Amusement/recreation services/sports
Auto dealers/service stations/repair
CFCs
Construction
Coal mining
Commercial waste industry (Hazardous and Solid)
Communications
Detergents/cleaning & finishing agents
Disinfecting and pest control services
Drugs/pharmaceuticals
Electric power generation
Electronic/electrical equipment and computers
Explosives, inks, adhesives, sealants
Farm raw materials
Fishing/hunting/trapping
Food/kindred products and food stores
Forestry
Furniture stores
Furniture/fixtures (manufacture of)
Health services/hospitals
Heavy construction (Buildings...)
Industrial inorganic chemicals
Industrial organic chemicals
Irrigation systems
Leather and leather products
Lumber and wood
AB
AB
ETB
CSMB
ETB
CSMB
CSMB
ETB
CSMB
ETB
CIB
AB
CIB
ETB
MB
CIB
AB
AB
CSMB
AB
CSMB
MB
CSMB
CSMB
CIB
CIB
AB
MB
MB
10
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REGULATED SECTOR INDEX
Abbreviations: AB - Agriculture Branch; CIB - Chemical Industry
Branch; CSMB - Commercial Services and Municipal Branch;
ETB - Energy and Transportation Branch; MB - Manufacturing
Branch.
Machinery (manufacture of) MB
Mass transit ETB
Metals (Mining/extraction/production/fabrication) MB
Mining and quarrying (except fuels) MB
Natural gas transmission ETB
Oil and gas extraction ETB
Paints, varnishes, lacquers, enamels CIB
Paper and allied products MB
Petroleum refining, distribution and related industries ETB
Photographic and medical goods MB
Pipelines ETB
Plastics, synthetic resin & rubber (production of) CIB
Plastics & rubber (manufacture of products) MB
Power production (electric and gas utilities) ETB
Printing/publishing industry CSMB
Public lands, wildlife, and forests AB
Railroads ETB
Restaurants CSMB
Retail (stores - all types except below) CSMB
Retail nurseries, lawn and garden supply AB
Sanitary services CSMB
Stone/clay/glass/concrete production MB
Textiles (mill products - 'apparel/fabrics) MB
Tobacco products CSMB
Transportation equipment (manufacture of vehicles....) MB
Transportation (air, land, rail, water) ETB
Water supply/wastewater treatment CSMB
Wholesale trade CSMB
Woodstoves MB
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SINGLE-MEDIA COORDINATION
OC will Retain Single-media Functions
The Office of Compliance recognizes that most Federal and State
environmental offices are organized by single media. In order to
facilitate access to, and promote coordination with, other offices,
OC has designated specific Divisions as the point of contact for
single-media compliance issues that arise outside the context of
a specific industrial sector. Major statutory issue areas are listed
below with the appropriate staff coordinators.
STATUTE
CAA
CAA
CWA
EPCRA
AHERA
CAA
CWA
SDWA
RCRA
TSCA
CWA
FIFRA
SDWA
Multiple
MANUFACTURING, ENERGY AND TRANSPORTATION DIVISION
ISSUE AREA COORDINATOR
General Sally Mitoff
Enhanced Monitoring Scott Throwe
Industrial Wastewater Peter Bahor
General Maria Eisemann
Asbestos Chris Oh
CHEMICAL, COMMERCIAL SERVOS AND MUNICIPAL DIVISION
Stratospheric Ozone Emily Chow
Municipal George Gray
Public Water Joe Sarcone
General Sandi Jones
General Ann Stephanos
AGRICULTURE AND ECOSYSTEM DIVISION
Non-point Source Water Lorilyn McKay
General Shruti Sanghavi
Underground Injection Control Rose Lew
Wetlands/Watersheds/Coastal Zones Lorilyn McKay
NUMBER
202-564-7012
202-564-7013
202-564-7029
202-564-7016
202-564-7004
202-564-7071
202-564-7069
202-564-7049
202-564-7038
202-564-7043
202-564-4151
202-564-4158
202-564-4147
202-564-4151
Statute Acronyms: CAA - Clean Air Act; CWA - Clean Water Act; EPCRA - Emergency
Planning and Community Right-to-Know Act; SDWA - Safe Drinking Water Act; RCRA -
Resource Conservation and Recovery Act; TSCA - Toxic Substances Control Act; FIFRA -
Federal Insecticide, Fungicide and Rodenticide Act.
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IMPLEMENTING THE NEW FUNCTIONS
Analysis, Targeting and Communication - Our New Focus
OECA will improve the targeting of enforcement actions against
the worst violators, while at the same time help to reduce the
transaction costs of understanding and complying with statutory
and regulatory requirements. The Office of Compliance will help
to achieve both of these goals in five ways: enforcement plan-
ning (priority-setting based on patterns of non-compliance and
risk, and coordination of environmental justice and ecosystem pro-
tection programs); targeting and data management (develop-
ing data systems that help target the worst offenders within a par-
ticular industry, that measure success based on compliance his-
tory and environmental results, and that allow public scrutiny of
facility-level environmental records); compliance guidance (ad-
vancing the Agency's ability to identify and detect violations, while
minimizing monitoring costs); compliance and enforcement strat-
egies (analyzing compliance patterns for specific industries and
designing appropriate compliance or enforcement strategies for
problem sectors), and auditing and compliance assistance (en-
couraging companies to develop strong auditing programs to
prevent or correct violations, and helping small businesses under-
stand and meet compliance requirements).
"Although we must maintain an imposing enforcement
presence as a means of deterring noncompliance,
traditional enforcement should be seen as a tool for
achieving the broader goal of compliance and not
as an end unto itself. Multi-media, whole facility ap-
proaches to enforcement represent the future of en-
vironmental protection and should be pursued when-
ever possible."
- Carol Browner
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OTHER OECA OFFICES
OFFICE OF ENFORCEMENT AND COMPLIANCE ASSURANCE
Steve Herman, Assistant Administrator 202-260-4134
Scott Fulton, Deputy Assistant Administrator 202-260-4137
Michael Stahl, Deputy Assistant Administrator 202-260-4543
Office of Site Remediation Enforcement (Mail Code - 2271) 202-260-4814
Bruce Diamond, Director
Responsibilities: Superfund and RCRA corrective action enforcement
Office of Regulatory Enforcement (2241) 202-564-2220
Robert Van Heuvelen, Director
Responsibilities: Civil judicial and administrative enforcement of regulatory pro-
grams; legislative policy and guidance development
National Enforcement Investigations Center (2211) 303-236-5100
Frank Covington, Director
Responsibilities: Technical and regional support for enforcement inspections and
investigations
Office of Criminal Enforcement (2231) 202-260-4539
Earl Devaney, Director
Responsibilities: Criminal enforcement policy and administration
Federal Facilities Enforcement Office (2261) 202-260-9801
Barry Breen, Director
Responsibilities: Enforcement and compliance activities at federal bases
Office of Federal Activities (2251) 202-260-5053
Richard Sanderson, Director
Responsibilities: NEPA compliance, inter-agency liaison, international enforce-
ment and environmental assessement
Administrative and Resource Management Support Staff (2201) 202-260-4543
Sally Seymour, Director
Responsibilities: Administrative support, budget, contracts, grants, and corre-
spondence control
Enforcement Capacity and Outreach Office (2201) 202-260-4140
Gerald Bryan, Director
Responsibilities: Oversight of National Enforcement Training Institute, liaison with
outside groups
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GPO : 1995 0 - 163-034 QL 3
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