vvEPA
United States
Environmental Protection
Agency
Office of Enforcement
and Compliance
Assurance (2201 A)
EPA 300-K-99-001
January 1999
www.epa.gov
Protecting Your Health &
The Environment Through
Innovative Approaches to
Compliance
Highlights from the
'asf 5 Years
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s I
A
from the
L .i
booklet describes some or
B years:ago
ter
is reorganization was
< of HJfeenforcement and
ngpfiblic'^altri anal the environment.
|nitiai3|||jiPA has undertaken to reinvent its
compliance programs. EPA is committe^te ^valuajing all these efforts and continually
improving our compliance programs.
Compliance with environmental laws is essential for achieving the public health and
environmental protections intended by these laws. EPA's reorganization recognized a
major role, not only for government, but for all stakeholders, hi ensuring this compli-
ance. First, enforcement functions were consolidated in a single entity to ensure an
efficient and effective enforcement program. Second, major new compliance programs
were put in place to foster voluntary compliance with public health and environmental
laws. This booklet highlights many of these new compliance programs in the interest
of sharing information with you and the rest of the public.
Over the last five years, EPA has invested considerable time and resources in establish-
ing programs and policies to implement our new vision. This vision focuses on creat-
ing an array of new tools, all developed to promote compliance with the Nations envi-
ronmental laws. Among these compliance initiatives are EPA's nine compliance assis-
tance centers that provide assistance to small businesses and others seeking to comply
with the law, a self-audit policy which provides incentives for voluntary discovery of
violations and rapid disclosures and correction, and the National Performance
Measures Strategy, a new approach to measuring compliance. These and other new
programs complement our strong base enforcement program. All of these efforts bene-
fitted tremendously from extensive stakeholder involvement in their development.
Today, as a result of this new thinking, we have stronger programs in place to protect
the American people and our natural world from the harmful effects of pollution. We at
EPA are committed to continuing our efforts to foster a strong national compliance and
enforcement program. Much work remains to be done in partnership with our col-
leagues at the state, tribal, and local levels. We welcome suggestions from you and all
stakeholders on how we can continually improve compliance with environmental laws.
As we approach the 21st century, EPA will continue to work with its partners to foster
and refine its. efforts to ensure compliance with the Nations environmental laws. In
doing so, we hope to further our goals of protecting all Americans from threats to our
health and the environment, and preserve our environment for future generations.
Steven A. Herman
Assistant Administrator
Protecting Your Health and the Environment Through Innovative Approaches to Compliance 1
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Protecting Your Health and the EnvironmentJhrough Innovative Approaches to Compliance
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Introduction 4
Protecting your Health and the Environment through
Compliance Assistance 6
National Sector-Based Compliance Assistance Centers
Sector Notebooks
On-Site Compliance Assistance Focused on National Compliance Priorities
Protecting your Health and the Environment through
Policies Designed for Businesses and Small Communities 12
Working with. Small Businesses
Working with Local Communities
Working with the Regulated Community in General
Protecting your Health and the Environment through
Compliance Incentive Programs 15
Targeted Compliance Incentive Programs
Protecting your Health and the Environment through
Better Targeting and Environmental Results Enforcement 19
Enforcement as a Partnership with States, Tribes, and Territories
Targeting for Environmental Results
Measuring the Results of Compliance and Enforcement Activities
Environmental Results Enforcement
Protecting your Health and the Environment through
Information Sharing... ..- 25
Protecting Your Health and the Environment Through Innovative Approaches to Compliance
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Many of America's environmental improvements over the last 25 years are the direct
result of a strong set of environmental laws and an expectation of compliance with
those laws.
EPA has headquarters^ regional and field operations devoted to ensuring compliance
with our Nation's er^lSiIn|ental laws and working in partnership with the states,
tribes,te^itories, arRlpcal governments.
~-
S,r19J>4, EPA reorganized its enforcement and compliance operations into the
;. This reorganizlifiojri wajjjjased on
^ent7its,enforcement program with new tools
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Protecting Your Health & the Environment
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Over the past five years, EPA has gready increased its efforts to develop compliance
assistance tools, particularly for small businesses, in different industry sectors. Why?
Because most small businesses will do the right thing if they have the information that
they need to comply. The key is to get information on environmental requirements into
die hands of all businesses, small, medium and large, who want to comply.
ji Compliance assistance encompasses a variety of efforts, from ensuring that the regulated
community Understands its obligations by providing consistent "plain language" descrip-
tion^ of environmental requirements, to a wide assortment of types of training tools.
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ip with industry associations, environmental groups, universities, and
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f^'sj other government agencies, EPA has launched nine Compliance Assistance Centers, all
"" accessible through Internet weฃ sites as well as toll-free telephone assistance lines.
| These Centers are just one approach to help businesses and governments, especially
1 small and medium-sized businesses and local governments, better understand and
comply with federal environmental requirements.
Each Center is targeted to a specific industry sector and explains, in plain language, the
federal environmental regulations that apply to that sector. Eight of the nine Centers
wer,e selected to serve sectors in which there are a large number of small businesses that
can cause ijal environmental impacts depending on the processes and practices that
they use. The benefit of the Centers is that they make information available to those
businesses who want to do the right thing, but need answers to their questions. Since
not all small businesses have access to the Internet, the Centers also provide information
through toll-free phone lines and fax mail.
: II
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Features of the nine EPA-sponsored Compliance Assistance Centers include regularly
updated news, compliance policies and guidelines, pollution prevention information,
sources of additional information and expertise, summaries of regulations and initia-
tives, access to e-mail discussion groups, vendor listings and directories, environmental
management software and benchmarking tools that can be downloaded from the
Internet. Some of the Centers also contain "expert help" features that guide a small
business to information, "virtual shops" that allow a user to click on any facet of an
illustrated operation and see what regulations apply, and online access to relevant state
regulations.
For the first time, local governments also have a Center devoted to serving their envi-
ronmental information needs. The local government center not only serves as a clear-
inghouse for regulatory and compliance information, but also provides case studies and
other "how-to" information related to waste water management, brown fields, solid
waste, and many other issues. A user-friendly aspect of the Center is its "virtual city."
