BETTER USE OF TECHNOLOGY IN COMPLIANCE MONITORING ACTIVITIES
FIELD ACTIVITY COMPLIANCE TECHNOLOGY STRATEGY
(FACT STRATEGY)
Prepared by:
National Compliance Monitoring Policy Branch
Compliance Assessment and Media Programs Division
Office of Compliance
Office of Enforcement and Compliance Assurance
U.S. EPA
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BETTER USE OF TECHNOLOGY IN COMPLIANCE MONITORING ACTIVITIES
FIELD ACTIVITY COMPLIANCE TECHNOLOGY STRATEGY
(FACT STRATEGY)
TABLE OF CONTENTS
EXECUTIVE SUMMARY 1
PART 1:
OVERALL STRATEGY FOR MAKING BETTER USE OF TECHNOLOGY 9
PART 2:
OVERVIEW OF OECA ACTIVITIES 17
PART 3:
PORTABLE PERSONAL COMPUTERS IN THE FIELD: OVERVIEW OF
HARDWARE/SOFTWARE OPTIONS CURRENTLY AVAILABLE 25
PART 4:
RESULTS OF SURVEY AND RESEARCH ON USE OF PORTABLE PERSONAL
COMPUTERS WITHIN EPA AND BY OTHER GOVERNMENT AGENCIES 33
PART 5:
APPLICATION OF THE KEY ELEMENTS FROM THE FACT STRATEGY: OECA'S
PILOT PROJECTS USING PORTABLE PERSONAL COMPUTERS 47
PART 6:
STRATEGY FOR EXPANDING THE USE OF PORTABLE PERSONAL COMPUTERS
TO OTHER PROGRAMS OR FUNCTIONS 67
PART 7:
LEVERAGING RESOURCES FOR EXPANSION SOFTWARE DEVELOPMENT AND
EQUIPMENT PURCHASES 85
PART 8:
CONCLUSIONS AND RECOMMENDATIONS 91
APPENDIX A:
AGENCIES SURVEYED WITH SUMMARIZED COMMENTS 101
APPENDIX B:
NUMBER OF INSPECTION PROGRAMS AND INSPECTION TYPES 119
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BETTER USE OF TECHNOLOGY IN COMPLIANCE MONITORING ACTIVITIES
FIELD ACTIVITY COMPLIANCE TECHNOLOGY STRATEGY
(FACT STRATEGY)
EXECUTIVE SUMMARY
Better use of technology in compliance monitoring activities has the potential to
significantly increase productivity and efficiency throughout the inspection process. It can also
improve the quality and timeliness of inspection reports and data entry.
The Office of Enforcement and Compliance Assurance (OECA), other EPA offices, and
other government agencies are increasingly incorporating the use of technology in their
compliance monitoring programs. This Strategy, referred to as the FACT Strategy, provides an
approach for improving the use of technology in the EPA compliance monitoring program on an
on-going basis. It discusses technologies currently being used or piloted, especially portable
personal computers, the advantages of using such technology, and options and recommendations
for moving towards the wide-scale use of technology to increase the efficiency of inspections.
This Strategy does not address on-going efforts within EPA to advance the use of
technical equipment for monitoring and sampling, e.g., satellite imagery and ground based
remote sensors.
FACT STRATEGY
Effectively incorporating technology into EPA's work requires an on-going effort where
certain steps are repeated. Because technology continues to change and improve, any one
technology adopted may be quickly out-dated and may no longer be the best technology for the
job. Part 1 describes the iterative steps for improving the use of technology in field activities.
These steps include:
SELECTION OF TECHNOLOGY
• Review the workflow process.
• Identify changes in the process that will improve performance and which can be
achieved by the application of new technology, increased availability of
technology, or replacement of aging equipment.
• Elicit information on what is being used by others.
• Ask persons doing the work being reviewed about their needs.
• Identify, research, and evaluate technology of interest.
• Select technology to adopt/expand or determine if aging equipment needs
replacement.
• Analyze potential impact on the enforcement process. Determine if new policies
are needed to address changes in process.
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• Determine if technology is ready to use or if more research or development is
needed.
IMPLEMENTATION OF TECHNOLOGY THAT IS READY TO USE
Working with the users:
• Develop and issue policies needed, e.g., to ensure integrity of the
inspection/enforcement process. Reassess as needed.
• Decide on equipment. Determine and communicate whether there is flexibility on
the specific equipment based on individual needs/preferences or if there is a need
to standardize or limit the specific equipment choices.
• Determine number of units needed, resources available, who will provide, and the
distribution process.
• Provide equipment to users and provide training/guidance as needed. Assess need
for technical support; if needed, determine source for this support.
• Re-evaluate periodically using steps above.
STEPS IF TECHNOLOGY IS NOT READY TO USE OFF THE SHELF
If technology of interest is not ready to use and more research is needed to determine best
equipment or there needs to be software development or further research into the best software
applications for the work, the following steps should be taken:
• Elicit information on the technology of interest.
• Identify hardware/equipment. If new technology, consider purchasing multiple
modules of the hardware to evaluate prior/during the pilot.
• Identify additional software application development needed if any, and who will
do this.
• Identify partners for a pilot; identify commitment for pilot, e.g., extent of
deployment, who is funding.
• Work with partners to review the workflow process; solicit information on their
needs and preferences.
• Complete development of software for pilot.
• Go through the steps for implementation of technology that is ready to use.
• Conduct pilot.
• Decide on areas of expansion for the pilot or for additional pilots. Repeat steps
for pilot and implementation of technology that is ready to use.
• Full implementation. Repeat steps for implementation of technology that is ready
to use.
• To update technology or expand further, repeat process.
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OVERVIEW OF OECA ACTIVITIES TO PROMOTE THE USE OF TECHNOLOGY
OECA activities to improve the use of technology in EPA's compliance
monitoring/inspection program have included:
• Piloting the use of Personal Digital Assistants (PDAs), early efforts.
• Piloting and expanding the use of Tablets for the Toxic Substances Control Act -
Polychlorinated Biphenyls (TSCA PCB) program, on-going.
• Providing 132 digital cameras to HQs and regional inspectors to ensure access to
such cameras for conducting inspections.
• Actively encouraging the sharing of information on new technology being used
through National EPA Inspector Workshops and other national meetings,
workshops, and training courses in which OECA participates.
• Improving how inspector training and credentials are tracked.
• Establishing a Change Board to facilitate sharing and adoption of new
approaches, including the use of new technology.
PORTABLE PERSONAL COMPUTERS
With appropriate software, portable personal computers can provide the inspector with
the ability to:
• Load documents such as permits, previous inspection results, regulations, statutes,
inspection manuals, and compliance assistance material.
• Prepare and print inspection forms.
• Document findings during the inspection using templates that eliminate
duplicative information entry.
• Prepare inspection reports utilizing software templates that self-populate with
information collected during the inspection.
• Transmit reports from the field.
Portable personal computers are currently available in several forms including Tablets,
PDAs, and Ultra Mobile Personal Computers (UMPCs). With this technology, information that
is used in multiple documents prior to, during, and after the inspection would only need to be
recorded once. With portable personal computers such as the Tablet or PDA, the inspector can
collect field notes in handwriting and draw diagrams that are recorded electronically for use in
the report. The software can convert the handwritten information to typed information and
populate forms, field notes, and the inspection report. Unlike a laptop, the Tablet or PDA allows
the inspector to work while holding the computer in one hand and entering the information with
his other hand without needing a desktop or a place to sit. In addition, it is possible to automate
the collection of field data so that it can be extracted from the information collected during the
inspection to populate the data fields required for reporting by direct transmission into EPA's
Integrated Compliance Information System (ICIS) or other Agency databases. This eliminates
the need for the inspector to enter data separately or to provide the data to a data entry person.
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Thus, this technology can reduce data entry costs, transcription errors, and time delays in data
entry.
Given the available technology, the increasing need to capture valuable knowledge of
experienced inspectors, and the potential for increasing productivity, it is an ideal time to give
serious consideration to changing from pen and paper to the use of portable personal computers
and software developed specifically for inspections. Other offices within EPA and other
government agencies have begun using portable personal computers such as the Tablet and
PDAs for inspection activities. Part 4 highlights results of an informal survey conducted by the
National Compliance Monitoring Policy Branch (NCMPB) in OECA on the use of portable
personal computers in the field. It includes an overview of EPA activities in this area as well as
examples from a survey of how other government agencies (federal, state, and local) are using
portable personal computers such as PDAs and Tablets including information on the benefits.
Lessons learned are included in italics. (Appendix A contains the results of the survey.)
In addition to the informal survey, the NCMPB held discussions about new technology
during the National EPA Inspector Workshops and other National EPA meetings, and conducted
research to learn more about what other EPA offices, individual regions, and in some cases,
individual inspectors were using in the field, and the lessons they had learned. The Branch also
met with other Federal agencies and contractors to hear about their efforts and ask questions
PILOT PCB PROJECT USING TABLET AND SOFTWARE TEMPLATES
A number of pilots using Tablets and PDAs have been conducted within EPA, including
a successful OECA PCB Pilot (discussed in detail in Part 5) using a Tablet and software
templates to conduct PCB inspections and prepare reports. The PCB Pilot provides a blue print
for selecting a program, developing software, and incorporating this technology effectively into
inspection work.
The goal of the PCB Pilot was to develop software for Tablets which would allow the
inspector to use the Tablet to prepare for an inspection, conduct the inspection using the Tablet
to take handwritten notes in the field, make drawings, generate the required inspection forms
during the inspection, and produce a nearly complete inspection report based on the handwritten
notes entered during the inspection.
For this pilot, the NCMPB, Region 5, and the State of Indiana worked together to identify
an agreed upon workflow process for conducting PCB inspections. OECA and its contractor
used the results of this workflow process to develop software and inspection templates for use on
the Tablet to prepare for and conduct inspections and self-populate inspection reports. Region 5
and Indiana field tested the software and Tablets. OECA is encouraging the adoption of this
technology by regions and states responsible for TSCA PCB compliance monitoring. OECA has
also initiated discussions with the regions and plans to facilitate efforts to develop software for
the TSCA asbestos inspection program, which utilizes the same inspection forms.
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EXPANSION OF THE PCB PILOT
The next step for implementing and continuing to evaluate this program is to expand it to
all ten regional PCB programs and to fund state PCB programs that are interested in using this
technology. The NCMPB has transferred grant funding to the regions for three states, who
requested grant money under their PCB compliance monitoring grant for purchasing the Tablets
and software to conduct inspections. Training sessions have been scheduled for these states. In
addition, this Strategy recommends that OECA consider funding the purchase of Tablets and
software for 15 inspectors who conduct PCB inspections. (Note: Most regions have one or two
PCB inspectors; Region 10 has eight and Region 2 has seven inspectors who are trained to
conduct PCB inspections). The Strategy recommends funding one to two Tablets per region.
This investment will provide additional information on what is needed to successfully adopt this
technology in the field. One of the lessons learned from the information received during the
survey and the many discussions with programs beginning to implement this technology is that
continued support is needed as with any new computer technology.
Part 5 also discusses options for expanding the PCB project to address collection and
entry of data into the Agency's databases on compliance and enforcement, i.e., ICIS. For 2007,
regions are to enter their TSCA inspection data into ICIS. The next phase of the PCB project is
to modify the template to use data collected by the inspector during the inspection to self
populate a form, which can be printed and provided to the ICIS data entry person or entered by
the inspector into ICIS. Ideally, the software would be able to use the data collected in the field
in handwritten form or typed, to populate the ICIS data fields and directly transmit the data,
including Inspection Conclusion Data Sheets (ICDS) data, to ICIS, eliminating separate data
entry. Parts 5 and 6 discuss options for future work that include developing software to achieve
direct transmittal of inspection data (e.g., facility name, date/type of inspection) from the Tablet
to ICIS using information collected during the inspection.
EXPANSION OF TABLET USE TO OTHER INSPECTION PROGRAMS
The FACT Strategy recommends that OECA begin an initiative to expand its use of
technology, specifically the use of portable personal computers with appropriate software to
other inspection programs. It also recommends expanding the capability of this technology to
not only prepare for, conduct, and write inspections but also to provide direct data entry into
EPA's databases. Parts 5 and 6 identify options for doing this. Using the iterative process to
expand to additional inspection programs will allow adoption of improved hardware and
software technologies as they become available.
Transitioning from a pilot in one program for one type of inspection to adopting the use
of this technology in additional programs requires careful consideration of many options as well
as funding available. There are many directions that can be taken to improve the use of
technology in EPA's compliance monitoring activities. It is important to determine what gets
automated, whether states or tribes are included, and where to start. Regardless of which options
are selected, it will be important to incorporate the steps identified in Part 1 of the Strategy.
Options range from phasing in individual programs to developing enterprise-wide software. Part
6 addresses options for expanding the capabilities of the software to address various functions
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(e.g., loading permit information prior to the inspection, report writing, direct data entry) and
options for expanding to other programs (identifying a few programs for a phased in approach or
a systems based approach). Part 7 discusses options for providing hardware to regions and
states/tribes, including a discussion on leveraging resources to provide the hardware, i.e., the
portable personal computer. It also discusses options for leveraging resources for software
development. Part 8 includes a brief summary of conclusions and recommendations in the
Strategy, including a recommendation to periodically update the technology survey and to
collaborate with other EPA offices.
At this time, there are numerous individual efforts in this area. Individual offices and
sometimes individuals within EPA and states are adopting better technology for specific
programs, developing their own checklists/templates for PDAs, Tablets, or laptops. Other
offices within EPA such as the Underground Injection Control (UIC) program have developed
templates for UIC inspections across the regions. The Office of Environmental Information
(OEI) is developing templates for obtaining Global Positioning System (GPS) data during
inspections which is intended to be used for all programs. A coordinated approach among
programs would reduce duplicative efforts and incompatible systems as various offices seek to
adopt portable PC technologies to improve how they do inspection work. Establishing a
workgroup to be co-chaired by the NCMPB in OECA and OEI and with representatives from
other offices and regional programs is strongly recommended. The purpose of this workgroup
would be to share information on the various efforts and identify areas where joint efforts would
be advantageous. It will also provide a forum for sharing lessons learned.
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BETTER USE OF TECHNOLOGY IN COMPLIANCE MONITORING ACTIVITIES
FIELD ACTIVITY COMPLIANCE TECHNOLOGY STRATEGY
(FACT STRATEGY)
PARTI
OVERALL STRATEGY FOR MAKING BETTER USE OF TECHNOLOGY
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PARTI
OVERALL STRATEGY FOR MAKING BETTER USE OF TECHNOLOGY
1.0 OVERVIEW
The route to ensuring that programs are using the best technology on an on-going basis is
not linear. Rather this is a cyclical process. While some parts of the process are more step-like
where one picks a technology and then takes steps to pilot and expand and selects from various
options, this is only one phase of ensuring good use of technology.
To understand this concept, consider EPA's approach to providing staff with desktop
computers. The goal was not to purchase a computer for each employee. Instead, the goal was
to provide each employee with "up-to-date" equipment including software and skills to
effectively incorporate the use of the technology into EPA's work. EPA has an on-going
evaluation plan to assess the state of this technology, make changes to hardware and software
being used, and replace computers as necessary to ensure they are state-of-the art.
Technology is constantly changing. This has been especially rapid in technology that can
be adapted to field use such as digital cameras and portable personal computers (PDAs and
Tablets). For portable personal computers, there have been tremendous advances, both in the
hardware and software capabilities. Although advancements will continue, this doesn't mean
OECA should wait until the technological developments are "complete" anymore than it did
when it adopted desktop computers for office use.
This part of the Strategy identifies key elements of a continuous cycle for incorporating
technology into OECA's compliance monitoring work and ensuring that such technology is
continually updated.
1.1 KEY ELEMENTS FOR MAKING BETTER USE OF TECHNOLOGY
These steps were identified by analyzing two of OECA's recent efforts to make better use
of technology in field activities. The two projects analyzed were the 1) TSCA PCB Pilot Project
involving tablets and software template development, and 2) a project for providing digital
cameras to regions and HQs to ensure that inspectors have access to digital cameras during
inspections.
SELECTION OF TECHNOLOGY
• Review the workflow process.
This phase involves an overview of what the work is and how it is carried out and by whom.
The detailed analysis of the workflow process occurs later. Training in knowledge
management can be helpful.
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• Identify changes in the process that will improve performance and which can be
achieved by the application of new technology, increased availability of technology, or
replacement of aging equipment.
Changes that can improve performance may include changes such as simply assuring that all
inspectors have the necessary equipment or changing how information is collected and
stored. Areas of improvement in the use of technology can include quantity and quality.
• Elicit information on what is being used by others.
Within own program, find out what other offices are doing.
For other programs, attend national meetings and invite others to give presentations at
meetings.
For other agencies, contact those with similar work, e.g., FDA.
Read magazines/newspapers/press.
Consult with others who have an interest in computers/software.
• Ask persons doing the work being reviewed about their needs.
An example is OECA's decision to provide digital cameras to inspectors originated during a
discussion at the National EPA Inspectors Workshop. When asked what problems or issues
there were, inspectors indicated that they needed more digital cameras in the regional offices.
• Identify, research, and evaluate technology of interest.
Check websites, industry sources, and experts within and outside the Agency. Determine
capabilities and limitations of the technology for the intended work process. Find out the
options for the technology and determine the advantages and disadvantages, e.g., for portable
personal computers, there are three main types currently available - Tablet PCs, PDAs, and
Ultra Mobile PCs (UMPCs).
• Select technology to adopt/expand or determine if aging equipment needs replacement.
• Analyze potential impact of making this change on the enforcement process. Determine
if new policies are needed to address changes in process.
It is particularly important to determine if policies/guidance documents are needed to ensure
the evidentiary value of the documentation collected during the inspection or to provide
adequate security for enforcement sensitive or confidential information.
• Determine if the technology is ready to use or if additional research or development is
needed.
An example of technology which is ready to use "off the shelf' is the digital camera. The
decision to make better use of this technology meant that funds were needed to supply a
sufficient number of cameras. Decisions were focused on what type of camera to buy,
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features needed and funding sources. However, even with ready to use technology, an
analysis of the changes made by using such technology identified a need for a guidance
document on how to ensure the integrity of the photograph as evidence and technical
guidance on battery life and types of batteries to use in the field.
An example of technology where more research and development was needed is the use of
PC Tablets. While the Tablet hardware is ready to use, decisions on what software to use
and the development of specific templates to capture field data for PCB inspections were
needed to maximize the usefulness of the technology.
IMPLEMENTATION OF TECHNOLOGY THAT IS READY TO USE
Working with the users:
• Develop and issue policies, e.g., to ensure integrity of the inspection/enforcement
process. Reassess as needed.
Review the workflow process and evaluate what has changed. If there were previous
policies/procedures in place, determine if they remain applicable or if new
policies/procedures are needed.
Determine if there are security concerns that need to be addressed.
• Decide on equipment.
For equipment purchases, solicit information on users' needs and preferences.
Determine and communicate whether there is flexibility on the specific equipment based on
individual needs/preferences or if there is a need to standardize or limit the specific
equipment choices.
• Determine number of units needed, resources available, who will provide the resources,
and the equipment distribution process.
A phased-in approach for providing equipment may be needed depending on resources
available. Determine if there are advantages to centrally purchasing equipment (e.g. cost
savings, standardization, more efficient) instead of providing funding to individual
offices/regions.
• Provide equipment to users and provide training/guidance material as needed. Assess
need for tech support and determine source.
Determine if training and/or a manual is needed. Determine who will provide, how, and
when. Note, a training course or a manual may need to be developed.
• Reevaluate periodically using steps under the Selection of Technology.
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STEPS IF TECHNOLOGY IS NOT READY TO USE OFF THE SHELF
If more research is needed to determine the best equipment or if there needs to be software
development or further research into the best software applications for the work, the following
steps should be taken:
• Elicit information on technology of interest.
Attend meetings internal/external - ask questions, include technology on agenda.
Conduct informal survey internally.
Search the web to identify agencies using technology.
Call other agencies identified by the above activities and ask what they are doing and the
benefits.
Invite others to come in and discuss their use of technology or ask them to give presentations
during meetings.
• Identify hardware/equipment.
For technology that is not ready to use and for which additional research into hardware
features or software development is needed, consider purchasing different types or models of
the hardware to evaluate prior to and/or during the pilot.
• Identify additional software application development needed if any, and who will do
this.
This requires a mixture of personnel with background knowledge of software development
and those who may lack prior knowledge related to software or technology as well as persons
with a high level of program expertise to collaborate and create a workable solution.
• Identify partners for a pilot; identify commitment for pilot, e.g., extent of deployment,
who is funding.
Identify potential partners - especially from the ultimate users of the technology, i.e.,
regional or state/tribal inspectors and their managers.
Select individuals willing to invest time and energy in a pilot and in evaluating the
technology, ideally a mixture of proficiency working with the technology.
• Work with partners to review the workflow process; solicit information on their needs
and preferences.
Persons responsible for decisions on software should be knowledgeable of the program, meet
with the technical experts/users to fully capture the workflow process, and consider
accompanying an inspector during an inspection to better understand the workflow process.
• Complete development of software for pilot.
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• Go through the steps for implementation of technology that is ready to use.
• Conduct pilot.
Decide on what to pilot.
Identify what is needed prior to piloting.
Perform detailed workflow process analysis.
Identify policy or software needs.
Identify commitment and extent of deployment for pilot, who is funding.
Identify areas of flexibility.
Decide on timeframe and scope of pilot.
Have users become familiar with equipment its capabilities.
Identify process for training users.
Have user conduct a field test under actual use conditions.
Evaluate and revise as needed during pilot.
Solicit feedback from pilot.
Revise as needed.
• Decide on areas of expansion for the pilot or for additional pilots.
Decide on programs or activity being expanded.
Conduct outreach for program.
Repeat steps for pilot.
Repeat steps for implementation of technology that is ready to use.
• Full Implementation
Prior to full implementation, repeat steps for implementation of technology that is ready to
use.
Conduct outreach/discussion with partners.