This is a mockup of a city with different illustrations, such as a city landfill, city garage,
solid waste truck on the road, a city water tank, just to name a few examples. A local
official can double click on a segment of the city, like the city water tank, and identify
all of the federal regulations that apply to a municipality. The intent is to provide a
visual aid to finding the information that a local government may be looking for.
We know that businesses are using these Centers based on a review of usage data.
From January to June 1998, the "Web sites of the five Centers open at the time logged
almost 75,000 distinct visits at their sites and responded to over 2,000 calls and ques-
tions via e-mail and telephone assistance lines. The next couple of pages provide a
short summary on each Center, including each Internet address, so you can access the
Centers yourself. We encourage you to log onto each Center and offer your comments
suggestions for improvements.
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Protecting Your Health and the Environment Through Innovative Approaches to Compliance
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Printers' National Environmental Assistance Center
1-888-USPNEAC (877-6322)
http://www.pneac.org
The Printers' National Environmental Assistance Center offers satellite and on-location
training, compliance guides for state regulations, and two e-mail discussion groups on
technical and regulatory issues: PRINTECH, designed for technical printing issues,
and PRJNTREG, which focuses on environmental laws and regulations affecting the
printing industry. Over 1,800 viewers participate in PNEAC's annual Green and
Profitable Printing national pollution prevention videoconference that is downlinked
to 28 states and Canada. PNEAC is operated by the University of Illinois Waste
Management Resource Center, the University of Wisconsin's Solid & Hazardous Waste
Education Center, and the Graphic Arts Technical Foundation.
National Metal Finishing Resource Center
1-800-AT-NMFRC (286-6372)
http://www.nm frc.org
The National Metal Finishing Resource Center allows its Web site users to search tech-
nical databases for abstracts, full-text articles, and reports; search a Vendor Directory
for over 300 suppliers of metal finishing equipment and services; and use on-line
calculators to determine flow requirements for rinsing, coating weights, and costs esti-
mates. On the Compliance Assistance page under state Primary Environmental
Regulatory Agencies, users can click on any state on the map to obtain an online list-
ing of state regulations that apply to metal finishing.
National Agriculture Compliance Assistance Center
1-888-663-2155
http://www.epa.gov/oeca/ag
The National Agriculture Compliance Assistance Center directs its communications
efforts primarily at agricultural information providers. A popular feature is a compre-
hensive listing of the 34 major federal laws that apply to farmers, which are also acces-
sible graphically. Users can click on any part of a farm illustration and find out the rel-
evant federal regulations.
CliemAlliance
1-800-672-6048
http://w\vw.chemalliance.org
ChernAlLiance is the new Compliance Assistance Center for the chemical industry.
1 Among its features is an exciting "expert help desk," which offers an interactive guide
'. to finding compliance resources specific to a user's needs. Take a "virtual plant tour"
to find out which regulations apply to your company's operations by clicking on a
detailed chemical plant illustration. Make your own bookmark to keep track of
important links to favorite regulatory, pollution prevention, and chemical industry
'.Websites. ' '",.'U ,
ChemAlliancc is operated by the Center for Clean Industrial Treatment Technologies
(CenCITT), a research consortium, along with Pacific Northwest National Laboratory
arid the University ofWisconsin's Solid and Hazardous Waste Education Center.
"After years of
waiting for this type
of resource, I find
the National Metal
Finishing Resource
Center to be a valuable
part of our daily
business. The Center
provides comprehen-
sive information on all
metal finishing topics
in a timely manner -
instant gratification!"
lartyZiiko, President,
ChromeTech Inc.
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"The resource 1
appreciate most is
the online technical
information database.
The ability to search
keywords and then
download them out
of the library is
convenient and useful
and is also surprisingly
rare in this age of
Dave Dudek, North Carolina
State University
Transportation Environmental Resource Center
1-888-459-0656
http://www.transource.org
The Transportation Environmental Resource Center provides compliance assistance
services for each mode of commercial transportation air, shipping and barging,
pipelines, rail, and trucking. Each home page offers a menu of technical fact sheets,
regulatory information, contacts, bibliographies, sector notebooks, and related com-
pliance Web sites. The Center is operated by the American Association of Airport
Executives and the American Trucking Association.
Paints and Coatings Resource Center
http://www.paintcenter.org
The Paints and Coatings Resource Center provides regulatory compliance and pollu-
tion prevention information to individual organic coating facilities, industry vendors
and suppliers, and others. The Paint and Coatings Regulatory Locator helps users
find relevant state and federal regulations. A technical database with over 5,000 full
text conference papers and journal articles is also available online.
Local Government Environmental Assistance Network (LGEAN)
877-TO-LGEAN (877-865-4326) http://www.lgean.org
LGEAN is aimed at facilitating communications among state and local officials,
inspectors, and regulators, and promoting local government participation in the fed-
eral rulemaking process. LGEAN is a "first-stop shop" providing environmental
management, planning, and regulatory information for local government elected and
appointed officials, managers, and staff. LGEAN offers 24-hour access to regulatory
and pollution prevention information, message boards, regulatory updates, grants
and information, and much more. LGEAN also offers a fax-on-demand service, a
quarterly newsletter, "SCAN," and a "Web site.
LGEAN is coordinated by the International City/County Management Association
in partnership with the American Water Works Association, Air & Waste
Management Association, Environmental Council of the States, National
Association of Counties, Solid Waste Association of North America, and Water
Environment Federation.
Printed Wiring Board Resource Center
http://www.pwbrc.org
The Printed Wiring Board Resource Center offers a state Regulations Locator, with
air, water and hazardous waste regulations hyperlinked for each state. A
Recordkeeping and Reporting Requirements Database, containing detailed entries
on over 1,100 federal and Texas regulations, is available for downloading. And a
unique guide provides pollution prevention information for each of the major
process steps for multilayer board manufacturing. PWBRC is operated by the
National Center for Manufacturing Sciences in partnership with the Institute for
Interconnecting and Packaging Electronic Circuits.
Protecting Your Health and the Environment Through Innovative Approaches to Compliance
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CCAR-GreenLinkฎ
1-888-GRN-LINK (476-5465)
http://www.ccar-grcenlink.org
CCAR-GreenLinkฎ, the Automotive Compliance Information Assistance Center,
provides compliance assistance to the automotive service industry, primarily owners
and technicians of auto body and repair shops, but also automotive trade associations,
automotive educators and students, and new car dealer service departments. CCAR-
GreenLinkฎ develops materials for the automotive service industry, such as a consoli-
dated screening checklist and environmental curriculum modules diat walk shop
owners and technicians through statutes, regulations, and health and environmental
issues. The "Virtual Auto Shop" allows users to click on any part of a picture to call up
environmental information for a particular shop activity. The Center is operated by
CCAR, the Coordinating Committee for Automotive Repair, a consortium of automo-
tive industry affiliates.
Sector Notebooks
In addition to the Centers, EPA has developed other tools to enhance compliance with
environmental laws on an industry by industry basis. Sector Notebooks are industry
sector profiles which help owners and operators of regulated industries understand
their regulatory obligations through comprehensive plain-English guides.
Since 1995, EPA has published profiles of 28 major industries and distributed over
300,000 copies in printed and electronic form. You can access these Notebooks your-
self through the Internet at "http://www.epa.gov/oeca/sector/"
Each profile contains information on the overall compliance history of the industry,
applicable federal laws and regulations, industrial processes, the amount and type of pol-
lutants generated, applicable pollution prevention approaches, and current cooperative
programs designed to improve die environmental performance of-each industry. The
notebooks are virtually the only government publication in which all of these cross-cut-
ting environmental issues are presented in a single document per industry sector.
Why is this important? This information can be used to develop industry-based assis-
tance strategies to improve overall compliance in ways that are cheaper, cleaner, and
smarter. By using the Sector Notebooks, federal and state governments, the regulated
industries, and the public will be better able to define the key environmental issues
associated with each industry. The public will have greater access to information con-
cerning industries within their communities.
If you're interested in finding out about other compliance assistance tools developed by
EPA, wcVe prepared a separate booklet entitled "Compliance Assistance Tools" which
provides an inventory of EPA national materials published to date. You can access
information on this booklet at "http://www.epa.gov".
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Oil-site Compliance Assistance focused on National
Compliance Priorities
In addition to the development of compliance assistance materials and tools, over the
past several years, EPA has identified specific industry sectors as priorities for national
sector-wide compliance assistance efforts. There are efficiencies and environmental
benefits to addressing environmental problems on a sector-wide basis.
EPA regions and states have undertaken many such assistance projects in partnership
with industry. EPA's Fiscal Year 1996 and 1997 "Enforcement and Compliance
Assurance Accomplishments Reports" (available at "http://www.epa.gov/oeca") contain
descriptions of these projects in every region of the country. For example:
In 1997, EPA, Virginia, Maryland, the District of Columbia, and the Korean Dry
Cleaners Association of Greater Washington partnered to address the needs of the
Korean perchoroethylene dry cleaning community. Dry cleaners were selected
because they can result in significant multi-media chemical releases to the environment
and have the potential to significantly impact human health and the environment.
The partners developed a mentoring program where experienced dry cleaners (coach-
es), who have been trained by EPA and the states, assisted less sophisticated dry
cleaners to increase their understanding of, and compliance with, environmental
requirements. The compliance rate of participants was estimated to be 20% higher
than other dry cleaners in the area.
Similarly in 1996, targeted compliance assistance efforts in EPA's Adanta Office
included both dry cleaners and chrome electroplaters. These two industries were tar-
geted for compliance assistance in Florida and Georgia due to new national emission
standards for hazardous air pollutants (NESHAPs) aimed at reducing inhalation risks
to the public and workers. These initiatives educated industry to enhance compli-
ance, evoke changes in behavior, and resulted in increased compliance rates. Georgia
reported an 81 percent compliance rate for chrome electroplaters with the new air
toxics NESHAP. Florida reported 64 percent of dry cleaners targeted this year
entered the regulatory system via notification as a result of compliance assistance.
Protecting Your Health and the Environment Through Innovative Approaches to Compliance 11
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Protecting Your Health & the Environment
through
Policies Designed to
Promote Compliance
''Businesses
-.and Small . -
Communities
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Once the regulated community has access to the information which they need to com-
ply and obtains compliance assistance, they then must use that information to check
their own compliance status. Over the past several years, EPA has worked with our
state and local partners and small business groups to develop specific policies which
provide real incentives for industry and others to voluntarily identify and correct their
own environmental violations.
Why? Because such policies encourage voluntary actions by the regulated community
to protect public health and the environment, while still providing full openness and
the accountability that the public expects. Three such policies are described below.
Working With Small Businesses
EPA's Final Policy on Compliance Incentives for Small Businesses is one of the 25 regula-
tory reform initiatives announced by President Clinton in 1995. Issued in May 1996,
the policy promotes environmental compliance among small businesses with 100 or
fewer employees. The policy rewards responsible small businesses by providing penalty
waivers or reductions if the small business receives compliance assistance, conducts an
environmental audit, detects violations as a result of it, and agrees to correct the viola-
tions by a date certain.
As part of its small business policy, EPA encourages its state partners to combine their
delegated enforcement authorities and compliance assistance efforts to enhance compli-
ance among small businesses. EPA defers to state policies that provide penalty mitiga-
tion or waiver for small entities and that are generally consistent with the EPA policy.
More than 150 small entities have returned to compliance under the Agency's incen-
tives policies. EPA has so far reduced or waived penalties by $900,000 for more than
90 small entities that disclosed and corrected their violations. The Small Business
Policy provides small businesses a whole other avenue by which they can demonstrate
good faith commitment to environmental compliance.
This work is just one example of how EPA meets its obligations under the Small
Business Regulatory Enforcement Fairness Act (SBREFA). Passed by Congress in 1996,
SBREFA requires agencies to better assist small entities through improved outreach
and compliance assistance activities, development of flexible penalty policies, and con-
sideration of potential impacts on small entities in regulatory development and review.