Have user conduct field test initially.
Implement routine use.
• To update technology or expand further, repeat process.
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Overall Strategy for Making Better Use of Technology
Selection ofTechnology
» Review the workflow process.
» Identify changes in the process that will
improve performance and which can be
achieved by the application of new
technology, increased availability of
technology, or replacement of aging
equipment
• Elicit information on what is being used
by others.
• Ask persons doing the work being
reviewed about their needs.
• Identify, research, and evaluate
technology of interest
• Select technology to adopt/expand or
determine if aging equipment needs
replacement.
• Analyze potential impact of making this
change on the enforcement process.
Determine if new policies are needed to
address changes in process.
• Determine if the technology is ready to
use or if additional research or
development is needed.
No
Steps if Technology is Not
Ready to Use off the Shelf
• Elicit information on technology
of interest.
• Identify hardware/equipment
• Identify additional software
application development needed
if any, and who will do this.
• Identify partners for a pilot;
identify commitment for pilot,
e.g., extent of deployment, who is
funding.
• Work with partners to review the
workflow process; solicit
information on their needs and
preferences
• Complete development of
software for pilot
Implementation ofTechnology that is Ready to Use
Develop and issue policies, e.g., to ensure integrity of the inspection/enforcement
process. Reassess as needed.
Decide on equipment.
Determine number of units needed, resources available, who will provide the
resources, and the equipment distribution process.
Provide equipment to users and provide training/guidance material as needed. Assess
need for tech support and determine source.
Reevaluate periodically beginning with a review of the workflow process.
Conduct Pilot
Decide on what to pilot.
Identify what is needed prior to piloting.
Perform detailed workflow process
analysis.
Identify policy or software needs.
Identify commitment and extent of
deployment for pilot, who is funding.
Identify areas of flexibility.
Decide on timeframe and scope of pilot.
Have users become familiar with
equipment its capabilities.
Identify process for training users.
Have user conduct a field test under
actual use conditions.
Evaluate and revise as needed during
pilot.
Solicit feedback from pilot.
Revise as needed.
Decide on Areas of Expansion
for the Pilot or for Additional
Pilots
• Decide on programs or activity
being expanded.
• Conduct outreach for program.
• Repeat steps for pilot.
• Repeat steps for
implementation of technology
Full Implementation
Prior to full implementation,
repeat steps for implementation
of technology- that is ready to
use.
Conduct outreach discussion
with partners.
Have user conduct field test
initially.
To Update Technology or Expand Further, Repeat Process.
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BETTER USE OF TECHNOLOGY IN COMPLIANCE MONITORING ACTIVITIES
FIELD ACTIVITY COMPLIANCE TECHNOLOGY STRATEGY
(FACT STRATEGY)
PART 2
OVERVIEW OF OECA ACTIVITIES
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PART 2
OVERVIEW OF OECA ACTIVITIES
2.0 OVERVIEW
EPA's compliance monitoring and enforcement program is responsible for ensuring
compliance with federal environmental statutes dealing with prevention and control of air
pollution, water pollution, hazardous waste, toxic substances and pesticides. Inspections are a
primary tool in determining compliance for the Agency. An active field presence deters
violations and helps bring regulated facilities into compliance. Enforcement actions also
motivate violators to cease noncompliant actions and return to compliance.
The integration of technology into workflow processes for compliance monitoring and
enforcement can increase the efficiency of the inspection process, improve the timeliness of the
inspection report, improve the timeliness and accuracy of data entry, and increase the speed and
efficiency of case development and enforcement actions. Development of workflow processes, a
necessary step to developing software templates, also offers an effective way of capturing the
knowledge of experienced inspectors and providing more uniformity to inspections. In addition,
the use of technology can streamline management of the program in such areas as tracking
inspector training requirements.
The advancement of new technologies such as portable, lightweight computers and
improved software capabilities has made it possible to collect information in an electronic format
in the field. Rather than using pen and paper, electronic information can be used to create
inspection forms, prepare inspection reports electronically using the information generated
during the inspection, and submit data in a timely manner to the appropriate database. Digital
cameras allow the inspector to immediately view the picture and save it, alleviating the need for
waiting for film to be developed. GPS equipment provides accurate information on the latitude
and longitude of a facility or site. Both GPS data and digital photographs can be incorporated
into the inspector's reports electronically. Data on the inspection, such as facility, date, time,
type, etc. has the potential to electronically move from the inspector's data collected during the
inspection directly to Agency databases such as ICIS. The potential for inspectors and others is
that data or information can be compiled quickly and accurately, and automatically integrated
into existing databases, inspection reports, and other documents including forms. This same data
could populate case preparation and enforcement response documents. Although this Strategy
will reference possible applications to case preparation and enforcement response documents, it
primarily addresses applications to inspection programs.
2.1 SUMMARY OF OEGA ACTIVITIES
While there are many applications of technology, this overview summarizes recent and
ongoing efforts within OECA to foster the use of technology by inspectors in the field,
specifically the use of PDAs, and Tablets, digital cameras, and tracking systems for inspector
credentials and training requirements.
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Portable Personal Computers
OECA has reviewed, piloted, and evaluated several portable personal computers over a
number of years. A general discussion of portable personal computers, including information
for hardware evaluated by OECA, is found in Part 3. Part 4 discusses the results of a survey of
EPA efforts as well as research into what other government agencies are using and their results.
A detailed discussion on OECA's PCB Pilot and its expansion is found in Part 5 following the
technical discussion of this technology and an overview of its potential benefits.
National EPA Inspectors Workshops Feature New Technology Panel Discussions
The National EPA Inspectors Workshop, hosted by OECA (previously held annually but
now held every other year), is attended by inspectors from all regions across all programs. It
offers a unique opportunity for inspectors to hear what other programs, other regions, and even
other government agencies are doing to make better use of technology for inspections. This
topic has been on the agenda during each of the six workshops held. EPA headquarters and
regional personnel have participated in these panel discussions. Discussions have mostly been
about digital cameras and portable computers such as PDAs and Tablets. In addition, states have
given presentations as have the Federal Aviation Administration (FAA) and Food and Drug
Administration (FDA). During a couple of the workshops, display tables were provided for
industry to demonstrate their portable personal computers.
The upcoming Workshop in December 2007 will again feature presentations on new
technology for field use. The use of portable personal computers will be discussed in depth.
There will also be discussion by regions on other types of technology used for
monitoring/analyzing pollutants.
Digital Cameras
When digital cameras first became available, inspectors were using 35 mm cameras or
Polaroid cameras to take photographs during inspections. They created photo logs as they took
the pictures, recorded time, date, and their initials in the photographs for later use as evidence,
and included selected photographs in the inspection report by taping them to pages inserted into
the report. Initially, a few inspectors requested their offices to purchase digital cameras, and they
began to use them for inspections. More inspectors opted for the digital cameras. As technology
improved, the advantages of the digital camera in the field increased. Inspectors can take
pictures in the field and view them instantly, ensuring they have a good photograph which
captures what they intended. Digital cameras are easy to use and compact. The camera records
the data and time of the photograph. Most can also provide short video recordings, which can be
useful for certain types of documentation during inspections. The inspector can directly insert the
photograph into the inspection report if he chooses. As this technology became more common
place, there were many lessons learned. To share the lessons learned and to facilitate the use of
this technology, OECA did the following:
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• Developed and Issued Digital Camera Guidance for Civil Inspections and Investigations
As more inspectors began to use digital cameras to gather evidence, the NCMPB,
Compliance Assessment and Media Programs Division (CAMPD), Office of Compliance
(OC), OECA worked with regional and headquarters inspectors and attorneys to develop
guidance on recommended procedures to ensure the integrity of the digital image and
resulting photographs as evidence. The Guidance was issued July 2006 and is available on
the EPA Inspector Intranet Website: http://intianet.epa.gov/oeca/oc/campd/inspector/.
The Guidance also provides basic technical information for the inspector on the selection and
use of digital cameras including practical tips such as recommendations on the type of battery
needed for taking photographs in extreme hot or cold weather and a discussion of computer
requirements.
The NCMPB continues to address policy questions as they arise regarding the use of
digital cameras. Recent discussions with the regions indicate that there are differing policies
on providing copies of digital images to the inspected facility. The Branch has researched
the practices among regions and is developing a national policy on this issue.
• Centrally Funded and Provided 132 Cameras to Regions/HQs for Use by Inspectors
During the December 2005 National EPA Inspector Workshop, inspectors expressed
their concern that the regional offices did not have a sufficient number of digital cameras
available to ensure that inspectors had access to them for inspections. To address this
concern, Catherine McCabe, Principle Deputy Assistant Administrator, OECA, provided
funding to purchase digital cameras which were distributed to the regions and headquarters
for use by inspectors. The initial purchase provided 93 cameras. A second purchase was
made in July 2007, which provided an additional 39 cameras. Regional and headquarters
offices have purchased digital cameras on their own as well.
• Plan to Provide Training on Taking Photos for Use as Evidence
A training session on taking digital photographs during an inspection will be offered
during the December 2007 National EPA Inspector Workshop. It will include a review of the
Digital Camera Guidance.
Tracking Inspector Training: Train Trax
The NCMPB has evaluated different databases to use for tracking training requirements
for inspectors. They have identified Train Trax, a database currently used by On-Scene
Coordinators as a data system that is currently available at no charge and which can track
training and provide advance notification when training is required, e.g., annual refresher
courses. This system can be accessed nationally and can be used to verify completion of training
prior to issuing credentials. OECA will work with regions that agree to use Train Trax to help
enter data and to provide training.
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Tracking Credentials
The NCMPB currently provides EPA credentials to regions to provide to employees of
states and tribes that meet criteria in the 2004 Guidance on Issuing EPA Credentials to Authorize
Employees of States/Tribes to Conduct Inspections on EPA's Behalf. The NCMPB tracks the
transfer of credentials to the regions using an Access Database. The region is responsible for
tracking the issuance of the credential to the state/tribe.
The Office of Administration and Resources Management (OARM) tracks credentials
issued to EPA employees. Credentials issued to Senior Environmental Employees (SEE) or
contractors are tracked by the office responsible for the grant/contract.
OECA is pursuing discussions with OARM to issue and track all EPA credentials in a
centralized database using the recently adopted electronic system which allows photographs and
signatures to be sent electronically. Alternatively, OECA is evaluating the feasibility of
developing a system similar to OARM's which provides increased security for the issuance,
delivery, and tracking of EPA credentials. This avoids the need for each region to have a
separate tracking system for issuing EPA credentials to states/tribes.
Change Board
OECA sponsors a Change Board, which is a group established with managers within
OECA, to recognize and support compliance monitoring and enforcement projects proposed by
regions and HQs offices, including outside of OECA, which have the potential to effect positive
change. Best Practice Awards are provided to those projects which have been successfully
implemented and which can be replicated across regions. This allows innovative approaches to
be piloted and evaluated. In February, 2005 OECA gave a Best Practice Award for a project
which focused on the use of PDAs programmed with checklists to inspect and inventory Class V
Wells in the Underground Injection Control program.
Enforcement and Compliance Document Sharing
The Enforcement Targeting and Data Division (ETDD) has been exploring the possibility
of integrating enforcement and compliance documents for State and Federal activities into EPA's
Online Tracking Information System (OTIS). These materials would supplement the existing
summary data with detailed site compliance history, thus providing a single source for both
inspectors and case developers to compile facility information. If permits, past inspection
reports, facility self-reports, and enforcement documents (e.g., Notices of Violation, Compliance
Orders, and Consent Decrees) were readily accessible and downloadable, they could make pre-
inspection and case development activities more efficient. In addition to these direct benefits,
document sharing of compliance and enforcement materials could have additional benefits of
improved oversight. The NCMPB has expressed interest in whether inspection reports for
inspections conducted by states/tribes using EPA credentials on behalf of EPA could be
submitted to the region electronically for review. This would eliminate the need for the state to
submit hard copies to the region.
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Although some enforcement and compliance documents are already available in EPA
databases—and could potentially be linked to OTIS—there is currently no source for inspection
reports. An important step in the document sharing process would be to develop a method to
electronically store inspection reports. While developing a new database would be costly and
time-consuming, the Office of Compliance is exploring ways to leverage existing agency
systems (e.g., OSW's Emergency Response Team website), and alternative funding sources (e.g.,
Grants Administration Division, or Office of Environmental Information's Network Exchange
Grants).
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BETTER USE OF TECHNOLOGY IN COMPLIANCE MONITORING ACTIVITIES
FIELD ACTIVITY COMPLIANCE TECHNOLOGY STRATEGY
(FACT STRATEGY)
PART 3
PORTABLE PERSONAL COMPUTERS IN THE FIELD: OVERVIEW OF
HARDWARE/SOFTWARE OPTIONS CURRENTLY AVAILABLE
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PART 3
PORTABLE PERSONAL COMPUTERS IN THE FIELD: OVERVIEW OF
HARDWARE/SOFTWARE OPTIONS CURRENTLY AVAILABLE
3.0 PORTABLE PERSONAL COMPUTERS AND SOFTWARE TEMPLATES
The use of mobile, lightweight hardware and software allows the inspector to collect and
use information in the field in a manner that reduces redundancy by writing once and
subsequently populating numerous documents. This can expedite the preparation of inspections
as well as the completion of the inspection report and entry of data into EPA's data systems.
Eliminating the need to record the same information numerous times and by different individuals
can also improve data quality. The ability of these computers, unlike a laptop, allows the
inspector to collect data by handwriting including drawings as though he were using pen and
paper, to save the information electronically and to incorporate it into typed format into forms
and reports including the inspection report. This can dramatically improve efficiency during an
inspection. Technology exists which can make it possible to use this same information to
populate EPA's databases, e.g., ICIS.
While this Strategy focuses on the inspector and the inspection process, the same
technology could be applied to case development and the issuance of enforcement actions.
Software templates can be developed to identify violations and appropriate enforcement
responses and to prepare the enforcement action, taking advantage of templates to self populate
fields using information already entered by the inspector during the inspection.
3J STRATEGIC VISION
The increased use of technology such as computer hardware and software is one way to
improve the collection of information during inspections as well as data collection in Agency
databases such as ICIS. Using this technology in compliance monitoring and enforcement
workflow processes can improve accuracy, consistency, and efficiency in the information
collected and used by EPA managers and staff. Benefits include:
• Accurate data entry.
• Quick generation of accurate and complete documents and reports.
• Consistent information across regions, programs and individuals.
• Reduction of physical documents that an inspector takes with him. CFRs,
program policies, testing methodologies can be carried as electronic files not as
paper; forms are electronic files that can be printed anywhere.
• Quick tally and summary of inspection data.
• Ability to highlight specific areas for inspection as records are reviewed and
information collected during the inspection.
• Collection and integration of other sources of field data into reports, i.e., photos
and physical samples.
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There are a number of individual programs and individual inspector efforts to better use
technology in the field, especially portable personal computers. While inspectors often take their
laptops with them to use after the inspection, some inspectors are turning to the lightweight, very
portable units such as the Tablet and the PDA. While these units are convenient word processing
units, in the field, they can be used to record handwritten notes and diagrams. More importantly,
with appropriate software, they can automate much of the inspection process by populating
reports and forms automatically using information that has been entered once. This offers
tremendous potential to improve how EPA inspectors do their work. It also facilitates the
transfer of knowledge from senior inspectors who have extensive experience in conducting
inspections to software templates that can help lead a less experienced inspector through the
inspection process. With the tremendous improvements in the actual technology of these
portable units, it is an opportune time to consider how OECA might improve its work-flow
processes by adopting such technology.
HYPOTHETICAL EXAMPLE
A hypothetical example of how using workflow processes could improve an EPA
inspector's efficiency in collecting and reporting inspection data using software and hardware
that is currently available is provided below:
It's Monday morning. Inspector Jane Hughes is beginning her workweek by
preparing for a Resource Conservation and Recovery Act (RCRA) inspection at the
"ACME Corporation" scheduled for next week. Within this week, Inspector Hughes Will
download past inspection reports, review past enforcement actions, and download
applicable inspection forms, CFR citations, RCRA policies and equipment checklists all
from the local area network on to her portable computer (PDA or Tablet). In addition to
these compliance monitoring materials, there is a variety of pollution prevention
pamphlets and compliance assistance information available to Inspector Hughes.
The inspector has the choice of taking the compliance assistance materials with
her or downloading it in the field using wireless communications. In addition, Inspector
Hughes is equipped with a portable scanner, a portable color printer, a GPS antenna and
software, and a digital camera. This equipment allows the inspector to accurately
identify sites within the facility using geospatial data, capture the condition of the facility
at the time of the inspection, collect data electronically, print out required documents, and
leave the facility with initial results of the inspection.
When Inspector Hughes finishes collecting the field data, she will be able to
automatically generate a 90% complete inspection report and a completed compliance
monitoring form ready for transmission to the ICIS database from the data collected
during the inspection. Once the samples are analyzed and reported, Inspector Hughes
will complete the inspection report and forward it electronically to her supervisor for
approval.
When the inspection report is approved, the report and all supporting
documentation are again forwarded electronically to the regional case officer, who
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reviews the documentation to determine the appropriate enforcement response. Should
the response be an administrative or civil enforcement response, the case officer takes the
inspection and supporting data and synchronizes with the administrative enforcement
response documents. Once the violations are identified, the case officer inputs the RCRA
violations into the RCRA Penalty Policy Worksheet, which automatically generates a
proposed penalty. The case officer reviews and modifies the documents to reflect
accurately the enforcement action to be taken against "ACME Corporation".
Once the enforcement action is finalized, actions to be taken, pollution reductions,
penalties, and SEPs are sent to Regional Counsel for review and approval. When the
enforcement action is resolved, data from the enforcement action is entered into the
enforcement actions section in ICIS. If there are milestones to monitor, a tickler system
can alert the appropriate staff person of what is due to the Agency and when.
3.2 PORTABLE PERSONAL COMPUTERS - CURRENT HARDWARE
The primary portable hardware technologies used today for collecting inspection
information are Personal Digital Assistants (PDAs) and Tablet PCs (Tablets). Some companies
have developed specialized hardware for inspection tasks, but these tend to be dedicated to
specific functions and unsuitable for EPA's wide array of inspections. Both PDAs and Tablets
present their own advantages and disadvantages. PDAs generally cost a few hundred dollars per
unit, while Tablets are several thousand dollars each. Due to their size and memory/storage
limitations, PDAs lend themselves to checklist style inspections, while Tablet PCs allow for
adding more text and provide increased software options and capabilities. A comparison of each
type of hardware is outlined in Table 1 below.
TABLE 1: COMPARISOl
V OF TABLETS TO PDAS
Tablet PCs
PDAs
Screen is 10 to 12 inches diagonally;
approximately the size of a piece of paper;
size is good for notes and text. The inspector
can write on the screen with a stylus; similar
to taking notes on a paper pad.
Small screen works better for checklists with
yes/no answers. May limit the scope of the
inspection. Difficult to use to record lengthy
notes and text.
Size of screen allows inspector to draw
diagrams and read pre-loaded reference
material such as CFRs or statutes.
Small screen size makes drawing diagrams
and reading long documents difficult.
Inspector has to scroll down.
Good handwriting recognition ability; better
than the PDA. New Windows Vista Tablet
operating system greatly improves on the
handwriting algorithm. Converts notes to
typewritten text.
Handwriting recognition not as good as the
tablet; inspector less likely to take notes
though due to screen size.
Keyboard component allows inspector to
type text. Keyboard is similar to that of the
desktop PC. Allows touch typing.
Keyboard is small and doesn't allow touch
typing with 10 fingers. Stylus or typing with
one or two fingers/thumbs.
Allows digital signatures.
Allows digital signature.
Can be connected to a portable printer for
Generally must be connected through a laptop
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printing forms pre-filled by the computer.
or computer to print.
Can double as an inspector's computer.
Cannot double as an inspector's computer.
Heavier and bulkier than a PDA. Maybe
more difficult to hold/carry for a long time or
in places where the inspector's hands need to
be free such as climbing a ladder.
Cases/shoulder straps are available.
Small, lightweight - can be placed in a pocket
when inspector needs his hands free.
Higher costs - 10 x the price of the PDA.
Low cost.
Can be used as a scheduler.
Can be used as a scheduler.
Familiar XP interface is easier to adapt to.
Uses Microsoft Windows Mobile or Palm OS,
which may not be compatible with all
applications. Software may be unfamiliar.
Can be connected to a GPS receiver to
collect geospatial data.
Can be connected to a GPS receiver to collect
geospatial data.
Note: Although PDAs have been used for collecting inspection information, with the
introduction of the Tablet PCs, most inspection programs have been moving away from PDAs
and are adopting Tablet PCs. One office is considering Ultra Mobile PCs, which are mid-sized
between Tablets and PDAs.
Examples of PDAs and Tablets are pictured below. Figure 1 is a clamshell or notebook
Tablet with an integrated keyboard. Its screen pivots at a single point and rotates to cover the
keyboard. Figure 2 is a Windows-based PDA, which can fit comfortably in a person's hand.
Figure 3 is a Tablet PC from Motion Computing. It does not have an integrated keyboard like
the Toshiba; instead data is entered via an on-screen (i.e., digital) keyboard or an external plug-in
keyboard. The Toshiba and Motion Computing systems each have a 12" screen (diagonal) and
weigh about 3 pounds. All use a stylus or pen primarily to enter data; keyboards can also be
used by each unit.
Figure 1 - Toshiba Tablet
Figure 2 - HP iPAQ PDA
Figure 3 - Motion Computing
Tablet
In addition to purchasing the base unit—PDA or Tablet—there are many accessories
available for field use. The most useful additions include portable printers and scanners, Global
Positioning Systems (GPS) and Global Information Systems (GIS), digital cameras/recorders,
wireless technology, and Bluetooth devices. Portable printers allow the inspector to print various
forms and notices on-site. Scanners allow the inspector to photocopy documents into electronic
files during the inspection. GPS and GIS accurately identify or locate a position. Digital
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cameras allow inspectors to take photos and save the pictures electronically to their reports.