Working with Email Communities
jjke small businesses, small communities often lack the administrative, technical, or
financial capacity to ensure environmental compliance, but their compliance problems
can have a major impact on the state of the environment. Thirty percent of Americans
live in towris having 2,500 or fewer residents.
As part of the Clinton Administration's common sense efforts to reexamine the way we
do business, EPA developed its Policy on Flexible State Enforcement Responses to Small
Community Violations .to promote increased compliance with environmental regulations
by small communities. It provides the tools and flexibility that small communities need
to/achieve environmental compliance on a sensible schedule and with penalty reduc-
Protecting Your Health and the Environment Through Innovative Approaches to Compliance | 13
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tions for correcting violations. EPA's policy encourages states to work with small com-
munities to address their environmental problems. The Agency defers to the state's
efforts to return a small community to compliance.
Protection of public health and the environment remains EPA's fundamental goal.
Enforcement flexibility, within the framework of such policies, can promote increased
compliance by allowing communities to focus on their worst environmental problems
first, and by reassuring them that asking for help need not result in the assessment of
a penalty.
Environmental Auditing:
Working with the Regulated Community in General
In addition to the Small Business and Small Communities Policy, over the past five
years, EPA has developed an Audit Policy which encourages all companies to self-
police by giving them real economic incentives to self-monitor, disclose, and correct
environmental violations.
Under the policy, EPA eliminates or reduces penalties for companies that detect viola-
tions through an environmental audit or compliance management program, voluntari-
ly disclose the violations to EPA, and take prompt action to correct them. Importantly,
the policy encourages self-policing in a fair manner without tolerating secrecy, provid-
ing blanket immunities, or excusing criminal conduct.
EPA's policy, Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention
of Violations (December 1995) was the result of an intensive, 18 month public process
to find the best way to encourage companies to police themselves while preserving fair
and effective enforcement.
In fashioning this policy, EPA sought the input of other federal agencies, state attor-
neys general and local prosecutors, state environmental agencies, the regulated commu-
nity, and public interest organizations.
Thus far, over 318 companies have disclosed and corrected violations under the audit
policy at more than 1,668 facilities. The rates of disclosing companies and corrected
violations under the policy have increased every year since its effective date.
; :; EPA recently surveyed users of the Audit Policy. Eighty-eight percent of the respon-
i dents said that they would use the policy again, and 84% would recommend it to oth-
"^'&f^Tljฃ survey results also reveal that the policy encourages about half of die users to
make specific improvements in the auditing programs and environmental management
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Protecting Your Health & the Environment
through
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Now that policies exist which provide incentives for industry and others to comply,
EPA has taken steps to actively encourage their use through a variety of new
Compliance Incentive Programs. Why? Because there are real benefits to the public
and the environment when the regulated community audits their own compliance
status jrufcorrects their environmental violations. ~ . i' '
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Cojnpliance with environmental laws cannot be achieved without vigorous efforts by
thg regulated community to monito? and ensure their pwn compliance: Use of self
auditing and environmental management systems have become routine practices at
responsible companies. EPAs compliance incentives programs are geared at encour-
aging these efforts. As part of our continuing reinvention efforts, the Agency intends
to initiate additional programs, such as those described below, in years to come.
Targeted Compliance Incentive Programs
"Compliance Incentive Programs" use a combination of compliance assistance, envi-
ronmental audits, self-disclosure of violations, and reduced or eliminated penalties
for those participating in the program. Below are six examples of such projects and
programs which have been undertaken by EPA in partnership with the states and
regulated community.
Companies as Environmental Leaders:
The Environmental Leadership Program
As part of die Clinton Administration's reinvention of regulation to achieve the
best environmental results at the least cost, EPA launched a one year pilot of the
Environmental Leadership Program. This program was designed as a partnership
with industry, to jointly come up with what constitutes an environmental leader.
Protecting Your Health and the Environment Through Innovative Approaches to Compliance 15
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Facilities of 12 private companies and utilities, as well as two federal facilities,
used innovative management techniques such as environmental auditing and pollution
prevention to reduce the burden of paperwork and inspections on the facilities, while
enhancing compliance with existing environmental laws.
States were active participants in the ELP selection process. The facilities
participating in the ELP pilot program helped EPA and die states identify ways to
streamline reporting requirements and reduce inspections, without sacrificing environ-
mental and public health protection. The facilities acted as laboratories to evaluate dif-
ferent elements of what might comprise an "Environmental Leader," e.g., development
of Environmental Management Systems, mentoring programs, etc.
Compliance Incentive Programs Which Encourage Use of
Environmental Management Systems
EPA, through its Region 1 New England Office and the New England states, has
implemented the StarTrack program which provides outreach and assistance to facili-
ties with substantial environmental requirements to encourage die use of compliance
audits and environmental management systems to improve environmental compliance
and performance and to provide more facility performance information to the public.
Under the pilot StarTrack program, participating facilities work towards compliance by
conducting annual multi-media compliance and environmental management audits
which undergo third-party verification, implementing environmental management sys-
tems, and publishing annual compliance reports to provide die public widi informa-
tion regarding facility progress in waste reduction and energy, water and hazardous
materials usage.
In the first year of implementation, eight companies in New England participated,
with nine additional facilities joining in year two. Environmental indicator reports of
participating facilities show a history of improvement in environmental performance
and pollution prevention as a result of this compliance incentives program.
Using Compliance Incentives to Identify Hazardous Chemicals
in Your Community and Improve Accident Response
Among other things, the Emergency Planning and Community Right to Know Act
(EPCRA) requires facilities to submit annual inventories of hazardous chemicals on site
to local fire departments and state emergency responders so that they can be prepared
In case of an accidental chemical release. Unfortunately, there have been many
Instances where EPCRA reports have not been filed, accidental chemical releases
1 ll I'1' I"1 dctlirr|d, and emergency workers have walked into unknown dangers resulting in
injury or death.