Wireless technology allows web access to agency data and information. Bluetooth technology
allows two pieces of equipment to communicate without wires, which might otherwise be
tangled and lost in the field. While these add-ons are desirable, there are costs associated with
them.
3.3 PORTABLE PERSONAL COMPUTERS - CURRENT SOFTWARE
The hardware is only as useful as the software it is operating. Without appropriate
software, the portable personal computer is a word processor and a place to take notes. To
maximize the return on the investment of purchasing these units and to achieve efficiencies in
how inspections are conducted, it is important to identify appropriate software that can collect
the requisite information during the inspection process and facilitate the inspection and
preparation of the inspection report. Software can be programmed to load background
documents, populate and print completed inspection forms, reduce repetitive entry of the same
information, collect inspection field notes, collect data for the Agency's databases, and populate
inspection reports using information collected during the inspection.
It is important for software to take full advantage of the benefits of the hardware, but
more importantly, for the software's capabilities to fully integrate the inspection workflow
process. One reason why some efforts to adopt technology do not succeed is that the software's
capabilities are not fully utilized or tested, which leads to an incomplete trial of the workflow
process that may end in rejection.
In general, there are three broad categories of software: commercial off-the-shelf
(COTS), customized, and proprietary. The cost associated with each category tends to increase
exponentially from hundreds to hundreds of thousands of dollars with the level of programming
required. This cost is also relative to the degree of automation, and ultimately, efficiency.
COTS software such as spreadsheets, databases, and word processing software are the least
expensive and often lead to small increases in productivity because they are viewed and used as
individual functions and they are not integrated into multiple tasks. If the software is
customized, either in-house or by a third party, the individual software can usually combine
several tasks such as site selection, data collection, and report writing. Software packages such
as Microsoft Access and InfoPath on the Tablet or Dragon forms on the PDA can be used to
create forms or checklists specific to each inspection program. Finally, proprietary software can
often integrate the field activities with an agency's database creating real-time updating of data
and reducing the need for multiple data entry. Table 2 summarizes the type and potential cost of
various software programs.
TABLE 2: TYPES OF SOFTWARE SOLUTIONS AND POTENTIAL COSTS
Solution
Cost
Note taking software (COTS)
$100
Spreadsheet/Database forms (COTS)
$100s-$1,000s
Customized Commercial Form/Checklist Software
$l,000s-$l0,000s
Proprietary Software Solutions
$10,000s-$l,000,000s
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BETTER USE OF TECHNOLOGY IN COMPLIANCE MONITORING ACTIVITIES
FIELD ACTIVITY COLLECTION TECHNOLOGY STRATEGY
(FACT STRATEGY)
PART 4
RESULTS OF SURVEY AND RESEARCH ON USE OF PORTABLE PERSONAL
COMPUTERS WITHIN EPA AND BY OTHER GOVERNMENT AGENCIES
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PART 4
RESULTS OF SURVEY AND RESEARCH ON USE OF PORTABLE PERSONAL
COMPUTERS WITHIN EPA AND BY OTHER GOVERNMENT AGENCIES
4.0 METHOD USED FOR INFORMAL SURVEY
The National Compliance Monitoring Policy Branch (NCMPB) conducted a survey
during the summer of 2005 of headquarters and regional EPA offices that have inspectors to
determine the level of technology use among EPA inspectors. A summary of information
obtained from the survey as well as other available information on EPA's efforts to adopt
portable personal computers to field use is provided below. The PCB project being implemented
by the NCMPB, Region 5 and the State of Indiana are included in the summary below but
detailed information is provided in Part 5 of this document.
In addition to surveying EPA regions and offices with compliance inspectors, the
NCMPB contacted over 30 different federal, state, local and foreign agencies. While this
research effort was not designed to be comprehensive, the NCMPB identified a number of
agencies at the federal, state, local, and international level that are using portable personal
computers in the field. The NCMPB staff asked about hardware and software being used in
either an inspection or enforcement capacity and solicited information on the results other
agencies were achieving by using the technology.
The agencies contacted were identified by web searches of news reports about
governmental organizations investigating or using new hardware and software in the course of
compliance monitoring activities. The NCMPB also contacted federal agencies with compliance
monitoring responsibilities as part of their mission and other organizations identified by OC
managers as ones using new technology.
During the inquiry, the NCMPB staff described the purpose of the call and asked
questions about their project to determine the name, the objective and a description of the
project; the cost to develop; the known benefits, if any, of implementing the project including
savings in inspector time, program dollars saved, and data improvement. While most of the
respondents could provide a name for the project and a description, in many cases, the
respondent did not know the cost for development nor could they provide evaluation information
on the success of the project. Much of the evaluation information provided was anecdotal.
Information collected during the survey is found in Appendix A. Examples which show the
types of projects being implemented and information on their benefits are provided below.
4.1 OVERVIEW OF THE SURVEY AND RESEARCH
In 2007, the NCMPB updated the information from 2005 based on summer interns
contacting a number of the original contacts. During the initial contact in 2005, many of the
agencies questioned indicated they were considering the possibility of automating their
inspection processes through new hardware and software solutions. Many of the contacted
agencies have not implemented these programs quickly due to high start up costs and/or
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restrictive budgets. However, given the multitude of options and the high variability in costs in
implementing new workflow processes, a majority of agencies found some way to incorporate
new technology into the inspection workflow process. In most cases, the savings in efficiency
and productivity outweigh the initial investment. The primary difficulty for government
agencies is defining the appropriate level of integration based on data needs and available
funding. Many government programs successfully funded new technology programs for their
field agents from several different sources although the benefits and efficiencies occurred at
different points within the workflow process. It is sometimes difficult for one part of the
organization to justify the costs when the benefits are dispersed across the whole organization.
Appendix A provides a detailed list of results from the survey. The discussions below
highlight examples of the various ways in which agencies are adopting technology and the
results.
4.2 USE OF PORTABLE PERSONAL COMPUTERS
Agencies at the federal, state, and local level are making progress in adopting portable
personal computers into their field work. Within EPA, there are a number of efforts. Some are
program wide, e.g., the Safe Drinking Water program developed and field-tested PDAs for their
Underground Injection Control (UIC) Class V inspection program and Sanitary Sewer Survey
program. OECA's pilot of the PCB inspection template is directed towards one type of TSCA
inspection. At this time, efforts within EPA are program specific or even specific to a region or
to individual inspectors; these efforts seem to be increasing. Some efforts focus on the use of
checklists which are filled in during the inspection, and others seek to maximize the use of
technology to automate the inspection and report writing process.
4.2.1 U.S. ENVIRONMENTAL PROTECTION AGENCY (EPA)
OECA
At this time, OECA's primary focus is on the use of Tablets and software that can be
used to prepare for an inspection, conduct the inspection, prepare the inspection report, and
report information on the inspection (facility, date, inspector, type, etc) into Agency databases.
• TSCA PCB Pilot
Current efforts include the TSCA PCB Pilot project. Software was developed based
on the inspection work flow process and allows the inspector to record information once and
the software uses that information to populate forms. Information that is entered prior to the
inspection and during the inspection can be manipulated by the software so that it populates
screens as the inspector conducts the inspection, e.g., information gathered during the
opening conference and by reviewing records at the facility can be used during the walk
through without the inspector having to re-enter the information. This can help the inspector
during his walk through. For example, he can flag what equipment he wants to inspect, and
the computer will show the pertinent information recorded during the records review when
the inspector physically inspects the equipment. The software can take information and
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photographs gathered during the inspection and use it to populate the inspection report. Part
5 provides an in-depth discussion of the pilot, for the PCB program and expansion of the
pilot. The pilot provides a blueprint for applying the FACT Strategy and adopting this
technology.
• Survey of use of new technology within EPA, other Federal Agencies, and States
The NCMPB conducted web searches, made phone calls and sent e-mails to gather
information on the extent that other agencies or offices are adopting technology, especially
portable personal computers, for field use by compliance inspectors. Appendix A contains
the results of the survey. In addition to the survey, the NCMPB met with the FAA and FDA
to discuss their use of technology.
• OECA and OEI coordination
The NCMPB has periodically checked in with the OEI to ensure that its efforts were
consistent with OEI policy. OEI participated at one of the National Inspector Workshops and
provided an update on their work. Recently, the NCMPB met with OEI staff to discuss a tool
which OEI is developing, the Facility Field Data Collection Tool. OECA will share this
FACT Strategy with OEI and work to identify areas of common interest for further
development.
• Discussions at national meetings
The NCMPB has given presentations at EPA and state meetings on its PCB pilot
project. They made a presentation at the June 2007 National PCB Meeting, which was
attended by EPA PCB personnel. They also led a discussion of this topic at the October 2007
Field Operation Group (FOG) Meeting. The FOG consists of EPA Regional supervisors and
staff who conduct environmental monitoring and/or compliance inspections. Meetings such
as these provide an opportunity to not only share what OECA is doing but to also gather
information on what others are doing.
• Outreach to states
The NCMPB participated in the Planning Committee for the September 2007
Pesticide Regulators Enforcement Program (PREP) Compliance Monitoring course. They
gave a presentation on the use of new technology for compliance programs during the course.
In August the NCMPB gave a presentation for Region 1 and its states that conduct
TSCA asbestos inspections. Additional presentations were given at a Region 4 state asbestos
meeting and a tri-regional asbestos meeting with Regions 1, 2, and 3 their states.
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UIC PROGRAM
In 2002, the Office of Water began developing UIC software for PDAs through a
contractor. Due to the lack of a national UIC database, and the regional variation in data, the
software had to be developed individually for each region. The software consisted of a series of
checklists on a PDA with GPS integration, and an interim Access database for a laptop. After
collecting data on the PDA, inspectors could connect to the laptop, print trip reports from the
field, and export data to the regional database. Each program was developed by spending a day
analyzing the workflow process with regional inspectors. The contractor would develop a
sample program, which would be tested by the region before delivering the software. At the
same time, many of the regional databases were upgraded to Microsoft Access databases.
Training consisted of an operations manual developed at Headquarters, and training by a lead
inspector at the regional level. One primary benefit of the software was the reduction in
transcription errors.
By 2006, seven regions were using PDA software for their UIC inspections. The total
cost for the programs, including upgrading regional databases, ranged from $45,000 to $100,000
per year. The Office of Water stopped funding and supporting the UIC software in 2006, but
many regions continue to use the software. Some regions have even tried to broaden and
improve the software themselves. Meanwhile, Office of Water has shifted toward developing a
national UIC database.
SAFE DRINKING WATER - SANITARY SURVEY PROGRAM
The Office of Water developed a PDA template in 2004 for use in its Sanitary Survey
Program. Since different states have different survey requirements, the software allows for
individuals to add their own questions or create standard sets of questions depending on the
drinking water system they are going to survey. The software prints reports, cover letters, and
deficiencies in the field; exports data to the Safe Drinking Water Databases; and makes it easier
to follow-up. Most surveys are not considered inspections. As of November 2006, 16 states and
several EPA regions have tested the software or started developing question sets to begin testing,
and over 800 surveys had been completed. In fall 2005, Office of Water released a new version
of the software for Tablet PC, which allowed inspectors to choose their application based on
hardware preference and the length of the survey. According to preliminary results, inspectors
are finding a savings of between 3 to 14 hours in conducting sanitary sewer surveys using the
new hardware and software. The Office of Water publishes a newsletter with updates about the
software and its use.
OEI - SOFTWARE FOR PORTABLE PERSONAL COMPUTERS
OEI has developed a Facility Field Data Collection Tool, which is a software model
designed to support the EPA Locational Data Improvement Project. The application software
enables users to capture latitude/longitude readings in the field—using a GPS receiver—and add
comments. The system can also connect to the Facility Registry System (FRS) for import and
export, or be exported to a text file for upload into any database. Currently the application runs
on Windows Mobile (for PDAs) or Windows XP (for Tablet PCs or Ultra Mobile PCs). The
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design of the tool allows for integration into other software applications. OEI is currently
beginning field usability tests.
QSWER AND REGIONAL EMERGENCY RESPONSE TEAMS
The Emergency Response Team has developed an extensive set of tools for its On-Scene
Coordinators. Applications for field use allow for modeling, 3D mapping, statistical analysis,
data acquisition, and data management. On-Scene Coordinators use a variety of hardware,
including PDAs, laptops, GPS, digital cameras, scanners, and data monitors. This combination
of tools allows for real time coordination of office and field activities. The unique needs for:
immediate response; coordination of multiple individuals in different locations; and
communication from individuals who spend extended periods of time on-site, provides the
incentive for the Emergency Response Team to use technology in the field.
One of the primary tools used by ERT has been in constant development over the past 15
years. Scribe—a required deliverable for all EPA Emergency Response contracts—allows for
captures of sampling, observational, and monitoring field data. Examples of Scribe field tasks
include Soil Sampling, Water Sampling, Air Sampling and Biota Sampling. Scribe can import
electronic data including Analytical Lab Result data (EDD) and Sampling Location data such as
GPS. Outputs include labels for collected samples, Chain of Custody generation and Analytical
Lab Result data reports. The flexible user interface allows individuals to manage, query and
view all the information, or export electronic data to other tools, so sampling data may be further
analyzed and incorporated into report writing and deliverables. Additionally, Scribe supports the
development of PDA extension applications by OSCs or the Emergency Response Team on an
ad-hoc basis. OSWER has a dedicated staff of EPA and contract employees to develop and
support the software. All of the tools are shared and discussed among regions through an IT
Forum, Federal Remediation Technologies Roundtable, and a framework that stores the
applications centrally.
The Scribe system has been used for many EPA response actions including World Trade
Center, the Columbia Shuttle recovery, and Hurricanes Katrina and Rita.
REGIONS
• Region 1 TSCA Program
In 1998, Region 1 developed a Microsoft Access based system to audit asbestos
training providers, based on a checklist created by states in Regions 1, 2, 3, and 4 to enhance
reciprocity. In 2001, it was expanded to include a checklist-based tool for Asbestos Hazard
Emergency Response Act (AHERA) inspections. The system is used on laptop computers,
and allows inspectors to identify observations related to specific statutory requirements.
Summary reports of inspections and links to photos are also integrated into the software.
Since 2001, a TSCA Lead inspection checklist has been added, and the states are looking to
upgrade the system to work with Tablet PCs with a Web-based feature to immediately update
their databases over a secure site.
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• Region 2 UST Program
Beginning in 2001, a Region 2 inspector, in collaboration with the State of New
York, began developing a PDA based software tool for Underground Storage Tank (UST)
inspections. Development of the software was based on a thorough analysis of an inspector's
workflow. After initial design, the inspector created a series of paper based checklists for
inspectors to use and test in the field. This process helped to refine the checklists without
additional programming. After many iterations of testing, the software allowed inspectors to
collect facility information, inventory USTs, and collect GPS data using a combination of
checkboxes, drop-down menus, and handwritten entry. Progress on the project stopped in
2005 when the inspector wanted to upgrade the back-end database to allow updates from the
field. The IT department would not support the new database software. Since that time, the
inspector has moved to the National Pollutant Discharge Elimination System (NPDES)
program and is trying to develop a storm water inspection checklist. The Region 2 UST
office is currently looking into having a contractor upgrade the PDA software. They have
received funding from the Office of Underground Storage Tanks (OUST), but the Office of
Site Remediation Enforcement (OSRE) denied additional funding.
INDIVIDUAL EFFORTS IN REGIONAL OFFICES
A number of inspectors have been investigating the use of PDAs or Tablets on their own.
Some inspectors believe that pen and paper is still the most efficient method of data collection,
and they consider the new workflow process using new technology an unwelcome distraction.
Other inspectors ask why EPA has not invested in new workflow processes to adopt the new
technologies when states in their region have been using PDAs and Tablets for some time.
4.2.2 OTHER U.S. GOVERNMENT AGENCIES
FOOD AND DRUG ADMINSTRATION (FDA)
FDA uses the Tablet and software to generate reports providing during closing
conference. They don't use it to conduct the inspection although it provides inspection targeting
information. They also use the deficiency data to analyze deficiencies across sectors.
The Food and Drug Administration is responsible for inspecting a variety of facilities,
including fish processing plants, pharmaceutical and medical devices manufacturers and
cosmetics. Many companies inspected by the FDA complained that enforcement response
among the regional offices varied greatly. There was a concern that a violation in one region
resulted in a warning letter while, the same violation in another region resulted in a fine.
Industry wanted consistency in the agency's enforcement response. In response, the FDA began
in 1999 and completed in 2003 their first module called Turbo Electronic Inspection Report
(Turbo EIR). Today, 1,200 FDA inspectors use this module. The Turbo EIR has several
functions. It allows inspectors to download their assignments, generate and print reports and
citations, and upload the field data into an agency-wide database for real-time updates. The
software contains "plain English" translation of the CFR that ensures the prescribed information
is used to issue inspection observations consistently throughout the country. The primary benefit
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of this program is quality control. Standard procedures and language are used in all reports.
This workflow process has promoted more unified enforcement actions by the Agency.
The Turbo EIR module is the equivalent to an EPA inspector providing his/her
observations during the closeout meeting with facility representatives. While the EPA inspector
provides a list of potential deficiencies, the FDA inspector provides the facility representatives a
formal printout of the specific deficiencies found by the inspector at the facility. The Turbo EIR
includes the Code of Federal Regulations and plain English language for each regulation. The
FDA inspector identifies the deficiencies in the software, prints the information onto the FDA
form (FDA-483), the FDA's official notification of deficiencies, and gives the FDA-483 to the
facility representative. The deficiency data is uploaded onto the mainframe back at their office.
Any FDA inspector can search the database to determine if similar deficiencies are occurring in
other company facilities in the US or if the deficiency is a common problem within an industrial
sector.
In tenns of cost, the FDA spent roughly $2 million dollars from 1999 to 2005,
developing, testing, implementing, training and working through software issues. The FDA
currently spends approximately $35,000 a month for programming support from the USDA, one
FDA FTE and one Project Officer FTE for contract oversight.
There are some unique items to note about the FDA project. The programmers are based
in the Department of Agriculture. Should EPA utilize their services, costs should be a bit lower
since software and knowledge have been developed during the FDA project. OECA could join
with the FDA contract to take advantage of development costs already paid for by the FDA. The
other unique feature is the development of the plain English verbiage of the CFR used in this
software. The FDA figures 1000 man-hours, both program and legal, staff and managers, were
required to develop the plain English verbiage.
IJ.S. POSTAL SERVICE
In 2003, the U.S. Postal Service equipped 600 safety inspectors with Compaq iPAQ
PDAs to annually inspect their 39,000 Post Office facilities for OSHA requirements. Inspectors
use software that a team of in-house and contract programmers began developing in 2001. The
software integrates three databases into a checklist, and provides a web interface to upload
information into an Oracle database and immediately print reports and access references.
CENSUS BUREAU 2010 ENUMERATION PROCESS
The Census Bureau awarded a contract to make the 2010 enumeration process paperless.
The software and hardware are standardized to the Census' IT policies and there is no ability by
the user to amend the workflow process. The software will allow the enumerator to follow-up
with citizens who did not submit their long or short census form. All the information will be on
a handheld unit similar to a TREO. The TREO is a combination phone and PDA. It will have
wireless capability with information transmitted on a regular basis to the national database. This
project is a true makeover for the enumeration process scheduled in 2010. As of May 2007 the
product is being field-tested. The contract award totals $600 million. The contract includes all
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hardware (500,000 handheld units) and software, back-end programming thru database, wireless
development, training and support. A unique feature about this project was how the contracting
process was used. The Census knew what it wanted in terms of performance but did not know
what hardware and software there was that could address their needs. During the contract
process, each contractor was required to develop a prototype of the software and hardware that
would be used in the field. As a result, the Census Bureau currently has an 85-90% complete
prototype package. There will be some modification to the prototype software to reach the final
product but this contracting process took about six months to complete yielded a near perfect
workflow process which was scheduled for field testing by May 2007.
4.2.3 STATE AND LOCAL AGENCIES
The survey contains many examples of the use by state and local agencies. States and
local governments seem to be ahead of the Federal government in their efforts to adapt this
technology to specific programs. See the Appendix for additional examples.
SOUTH FLORIDA WATER MANAGEMENT DIVISION (SFWMD)
They use mobile laptop computers with data link cards. The software is Avantgo
business server. Digital photos and GPS can be incorporated. The original program was
developed in 1999. It was developed in-house for time reasons. Everything is done through web
browsers. The SFWMD used an analysis of workflow process to develop the software. It was a
one year process from development to deployment. The M-business server is high security.
They created a Web-based technical manual, and there is personal training for each new person.
There was resistance from more experienced inspectors who were concerned with security
issues. Also some of the inspectors found that small PDAs are hard to enter data, but the mobile
tablet PC does not have that problem. There are 45 inspectors, and they are adding ten more in
the next few months. They are required to use the technology. Over the last six years about
2,000 inspections, focused on wetlands and storm water programs, have been completed with
this technology. They have not encountered any legal, enforcement, technical, or security issues.
The Avantgo start-up cost was $10,000; the 25 original PDAs cost $300 a piece. The
programmer time was about $45,000. It was about $60,000 total. The program paid for itself in
less than a year.
FLORIDA HEALTH DEPARTMENT IN VOLUSIA COUNTY
Their program includes the use of arc pad with attached GPS service, and XV6700
Pocket PC/IPAC. The technology is used for several different inspection programs to pre-fill out
forms and to upload information back to a database. These inspection programs focus on septic
tanks, pools, and irrigation systems. The technology does not incorporate digital photos. The in-
house program began 3-5 years ago. It was developed using a combination of statute-based
checklists and analysis of the workflow process. It allows detailed notes to be taken by
inspectors, should the inspector desire. The program took a couple of months to develop and a
couple of months to implement, but it is constantly being revised. The inspectors were given
hands-on training on how to use the technology. At the beginning of the program they
encountered resistance from inspectors because of the small size of the Pocket PCs. Inspectors
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are encouraged, but not required to use the technology. They have not encountered any legal,
enforcement, technical, or security issues. Hardware costs are roughly $10,000 (rough figures)
and software costs are roughly about $10,000. The cost per inspector may be going down from
around $1,750 per inspector to around $1,500 because upgrading the software is less expensive
than buying it. They have experienced time savings by elimination of duplication of effort,
reducing the of chance errors. Efficiency has improved.