In 1996, EPA learned that a number of accidental releases had occurred at facilities
within, the Food ^ and Kindred i Products Sector^As^ a rault^ the EPA Regions worked ^
i^oMjy'w^iratc^rniergehcy Response'Commlssions to determine whether specific
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inventories of hazardous chemicals on site. Chemicals used by the food processing
industry include anhydrous ammonia, chlorine, sulfuric acid, and nitric acid.
EPA first conducted compliance assistance and outreach efforts, and then gave facilities
a specific period of time to come into compliance and submit their inventories of haz-
ardous chemicals, while paying a greatly reduced penalty of $2,000 per facility for
identified violations.
Some 175 companies signed agreements with EPA to come into compliance with
EPCRA ง312. As a result of this program, state and local emergency responders and
community members are better able to plan for, and respond to, accidental releases of
hazardous chemicals.
Reducing Threats to the Nation's Waterways through
Compliance Incentives
As part of President Clintons Clean Water Action Plan, in November 1998 the
Environmental Protection Agency and the National Pork Producers Council (NPPC)
entered into a voluntary compliance program to reduce environmental and public
health threats to the Nation's waterways from runoff of animal wastes from pork-
producing operations.
Under this initiative, participating pork producers will have their operations (as many
as 10,000 facilities) voluntarily assessed for Clean Water Act violations by certified
independent inspectors. Producers who promptly disclose and correct any discovered
violations from these audits will receive a much smaller civil penalty than they might
otherwise be liable for under the law.
The program will help control runoff from animal feeding operations, a major source
of water pollution, associated with such threats to public health and the environment
as Pfiesteria outbreaks.
In implementing this program, EPA will consult closely with the states, who may
administer the program directly.
Using a Multi-Media Approach to
Compliance incentive Programs
Another example of a compliance incentives program is the pilot initiated by EPAs
Chicago Office (Region 5) to secure environmental improvements at steel mini-mills
in Illinois, Indiana, Michigan, Minnesota, Ohio, and Wisconsin. A mini-mill is a steel-
producing electric arc furnace shop with an associated rolling mill. This industry sector
has realized significant recent growth, possibly changing the compliance status of some
facilities with regard to multi-media regulatory requirements.
EPA provided the mini-mill sector a period of six months to self-audit and resolve vio-
lations in accordance with EPAs Audit Policy or, if applicable, the Small Business
Policy. EPA encouraged companies to share their audit results and self-disclose any vio-
Protecting Your Health and the Environment Through Innovative Approaches to Compliance 17
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lations. EPA also offered outreach and technical assistance, conducted public briefings,
and created a home page on the Internet for companies wanting more information.
Half of the operating mini-mills in EPA Region 5 participated in the project and the
majority of these self-disclosed violations to the EPA and came up with plans to cor-
rect them. The Region and states are following up with multi-media inspections of the
facilities that did not conduct self-audits under the program and developing enforce-
ment actions as necessary to ensure compliance within the rest of the sector.
Preventing Risks from Toxic Chemicals
Through Compliance incentives
Under the Toxic Substances Control Act (TSCA), companies that manufacture, process
or distribute chemicals are required to inform EPA of any information that reasonably
supports the conclusion that a chemical substance or mixture presents a substantial risk
of injury to your health or the environment.
Several years ago, the Agency discovered that some regulated industries were not sub-
mitring information on chemical hazards and exposure. To encourage chemical compa-
nies to voluntarily audit their records and submit all relevant data to EPA, the Agency
Initiated a program that would allow for a company's liability to be capped at $1 mil-
lion for those companies that conducted audits, identified violations, and submitted
required substantial risk data within a certain deadline.
As a result, 123 companies undertook environmental audits. EPA received over 11,000
previously unreported studies or reports on chemicals that may cause health or envi-
ronmental harm and collected over $22.7 million in penalties.
jur Health and the Environment f hrough Innovative Approaches to Compliance
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Protecting Your Health & the Environment
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Compliance alliance ancl incentive programs will continue to be used by EPA
because they help the regulated community, comply with the law. But EPA will also
continue to maintain a strong base enforcgment program. ^V^hy? Because strong
enforcement remains critical to ensuring compliance by those who continue to violate
the law despite opportunities to come int<5 /compliance.
Strong enforcement achieves environmental protection by deterring potential violators,
bringing actual violators into compliance,; rectifying damage to the/environment, and
assuring that those who follow-the law will not be put at an economic disadvantage by
those who ignore jheir environmental obligations. Since the reorganization, EPA has
implemented a number of new policies and programs to enhance our focus on envi-
ronmental results which can be achieved through effective enforcement.
Enforcement is a Partnership with state, tribes and territories
Effective environmental regulation requires a strong partnership with states, tribes, and
territories.
Most federal environmental statutes recognize the importance of this partnership by
authorizing delegations to states of the responsibility for implementing and enforcing
most federal programs, tribal governments remain the primary parties for managing
environmental programs on tribal lands where they have the capacity to do so. This
framework provides states and tribes the opportunity to tailor solutions to address local
health risks and environmental problems.
Protecting Your Health and the Environment Through Innovative Approaches to Compliance 19
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These statutes also recognize the necessity and importance of the federal Governments
role and give EPA the authority and responsibility to establish baseline national stan-
dards for public health and the environment and to take action to ensure that these
standards are implemented and enforced fairly and consistendy throughout the coun-
try, so that public health is protected.
Targeting for Environmental Results
Effective compliance and enforcement is not only dependent on a partnership with
states, tribes, and territories, it's also dependent on effective targeting of the most sig-
nificant public health and environmental risks. Because of this and a recognition that
government resources are finite, EPA has worked since the reorganization to improve
our ability to target our efforts to areas of greatest need.
EPA has enhanced these targeting approaches by using a broad array of environmental
quality information, demographics, and information on the results of our compliance
monitoring activities. We target our enforcement and compliance assistance efforts tak-
ing into account:
sector-based environmental problems or compliance patterns;
statute-specific compliance problems; and
an analysis of compliance/enforcement history and pollutant releases.
New methods of examining these data incorporate risk considerations, which predict
the relative effects of facilities, or groups of facilities, on the human population.
When targeting is effective and violations are identified, the process of bringing the
violators back into compliance can result in significant impacts on human health and
the environment.