FLORIDA DEPARTMENT OF ENVIRONMENTAL RESEARCH MANAGEMENT
Their program uses Tablet PCs with Microsoft Windows Shop and custom built software.
They can incorporate GPS/GIS maps and digital photos. The program began in 2003. The
software was created in-house. They used both statute-based checklists and analysis of
workflow process. The program is constantly being revised with more than five versions
developed in the first four years. The 5th version is coming out in the next few weeks. There is a
separate training group for the technical process. Inspectors are required to use the tablets.
There was some resistance from inspectors at first, but no more than is usual for any change in
the inspection process. There are 70-75 inspectors using the tablets. No novel legal,
enforcement, technical, or security issues have come up. Nobody has done a study on efficiency
but the consensus is that the program has increased the number of inspection per year and been
worth it.
RHODE ISLAND DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
In 2005, the Rhode Island Department of Environmental Management reported that they
use Tablet PCs with Microsoft Office InfoPath to conduct UST inspections. The InfoPath
software transformed a ten-page paper checklist into a single form that auto-fills with pre-
inspection information. During an inspection, the inspector can access all the references and site
history he/she needs as it was downloaded before going into the field. In addition, the software
and digital pen allow the inspector to draw and store site diagrams on the form. The data is
uploaded to their Oracle database allowing for immediate follow-up with enforcement action.
The new system is expected to save about $200,000 per year compared to the paper process.
Update from June 2007: Their program is still in its pilot stage. Inspectors just started
using tablets in the field within the last couple of months. Underground storage tank inspectors
are now using HP Tablet PCs. They can incorporate other electronic data such as digital photos
and GPS. The software for the programs was developed by consultants based on Microsoft
software. They used a check list to develop the software. The check list is part of a larger
system of data management tools developed by a consultant. Three inspectors are currently
using the Tablet PCs and one more is being trained. They are getting input from the inspectors
and deciding how to alter the program. The inspectors get in-house training on how to use the
tablets. They encountered a little resistance from the inspectors, the major complaint being that
the screen is hard to read in the sun. The program began with a Microsoft grant for upwards of
$100,000. Because this is a pilot program, they are still waiting for some feedback on time
savings.
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TEXAS STATE BOARD OF BARBER EXAMINERS
Since 2001, the Texas State Board of Barber Examiners, with eight inspectors, has used
PDAs equipped with wireless technology to visit fifteen to twenty businesses per day to check
for sanitation violations. It took about one year to develop the software and to work through the
software bugs. With the implementation of the new technology into their inspection process, the
Board eliminated paper forms, reduced transcription errors and duplicate data, saved time in the
field, and reduced office staff (a direct saving of $28,000 per year).
4.2.4 FOREIGN GOVERNMENT AGENCIES
HONG KONG ENVIRONMENTAL PROTECTION DEPARTMENT
In 2000, the Hong Kong Environmental Protection Department equipped inspector teams
with PDAs to carry out inspections of chemical waste collectors and their vehicles. The
inspectors download site histories from their database, complete inspection checklists, and
synchronize the inspection data into their database for processing, and report generation. The
agency found that the teams saved 1.5 man-hours per day, with an increase in productivity of
10%. This solution reduced paper waste, data duplication, and data entry errors. Beyond PDAs,
the Environmental Protection Department started a GIS-based system for logging and mapping
public complaints about potential polluters, and the Department requires major development sites
to mount webcams at construction sites for public internet monitoring.
NEW ZEALAND MINISTRY FOR THE ENVIRONMENT
Inspectors in the New Zealand Ministry for the Environment are field-testing PDAs. The
current system produces draft letters and allows access to site history in the field. Ultimately,
they hope to have a system that will pre-load inspection forms and site information, record
findings, integrate digital photos, print out forms, and download real-time information.
UNITED KINGDOM HEALTH CARE WORKERS
The healthcare sector in the United Kingdom equipped health care workers with Tablet
PCs using Microsoft InfoPath during patient visits. This allows for a team approach to patient
care by creating a single record with information shared among the database systems of several
care agencies. The solution is expected to save £3 million ($5.95 million) by eliminating
assessment duplication, and reduce administrative costs by £850,000 ($1.69 million).
4.3 ADVANTAGES AND DISADVANTAGES OF PORTABLE PERSONAL
COMPUTERS IDENTIFIED BY THE SURVEY/RESEARCH
PDAs have been on the market since 1997 and Tablet PCs since 2001. Agencies that
adopted their use see benefits within their organizations and a positive return on investment. In
the case of the South Florida Water Management District, a cost analysis of their $10,000
investment into their PDA program produced a savings of about $70,000 annually.
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Advantages:
• Improves efficiency and productivity.
• Decreases data entry errors by doing away with replication.
• Reduces paper waste.
• Can carry all reference materials in the PDA or Tablet.
• Decreases time spent preparing reports.
• Standardized responses ensure consistency.
• Standardized inspection reports, uniformity of inspection data across the
organizations.
• Provides solid evidence for any legal disputes or hearings.
Disadvantages:
• Initial cost of development, time to develop, training and deployment.
• Staff resistance in adopting a new workflow process and/or new
equipment/software.
• Issues/bugs may arise that were not detected during initial testing.
• On going costs of maintaining and/or upgrading the software plus adding new
functions/capabilities over time.
• Costs of maintaining and replacing equipment.
4.4 ADDITIONAL CONSIDERATION IDENTIFIED DURING THE SURVEY AND
RESEARCH LESSONS LEARNED
Adapting to new workflow processes and using new hardware and software in the field
requires planning and awareness of the technology's capabilities. Before purchasing the
equipment or software, managers need to check with their Information Technology (IT)/Help
Desk to ensure that the equipment and software will be supported. Knowledge of IT policies
including security requirements can impact the choice of hardware and software.
Energy use becomes an important consideration for the inspector using a portable
computer and other portable devices to collect compliance monitoring information. Inspections
usually last several hours and access to an electrical outlet may not be convenient. Extra
batteries and portable chargers will be required to help the units last through the day. The
possibility of data loss can be reduced by manipulating the device's software to extend battery
life. In this new workflow process, regular data backup is necessary to ensure the collected field
data is not lost during the inspection.
The physical environment in which an inspector operates can be a limiting factor when
using electronic devices. Temperature, glare from sunlight, or exposure to water or hazardous
materials are all concerns. However, polarized screens, units without fans, and even ruggedized
versions of PDAs and Tablets are available. There may be situations where the environment is
so hazardous that using any electronic device within the environment could cause an explosion.
There are ruggedized units that can operate in most of these environments.
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The cost to purchase portable computing devices is a definite consideration, as the
Tablets are more expensive when compared to comparable desktop systems. The cost and risk of
damage can be spread out by purchasing the Tablet and requiring the inspector to use the Tablet
as both his desktop unit as well as a field unit. Leasing mobile units might be an alternative as
hardware technology changes rapidly. The Colorado Department of Agriculture has been using
Tablets in the field for several years and has a leasing plan with one of the Tablet manufacturers.
As part of the leasing program, the department purchased an Accidental Damage Replacement
(Insurance) Plan. If anything happens to the Tablet, the manufacturer will replace the Tablet free
of charge, no questions asked. The Colorado Department of Agriculture has yet to take
advantage of the replacement plan.
As with anything new, employees are apprehensive when a change is made within the
organization. Introducing new workflow processes along with new hardware and software will
cause anxiety. Some EPA inspectors have raised the issue of learning a new and foreign process
that is very different from what they have become accustomed. This is a valid concern when
introducing any new system or set of procedures. One way to reduce the anxiety is to
incorporate the future users into the planning and development stage. This process helps ensure
that when the workflow process is ready to be implemented, the users understand the new
workflow process and have had adequate training including support services.
When considering the adoption of a new workflow process into inspection and
enforcement programs, there are additional issues to consider and respond to in order for the
workflow process to have a successful implementation. These issues include:
• Make sure technology fits the goals; don't set goals to available technology.
• Increase familiarity with applicable hardware through purchase and use of
devices.
• Provide adequate training and support.
• Personal interaction with operators still required.
• Security: passwords, FOIA request access, CBI, backups.
• Integration into back-end system (ICIS).
• Provide look and feel of paper forms.
• Include business stakeholder in design.
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BETTER USE OF TECHNOLOGY IN COMPLIANCE MONITORING ACTIVITIES
FIELD ACTIVITY COMPLIANCE TECHNOLOGY STRATEGY
(FACT STRATEGY)
PART 5
APPLICATION OF THE KEY ELEMENTS FROM THE FACT STRATEGY: OECA'S
PILOT PROJECTS USING PORTABLE PERSONAL COMPUTERS
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PART 5
APPLICATION OF THE KEY ELEMENTS FROM THE FACT STRATEGY: OECA'S
PILOT PROJECTS USING PORTABLE PERSONAL COMPUTERS
5.0 OVERVIEW
The NCMPB has successfully applied the key elements identified in Part 1 for making
better use of technology for the TSCA PCB inspection program and conducted a pilot program
with Region 5 and the State of Indiana. Software templates have been developed and are in use
that load documents prior to inspections and allow one time entry of information by the inspector
to populate multiple forms, field notes, photo logs, and inspection reports. Part 5 provides
detailed information on the NCMPB's early efforts to pilot PDAs and voice recognition software
and explains the reasoning behind its selection of the TSCA PCB Inspection Program for the
pilot and why it chose to pilot the larger Tablet rather than the smaller, less expensive PDA.
Lessons learned are identified in italics throughout this part. Examining the process the NCMPB
used for the PCB pilot demonstrates how one moves from identifying the technology to improve
a workflow process through to a pilot project. It describes the process to develop inspection
program specific software. Cost information is also provided.
This part recommends that OECA expedite the expansion of the TSCA PCB pilot to all
Regions and to states which conduct inspections under TSCA Compliance Monitoring
Agreements by providing funding for equipment. The NCMPB has already provided TSCA
STAG funds to regions to provide to additional states to purchase Tablets and to participate in a
training course being conducted by the NCMPB in fall of 2007. The NCMPB will provide the
software templates. Regions are very interested but have not purchased Tablets. OECA plans to
purchase and provide 15 Tablets to the regions at an approximate cost of $4,500 per Tablet
(including needed accessories) for a total amount of $67,000. This will equip one to two
inspectors per region. Most regions only have one or two PCB inspectors. (There are 26 PCB
inspectors across regions.)
In addition to the PCB Pilot, the NCMPB is working with regions to help them develop a
software package for TSCA AHERA (asbestos in school) inspections. Note that the inspection
forms are the same as for TSCA PCB inspections, eliminating the work needed to develop
electronic forms for the Tablet. The NCMPB is in the process of working with Regions 1 and 3
to evaluate the AHERA workflow process and discussing how the regions can merge their
existing systems with features from the PCB template. Region 1 states have already requested
funding to purchase Tablets under the TSCA STAG funds, and the NCMPB has provided this
funding to Region 1 to transfer to their states.
The final recommendation in this section is to provide funding to develop inspection
software that is able to communicate directly with OECA's databases to:
• Allow inspectors to upload inspection data directly from information entered during
the inspection to ICIS.
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• Download data for targeting, providing assignments, and pre-inspection review, e.g.,
information on permits and compliance history.
In addition to the time and cost of integrating any export capabilities into inspection
templates, there is a need to ensure that ICIS has the ability to import the batched data. This
functionality is currently not a priority for ICIS development. Management would need to make
this an ICIS priority and fund the development in order to fully integrate field data collection
with ICIS. A joint effort between the NCMPB and ETDD would be required to develop the
export and import functionality and ensure compatibility. The NCMPB would ensure that
software exports meet the business rules developed by ETDD, and ETDD would lead the efforts
to develop the ICIS import functionality.
Finally, this section identifies policy issues that were raised during implementation of the
PCB pilot. The issues are primarily related to data security and enforcement sensitivity of
information. Further investigation is needed to determine the extent of policy or guidance that
would need to be developed. These policy issues are relevant to any compliance program that
uses technology in the field.
5.1 EARLY EFFORTS
Starting in 2000, OECA began reviewing the inspection workflow process and identified
the potential for handheld devices to capture field information electronically. The NCMPB
researched the available technology and selected PDAs to determine if they could be used to
benefit inspectors in the field.
PDAS FOR COLLECTING ICDS INFORMATION
The first attempt by the NCMPB to use PDAs was in conjunction with the development
of the ICDS form. The NCMPB provided PDAs to Region 2 to collect ICDS information. The
inspectors completed their inspections with pen and paper, and then used the PDA to input ICDS
information into an electronic form. Since the ICDS form was only a small part of the
information collected, it was faster to continue with the paper form than to switch to the PDA.
The pilot demonstrated that even if a given task is improved, the use of field activity collection
technologies must take into account the entire workflow process.
PDAS FOR RCRA INSPECTORS
Later, Region 9 conducted a limited piloted using PDAs provided by OECA for RCRA
inspections. No RCRA specific software templates were developed. The inspectors used the
limited MS Word and Excel software that came with the PDA. The inspectors created their own
checklists on MS Word and proceeded to collect field information. However, this was a two
person effort. One inspector used the PDA while the other used pen and paper. This pilot
demonstrated the need for software specific to the program.
OTHER USES OF TECHNOLOGY IN THE FIELD
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Additional individual efforts have been made by inspectors to use PDAs in the field.
OECA shared their information and knowledge as requested. Several inspectors developed
checklists which they used to conduct inspections. Most inspectors found PDA screens to be too
small and that while drop down menus and checklists worked okay, they found it difficult to take
extensive notes or to draw diagrams.
Technology was not limited to the use of PDAs. OC also funded voice recognition
equipment for a pilot with one inspector in Region 4; at that time, this technology did not seem
to work well. Additionally, a few inspectors adopted the use of video taping equipment for
inspections. In some cases, they used their digital cameras to take short video clips during
inspections. They found that short video clips of no more than several minutes could be useful
during enforcement cases.
LESSONS LEARNED FROM EARLY EFFORTS
Lessons learned from these early efforts included valuable information on obstacles to
adopting new technology. These efforts also demonstrated the importance of software that
facilitates data collection and report writing. A great deal of useful information on technical
considerations such as battery life, time and training needed to learn to use the hardware, and
whether facilities objected to its use was collected and shared during National Inspector
Workshops and is listed in the lessons learned sub-section below. Note: Facilities have not
objected to the use of PDAs or Tablets during inspections.
Lessons learned:
• Using portable personal computers is not worthwhile unless it is used for most or all
of the inspection and inspectors are more likely to use the portable computer if it can
be used for most of their work. If the application is limited and results in them having
to switch between pen and paper and the computer, inspectors are unlikely to take it
into the field and it is less efficient.
• Providing the equipment without software provides limited success. While some
inspectors have found ways to improve the inspection process using various
technology, it is far more efficient to design software that meets the needs of many
and reflects upfront input from the persons using it.
• Screen size of the PDAs is too small and does not lend itself to inspections that
require more than checklists or yes/no answers to questions. It's too difficult to type
text other than abbreviated text. It is too difficult to use a PDA to draw complicated
diagrams, often a necessary part of documentation. Please note that the upcoming
workforce that grew up text messaging on cell phones may not have the same
concerns as inspectors that learned typing skills on a full keyboard.
• The technology keeps changing and improving. What did not work well a few years
ago may work later as the technology advances. It is important to revisit the
technology periodically to determine what advances have been made.
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• Industry accepted the use of the portable computer during the inspection. Some
technologies can interfere with the inspection process especially during interviews,
e.g., filming a person being interviewed is likely to hinder the interview as the person
is usually more careful of what he/she is saying and may be more nen'ous.
• Training/guidance will be needed to share information on battery life and operating
conditions that may affect battery life or operation of the Tablet, e.g., extreme
temperatures.
• Early efforts indicate that inspectors need some time to learn how to use the
equipment. It will be important to provide ample opportunity for inspectors to get
comfortable with using the equipment itself as well as the software. It will be more
productive to train on template use after the inspector has learned the basics of the
device. The inspector's comfort level with using the device is an important factor.
At the same time, new hires that grew up routinely using computers and who have
relied on computers much of their lives expect to use this type of technology in their
jobs.
5.2 TSCA PCB INSPECTION PILOT USING TABLETS
INITIAL EFFORTS
In 2004, the NCMPB began investigating the use of Tablets as an alternative to the
smaller PDAs. The Branch decided to attempt to load TSCA inspection forms such as the Notice
of Inspection and the Receipt for Samples on the Tablet using software that would allow forms to
be populated using the Tablet and printed from the Tablet on-site. To explore what might work
best for doing this, two different types of Tablets were purchased for use to develop the TSCA
PCB Pilot.
BASIS FOR SELECTING THE PCB INSPECTION PROGRAM
The PCB program was selected because the NCMPB is the media lead for this program
and has technical expertise on the rule requirements and how inspections are conducted. The
Branch had recently completed updating the PCB Inspector Manual, which provided a good
starting point for identifying the workflow process. Senior and junior inspectors and supervisors
participated in the development of the PCB Inspector Manual. This helped ensure there was
basic agreement on the inspection process itself. An agreement on the detailed specifics of the
work flow process is critical to being able to develop program specific templates.
In addition, PCBs were selected because the NCMPB manages the TSCA State and
Tribal Assistance Grants (STAG) for compliance monitoring programs. The STAG grants
provided a mechanism for funding the purchase of the Tablets for potential state partners for the
pilot. Under TSCA PCB compliance monitoring grants, states conduct inspections on EPA's
behalf using EPA procedures. Thus, templates developed for EPA's TSCA PCB inspection
program could also work for the state. Under TSCA PCB grants, states are required to submit
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the inspection reports to the region because the state conducts the inspection under EPA's
authority using EPA credentials. This provided an added opportunity to evaluate the reports
generated using the new technology.
IDENTIFYING PARTNERS FOR A PILOT
In order to identify specific partners to pilot the template, in December 2004, the
NCMPB demonstrated the forms at the National EPA Inspectors Workshop. This generated
quite a bit of interest and came at a time when the NCMPB was in the process of attempting to
expand the capability of the software to gather field data and populate forms and the inspection
report. Region 5 and the State of Indiana were interested as they were exploring the use of
Tablets for their PCB inspection program.
Lessons learned:
• Expanding to the states is easier if the states use the same forms and procedures
as EPA does, which is the case for the TSCA PCB template. As the program is
expanded to asbestos inspections (see EXPANSION TO TSCA AHERA below), the
Agency will have an opportunity to see how well this works when expanding to
states that inspect under their own laws and regulations. TSCA AHERA offers the
opportunity to see both as half of the states have waivers and operate under their
own regulations and the other half do not and must use EPA forms and
procedures.
• Generating strong interest in using this technology is important especially in its
initial use. Presentations and demonstrated success will help ensure interest.
WORKING WITH PARTNERS TO REVIEW THE WORKFLOW PROCESS AND
SECURE EQUIPMENT
In 2004, Region 5 and Indiana agreed to work with the NCMPB to evaluate the use of
Tablet computers with commercial off-the-shelf software to collect PCB inspection data under
field conditions and create inspection reports. In early 2005, the NCMPB staff and the
contractor developing the software template met with Region 5 for a day to discuss the project
and to capture the PCB inspection workflow process in detail, using the recently updated TSCA
inspection manual as a starting point. While the contractor began work on the software, the
NCMPB collaborated with Region 5 to provide them with hardware and software packages for
regional use, as well as STAG funds under the TSCA Compliance Monitoring Program Grants to
purchase hardware for states. Region 5 negotiated and awarded the grant to Indiana for this
activity. Managing funding for the hardware was a critical component of working with the
partners in the pilot project to ensure that both the hardware and software packages were ready
for the pilot. In August 2005, the NCMPB and the contractor met with Region 5 and Indiana
inspectors and their supervisor to provide training on the newly acquired hardware (the Tablet)
and to review the beta version of the software.
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Indiana chose to replace their six inspectors' desktop PCs with Tablets, consistent with
their policy of one computer for one employee. This compelled the inspectors to learn quickly
how to use the Tablet computer.
Lessons learned:
• The level of effort to reach agreement on an acceptable workflow process for a
specific type of inspection can have a major impact on the time and resources it
will take to develop software templates. Proceeding in programs that have
recently updated old inspection manuals may be the better approach.
Alternatively, developing the workflow process for an inspection to develop a
template also provides the basic information needed to update out-of-date
manuals. What is not desirable is to use outdated manuals to map the workflow
process for software development.
• Development of agreed upon workflow processes provides an excellent knowledge
management tool as this activity can capture the expertise of well experienced
inspectors in the Agency. It can also be used as a starting point for developing
updated inspector training.
• New technology is more likely to be embraced and adopted if someone is
supplying the equipment rather than requiring offices to find the money in existing
budgets. Thus, the availability of state grant funds for this activity made it more
attractive to the states. Money to fund the purchase of new equipment under the
TSCA grant was provided in addition to the previous amounts funded for each
grant. Under TSCA, states still had to contribute 25% of the total amount of their
grant.
• Inspector support is needed to ensure that an effective workflow process that has
agreement across the program is developed. The effectiveness of the inspection
will depend a great deal on the quality of the workflow process identified in the
development stage.
• Prior to selecting the type of computer that is to be purchased, consultation with
the program's IT support office and familiarity with purchasing policy
restrictions is advised. Any expansion to other programs or within the PCB
program needs to be cognizant that decisions on equipment and software may be
impacted by IT policy or purchasing policies. Be aware that flexibility on
equipment decisions may be needed. It is not a good idea to decide on a
particular type of computer/software and simply provide it to another office, state
or EPA, and assume that their IT office will support it or that there are no other
restrictions. For example, in Indiana's case, there was a policy of one computer
for one inspector. Providing a Tablet under the TSCA state grant did not change
this requirement. When the NCMPB were considering PDAs for field work, an IT
issue arose as to PDAs with Microsoft Windows versus Palm Pilots. Regional or
state IT policies impact equipment choices.