Supplemental Environmental Projects,
Benefits to the Environment
Supplemental Environmental Projects (SEPs) are an excellent example of how enforce-
ment can result in environmentally beneficial projects that did not exist previously.
Since the reorganization, EPA has increased its use of SEPs.
A SEP is an environmentallv beneficial project which a violator agrees to undertake in
Settlement of a"n errvironment^ but which the violator is not oth-
erwise legally required to perform. In return, some percentage of the cost of the SEP is
considered^ a factor in establ|hing die appropriate setdement penalty paid by the
vJo ator. ''
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In fiscal years 1995 when EPA first issued a draft SEP policy through 1997,
EPA negotiated settlements in 820 cases which contained SEPs. The SEPs were valued
at approximately $254 million! Most significantly, these SEPs have contributed to the
reduction of millions of pounds of toxic chemicals releases.
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luce or remediate the risks or harm that may have been
alter a violator's obligation to
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remedy a violation expeditiously and return to compliance. SEPs thus provide environ-
mental and public health improvements which would not otherwise be available except
for the setdement incentives provided by the SEP Policy. SEPs often involve pollution
prevention or other innovative technologies that may result in greater environmental
protection at reduced cost.
EPA revised its SEP Policy based on early experiences and in 1998, issued the Final
Supplemental Environmental Projects Policy, encouraging public participation when
negotiating SEPs and enhancing the Policy's clarity and flexibility.
Measuring the Environmental Results of Enforcement:
The National Performance Measures Strategy
As part of EPA's reinvention efforts, we have also focused on better ways to measure
the results of our compliance and enforcement activities. Why? Because through prop-
er measurement, we can determine the real impact of compliance and enforcement on
risk reduction and environmental protection.
In so doing, EPA can determine which tools and strategies are working best to ensure
compliance and to allow the Nation to examine whether the regulated community is
meeting its responsibilities to comply with the law.
In the past, EPA primarily used activity or output measures, such as the number of
inspections conducted, enforcement cases issued, and penalty dollars assessed, as its
principal measures of performance. These numbers remain a useful measure of the gen-
eral presence of the EPA enforcement and compliance assurance effort, but they do not
help us measure the state of compliance with environmental laws, the environmental
results achieved, nor the degree to which program objectives are being met and non-
compliance problems are being addressed.
The National Performance Measures Strategy is EPA's pioneering effort to identify,
design, implement, and use meaningful performance measures to assess the effective-
ness of our national enforcement and compliance assurance program.
During 1997, EPA held more than 20 public meetings with stakeholders including
environmental organizations, regulated industries, environmental justice advocates,
state environmental departments, oversight agencies, and academic experts to iden-
tify the "vital few" performance measures which could best serve EPA and the public.
During 1998, EPA managers and staff, assisted by contractors and expert consultants,
worked to design the measures by developing definitions, information collection and
reporting processes, and modifications to existing data systems.
Over the course of 1999, the measures will be implemented in stages, and the entire
set of twelve measures (known as the Performance Profile) will be fully operational by
the beginning of Fiscal Year 2000 (October 1999).
The Performance Profile includes eight measures of environmental results or outcomes:
noncompliance rates for selected regulated populations; environmental and human
Protecting Your Health and the Environment Through Innovative Approaches to Compliance 21
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New Approach' to Measi^ihg,ftes^^J;
Measuring the Results of Federal Enforcement Actions as
Reductions In Pollutants (FY 1997} . ' " : ";/' :;>>''J;:'
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ppl|utant , .
PCBs and PCB-containing Material
Volatile Organic Compounds
Tailings
Paniculate Matter
Carbon Monoxide
Lead
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Chromium '
Sulfurfc Acid
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Reduction i6oandsl
576,585,000
62,562,000
28,000,000
24,555,000: ,'" 5 ,
21,502,000:
10,297,000. ..... .;
7,666,000 .' ,
6,329,000 .. ... . v;.
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Measuring the impact of State Actions in New/ terms
Clean Air Act "New Source Review" actions cut.Nqx>y;3Q;9rit;!ง,r!i0:.;.:j;;
case and 162 tons in another case, the equivalent'of .r^rptiylnp; ^'^V^IlgP
passenger cars from the roads a yean : '-;.-. : . " * . ' ',; ;. ^ '. "'; i::" 1" ';:$ s'-^f":^.
ป An Idaho Panhandle Initiative reduced particular ...... fW^f :^1>^'i|p^tt^'i.^]'|
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SaurtM' FY 1997 Enforcement and Compliance ^Jsfencl;A^^|i|lT^fi@e|g|
health improvements from enforcement actions, compliance assistance, and initiatives
which integrate assistance and enforcement; disclosure and correction of violations
using EPA compliance incentive policies; timeliness of return to compliance by signifi-
cant violators; and recurring or new violations by significant violators.
These measures will help EPA and the public assess the state of compliance, the envi-
ronmental improvements resulting from the full range of EPAs enforcement and com-
pliance assurance activities, and the changes in behavior of regulated entities. The
Profile also includes four measures of program activity or outputs. The number of
inspections conducted and enforcement cases issued will remain important activity
measures, while other output measures of the number of facilities/entities reached
through compliance assistance and the amount of capacity building efforts for state,
tribal, and local governments will also be used to measure performance.
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What's the bottom line? The Performance Profile will allow EPA and the public to
know not just the amount of activities conducted by the enforcement and compliance
assurance program, it will also measure the results achieved by those activities, enable
EPA and the public to examine the relationship between activities and results, and help
Identify how strategies and activities need to be changed or applied to produce the best
possible environmental results.
. can now determine the pounds of pollutants reduced through enforcement
~ ~':l* * " A' actions wEicE produce particular kinds of bene-
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Protecting Your'HealtH and the Environment Through innovative Approaches to Compliance
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As individual measures are implemented in 1999, and when all the measures are fully
operational in FY 2000, EPA will be able to better measure the performance of our
programs and their effectiveness in ensuring compliance, provide the public with better
data, and enhance our ability to protect the environment.