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TSCA PCB TEMPLATE - DEVELOPMENT OF SOFTWARE AND FEATURES
The inspection template was developed specific to the workflow process identified for
PCB inspections for use on the Tablets in the field. The template includes the capacity to load
documents needed for an inspection, prepare and issue required forms, document findings during
the inspection, eliminate duplicative information entry, and prepare inspection reports using
templates that self-populate with information collected during the inspection
Inspectors participating in the pilot have Tablets that are pre-loaded with TSCA
inspection forms, the PCB Inspection Manual, the PCB regulations, and a Microsoft Access
template to collect field information. MS Access was selected as the software that could meet
the workflow requirements. The MS Access templates are programmed to take information
entered and populate any template within the software file. As a result, the inspector need only
record information once. The software uses that information to populate forms, the inspection
field notes, and the inspection report.
Information that is entered prior to the inspection and during the inspection can be
manipulated by the software so that it populates screens as the inspector conducts the inspection.
For example, information gathered during the opening conference and by reviewing records at
the facility can be used during the walkthrough without the inspector having to re-enter the
information. He can flag what equipment he wants to inspect during his records review. The
computer will show the pertinent information recorded during the records review when the
inspector physically inspects the equipment. Because of the Tablet's software capabilities, the
inspector can input data by handwriting/printing; the software will convert it to text. Creating
drawings/diagrams is also easy using the Tablet, and these images can easily be incorporated into
the template and report. When photographs are added to the hard drive, the software gathers all
the information and produces a nearly complete inspection report with photographs, sample
results, and detailed information on the equipment inspected.
TSCA PCB TEMPLATE - TRAINING AND FIELD TESTING
Field Test by the NCMPB - One member of the NCMPB accompanied a Region 3 inspector on
two PCB inspections and took notes during the inspections. Each inspection took three to four
hours during which time NCMPB staff used the Microsoft Access based PCB template. Battery
life was sufficient to power the unit through the inspection process from pre-inspection to closing
conference. Battery life was low by the end and may not have lasted beyond 4-5 hours.
Lessons learned:
• Inspectors should have an additional battery pack available. To improve battery
life, they should use the extended battery pack, reduce the tablet screen brightness
settings when powered by the battery, use a car charger, or plug in the unit
during indoor conferences. These issues should be addressed in a
guidance/training document.
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• The Tablet was light and easy to carry during the inspection. The polarized
screen was easy to read, even outside in direct sunlight. A smaller unit might be
more convenient. The inspector carried other equipment such as a flashlight and
a digital camera.
• The inspector should consider using a sling case such as the Motion '.s bump case
or Intelligent Technologies Tablet PC case. By using this type of carrier, the
inspector will not need to set down equipment or ask someone to hold it when he
is taking photographs. A carrier such as these would allow the inspector to use
both hands when climbing a ladder.
• Inspections involve different conditions, including harsh weather conditions. If
the inspection involves harsh weather conditions, added protection is available in
the form of a case such as the OtterBox 4600 Tablet PC Case for the Fujitsu
Stylistic Tablet PC.
Pilot with Indiana - The NCMPB provided one Tablet, with accessories (see discussion under
costs), to Region 5. They also provided TSCA grant funding to the Region to fund Indiana's
purchase of Tablets, Tablet accessories, and travel costs for training. Indiana obtained Tablets in
time for most inspectors to become familiar with the Tablet's features. One Indiana inspector
received his Tablet just two days before the training occurred.
After the initial training, Indiana inspectors began comparing the old workflow process to
the new workflow process. During the inspections, one inspector used the traditional pen and
paper to take field notes while the other used the Tablet. Within three months, the State relied on
the Tablet rather than having a backup by using pen and paper. The NCMPB invited two
representatives from Indiana to give a presentation on the Pilot at the December 2005 National
EPA Inspectors Workshop. During this time, they also met with the NCMPB staff to discuss
their experience and to identify areas for improvement.
Lesson learned:
• Even though the EPA and the state were in agreement on the project, it took
awhile for the state to receive the funds due to some delays in their PPG grant
due to issues unrelated to the TSCA grant.
• Training will be needed and is desired by those considering this technology.
Training will help improve the comfort level and avoid costly mistakes in using
this technology, e.g., losing data or having the battery die during the inspection.
• It is easier to train the inspector on the software if he is already familiar with the
equipment and how to operate it. Learning to use the software is easier if the
inspector has completed the manufacturer's tutorial on pen use and functions and
has accustomed himself to pen entry. Time to learn to use the basic Tablet prior
to training on the software will help make the transition easier. Also, during the
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initial few months of the pilot, Indiana had two inspectors participating in
inspections being conducted with the Tablet.
• When initially testing the Tablet PC in the field, it is important to have multiple
inspectors. This allows the inspection notes to be captured in writing on paper
and via the Tablet. It also helps to identify the efficiencies or areas where
changes might need to be made within the Tablet and software.
TSCA PCB TEMPLATE - PERIODIC RE-EVALUATIONS AND REVISIONS
IDENTIFIED DURING PILOT
The field testing allowed the inspectors and the NCMPB to assess the usefulness of the
Tablet and software and to identify software changes that were needed. Certain features of the
PCB template, such as the ability to collect all necessary information to generate an inspection
report did not require revision. Revisions were identified based on input from regional, state,
and the NCMPB staff identified a need for better print and edit capabilities for the forms.
Originally, the forms printed out as MS Access reports, but this does not allow modification to
forms. Listed below are the specific revisions made to the software template based on initial
field tests:
• Converted the inspection report and assorted detailed reports from MS Access to
MS Word so the inspector can edit the field notes and the print output is more
accurate. Continued use of Microsoft Access to collect information, but added
capability to convert data to a format that can be read by word processing
software.
• Added Small Business Regulatory Enforcement Fairness Act (SBREFA) fact
sheet that can be printed in the field.
• Added capacity to populate a form that can be provided to data entry personnel to
enter into ICIS. At this time, a form that collects ICIS required information
including the ICDS form has been added to the basic template. The goal is to
have the form self populated by the software using data already entered by the
inspector as he conducts the inspection.
Lesson learned:
• Re-evaluations and on-going revisions are critical to successful software
development because even the best workflow process design is not a substitute for
actual field testing.
• Technology continues to improve; moving somewhat slowly in this project has not
been a disadvantage in that technology has improved.
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5.3 COSTS TO DATE
I TABLE 3: SUMMARY OF OECA'S COSTS TO DATE FOR THE TSCA
| PCB TEMPLATE PROGRAM PILOT
| TASK
HARDWARE/SOFTWARE
COST
TSCA Forms
Development and
Defining the Workflow
Process w/ Region 5
Electronic TSCA Forms
$9,000
1 Software Development
PCB Template
$34,000
Revisions to Template
(4th Quarter 2007)
Revised PCB Template
$13,000
Hardware Costs
(Regions/HQ)
Tablets with accessories (2
Regions, 1 HQ)
$15,000
EPA's State Grant Costs
Tablets with accessories (6
units)
$28,000
COSTS OF SOFTWARE
For software development, OC spent $56,000 for contractor support through FY 2007.
The total OECA outlay included $9,000 for the initial TSCA forms and workflow process
development, $34,000 for template development in Microsoft Access, and $13,000 for the
updates identified during the pilot—which will be completed in FY 2007. Note - the $34,000
was spent over 3 years, and the maximum in any one year was $25,000.
COSTS OF HARDWARE AND ACCESSORIES
The NCMPB purchased three Tablets - one for HQ staff use and two for the Region 5
inspectors. EPA provided $28,000 in STAG funds towards the purchase of six complete sets of
equipment plus travel costs for training for their inspectors under the TSCA Compliance
Monitoring Cooperative Assistance funds. Note: TSCA requires states to contribute 25% of the
total grant amount. The hardware packages included the Tablet, mobile combo printer/scanner,
mobile CD-RW player, pre-loaded software (MS Office Professional Suite and Adobe Acrobat),
an extra battery for the Tablet, carrying case for hardware, and a protective case for the Tablet.
Tablet PC cost depends on the type of Tablet selected. When the NCMPB first began
exploring this technology, there were only a few Tablet manufacturers. Since the introduction of
Tablets in 2003, the technology has improved and more companies are manufacturing Tablets.
Factors to consider in Tablet PC selection are: power, speed, weight, ruggedness, screen features
such as polarization, and personal preferences. Indiana chose Motion Computing Tablets for
their original use, while Region 5 selected Toshiba Tablets.
As explained previously, Indiana has a policy of one computer for one inspector. Thus,
Indiana inspectors had to give up their desktop personal computers when they received the
Tablet. This provided an extra incentive for them to get familiar with the use of these computers
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quickly. The downside of this approach is that not all inspectors may be receptive to this
approach. This approach provides and option for cost management. EPA and states already
provide personal computers for their employees. If the Tablet is purchased to replace the
desktop computer, this could reduce the extra costs for purchasing Tablets for use in the field.
Note: This approach requires a docking station.
5.4 EXPANSION OF THE TSCA PCB PROGRAM PILOT
The next step for implementing and continuing to evaluate this program is to expand it to
EPA regions and states with the TSCA PCB Compliance Monitoring Grants. The NCMPB has
already made extensive efforts to ensure that managers and inspectors in regions and states know
about the availability of the PCB template and STAG funding for states. Additionally, the
NCMPB has developed a training program for inspectors, and recommends OECA funds Tablets
for regional inspectors to expedite the expansion process.
SCOPE OF THE PCB PROGRAM
The PCB program is primarily a federally implemented program, with nine states that
have cooperative compliance monitoring grants. There are no PCB state programs other than in
those states with EPA grants, and TSCA preempts states unless their regulations are identical to
EPA's. All state inspection reports are submitted to the region, and the region is responsible for
taking enforcement action, if appropriate. There are 26 EPA inspectors assigned to PCB
inspections in the regions, and EPA inspectors generally inspect in states without grants, but also
conduct oversight/training inspections with grant states. Most regions have only one or two
inspectors who are dedicated to the PCB program. However, Regions 2 and 10 have 15
inspectors between them, most of whom conduct other types of inspections in addition to PCB
inspections. Regions 2 and 10 do not have PCB state grants. In Fiscal Year 2006, EPA
inspectors conducted 171 inspections (including those conducted by Senior Environmental
Employees), and states conducted 336 PCB inspections.
EXPANSION TO REGIONS
Staff from the NCMPB have discussed the use of the Tablet with templates during PCB
monthly conference calls and at the June 2007 National PCB meeting in Washington, D.C.
During the meetings, cost estimates were provided for the hardware packages including the
accessories such as carrying straps, and photocopier/scanner. Most regional staff and inspectors
were interested in learning more and after seeing a demonstration of the Tablet and software and
what it can do. However, staff in one region indicated that they are strongly opposed to adopting
this technology for PCB inspections—but other staff in that Region are interested in its use for
AHERA inspections. Reception to changing from pen and paper to personal computers,
therefore, varies with individual preferences and experience with technology. Despite the
interest from most regions, staff also indicated they did not believe their offices had the resources
to purchase the hardware. In order to assist regions in the adoption of the PCB template, this
Strategy recommends funding the cost of Tablets for one to two inspectors per region (estimated
funding needs are detailed below).
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EXPANSION TO STATES WITH PCB GRANTS
The NCMPB is pursuing expanding the pilot to other states implementing PCB programs
through the use of STAG funding for their TSCA compliance monitoring programs. Funds will
assist in costs for hardware, accessories, and travel for training. EPA's National Program
Guidance, the TSCA State grant guidance, and the Catalogue of Domestic Federal Assistance all
included language encouraging states with PCB programs to adopt the Tablet and software for
conducting inspections. At this time, OECA has sufficient STAG funding to provide this
additional funding to existing grants. These funds can only be provided if the state can fund 25%
of the total grant.
In addition to Indiana, three of the other eight states with PCB grants have already
indicated that they are interested in adopting this technology. One state (Alabama) would like to
purchase Tablets but cannot provide the 25% of the total grant as required by the TSCA statute
for state grants for this year; they plan to participate in FY 2008. Region 5 has requested $5,000
in additional state grant funds for Indiana to upgrade equipment used in the PCB Pilot program.
They will purchase scanners better suited to field use as well as wireless internet cards to e-mail
documents from the field including the inspection data and inspection reports. Illinois will
receive $12,000 in TSCA grant funds to purchase Tablets and for travel to attend training on the
use of Tablets and the PCB inspection templates. The NCMPB has reprogrammed the funds to
Region 5. Missouri has already received its grant funding and two inspectors traveled to
Washington, D.C. in September 2007 for a two day training program, hosted by the NCMPB.
Region 8 and North Dakota indicate that they are interested in learning more about the Tablet
and templates developed before making a commitment. The NCMPB is setting up a meeting to
review the templates. Timing of when the states purchase and begin to use the software will
depend on when their grants are amended to include the funding and to some extent on how
quickly they can identify the appropriate hardware based on IT/state policy considerations.
TRAINING/GUIDANCE FOR STATES AND REGIONS
The NCMPB staff will provide the necessary training for both regional and state
inspectors on the use of the Tablet PCs and the PCB template. Staff is available to provide
training either in Washington, D.C. or the region/state, depending on availability of travel funds.
Webex, an on-line conferencing system, may also be used for training. This option would have
minimal cost due to the lack of need for travel funds, but it would not provide the hands-on
experience of on-site training.
Training material has been developed by the NCMPB for use by regional and state
inspectors. It will address technical information such as battery life, suggestions for phasing in
the use of the Tablet during inspections (e.g. the inspector should initially use the Tablet in the
office and for the first few inspections have another inspector collect the information by pen and
paper as the original inspector uses Tablet), and points on the use of the Tablet including
troubleshooting.
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ESTIMATED FUNDING NEEDS FOR PCB TEMPLATE EXPANSION
Since the PCB Template is complete, and training materials are being developed in-
house, hardware and travel costs are the only immediate funding needs. Regions have already
indicated concern with their ability to fund hardware and travel costs for small programs. The
NCMPB proposed and OECA management has decided to provide centralized funding and
sourcing for the hardware, similar to the distribution of digital cameras described in Part 2.1.
After consulting with regional inspectors and IT staff, the NCMPB will identify two or more
Tablet PCs from which the regions could choose. The benefits of providing standard sets of
hardware and accessories to all regions include that it would ensure that the systems are fully
compatible with the PCB Template and that it would facilitate the NCMPB's ability to provide
technical support. Additionally, the unit price of the Tablets may be lower if they are purchased
with a single acquisition. The NCMPB has also developed a schedule for rapid deployment of
the PCB Template if all the hardware is acquired at the same time. Since funding for states is
available through STAG funds, states will continue to be encouraged to purchase the appropriate
hardware; ideally training could be provided for both states and regions at the same time. At this
time, there are no immediate changes to be made to the PCB Template. However, as more
inspectors provide their input and make suggestions to automate other functions, there may be a
need to enhance the template in the future. Table 4 below depicts the estimated costs of
expanding the TSCA PCB Program Pilot to other regions/states.
TABLE 4: TASKS, COSTS, AND SCHEDULE TO EXPAND PCB PILOT
TASKS
COSTS
SCHEDULE
Identify inspectors who will
receive Tablets.
$0
NCMPB staff time
3 weeks
Identify regional IT
requirements in terms of
equipment manufacturers and
types of units.
$0
EPA inspectors will consult
with IT staff.
8 weeks
The NCMPB will order and
arrange for delivery of one to
two Tablets to each region.
$67,000
15 Tablets and accessories
purchased by OECA at a cost
of $4,500 each.
18 weeks
(may be less; will
depend on the
procurement
procedure; need to
submit paperwork,
await delivery)
Train Inspectors
$18,000
Travel costs for regional
inspectors to be provided by
each region. Ideal to combine
training state and EPA
personnel.
$0 for WebEx training. Plan
to offer both WebEx and in
person training as necessary.
6 weeks min.
(2 days training,
remainder time
scheduling, travel
arrangements)
Will plan to work
with regions in event
there are upcoming
meetings with their
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states to minimize
travel costs.
Update & Maintenance
No immediate needs with
current template. See
discussion on ICIS (5.6) for
immediate funding needs.
Approx. $15,000 to $30,000
may be needed based on
feedback from regions.
Future
enhancements could
take up to 8 weeks,
but the existing
template could be
used at the same
time.
Total
$85,000
$67,000 from OECA, and
$ 18,000 from regions.
Est. 35 weeks
(Equipment delivery
is main issue)
5.5 EXPANSION OF TEMPLATES TO TSCA AHERA
The NCMPB has begun initial work to expand the TSCA software package to TSCA
Asbestos Hazard Emergency Response Act (AHERA) asbestos in school inspections. Region 1
TSCA staff has indicated an interest in receiving guidance and support from Headquarters on this
project. Region 1 has already developed checklist-based software for laptop computers that state
inspectors use for asbestos inspections. However, the software has some limitations, and it is
primarily completed in the office based on pen and paper notes collected in the field. Region 3
has also begun developing Tablet PC software for asbestos NESHAP and AHERA inspections.
NCMPB will coordinate these regional efforts to develop AHERA inspection software. After the
completion of a pilot will facilitate adoption of the software by regions and states by providing
copies of the software, a training manual (based on the PCB inspection manual), and STAG
funds ubder the TSCA compliance monitoring grants. NCMPB will coordinate this review
process.
Similar to PCBs, the TSCA asbestos program, especially AHERA, is a small program
that has very defined requirements and lends itself to the development of uniform inspection
procedures. The Branch has the OC lead for this program and also funds state grants under this
program. For states without waiver status, TSCA asbestos inspections require the same
inspection forms as TSCA PCB inspections. Expanding to AHERA offers the unique
opportunity of working with states that must use EPA forms and procedures, i.e., the non-waiver
states, as well as states that adopted regulations that mirror the federal requirements and conduct
inspections under their own authority. Branch staff has taken additional technology and AHERA
training both to improve their expertise on asbestos issues under AHERA in general for other job
responsibilities as well as to build their expertise in order to develop the workflow process. Staff
has also participated in AHERA inspections with both regional and state inspectors. Unlike the
PCB program, inspection manuals have not been updated recently. At the same time, the
regulations have not changed either. The development of the AHERA inspection software would
mirror the approach used with the PCB pilot project. The final product would include the
inspection software with printable forms and reports. It would not include the ability to transfer
data into ICIS.
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ESTIMATED FUNDING NEEDS FOR EXPANSION OF SOFTWARE TO TSCA
AHERA
The NCMPB began the workflow definition process by meeting with Region 1 inspection
staff at the end of September 2007, and will assist them by reviewing their final workflow
process. After the initial workflow process is completed, it will be reviewed by other regional
and state inspectors. Several AHERA inspection protocols have already been developed by other
regions, and having them review the workflow process will ensure that expansion of the AHERA
inspection software will be an easy transition.
Since the NCMPB has already developed the template for PCBs, and Region 1 has
AHERA inspection software, these resources could be leveraged to develop the necessary
inspection software for the field. The NCMPB will work with Region 1 to provide its pilot state
appropriate STAG funds for contractor support in software development. Discussions with
Region 3 about their efforts will continue and their ideas will be incorporated as appropriate.
If Region 1 completes the software with a non-waiver state, as is planned, the inspection
software has the potential to be used by EPA inspectors as well. If the pilot is successful,
regional EPA inspectors should be encouraged to use the system. Regions will need to provide
the necessary hardware to its inspectors. Estimated hardware costs are similar to the PCB
program, with one or two inspectors per region at a cost of $4,500 per inspector. With regard to
funding states, the NCMPB has communicated to the regions that funds are available under the
TSCA STAG funds to provide Tablets to states with cooperative compliance monitoring grants
for the TSCA asbestos program. Region 1 has already requested funding for Tablets for some of
its states. Again, like PCBs, this grant program requires states to contribute 25% of the total
grant. NCMPB and Region 1 will need to discuss training and expansion of the new software
once it is completed.
TABLE 5: TASKS, COSTS & SCHEDULE TO DEVELOP AHERA
INSPECTION SOFTWARE
TASKS
COSTS
SCHEDULE
Assist Region 1 in
defining workflow
process.
$0
Staff time to provide
input in defining the
workflow process.
4 weeks
Review workflow
process with regional
and state inspectors.
$0
Staff time to review
workflow process and
provide feedback.
6 weeks
Develop appropriate
software based on
workflow process.
[Estimate $25,000-
40,000]
NCMPB anticipates
providing STAG funds
upon request to Region
1 to fund a state for this
project.
26 weeks I
To set up contract and
complete development.
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Purchase hardware for
pilot
$9,000
NCMPB anticipates
providing STAG funds
upon request to Region
1 for its pilot state to
purchase Tablet PCs.
2 weeks
Pilot software and
make revisions.
[Estimate $5,000]
NCMPB anticipates
providing STAG funds
for software revisions,
if needed.
16 weeks
Hardware purchase for
expansion.
$51,000
OECA or regional
funds depending on
funding options.
TSCA STAG money
depends on state
interest and
commitment. Plan to
use existing funding.
18 weeks total
(May be less if similar
requirements to PCB
software. Submit
paperwork, await delivery)
Training on Tablet and
Templates
$11,000 Travel
11 regional inspectors
Interested states would
fund from STAG
grants.
$0
WebEx through NETI
access
6 weeks (one for
preparation and one for DC
meeting)
Total
$61,000
For hardware and
training for EPA
inspectors, provided by
regions or OECA.
[Estimated $54,000]
STAG funds for state
pilot. Additional
STAG funds may be
provided to regions
(contingent on
availability) if more
states are interested in
using the software.
74 weeks
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5.6 SOFTWARE DEVELOPMENT TO PROVIDE DIRECT INTERFACE WITH
ICIS
One of the primary benefits of collecting information electronically in the field is to
reduce data entry errors and to ensure timely, accurate data entry into Agency databases.
Although inspection software, such as the PCB Template, can already aid in inspection report
completion and electronic recordkeeping, in order to fully integrate the data into agency
databases, the functionality to import the data must be developed for those databases.
Electronically completing a form that is given to a data entry clerk is only an interim solution. In
order for the data integration to be seamless, both the inspection software and the agency
databases must have similar data structure, as well as the ability to export and import that data.
EPA's primary enforcement and compliance database, ICIS, does not currently have the
ability to import compliance monitoring data using a batched method. Even if inspection
software had the data available and the ability to export the data, it will still have to be entered
into ICIS separately. This Strategy proposes that OECA management make it a priority to fund
the development of batched compliance monitoring data import for ICIS. The first step for this
integration would require that the data structure standards are available for developers who are
creating inspection software. This would ensure that all of the necessary data is collected in the
inspection software, and that the software exports that data using the correct structure.
The PCB inspection software could be used to test the compliance monitoring import
functions. If the appropriate ICIS batch process is developed, this could be used for all
inspection software whose regulatory programs use ICIS as the database of record. A joint effort
between the NCMPB and ETDD could begin the process to develop the business rules needed to
import compliance monitoring data. The NCMPB would then build the appropriate export
functionality into ICIS while ETDD leads the efforts to develop the ICIS import functions. The
immediate benefit of funding this project would be to reduce the resources needed for data entry
of inspection data.
5.7 POLICY ISSUES
Implementation of new technology in the field raises policy issues as well as process
issues. Potential questions/issues identified during the PCB Pilot include the following:
• Indiana plans to use wireless cards to transmit inspection reports. There are
possible security risks, and guidance to address the potential risks will need to be
developed as we expand the project.
• Expanding the use of Tablets to regional inspections raises issues regarding the
handling of CBI. There is current guidance on the use of computers for CBI but
additional guidance may be needed to address CBI collected electronically as
field notes on a personal computer and whether such information can be
transmitted over wireless cards. The NCMPB will work with the Office of
Prevention, Pesticides, and Toxic Substances (OPPTS) and the Office of General
Counsel (OGC) staff on this issue. States do not have access to TSCA CBI.
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• Policy concerning security issues and technology issues can rapidly change.
While the NCMPB has checked in periodically with OEI, it is important to stay
abreast of IT policies, especially concerning security of data. In rolling out the
pilot to other regions and states, they will need to check their own office's IT
policies and security policies to ensure that use of this technology is in
compliance with other requirements.
• The IT policy or practice regarding the use of Tablets as an employee's personal
computer will need to be considered. For Indiana, the inspector was required to
give up his desktop computer in order to have a Tablet. At EPA, some desktops
are being replaced with laptops. Tablets have not replaced desktops in OECA
although this may be occurring in other offices. If IT staff agrees that the Tablet
can replace the desktop and that the Tablet can be connected to the LAN system,
then there may be cost savings in that Tablets replace the personal computers
rather than being additional equipment. Follow-up with the IT personnel is
needed to determine if this is feasible.
• Issues may arise as to what information is provided to the facility during the
inspection. A question has been raised regarding digital photographs and whether
the inspector may provide copies of the digital photographs to the facility during
the inspection at the facility's request. Similarly, if the inspector uses the
computer to scan in documents, facilities may ask for electronic copies of what
the inspector scanned. Policies for this type of issue will be needed.
• Process issues regarding what physically is transferred from the inspector to the
case development officer to the attorney handling the case. One question will be
whether electronic copies are sufficient or whether hard copies of the inspection
report and attachments such as photographs will need to be provided for cases that
go to hearing. Issues may arise as to what is kept as the official record and by
whom. Research into what Courts accept will be needed also if EPA decides on a
paperless approach.
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BETTER USE OF TECHNOLOGY IN COMPLIANCE MONITORING ACTIVITIES
FIELD ACTIVITY COMPLIANCE TECHNOLOGY STRATEGY
(FACT STRATEGY)
PART 6
STRATEGY FOR EXPANDING THE USE OF PORTABLE PERSONAL COMPUTERS
TO OTHER PROGRAMS OR FUNCTIONS
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PART 6
STRATEGY FOR EXPANDING THE USE OF PORTABLE PERSONAL COMPUTERS
TO OTHER PROGRAMS OR FUNCTIONS
6.0 INTRODUCTION
OECA manages enforcement and compliance activities across a broad range of media
programs. Approximately 40 inspection types fall under these inspection programs. Inspection
manuals usually establish the process for conducting these inspections. Inspections by EPA as
well as states and tribes are a primary tool in determining compliance with environmental
statutes. There is a tremendous potential to improve the efficiency of EPA's compliance
monitoring programs through better use of technology, specifically the portable personal
computer. The PCB Pilot established that it is feasible to successfully integrate the use of
portable personal computers and software into the preparation and conduct of inspections and the
preparation of inspection reports. Benefits include expedited report preparation, electronic data
that has the potential to be exported into databases, and standardization of inspection procedures.
While Part 5 focused on on-going efforts and provided a strategy for the short term with a focus
on TSCA PCB and TSCA AHERA inspections, this part provides a discussion of directions
OECA could take to improve its use of available technology, separated into near-term and long-
term options. Cost estimates, especially for the longer term options, are very rough and would
need to be refined for options selected for further development. Initial scoping work would need
to be completed in order to arrive at more accurate estimates. There are many choices that can
be made, and many of those are not mutually exclusive.
6.1 OPTIONS FOR EXPANDING THE USE OF PORTABLE PERSONAL
COMPUTERS IN COMPLIANCE MONITORING ACTIVITIES
Developing software that can be applied across inspection programs to facilitate data
collection and reporting is a huge task given the number of inspection programs and the diversity
of operations between programs, across ten regional offices, and across the states/tribes.
Similarly, ensuring all inspectors have access to the equipment for use during inspection will
also be a challenge. While the PCB template for use on Tablets allows the inspector to collect
field data and print out an inspection report, several TSCA forms, and a data sheet for separate
ICIS entry, and organize data collected during the inspection electronically for use during the
inspection, there are other functions that could be selected for automation.
One example is the automation of data entry into Agency's databases by directly using
information collected during the inspection using the Tablet. Under the current PCB template,
the data from the ICDS form and inspection information collected automatically are input into
ICIS by printing the information collected by the software during the inspection and having
someone separately enter the data into ICIS. As discussed in Part 5.6, one of the objectives of
this national strategy is to identify directions that could make the information/data process
seamless between the computer/mobile unit and ICIS, thereby reducing human error by manual
typing of the information into ICIS.
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Choices for incorporating portable personal computers into OECA's compliance
monitoring programs include bringing in programs one by one, adopting a system-wide
approach, or developing a combination of approaches. Not only are there choices on what
programs are addressed, but there are also choices on what functions are automated - targeting;
scheduling/providing assignments to the inspectors; providing resource materials on the Tablet,
including compliance assistance; providing resources from EPA's databases, such as permit
information or results from the previous inspection, to data entry to case development functions.
This part discusses options on identifying what to automate. To expand initially, this Strategy
recommends that initial efforts focus on the functions piloted during the TSCA PCB pilot along
with adding a data entry function to facilitate data entry into Agency's data bases such as ICIS.
Whether expanding this technology to one program or multiple inspection programs, decisions
will be needed to determine what functionality will be developed for each program. Ultimately,
much of the decision making on the options discussed in this part will be based on funds
available and interest by headquarters and regional programs in this technology.
Based on a review and analysis of the types of inspection programs for which OECA is
responsible, a decision to expand the use of personal portable computers sequentially could be
based on the size of the program (number of inspectors/inspections), such as, the smaller
inspection programs (TSCA, FIFRA, EPCRA) or the larger inspection programs (CWA, CAA,
RCRA). The expansion could focus on the current OECA National Priorities or use a sector-
based approach (petroleum refineries, cement kilns, coal-fired power plants). To expand to the
larger inspection programs, success is more likely if specific types of inspections are identified,
and the FACT Strategy applied to them separately. Expansion could be phased in for the larger
programs.
One approach for addressing multiple programs is to use a systems-based approach. A
national workgroup would provide the necessary data and program standards that would apply to
their specific media program workflow process. This would require each national inspection
program (by statute) to bring together representatives from the regions and headquarters to
establish uniform processes, templates and reports for each individual program. Template or
software development would occur on an ad hoc basis even on a regional program basis. OECA
could provide parameters/criteria for this approach and maintain a list of available software by
media program and region.
Another way to implement a systems wide approach is to identify certain elements that
are common and develop a template that works for the element across all statutes. An example
would be to develop templates for chain of custody information or for entering ICIS data.
Last, an option could be an enterprise wide approach that seeks to develop agreed upon
software across all programs. Given the differences in programs, from a policy standpoint, this
approach would be the most difficult and take the most time. It would replace the traditional
stove pipe type approach to implementing programs with a centralized, uniform approach across
statutes. It involves an up-front commitment to implementing change across all programs as part
of the software development process. This option requires the application of customized
Proprietary Software Solutions (cost estimates range from $10,000's to $l,000,000's) rather than
adapting commercial off the shelf software. Ultimately, it may save money over the
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implementing across programs using a sequential program by program approach. At the same
time, it may not allow the flexibility needed for some programs such as those inspections where
there are less prescribed methods for conducting the inspection.
To begin this effort, this document recommends that initial efforts be sequential. Before
considering a more enterprise wide or systems wide approach, an Agency workgroup should
convene to discuss approaches across programs. It may be better to gain more experience in the
application of this technology to individual programs before making decisions on changes across
all programs. Lessons learned from pilots/implementation should help inform the decision
making. Other decisions that impact how far this technology is expanded across EPA's
inspection programs and how quickly include decisions on who takes the lead and the extent to
which others commit to work on this, how the work is staffed, and the amount and source of
money. Many of the different types of decisions interrelate and must be made in the context of
all the choices. Table 6, below, lists categories of decisions, discussions follow on each of these.
Table 7 provides a summary of options for accelerating the delivery of templates and describes
for each option the office who would be responsible for requirements development and systems
development.
TABLE 6: DECISIONS TO BE MADE FOR EXPANSION RELATED TO
DEVELOPMENT OF SOFTWARE
Identification of Hardware. Selection will impact software decisions. Choices include Tablets,
PDAs, Ultra Mobile PCs, or other new technology as it is developed...
Identification of Functions to Be Automated
Method of Expansion to Other Programs - sequentially, simultaneous effort, combination
Approach to Software Development - specific to individual programs or systems based approach
for some functions or enterprise wide
Order of Work. Go through entire process for a specific program from mapping the workflow
process to software development to pilot to implementation or separate out tasks such as
workflow process and complete this task first for several or all programs or use a combined
approach. Mapping could also be done sequentially, simultaneous, or a combination of these
approaches.
Who Takes the Lead and Their Role. The role of the lead could include: developing software
and providing equipment; being a co-lead with other parties to providing standards, criteria and
oversight; or providing support on request.
Standards and Criteria. While these can be established, there are policies issued by other offices
that affect these.
Funding Options. These range from central funding to providing no additional funding. Funding
options apply similarly to providing equipment (Tablets or PDAs).
IHF.NTI FTC A TION OF HARDWARE
Part 3 presented information on the different hardware available and provided
information on the advantages of Tablets and PDAs. For inspections that can be conducted
through the use of checklists and drop down menus, the PDA may be preferable. Most
inspections require diagrams and field notes and more detailed inspection reports. The Tablet
provides advantages for this type of work. In addition, technology and types of hardware is
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evolving. Following the FACT Strategy which includes working with partners/end users on their
needs and preferences should be helpful. Funding decisions also impact this choice.
IDENTIFICATION OF FUNCTIONS TO BE AUTOMATED
Functions which can be automated include those identified immediately below as ones
automated under the PCB Pilot as well as others. Most can be automated for use with the Tablet
or PDA but the PDA is more limited as a result of memory and storage limitations.
Functions automated for the PCB pilot:
• Pre-inspection information.
• Forms for the inspection (templates to collect the necessary inspection information, forms
particular to the inspection program, forms required of any EPA inspection).
• Inspection data collection for collecting information during inspection and populating
forms, field notes, and the inspection report.
• SBREFA Fact Sheet - for printing during the inspection.
• Information collection for input into Agency's data bases, e.g., ICIS and ICDS
information collected via the software and printed for data entry at a later time.
• Reference materials identified as useful during the inspection (CFR, inspection manual,
compliance assistance materials, program specific information, and SBREFA materials).
• Outputs necessary after the inspection (inspection report, supporting documents, ICDS
form, inspection information for data entry).
• Data input (data to paper to ICIS - manually or data to ICIS - electronic synchronization).
• Inspector findings/observations.
• Preparation of inspection report using information entered during the inspection.
• Photos (create an electronic log, placement into reports, maintain photos per Digital
Camera Guidance).
Other functions that may be automated:
• Data entry into ICIS - see discussion under Parts 5 and 6 on this topic.
• Scheduling for inspections/assignments.
• Targeting information.
• Permit information, compliance history information, and previous inspection reports.
• GPS data.
• Samples (create an electronic log, placement into reports, chain of custody).
• Inspection information transferred for case preparation, paper or electronically.
• Design standard case development documents and Notices of Noncompliance and
Notices of Proposed Civil Complaints which can be populated automatically with data
entered during the inspections.
• Tracking system for settlement conditions.
• Wireless transmission of data (security protocols will be needed).
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Note: Additional functions listed here could be automated and piloted for the TSCA PCB
program. The Strategy recommends pursuing software development for other programs with
some revisions being made to the PCB pilot as identified by inspectors/managers during the
expansion phase with the exception of taking steps to interface with ICIS. This should be
pursued in addition to other expansion efforts.
METHOD OF EXPANSION TO OTHER PROGRAMS - DEVELOPING TEMPLATES
FOR OTHER PROGRAMS
Simultaneous efforts can be on-going although simultaneous for all programs would be a
costly approach. Part 7 discusses ways to leverage resources to develop software applications
and equipment delivery by distributing work across offices. Workable options depend on
funding and many of the other decisions identified in this section. A combination of continuing
to work on a few programs while convening a workgroup to discuss opportunities for a more
expansive approach offers a good solution. Lessons learned from the initial programs will be
useful whether a program by program approach is maintained or if a system based or an
enterprise wide solution is sought. A strategy for selecting specific inspection programs for
sequential development is provided below, recognizing that several programs could be in
different states of the FACT Strategy at any time, and some could be developed simultaneously
dependent on available resources and expertise.
Options could include a massive effort to develop templates for all programs. Initially,
the overall effort could focus on the workflow process analysis. OECA media leads could be
assigned to work with the regions to develop a workflow process analysis similar to the one
conducted for the PCB Pilot with the idea of capturing this for future template development.
Other options include an enterprise wide approach for certain overlapping activities such as
issuing Notices of Inspections (although not all programs currently provide), developing a
compliance history and inspection report database, or reporting to ICIS. It is more practical to
select programs for individual development unless sufficient funding and resources are made
available to consider an enterprise wide approach.
OPTIONS FOR SELECTING PROGRAMS FOR DEVELOPING TEMPLATES
• Small programs.
• Priority programs.
• Large programs (as a whole or specific types of inspections)
• Sector based approach.
• Systems based approach.
• Enterprise wide.
Developing templates and persuading programs to switch to portable personal computers
in the field rather than pen and paper can occur program by program or even region by region.
In some programs, it may work well to include states/tribes, especially for programs where they
use identical inspection procedures, e.g., when states/tribes inspect using EPA credentials. The
program by program approach may be the most feasible, especially given limited funding.
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APPROACH TO SOFTWARE DEVELOPMENT - SCALE OF AUTOMATION
Options range from developing software specific to each program to a selective enterprise
wide approach for a small subset of similar functions to developing this enterprise wide software
for some functions but allowing each program to have their own specific processes. Some
programs may elect to use the limited enterprise wide functions automated but may or may not
develop software that would assist in the inspection process and automatically generate reports.
This issue relates to what is to be automated for a specific program. None of these decisions
should be made in isolation from a review of all the available options.
• Develop software for individual inspection programs or groups of programs
under the same statute.
• Develop and adopt an enterprise wide approach for some functions which are
essentially the same across programs or would lend themselves to a uniform
approach. For example, consider developing a Notice of Inspection form that can be
used across all inspection programs. Develop template for such forms. Other
examples might be chain of custody forms and photo logs. ICIS data is another
possibility.
• Develop software for certain functions that apply to all programs but allow each
program to have their own individual forms/workflow process. Develop software
that allows the inspector to enter information one time which will then populate the
Notice of Inspection form for that program, or the photo-log for that program. This
allows each program to keep its current forms and procedures in place. This effort
would not include developing software that captures the entire inspection workflow
process. The inspector could still take notes during the inspection electronically. The
inspection report would not be automatically generated in draft.
ORDER OF WORK - APPLY FACT STRATEGY TO EACH PROGRAM OR
COMPLETE TASKS SUCH AS MAPPING THE WORKFLOW PROCESS ACROSS
PROGRAMS
Consider whether to go through the FACT Strategy from beginning to end for each
program or whether it would be beneficial to go through mapping the workflow process prior to
applying the FACT Strategy. This would provide information on the similarity and differences
between inspection processes and help with decision making on whether a systems based or
enterprise base approach would be feasible. It can also help with hardware and software
decisions.
Mapping all the workflow processes would provide information for future software
development efforts. Also, captures information prior to very senior inspectors leaving the
Agency (Succession Planning/Effective Knowledge Management). Decisions made after
mapping and determining which functions are sufficiently similar for enterprise wide software
development. In addition, this work could be used for updating inspection manuals and training
courses.
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WHO TAKES THE LEAD AND THEIR ROLE
The NCMPB is willing to take a lead role for applying the Strategy to expand the use of
personal portable computers, including software development, for use during inspections but
believes there are a number of options for how this could work to expedite expansion across
programs. Factors to consider on who has what role are primarily the expertise and experience
needed to effectively develop software and succeed in changing how inspections are conducted.
These skills include: knowledge management skills including expertise in mapping work flow
processes, expertise in conducting the type of inspection to be mapped (usually senior inspectors
and media lead experts), including familiarity and expertise in the statute and the regulations as
well as with Inspection Manuals/Policies/guidance documents, sampling skills including sample
preparation, and expertise with technology, both the hardware and software development.
Pulling together these skills is important to develop workable solutions. The lead could set
standards and criteria such as those found in the section below.
Software Delivery Process Stages: To better understand the skills needed to lead this effort,
below is a summary of the process stages for software delivery. See also Table 6.
Requirements Development - Defining the standards and expectations for building the
software. This process usually involves a workgroup of stakeholders (managers,
users, and developers or technology staff) to develop three types of requirements.
The three types of requirements are:
• Business Requirements - The broad visionary outline of expectations (i.e.
processes to automate);
• User Requirements - The workflow procedures and necessary documentation;
understanding the legal and technical requirements for conducting an
inspection as well as the actual sequencing of events during an inspection, and
how to write an inspection report is important for this stage.
• System Requirements - The technical abilities and limitations of specific
hardware and software.
System Development - Coding or contracting of coding based on the requirements.
Implementation - Testing, piloting, and expanding use of the templates.
Options for delivery of templates for other programs need to address who does the work
and how the work is done.
Identification of policies needed to address workflow changes. This is necessary to
ensure that the change does not negatively impact the enforcement process.
Who Leads the Effort - Options fnr Implementation
• The NCMPB: It isn't possible for the Branch to provide template development for more than
a few programs at a time unless there were additional FTE and contract money. Even with
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this, additional support would be needed from other offices and the regions. Options for this
support are included below and mentioned also in Part 7.
• The NCMPB as Co-lead with Other Offices: This could be a co-lead on multi-statutory
approach or as co-lead for applying the FACT Strategy to one or more programs.
• The NCMPB could chair a workgroup consisting of inspection program leads who in turn
would chair subworkgroups. NCMPB would provide oversight and guidance/support as the
workgroup members applied the FACT Strategy to identify the appropriate technology and to
develop software for automating inspection processes. Policy and technical support would
be provided. NCMPB would review progress at different intervals.
• Assign Media Leads with NCMPB providing technical guidance and support as requested.
NCMPB would serve as a clearinghouse on information on what is being done.
• Establish interagency workgroup and wait to find out their recommendations.
• Ask OEI to take this on.
• No one assigned. Provide Strategy and programs are on their own to decide if they want to
apply Strategy. NCMPB available to answer questions. FACT Strategy would be distributed
widely.
STANDARDS AND CRITERIA
The degree to which the lead or a workgroup develops standards and criteria can range
from very general to very specific. External factors often affect these. Awareness of these
external factors is important.
Options for standards include:
• Software/Hardware - Agency standards may impact this.
• Software - compatible with ICIS and allows transport.
• Software and hardware - Security features.
• Wireless technology (or not). - Security issues.
• Hardware - minimum memory, storage space on hard drive.
• IT office requirements - OEI - may vary with region/state.
• Windows XP or VISTA or web-based approach.
• Best Practices.
• Require inspection process consistent with inspector manuals/EPA guidance. (May
need to revise guidance).
• Other requirements such as whether Confidential Business Information is involved
and Agency statute specific requirements for handling this information.
• QA requirements for templates.
FUNDING OPTIONS
These are addressed in Part 7. Deciding that funding should be identified is perhaps the
first major decision. Options for funding range from centralized HQs funding, the optimum for
expanding the use of this technology in a uniform and expeditious manner, to using existing
funds.
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Table 7 provides an overview of the options available for accelerating delivery of
templates for other programs along with pro's and con's.
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TABLE 7: OPTIONS FOR ACCELERATING DELIVERY OF TEMPLATES FOR OTHER PROGRAMS
OPTION
REQUIREMENTS
DEVELOPMENT
SYSTEM
DEVELOPMENT
IMPLEMENTATION
PROS
CONS
CAMPD Pilots with
National Roll Out
Business: CAMPD
User: CAMPD with
media lead input
System: CAMPD
CAMPD
2-3 Templates every 2 years
based on current FTE,
following OPTIONS FOR
DEVELOPING
TEMPLATES
CAMPD familiarity with
development process;
Greater centralized control
and standardization of
templates; Lower cost
individual solutions spread
out over implementation
period.
Slow implementation schedule
for incorporation of all
inspections based on current
FTE and contract funding.