Environmental Results Enforcement
The Performance Profile will be applied to compliance and enforcement activities in
the future to measure their environmental and public health impacts.
Several examples follow which illustrate how well-targeted enforcement activities,
which apply innovative policies and strategies, can lead to significant improvements for
your health and the environment.
A Whole Sector Approach: Cleaning Up our Air
Over the past few years, EPA has found that frequently the most effective way to
address environmental noncompliance problems is on a sector basis.
A recent example occurred in 1998, when EPA and the Justice Department announced
an enforcement settlement with the seven heavy-duty diesel engine manufacturers who
were part of the largest Clean Air Act enforcement action in history. The settlement
resolved charges that the companies violated the Clean Air Act by installing software
that allowed engines to meet EPA emission standards during testing but disabled the
emission control systems during normal highway driving. When these engines are run-
ning on the highway, up to three times the limit of nitrogen oxide (NOx) emissions
result. "Why is this setdement important?
The setdement is expected to prevent 75 million tons of NOx air pollution over the
next 27 years and reduce total NOx emissions from diesel engines by one-third as of
the year 2003. These companies comprise 95 percent of the U.S. heavy-duty diesel
engine market.
EPA estimates that the companies will spend collectively more than $850 million to
introduce cleaner new engines, rebuild older engines to cleaner levels, recall pickup
trucks that have defeat devices installed and conduct new emissions testing. The com-
panies will also undertake a number of projects to lower NOx emissions, including
research and development projects to design low-emitting engines that use new tech-
nologies and. cleaner fuels.
A Multi-Media Approach: Cleaning Up the Air, Water and Soil
In another example of "environmental results enforcement," EPA and state regulatory
agencies worked jointly to address noncompliance across five environmental statutes at
the petroleum refineries of Ashland, Inc. located in Kentucky, Minnesota, and Ohio.
The corrective actions Ashland will undertake include improvements to the wastewater
drainage system at its Ohio facility to prevent the release of volatile organics into the
atmosphere, upgrades to the wastewater treatment system at the Kentucky plant to
Protecting Your Health and the Environment Through Innovative Approaches to Compliance 23
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reduce the release of harmful chemicals into the Big Sandy River, and the installation
of a series of wells to prevent the release of petroleum contaminants into the
Mississippi River in Minnesota.
As part of the settlement, Ashland also agreed to perform SEPs to restore and donate
274 acres of ecologically significant dune prairie grassland to the state of Minnesota for
permanent preservation as a scientific and natural area; assist the state of Kentucky
with air monitoring; install two hydrofluoric acid release detection and mitigation sys-
tems at the Ohio and Minnesota refineries to provide protection for the workers and
the surrounding communities from possible releases of hydrofluoric acid; establish an
environmental compliance promotion and education program in the state of
Kentucky; and improve an oil/water separation system and two tanks at the Ohio facil-
ity to substantially reduce the emissions of volatile organic hydrocarbons to the atmos-
phere
A Multi-Media Approach: Promoting the Use of Environmental
Management Systems to Prevent Violations from Recurring
A recent settlement with ASARCO exemplifies the benefits of a multi-media strategy
towards enforcement whenever appropriate. This precedential setdement is the first
time the federal government has entered into a setdement that resolves multi-media
violations involving multiple facilities at a single company.
In this precedential setdement, ASARCO was required to pay $6.38 million in penal-
ties and invest in excess of $50 million for environmental cleanup and supplemental
environmental projects (SEPs) to correct alleged hazardous waste and water violations
at two of its facilities in Montana and Arizona. The setdement will result in reduced
levels of toxic heavy metals such as mercury, lead, and arsenic being illegally released
Into the environment.
The settlement also marked the first time that a company agreed to establish an
enforceable environmental management system applicable at all of its active facilities
nationwide to identify and correct violations of environmental laws. In ASARCO s
case, this system covers 38 operating facilities with more than 6,000 employees in
seven states.
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Protecting Your Health and the Environment Through Innovative Approaches to Compliance 25
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Over the past five years, in addition to focusing on enforcement actions which lead to
environmental results, EPA also made citizens' access to compliance and enforcement
information a priority. Why? Because citizens must be involved in environmental pro-
tection. However, in order for this to occur, citizens need access to information.
Public access to data allows communities to monitor environmental conditions and
compliance records of nearby facilities and provides an additional incentive for busi-
nesses to be in compliance with environmental laws. It also allows communities to
monitor the performance of government agencies charged with implementing environ-
mental laws and improves data quality because the greater the use of information, the
more often errors will be found and corrected.
The Integrated Data for Enforcement Analysis (IDEA) system, for example, provides
interested members of the public with access to more than ten EPA databases. In fact,
many businesses are starting to use this system to monitor their own environmental
performance.
EPA believes that technology is now making management and maintenance of com-
puter records the most important way to track facility information, and is gradually
replacing the hard copy file approach to managing records. In fact, many states are also
beginning to also provide citizens with access to dieir compliance records. EPA plans
to continue efforts to expand access to compliance records through the Internet under
initiatives such as the Sector Facility Indexing Project.
Providing the Public with Access to information about EPA's
enforcement and compliance programs
A central gbal of EPA's reinvention efforts is td provide comprehensive infor-
mation abo!ut environmental compliance and enfpreetriehf issues to the.gen-
eral public and the regulated community in order to help deter non-compli-
ance, promote voluntary action by the regulated community, provide mean-
ingful Opportunities for public participation, and protect the public's right to,
know.
The EPA Web site currently contains about 4,200 enforcement and compli-
ance-related documents- and we expect tp triple that hungber by the end of
FY 1999, In addition, ERA'S Enhanced Public Apcess Tzisi*; Project will
makฎ all of the Agency's significant guidahce ahd policies 'electronically
accessible 10 Regions, states, industry, and the public, by the end qf FY 2000.
Users will be able to follow a user-friendly format to browse the system and
locate material of interest.