Centralized
Requirements for
Media Lead System
Development with
National Roll Out
Business: CAMPD
User: Media Leads
System: Media Leads
based on CAMPD
examples
Media Leads
CAMPD develops high level
requirements and OC assigns
media leads to develop
software for its programs at a
rate of 2-3 templates per
media every 2 years
Implementation occurs as
workflows are developed.
Needs high level buy-in from
media leads; Media leads may
have difficulties developing
sufficiently detailed
requirements.
Centralized
Requirements with
Development on an
Ad Hoc Basis with
Roll Out by Region,
Media, or Program
High Level
Requirements:
CAMPD/ETDD
workgroup define
minimum standards
Detailed
Requirements:
State and Regional
Individual Offices
Joint work group defines
high level minimum
requirements in 1-2 years.
Regions, media leads or
programs develop and
deploy the templates in their
area. CAMPD engages
actively in outreach and
manages lists of all software
developed.
Costs distributed across
agency and states;
Maintains standards while
providing flexibility for
implementation;
Leverages existing
templates; States could be
encouraged to develop
software through STAG
funds.
Templates scattered in time
and space, possibly with
duplicates; Initial buy-in may
be slow, but implementation
would accelerate as more
templates are developed and
used by inspectors.
Enterprise
Development with
Roll Out Nationally
Could consider
enterprise wide only
for functions that
are uniform across
inspection
programs, e.g.,
ICDS.
All Requirements: OC
Workgroup
ETDD
4-6 year process for
requirements and system
development similar to ICIS
or FDA's TurboEIR.
Consistent standards and
software; Depending on
option chosen, may be
able to leverage FDA
program contract.
Pre-developed software (PCB,
UIC, etc.) becomes obsolete:
Single hardware solution;
High initial cost; Potential for
high resistance from some
inspectors/managers/programs.
This would mean
standardizing across programs,
which is often difficult to do
within a program across 10
regions.
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6.2 NEAR-TERM OPPORTUNITIES
The following activities are presented as additional workflow projects that could be
implemented through OC's current process of selecting small inspection programs and
developing an inspection workflow process. This could be undertaken with current resources. In
addition to the expansion of portable personal computers to the TSCA AHERA program,
OECA's National Priorities provide a logical near-term opportunity for further expansion. One
of these opportunities is discussed in detail below.
NATIONAL PRIORITY
A workflow process can be developed for one of OECA's National Priorities, for
example, the Wet Weather priorities focused on Storm Water. The Office of Compliance is
aware of several storm water inspection templates having, been developed. One is currently
being used by an EPA region and a second by a contractor on behalf of a state. During the
workflow development process, the workgroup would review these storm water templates. One
or a combination of the templates could be adapted to create a national storm water inspection
template. The cost to implement would be one inspector per region equipped with a Tablet and
accessories at $4500 = $45,000. Travel for one storm water inspector from each region for one-3
day meeting at $ 1000 each = $10,000. The first meeting would be to review the various
templates currently developed and to develop a national storm water template to be used by all
the regions. Contractor support for the meeting and identification of workflow process =
$10,000. Template development should be $50,000 as most of the development has already
occurred. Total cost to implement is $115,000. Software training could be absorbed through
NETI's access to the WebEx software.
TABLE 8: TASKS, COSTS & SCHEDl
STORMWATER WORKFLOV
JLE TO DEVELOP
V PROCESS
TASKS
COSTS
SCHEDULE
Identify one inspector
per Region
$0
4 weeks 1
Identify workflow
process and forms
$10,000 (travel costs
for 10 inspectors)
2 weeks (one for preparation
and one for DC meeting)
Contractor support for
workflow process
$10,000
3 weeks (one week for
moderation and two for
report)
Review report with
group and determine
the appropriate
templates
$0
4 weeks
Template development
$40,000
4 weeks |
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Hardware and Software
$45,000 (for 10
inspectors)
26 weeks total (will need to
investigate purchase vs.
leasing option, submit
paperwork, await delivery)
Training on Tablet and
Templates
$10,000 travel costs
$0 (if able to utilize
NETI's access to
WebEx)
2 weeks (one for
preparation and one for DC
meeting
Pilot workflow process
$0
12 weeks (identify bugs,
improvement to template)
Template Modification
$10,000
3 weeks
Deployment
$0
Total
$115,000
$105,00 (using WebEx
for training)
40-52 weeks
6.3 LONG-TERM OPPORTUNITIES
The following activities are presented as workflow process that could be implemented
though they would require considerably more resources, staff, funds and time, to develop
workflow processes for a larger inspection program or modify ICIS to accept data from another
computer, from a wireless transmission or from the Internet.
SYSTEMS-BASED APPROACH
Two options are presented under this approach. The first option allows a national
program to identify and develop its own hardware/software workflow process for a particular
inspection program on its own time and cost. The second option identifies common (general)
activities, forms that are used across all inspection and/or enforcement programs.
Option 1 takes a holistic view that for a specific inspection program; all the regions
would come together and develop a workflow process for the particular inspection program, i.e.,
RCRA, CWA, CAA, etc. This approach requires a workgroup of regional, headquarters
inspectors, as well as IT representatives to develop a comprehensive workflow process package
for the inspection program. The information required in this package can be divided into three
categories:
• Business requirements - The broad outline of expectations from the specific
inspection program and Agency IT
• User requirements - The workflow procedures and necessary documentation
• System requirements - The technical abilities and limitations of specific hardware
and software
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The cost for this option includes some travel and staff time to develop the national
standards for a national inspection program. A group of 20 staff and managers meeting over 18
months to two years would be tasked to develop the necessary business, user and system
requirements that all inspection programs need to meet. Once this is completed, all ten regions
could pool their resources and create the workflow process at once, or each region could develop
the workflow process for that inspection program based upon the resources available. The cost is
approximately $51,000 to develop a national workflow process for one inspection program. The
requested funding is for travel costs.
TABLE 9: TASKS, COSTS & SCHEDULE TO DEVELOP NATIONAL
DATA AND PROGRAM STANDARDS FOR ONE INSPECTION
PROGRAM
TASKS
COSTS
SCHEDULE
Identify 16 inspectors
and managers (14
inspectors (one from
each region, two-first
line supervisors, NEIC
and HQ) four IT staff
(OEI, ETDD, Two
from the regions)
$0
8 weeks
Meetings (three -
initial, midterm and
final)
$51,000 (travel costs
for 17 people @
$1,000)
6 weeks (one for preparation
and one for DC meeting)
Final Systems Report
$0
18-24 months
Option 2 examines common activities associated with inspections or enforcement
activities. A review of each inspection program and enforcement activities might yield
commonalities for which a workflow process could be developed and used across all regions and
inspection programs. For example, each Office of Regional Counsel develops compliance
orders. A workflow process could be created to produce uniform compliance orders across the
ten regions. Information would be entered once and populated through all the forms. Since no
specific activity has been identified at this time, some costs are known, but others are uncertain
until the workflow process is identified, and its complexities are known.
TABLE 10: TASKS, COSTS & SCHEDULE TO DEVELOP UNIFORM
WORKFLOW PROCESS ACROSS TEN REGIONS
TASKS
COSTS
SCHEDULE
Survey inspection
programs and regional
counsel
$0 (staff time)
16 weeks
Analyze results;
identify common
inspection/enforcement
$0 (staff time)
3 weeks
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activities.
Select and prioritize
common activities
$0 (staff time)
2 weeks
Brief managers, select
common activity
$0 (staff time)
8 weeks
Identify workgroup (1
from each region)
$ 10,000 (travel cost)
8 weeks
3-day workgroup
meeting to identify
workflow process)
$3,000 (contractor
support)
1 week
Develop blueprint of
workflow process with
cost estimate
$3,000
3 weeks
Development of
workflow process
$50,000 - $200,000
(depending on software
and contractor's time)
12-52 weeks (complexity
and programming
requirements)
Template modification
and training required
3 weeks
Pilot workflow process
Total (Estimate)
$66,000-216,000
52 - 78 weeks
CONVERTING WHOLE INSPECTION PROGRAMS
The magnitude of converting EPA's compliance monitoring and enforcement programs
from a paper-based workflow process into an effective electronic workflow process will be
immense. Of the seven statutes overseen by the Office of Compliance, there are 40 inspection
programs. (See Appendix B, the identified inspection programs for which OC has responsibility).
CERCLA has been excluded from the list of statutes, as it is not a compliance-monitoring
program. The seven statutes are:
• Clean Water Act
• Clean Air Act
• Resource Conservation and Recovery Act
• Toxic Substances Control Act
• Federal Insecticide, Fungicide and Rodenticide Act
• Safe Drinking Water Act
• Emergency Planning and Community Right to Know Act
What would be the estimated cost of converting a large inspection program (data
collection and report creation only) from paper to an electronic-based program? The Clean
Water Act, an example of a large inspection program, has 15 major inspection programs and 38
inspection types. (See Appendix B for the PCS data input sheet for the specific inspection
programs and inspection types). The development costs of identifying the workflow process and
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creating the appropriate inspection templates for each of the 15 CWA inspection programs is
estimated at $300,000 each (or a total of approximately $4.5 million). Effectively adopting an
enterprise-wide solution, such as this, will require resources to identify the workflow process and
develop the proprietary inspection templates (at a programmer contract cost of $125 per hour),
converting the necessary forms and documents into electronic files and print-ready forms, reports
and other documents. This figure does not include the necessary hardware and ability to migrate
the collected data electronically from the hardware directly into ICIS. The $4.5 million cost is
based on initial projects costing more than the average ($300,000) while later projects costing
less than the average. This is due to the contractor's ability to use some of the initial developed
templates (common data fields) in the later inspection templates. The cost may be lower if a
single software solution is developed for all 15 CWA programs, but that would require initial
planning and standardization of inspection procedures.
TRANSFER INSPECTION DATA DIRECTLY INTO ICIS
One of the major objectives of this Strategy is to improve our collection of compliance
information and to insert the data into the appropriate ICIS data fields accurately. To ensure we
can achieve this objective, all workflow processes need to adhere to standards that ensure
whatever software is used to collect or generate compliance monitoring data/reports can be
shared with other workflow processes within the Region, among Regions and/or with
Headquarters. This approach allows the regional and Headquarters programs to select
appropriate software that meets their program's particular workflow needs while maintaining the
capability of sharing the information with others even though they use different software.
These principles should guide OECA as we move forward in creating new workflow
processes that interfaces seamlessly with ICIS:
• The product or workflow process must collect the necessary compliance
monitoring information to document the inspection and to create a complete and
accurate inspection report consistent with the current national program
requirements.
• The product or workflow process must be compatible with the ICIS database.
ICIS will be the national compliance monitoring and enforcement database for all
environmental programs, which OECA is responsible.
• The data/information created by the product or workflow process must be in such
a form so that it can be shared/utilized with other programs or other workflow
processes with little or no translation issues.
SOFTWARE STANDARDS FOR DEVELOPING A WORK FLOW PROCESS THAT IS
COMPATIBLE FOR DATA/INFORMATION ENTRY INTO ICIS
The initial standards can be divided into two areas: ICIS-specific requirements and
Agency requirements. ICIS-specific requirements are not available at this time; however, the
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ICIS manager indicates the extensible Markup Language (XML) will be one of several program
languages that will allow data to flow into ICIS electronically. The XML supports a wide
variety of software applications, but the applications must be able to communicate in a common
language. For that to happen, an XML Schema must be developed. The XML Schema
expresses shared vocabularies and allows computers to carry out rules made by people. The
Schema provides a means for defining the structure, content and semantics of XML documents.
Currently, the XML Schema being developed for ICIS Compliance and Enforcement is
scheduled to be available in approximately 36 months. Information about an XML Schema
currently used by ICIS can be found at:
http://iaspub.epa.gov/emg/portal.navigale del?P DATA IDENTIFIER-98296. This XML
Schema was created for the NPDES program.
In regards to Agency requirements, EPA developed the Central Data Exchange Network
in which future EPA data systems must comply. Current information about the Central Data
Exchange, Data Standards and the Exchange Network can be found at
http://iritranet.epa.gov/oic/proiectfactsheets.htni under Exchange Network.
How does this impact the current activities and future endeavors undertaken since the
XML Schema has not been finalized. It should have very little impact. During the
developmental stage of the workflow process, whatever software is selected, it must be XML
compatible. For example, the PCB Inspection Templates use MS Access software. MS Access
software is XML compatible. When the ICIS workgroup establishes its XML Schema, we will
need to review the PCB Inspection Templates to determine if the current data field names are
consistent with the XML Schema. If not, some work will be required to reconcile the
differences. The effort that went into developing the PCB Inspection Templates will not have
been wasted.
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BETTER USE OF TECHNOLOGY IN COMPLIANCE MONITORING ACTIVITIES
FIELD ACTIVITY COMPLIANCE TECHNOLOGY STRATEGY
(FACT STRATEGY)
PART 7
LEVERAGING RESOURCES FOR EXPANSION SOFTWARE DEVELOPMENT AND
EQUIPMENT PURCHASES
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PART 7
LEVERAGING RESOURCES FOR EXPANSION SOFTWARE DEVELOPMENT AND
EQUIPMENT PURCHASES
7.0 OPTIONS FOR LEVERAGING RESOURCES
Options for funding range from centralized funding to leaving it up to individual offices
to decide whether to invest in the use of portable personal computers. Centralized funding is the
preferred option for a number of reasons. It is more cost effective to centralize software
development instead of having decentralized efforts by individual regional programs/offices,
resulting in duplicative efforts without coordination or collaboration. Centralized funding of
equipment (hardware and accessories) is also highly recommended. It provides a strong
motivating factor for regions to switch from a pen and paper approach to the use of this
technology. Centralized funding also allows standardization of the equipment purchases and
cam be used to minimize the number of different types of equipment purchases. This creates
efficiencies in training and technical support, while ensuring that software and instructions
developed by headquarters will be applicable to the specific units purchased. Centralized
software development and equipment selection also provides cost savings with regard to
technical support.
EQUIPMENT- FUNDING OPTIONS
Decisions as to what type of portable personal computers will be used for a specific
program have a huge impact on funding needed. For some programs, especially those
inspections that require only a checklist, the PDA may be the equipment of choice. For most
though, the Tablet will likely offer the best option.
• Centralized funding.
Headquarters funds and centralizes decision on equipment. OECA or OEI
provides separate funds for the purchase of Tablets for inspectors as software
programs are developed for specific types of inspections. Hundreds of Tablets
would be needed over the long term to provide access by EPA inspectors.
• Tap existing OECA funds that are provided to the regions.
Taps OECA funds for compliance monitoring activities which are usually
distributed to the regions prior to their distribution. Purchase Tablets for
distribution to inspectors located in programs where software is developed and for
which regions request the equipment.
• Direct/request regions to use OECA funds to purchase Tablets.
Similar option to above but direct regions to use compliance monitoring funds
provided to the region by OECA to purchase equipment for inspectors in those
programs where software has been developed. OECA would provide guidelines
on equipment selection.
• Direct/request/encourage regions to replace existing desktop computers
assigned to inspectors with Tablets when upgrading the desktops.
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This approach uses the current method of acquiring computers. This results in an
inspector having only one computer; this eliminates the need for a region to fund
both a desktop and a Tablet for an inspector. It also provides every inspector with
a Tablet eventually. This same approach could be combined with a request to
expedite the replacement of the inspectors'desktop computers. This approach
will require further exploration with the IT staff to determine if it is a feasible
approach. Even if a different approach is adopted for funding Tablets, this option
is also worth considering in that it could be a mechanism for providing updates to
the Tablets as needed.
• Leasing.
Determine whether leasing is a viable option as technology changes quickly.
• Loaner program.
Headquarters purchases Tablets and loans to a region for three to six month trials.
This gives the region an opportunity to investigate the Tablet for a specific
program prior to purchasing with its own funds. Loans would be for inspectors in
a program for which software has been developed.
• STAG Funding for State/Tribal Inspectors
For States wanting to purchase Tablets, consider funding sources available under
TSCA, FIFRA, and Multimedia STAG funds.
• Technical support funding.
Explore whether technical support could be provided by the IT folks. This would
be the case if the desktop is replaced with the Tablet. It would be helpful to verify
whether regional IT staff would provide this support.
TEMPLATE DEVELOPMENT
While this is a funding issue, it is also an issue of expertise in hardware, software
development, specific regulatory requirements, inspection manuals/guidance/policies, and in
conducting inspections. This combination of skills and experience needed point out the necessity
to use a variety of approaches. It will be important to decide what skills are available and which
ones are not in deciding how to staff this work. Decisions made with regard to the options
presented in Part 6 will impact the choices for template development.
NCMPB lead.
Additional staff and contract support would be needed to address added programs.
Even with added support, some of the options below would also need to be
employed.
• Contracts/in-house programmers.
Contract funds will be necessary unless there are in-house programmers.
• In addition to staff, employ students through the Student Career Experience
Program (SCEP) and intern programs.
Employ students that have experience with software development and
environmental issues. Alternative, explore recruiting University teams to design
and develop the software for specific types of inspections.
• Recruit through Details.
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Preference given to experienced inspectors/data experts with programming skills.
Share work with ETDD.
Explore whether support can be provided through existing IT personnel.
Assign work to HQ/Region media leads either with oversight/support from
the NCMPB or a co-lead role.
Alternatively, assign work and provide standards and criteria. Note: Support
from OC program/media lead experts/staff, and in some cases from other offices,
and from regional experts and senior inspectors will be necessary to effectively
map workflow processes.
The NCMPB would provide support on request to offices interested in
developing software.
Use multimedia STAG funds to solicit requests from States interested in
developing software for their programs.
Use OECA STAG funds for a State to develop the inspection template for a
specific inspection program. The criteria for development to be provided by
OECA.
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BETTER USE OF TECHNOLOGY IN COMPLIANCE MONITORING ACTIVITIES
FIELD ACTIVITY COMPLIANCE TECHNOLOGY STRATEGY
(FACT STRATEGY)
PART 8
CONCLUSIONS AND RECOMMENDATIONS
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PART 8
CONCLUSIONS AND RECOMMENDATIONS
8.0 CONCLUSIONS
Effectively incorporating technology in OECA's compliance monitoring work on an on-
going basis can significantly improve the efficiency and quality of inspections, inspection
reports, and/or data entry into OECA's data bases. It is important to recognize that technology
will continue to change and improve and to remain open to modifying choices (including
hardware or software).' Advances in technology provide continuing opportunities to apply the
"best" technology available at the time and to make improvements in how EPA accomplishes its
work. Investing in new technologies which result in positive changes to the existing workflow
process requires time, money, and commitment on the part of management and staff.
FACT STRATEGY
Applying the FACT Strategy to identify opportunities for making better use of
technology by inspectors can maximize benefits. Experience indicates that inspectors are willing
to use effective technology that is provided to them; a number of them are willing to seek out
new technology and do the groundwork to try to improve how they do their work. While
individual efforts are valued, they often involve a trial and error approach without input from
others who may be making similar attempts.
Using the systematic, structured approach, described in this Strategy to identify, evaluate,
and select technology for use, expansion, or further development is strongly recommended.
Instead of a trial and error approach, it offers a process for upfront analyses, collaboration, field
testing, evaluation, and faster, broader implementation. In addition to providing for an analysis
of the workflow process and evaluation of hardware/software options, it also includes a step for
analyzing the potential impact of changes to the inspection and enforcement process. This
allows the identification of policy or procedural changes needed to ensure that the adoption of
new technology supports the enforcement process and does not negatively impact it.
USE OF PORTABLE PERSONAL COMPUTERS WITH APPROPRIATE SOFTWARE -
LESSONS LEARNED FROM THE TSCA PCB PILOT
The TSCA PCB Pilot demonstrated that it is feasible to develop software for use on a
Tablet that allows an inspector to enter information once during the inspection and have the data
automatically populate inspection forms, field notes, inspection reports, and data fields for
subsequent entry into Agency data bases, thus minimizing duplicative entry. Use of this
technology reduces the time to collect and record information during the inspection, facilitates
the inspection process, and generates nearly complete inspection reports electronically from the
information entered during the inspection.
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Investing in the "up-front" work to select software and develop specific templates
significantly increases the value added of using a Tablet PC. Simply providing hardware with
little investment in identifying software options appropriate for the specific workflow process
will not offer the same level of benefits.
While technology will continue to change and to improve, taking steps to incorporate the
use of portable personal computers should be initiated now. Work completed for different pilots
provides useful information and firmly lays the groundwork for future improvements. There
have been many lessons learned to date, as identified throughout the Strategy, which need to be
applied to any effort to expand the use of this technology. For example, input from inspectors
who do the work as well as program experts is key to correctly mapping the workflow process.
Their input on their needs and preferences is invaluable. In addition, allowing time for the
inspector to learn how to use the equipment, providing adequate training, and providing adequate
instructions prior to actual field use are necessary for successful field implementation. Creating
opportunities to share information on the use of the technology can generate interest and
capitalizes on lessons learned from the efforts of others.
Benefits of using this technology in the field include more timely completion of
inspection reports and data entry and increased consistency on how inspections are conducted
and the results reports. In addition, capturing the workflow process for specific types of
inspections using input from Agency experts and senior inspectors provides a tool for knowledge
management by recording detailed information on how to effectively conduct inspections.
EXPANDING THE USE OF PORTABLE PERSONAL COMPUTERS TO OTHER
PROGRAMS
Efforts are underway to expand the use of Tablets and the software templates to PCB
compliance programs in EPA's ten regional offices and to states operating under the TSCA PCB
Compliance Monitoring Agreements using STAG funds. In addition, preparatory work has been
initiated to begin software development for the TSCA AHERA (asbestos) program.
To expand the use of portable personal computers to other programs, there are many
options on how to proceed. Decisions on the best approaches will be determined in part by
available funding and who agrees to take the lead.