Last year, EPA also opened an Enforcement and Compliance pocket
and Information Center (ECDIC), which contains a library system for
identifying the Agency's enforcement and compliance assurance regulations,
policy and guidance, and related documents. This material will be physically
available at the ECDIC via hard copy or on microfilm, along with a report
generator for distributing information to the public. The Center will be anoth-
er valuable outreach tool of the Agency's enforcement and compliance
assurance program.
j andlhe'Envirorimenttiirougn fnnovaSveApproacries1 to Compliance
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Sector Facility Indexing Project
The Sector Facility Indexing Project (SFIP), a pilot program being developed by EPA,
is a first step towards integrating and providing access to more environmental informa-
tion than has ever before been available to the public in one location. During the first
eight months of its availability, the SFIP Internet site has been accessed with approxi-
mately 50,000 user sessions and 265,000 hits.
The SFIP profiles approximately 650 individual facilities in five industrial sectors:
automobile assembly, pulp manufacturing, petroleum refining, iron and steel produc-
tion, and the primary smelting and refining of aluminum, copper, lead, and zinc (non-
ferrous metals).
This project gives citizens the ability to access multi-media environmental data about
each facility on the Internet, such as the number of inspections, compliance with fed-
eral regulations, enforcement actions taken, chemical releases, and spills. Also available
is background information on the location and production capacity of each facility, as
well as information on the population of the surrounding area.
The information on each of these facilities is intended to satisfy the potential needs of
a range of stakeholders:
community groups interested in learning about the overall compliance record of a
nearby facility;
industrial trade associations interested in better understanding common compliance
problems in order to design compliance and self-policing programs;
an individual facility interested in identifying pollution prevention activities for its
chemical releases, both in terms of its own record or in bench-marking its perfor-
mance by looking at the records of similar facilities; and
and a state or local government interested in better access to integrated, multi-media
environmental data, which could be used to evaluate the impact of current facilities
in a specific geographic area.
From EPAs perspective, we see several uses for this data. The SFIP allows us to track
compliance records in individual sectors. This is a very important effort in terms of
assisting us in planning and measuring the effectiveness of compliance and enforce-
ment strategies. It allows us to build benchmarks across sectors to aid in targeting
resources for compliance and enforcement activities.
The project has undergone multiple federal and state data quality reviews and the pub-
lic has_ also had several opportunities to comment. As a final matter, EPA gave the
facilities themselves the opportunity to review the data. While most of the data was
found to be accurate, EPA made corrections as appropriate and will continue taking
comments as the pilot project evolves.
To allow users to access current environmental information as it becomes available, the
data included in the Project is updated regularly. The database is available on the
Internet at "http.7/www.epa.gov/oeca/sfi".
Protecting Your Health and the Environment Through Innovative Approaches to Compliance 27
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Public Access to Information About Your Drinking Water
One of EPA's primary goals is to ensure safe drinking water for all
Americans. In August 1996, Congress passed extensive amendments to the
Safe Drinking Water Act to ensure that our Nation's drinking water meets all
health standards. Under these amendments, the Agency will produce an
annual report based on state and tribal data which portrays the compliance
of drinking water systems across the country and which ensures public
access to information about the quality and source of their drinking water.
The first compliance report was issued in September 1998.
1996 data provided by the states showed that 86 percent of all Americans
are served by water systems with no reported violations. Nonetheless, EPA
and the states are working together to vigorously address those who are in
noncompliance with health-based standards, treatment technique require-
ments, and significant monitoring and reporting requirements. Continued
monitoring and improved reporting data will enable regulators and the pub-
lic to identify compliance concerns and develop appropriate strategies to
address any risks to public health. The EPA report is available on the Internet
at "http^/www.epa.gov/oeca".
Conclusion
These arc just a few examples of new and innovative approaches to doing business
which EPA intends to continue and expand upon in the future. We welcome your
thoughts and suggestions on any of the approaches you've just read about, or any
new ideas which you'd like to share. We encourage you to visit our Web sites, listed
on the next page, and to provide us with your feedback. Your input is critical as
EPA's compliance and enforcement program continues to work to fulfill its mission
on a daily basis to protect your health and the environment through innovative
approaches to compliance.
'. l;i"<'&,:>,& :.!;..;;>; iijsi Jif'Sf,i";i.^i^A' jf8: f';':'*':' ;! * >:'~':* '"'
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Audit Policy: Incentives for Self Policing
http://www.epa.gov/oeca/auditpol.html
Audit Policy Interpretive Guidance/Results from Audit Policy/Newsletters
http://www.epa.gov/oeca/apolguid.html
Small Business Policy
http://www.epa.gov/oeca/smbusi.html
Small Communities Policy
http://www.epa.gov/oeca/scpolicy.html
Supplemental Environmental Projects
http://www.epa.gov/oeca/sep/
National Performance Measures Strategy
http://www.epa.gov/oeca/perfmeas/npmsfinal.html
OECA Operating Principles
http://www.epa.gov/oeca/princip.html
Sector Facility Indexing Project
http ://www. epa.gov/oeca/sfl
Sector Notebooks & One Year Progress Report
http://www.epa.gov/oeca/sector/
Office of Compliance Fact Sheets
http://www.epa.gov/oeca/oc/fact.html
Compliance Assistance Centers Information
http://www.epa.gov/oeca/mfcac.html
1996 OECA Accomplishment Report
1997 OECA Accomplishment Report
http://www.epa.gov/oeca/96accomp.pdf
http://www.epa.gov/oeca/97accomp.pdf
EPA Environmental and Spatial Data
http://www.epa.gov/enviro/
EPA Center for Environmental Information and Statistics
http://www.epa.gov/ceis/
Environmental Monitoring for Public Access and Community Tracking (EMPACT)
http://www.epa.gov/empact/
Protecting Your Health and the Environment Through Innovative Approaches to Compliance 29
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Protecting Your Health and the Environment Through Innovative Approaches to Compliance
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We welcome your
comments and feedback.
Please mail to:
Office of Enforcement and Compliance Assurance (2201 A)
U.S. Environmental Protection Agency
Washington, DC 20460
Attn: Enforcement Capacity and Outreach Office
Protecting Your Health and the Environment Through Innovative Approaches to Compliance 31
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ISBN 0-1 6-049898-8
9"780160"498985"
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