Options range from developing software for each type of inspection under each statute to
an enterprise based approach. Factors to weigh in selecting an approach besides funding include
the extent to which the approach offers flexibility for individual programs (best provided by a
program by program approach) versus the uniformity and broad application of an enterprise wide
approach. An enterprise wide approach requires more up-front investment of personnel to
develop and agree upon uniform workflow processes. An enterprise wide solution will likely
involve less cost than developing solutions for each type of inspection within each statute. The
result would be Agency wide once completed. Programs are likely to be more resistant to this
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approach. Combining approaches may achieve broad implementation in a more realistic
resource scenario.
The Strategy strongly recommends applying the elements identified in Part 1 for any
expansion effort. Pilots are crucial to develop useable software technology that can be
implemented across regions. In selecting a partner with which to carry out a pilot, a high level of
interest and commitment by participants in the Pilot is necessary to success. As OECA considers
expanding the use of technology, this should be considered as one of the criteria for selecting
programs for this investment. Related to this, outreach efforts are an important part of
generating strong interest in using technology. Facilitating the sharing of success stories remains
a good investment.
The speed with which this technology could be expanded is very dependent on funding
and almost as important, the sources of that funding for both software development and
equipment purchases. Centralization or at least coordination of the various efforts to adopt
technology for inspectors is desirable to eliminate a large number of individuals or programs
repeating the same beginning steps. Adoption of new technology across offices, especially at the
regional and state level, will occur much faster if Headquarters develops the software and
provides the equipment, related software, training, and technical support. Identifying appropriate
equipment and limiting choices to a few types reduces potential problems of incompatibility of
hardware with software and makes providing technical support, training, and manuals easier.
8.1 LIST OF RECOMMENDATIONS
• Continue expansion of the PCB pilot to ail regions and states.
Continue outreach and training of PCB inspectors interested in adopting this technology.
Fund Tablets for regional inspectors: $60,000 (OECA)
Continue to provide technical support and training
• Continue to provide technical support, training, and funds to revise the software as
needed.
Fund travel costs for training as needed.
Funds software revisions as needed.
Develop policies as needed.
• Continue work to facilitate regional and state collaboration on the TSCA AHERA
pilot.
• Provide outreach to other programs to demonstrate what has been achieved for the
TSCA pilot program.
• Identify interface with ICIS as an ICIS priority.
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Pilot the PCB project for ICIS interface.
• Expand software development for inspections and investigations to National
Priorities (e.g., stormwater), or large programs (e.g., RCRA).
• Continue outreach, research and elicitation of information related to the use of
portable personal computers and other technology.
• Integrate field technology efforts within the Agency. Establish a workgroup co-
chaired by the NCMPB and OEI.
• Identify next steps for expansion after a review of the workgroup recommendations.
• Further analyze policy issues and develop policies as needed on an on-going basis.
8.2 DETAILED EXPLANATION OF RECOMMENDATIONS
• CONTINUE EXPANSION OF THE PCB PILOT TO ALL REGIONS AND STATES
Regions and several states have expressed interest and a number of states have requested
STAG funding to purchase Tablets and related equipment/accessories. Funds have been
transferred to regions. The NCMPB will provide training for regional/state personnel on
request; a number of states have scheduled training for fall 2007. The NCMPB will continue
outreach to regions and states with PCB programs to encourage them to adopt this
technology, i.e., the Tablet and templates.
Continue outreach and training of PCB inspectors interested in adopting this
technology.
Fund Tablets for regional inspectors: $67,000 (OECA funds)
Regional inspectors have indicated an interest but did not believe their region had funds to
invest in the Tablet. Providing funding or the actual Tablets and related equipment will
facilitate the use of this technology. In addition, it is likely that once PCB inspectors are
using this technology, other programs will be interested in working with OECA to develop
software capability for their programs and be willing to invest in the technology once they
see the benefits. Lessons learned from the survey and discussions with other agencies
indicate that initial funding of the purchase of the equipment by headquarters or some other
source besides the inspector's immediate office's administrative funds provides a strong
incentive for moving to this technology.
Provide training as needed. Training on the use of the Tablet and the software is important
to the success of the adoption of this technology. The NCMPB is prepared to provide
training in person and through WebEx.
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CONTINUE TO PROVIDE TECHNICAL SUPPORT, TRAINING, AND FUNDS TO
REVISE THE SOFTWARE AS NEEDED.
Fund travel costs for training as needed.
Funds software revisions as needed.
Develop policies as needed.
Lessons learned from researching efforts by other offices indicate that some level of
continued support is needed to maximize the use of the technology and to ensure that it is up
to date. In programs where continued support was not provided, use of the technology
declined, e.g., PDAs, in the UST program.
• CONTINUE WORK ON THE TSCA AHERA PILOT
As the media compliance monitoring lead for TSCA AHERA, the NCMPB will continue to
coordinate regional and state efforts to develop software for AHERA inspections. Since this
program is very similar to the TSCA PCB program and utilizes the same inspection forms,
the NCMPB will provide its experience with interested state and regional parties. NCMPB
staff has already begun work on analyzing the workflow process for AHERA inspections
with regional inspectors. Next steps include coordinating efforts between regions on the
project, assisting in identifying partners for a pilot, and providing funding through STAG
funds to assist states in developing software and conducting a Pilot.
Provide STAG money to regions to fund grants for AHERA states to purchase tablets
and to travel to EPA HQs/Regional offices for training.
At least one region has requested funding for Tablets for their states. Note: Under TSCA
Asbestos Compliance Monitoring Agreements funded with STAG funds, states must
contribute 25% of the total grant (statutory requirement).
• PROVIDE OUTEACH TO OTHER PROGRAMS TO DEMONSTRATE WHAT HAS
BEEN ACHIEVED FOR THE TSCA PILOT PROGRAM
The NCMPB has conducted a number of presentations at national meetings such as the
National PCB meeting attended by EPA PCB managers/staff. Presentations were also
provided at the pesticide managers training course on compliance monitoring (PREP course),
several asbestos meetings being held for regional and state personnel, and the National EPA
Inspectors Workshop, attended by HQ and regional inspectors across all media.
• IDENTIFY INTERFACE WITH ICIS AS AN ICIS PRIORITY
The potential for improving the quality and timeliness of the entry of inspection data,
including ICDS data on the results of the inspection (a GPRA measure) through this effort is
tremendous. More importantly, it significantly reduces the workload to collect data and enter
the data for EPA's databases. The inspector could collect information that is needed as part
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of his inspection and enter it once into the Tablet and the software would use this data to
populate the data fields for EPA's databases and transmit the data directly to EPA's ICIS
database. This could provide a mechanism for states/tribes to collect this data and enter it
automatically with little effort on their part.
Pilot the TSCA PCB Program for ICIS Interface: The work already completed for the
TSCA PCB Pilot positions this program as ideal for a pilot for developing software to
populate ICIS directly or through batch reporting. The official database of record for TSCA
PCB inspections is ICIS for both federal inspections and state inspections conducted with
EPA credentials.
• EXPAND SOFTWARE DEVELOPMENT FOR INSPECTIONS AND
INVESTIGATIONS TO NATIONAL PRIORITIES OR LARGE PROGRAMS
Encourage other compliance and enforcement offices to develop software for use in the field
in areas where they have the media lead. NCMPB can demonstrate its PCB template and
provide its experience with developing a workflow process. Primary efforts should be
focused on National Enforcement Priorities (e.g., stormwater, air toxics, and financial
assurance) and large programs (e.g., RCRA). NCMPB has already begun outreach efforts to
other programs. Each potential program will need to establish a workgroup to provide input
on the workflow process for that particular inspection or investigation program. The
workgroup should work with the NCMPB to decide on a process to elicit information on
what has done so far in this area by regional and state staff, identify partners for a pilot,
develop detailed information on the workflow process for inspections and report writing.
Costs will be determined after evaluating what work has already occurred for each program.
For a pilot similar to the PCB template, costs are expected to be $45,000 for initial contract
work and $9,000 to purchase two sets of equipment for regional inspectors. Additional
funding would be needed to include a state in a pilot.
• CONTINUE OUTREACH, RESEARCH AND ELICITING OF INFORMATION
RELATED TO THE USE OF PORTABLE PERSONAL COMPUTERS AND OTHER
TECHNOLOGY
Conduct periodic updates to the survey; continue to feature discussions of the application of
technology to inspections during the National EPA Inspectors Workshop, other EPA
National Meetings and Workshops, joint EPA state meetings, workshops, and training
courses, especially inspector training courses.
• INTEGRATE FIELD TECHNOLOGY EFFORTS WITHIN THE AGENCY -
ESTABLISH A WORKGROUP CO-CHAIRED BY THE NCMPB
The Office of Compliance, after speaking with representatives from several offices,
recommends the creation of an intra-agency workgroup for improving the use of new
technology in the field. This Strategy would be provided when the workgroup is formed.
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New information can be added to it on current efforts based on the workgroup. Ideally, the
workgroup would include managers from the various programs as well as staff level users
and software developers.
This project could begin with meetings with the workgroup prior to the National EPA
Inspectors Workshop in December. A plenary session on technology is scheduled during the
December Workshop. Additional discussions will occur in the media specific breakout
sessions. This effort could be followed by a two day meeting later in the year that includes
staff level users and software developers from OECA, OW, OE1, OSWER, ORD, and
regional offices to demonstrate the variety of field software and database solutions they have
developed. The workgroup would develop a summary of available technology and
recommendations on how to coordinate between offices to improve each program's use of
technology. The report will be shared with senior level managers, who may discuss cost
considerations and options for coordinating programs. The Workgroup would explore how
to best leverage resources for software development, equipment purchases, and technical
support across programs. It should- look at program specific and enterprise wide options. The
intra-agency field technology workgroup should continue to meet through monthly
conference calls to discuss progress and new developments across the Agency.
Staffs from several offices such as OEI and OSWER have indicated a strong interest in
participating.
• IDENTIFY NEXT STEPS FOR EXPANSION AFTER A REVIEW OF THE
WORKGROUP RECOMMENDATIONS
• FURTHER ANALYZE POLICY ISSUES AND DEVELOP POLICIES AS NEEDED
ON A ON-GOING BASIS
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BETTER USE OF TECHNOLOGY IN COMPLIANCE MONITORING
ACTIVITIES
FIELD ACTIVITY COMPLIANCE TECHNOLOGY STRATEGY
(FACT STRATEGY)
APPENDIX A
AGENCIES SURVEYED WITH SUMMARIZED COMMENTS
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APPENDIX A
AGENCIES SURVEYED WITH SUMMARIZED COMMENTS
SURVEYED AGENCIES
FEDERAL
Internal Revenue Service
Rob Leahy, Large and Mid Size Business Division Information Officer; (202-
622-0746).
As a pilot project in 2001, IRS equipped 150 agents with notebook PCs to
perform audits of diesel truck drivers. The notebooks were connected through
SafeNet, a government wireless VPN.
Source: http://www.mobileinlo.coni/Case Study/field inspection.htm
United States Forestry Service
Christine LaBerge, Walsh Environmental (303-443-3282)
Walsh Environmental conducted over 700 surveys in regions 2 and 3 for USFS,
EPA, BLM, and experimental forests. They use ruggedized notebooks, digital
cameras, and GPS units to survey water and wastewater sanitary conditions. Sites
varied from hand pumps to wastewater plants. The field data is imported into a
database for consistent wording, and the inspectors can print customizable reports.
Source: 2004 National PDA Conference presentation;
Occupational Safety and Health Administration
Glen Lamsons, Salt Lake City Health Response Team (801-233-4914)
Most offices use laptops for inspectors. The Office of Health Enforcement has
experimented with PDAs, but this has not been a coordinated effort. They have
been used as repositories of data, or for data logging with their measurement
equipment. About five years ago, Salt Lake City's Health Response Team tried to
integrate the PDAs with forms entry. They had a pilot project with Region 8, and
gave one to two pocket PCs to eight area offices. These contained standards and
the legalese for citations. The pilot failed because of budget cuts and problems
with getting their IT group to support the PDA software. Additionally, PDAs
were used on site at the World Trade Center. Currently, OSHA does not have any
program using full-time hardware or software.
National Oceanic and Atmospheric Administration
Tom Altvater, Environmental Compliance and Safety Office (301-713-2870
xl32)
NOAA inspectors use pen and paper, and sometimes laptops in the field for 20-40
inspections annually. Additionally, all 800 sites have self-inspections. The data
is transcribed and entered into an automated system that they have been using for
the past four to five years. Once it is entered into the system, assessments and
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findings are automatically e-mailed as weblinks. The system is compatible with
Tablet PC use, but they have not had money to purchase the Tablets yet.
United States Geologic Survey
Cynthia Duffield, Safety and Environmental Branch (703-648-7551)
Facilities complete a self-inspection checklist annually, with auditors conducting
inspections every four years. The data was previously entered into spreadsheets,
but they are now testing an in house interactive system that includes safety and
environmental standards and policies.
Bill Miller (703-648-7552)
During surveys, inspectors use specialized electronic equipment for data logging
and measurements, but nothing in terms of inputting the data.
National Park Service
Louis Rowe. Risk Management Program. (202-513-7222)
NPS has had a team of regional and local inspectors evaluate an automated
inspection system over the past 18 months. They want a consistent way to audit
themselves in field, using Tablet PCs that will populate fields automatically and
incorporate questions from other systems. NPS is preparing to develop the
software and test it over the next nine months. Note: Louis has sent information
on the needs of the agency and specifications of the three top programs they were
reviewing.
United States Postal Service
Frank Lundblad (202-268-3692) and Sam Pulcrano (202-268-2067), Safety
Performance Management
In 2003, USPS equipped 600 safety inspectors with Palm PDAs to annually
inspect its 39,000 Post Office facilities for OSHA requirements. Inspectors use
software that a team of in- house and contract programmers began developing in
2001. The software integrates three databases into a checklist, and provides a
web interface to upload information into an Oracle database and immediately
print reports and access references. This saves many hours of handwriting notes
and inputting data.
Source: httn://www.gen.com/print/22 31Z23963-1 .html
United States Census Bureau
The Census Bureau awarded a contract to make the 2010 enumeration process-
paperless. The software and hardware are standardized to the Census' IT policies
and there is no ability by the user to amend the workflow process. The software
will allow the enumerator to follow-up with citizens who did not submit their long
or short census form. All the information will be on a handheld unit similar to a
TREO. The TREO is a combination phone and PDA. It will have wireless
capability with information transmitted on a regular basis to the national database.
This project is a true makeover for the enumeration process scheduled in 2010.
The final product was tested for seven weeks in May and June 2007. The contract
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award totals $600 million. The contract includes all hardware (500,000 handheld
units) and software, back-end programming thru database, wireless development,
training and support. A unique feature about this project was how the contracting
process was used. The Census knew what it wanted in terms of performance but
did not know what hardware and software there was that could address their
needs. During the contract process, each contractor was required to develop a
prototype of the software and hardware that would be used in the field. As a
result, the Census Bureau currently has an 85-90% complete prototype package.
There will be some modification to the prototype software to reach the final
product but this contracting process took about six months to complete.
Source:
http://www.computerworld.com/mobiletopics/mobilc/storv/0J0801,110244.00,ht
ml
hUp://www.computerworld.com/action/article.do?command=viewArticleBasic&a
rlicleld=292016
Food and Drug Administration
Office of Regulatory Affairs: David Gallant (240-632-6812) & Scott Lewis (781-
596-7748).
Approximately 2,000 Inspectors use laptops and digital cameras n the field. They
have an automated system, TurboEIR, which was developed by programmers at
USDA. Scott Lewis is in charge of managing the program at FDA. Through the
program inspectors can download assignments, generate and print reports and
citations, and upload them into an agency wide database for real-time updates.
The EIR software contains a "plain English" translation of CFR regulations, and
ensures that this prescribed information is used to issue inspection observations
and automate the inspection report process. This is for quality control to ensure
that standard procedures and language are used for all reports, and that inspectors
adhere to the regulations. They are also looking to modify the program to allow
input from checklist PDA software that will be used during some of their easier
inspections.
Division of Field Investigations. Michael Rogers (301-827-5653)
They have been looking into the use of Tablet PCs, but do not have the funds to
provide them to all the inspectors. Blackberrys have not been provided either, as
they have not shown a significant cost to benefit ratio. They have compiled
standards and specifications for digital cameras.
Securities and Exchange Commission
Office of Compliance Inspections and Examinations, Lori Richards (202-551-
6200)
Laptop computers are provided for all examiners, and they use a docking station
with a monitor at the office. Senior supervisors use Blackberrys. The SEC
currently uses software for examinations that was created in house, but is looking
for vendor software for auditing. Since inspectors often collect e-mails and large
amounts of data, they use software called Autonomy and Concordance to sort the
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information. The SEC has developed techniques to analyze large amounts of
data, and to use standardized language in reports to maintain consistency between
the regions. They hope to have an automated system that will create and save
work papers in the field.
United States Department of Agriculture
Food Safety and Inspection Service, Pat Abraham (202-690-4165)
No new technology in use by field inspectors.
National Information Technology Center, John Laderer (970-295-5195)
NITC programmed the TurboEIR software used by FDA, but is unaware of any
technology use or automated software at USDA.
Environmental Protection Agency
Office of Water, UIC Program, Suzanne Kelly (202-564-3887)
In 2002, the Office of Water began developing UIC software for PDAs through a
contractor. Due to the lack of a national UIC database, and the regional variation
in data, the software had to be developed individually for each region. The
software consisted of a series of checklists on a PDA with GPS integration, and
an interim Access database for a laptop. After collecting data on the PDA,
inspectors could connect to the laptop, print trip reports from the field, and export
data to the regional database. Each template was developed by spending a day
analyzing the workflow process with regional inspectors. The contractor would
develop a sample program, which would be tested by the region before delivering
the software. At the same time, many of the regional databases were upgraded to
Microsoft Access databases. Training consisted of an operations manual
developed at Headquarters, and training by a lead inspector at the regional level.
One primary benefit of the software was the reduction in transcription errors.
By 2006, seven regions were using PDA software for their UIC inspections. The
total cost for the programs, including upgrading regional databases, ranged from
$45,000 to $100,000 per year. The Office of Water stopped funding and
supporting the UIC software in 2006, but many regions continue to use the
software. Some regions have even tried to broaden and improve the software
themselves. Meanwhile, Office of Water has shifted toward developing a national
UIC database. The PDAs improved efficiency, but some inspectors reported
trouble with their reliability and handwriting recognition.
Office of Water. Sanitary Surveys. Jamie Bourne (617-918-1610)
Beginning in 2003, EPA employed a contractor to develop an open platform
(software) to collect information for sanitary sewer surveys. This includes 1,200
detailed questions, which can be pared down to 100-120 questions for smaller
inspections. The question sets are flexible, and states can even design their own
questions and add them to the database. Once a survey of questions is designed, it
is put into a PDA for the inspection, and uploaded directly from the field upon
completion. The software can print reports, cover letters, and deficiencies in the
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field. Additional technologies include digital photos, GPS, and the ability to send
the data through the Internet. This workflow process makes it easier to follow up
on inspections than the previous method, which just stored reports in folders for
three to five years. As of FY 2007, 13 states are either using the software or field
testing. With the ability of the workflow process to develop smaller question sets
other states have expressed interest in using the software for their programs.
While it took approximately one year to work through software bugs and crashes
that occurred in the field, reports of time savings during inspections are now being
observed. According to preliminary results, inspectors are finding a savings of
between 3 to 14 hours in conducting sanitary sewer surveys using the new
hardware and software. While the intent of this workflow process is to input the
survey data into a central database, some states have had security issues with their
network administrators. In terms of hardware, PDAs were initially selected
because of their longer battery life. Initially, Tablets were not selected because of
cost, weight, and size, but they seem to be better for longer surveys that require
typing. In FY 2006, a Tablet version (software) was released and is being
evaluated by some of the states. The Office of Water publishes a newsletter with
updates about the software and its use.
Region 2. UST Program, Rebecca Jamison & David Bernstein
Beginning in 2001, a Region 2 inspector, in collaboration with the State of New
York, began developing a PDA based software tool for UST inspections.
Development of the software was based on a thorough analysis of an inspector's
workflow. After initial design, the inspector created a series of paper based
checklists for inspectors to use and test in the field. This process helped to refine
the checklists without additional programming. After many iterations of testing,
the software allowed inspectors to collect facility information, inventory USTs,
and collect GPS data using a combination of checkboxes, drop-down menus, and
handwritten entry. Progress on the project stopped in 2005 when the inspector
wanted to upgrade the back-end database to allow updates from the field. The IT
department would not support the new database software. Since that time, the
inspector has moved to the NPDES program, and is trying to develop a storm
water inspection checklist. In 2007 the Region 2 UST office began looking into
having a contractor upgrade the PDA software. They received funding from
OUST, but OSRE denied additional funding.
Region 1. AHERA Program. James Bryson
In 1998, Region 1 developed a Microsoft Access based system to audit asbestos
training providers, based on a checklist created by states in Regions 1, 2, 3, and 4
to enhance reciprocity. In 2001, it was expanded to include a checklist-based tool
for Asbestos Hazard Emergency Response Act (AHERA) inspections. The
system is used on laptop computers by state inspectors in Region 1, and it allows
them to identify observations related to specific statutory requirements. Summary
reports of inspections and links to photos are also integrated into the software.
Since 2001, a TSCA Lead inspection checklist has been added, and the states are
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looking to upgrade the system to work with Tablet PCs with a Web-based feature
to immediately update their databases over a secure site.
Office of Environmental Information, Andrew Lowe
In 2006, OEI began developing a Facility Field Data Collection Tool, which is a
software model designed to support the EPA Locational Data Improvement
Project. The application software enables users to capture latitude/longitude
readings in the field—using a GPS receiver—and add comments. The system can
also connect to the Facility Registry System (FRS) for import and export, or be
exported to a text file for upload into any database. The application runs on
Windows Mobile (for PDAs) or Windows XP (for Tablet PCs or Ultra Mobile
PCs). The design of the tool allows for integration into other software
applications. After a year of software development at a cost of $15,000, OEI
began field usability tests in summer 2007.
Office of Solid Waste and Emergency Response, Emergency Response Team.
Robert Cibulskis
The Emergency Response Team has developed an extensive set of tools for its
On-Scene Coordinators. Applications for field use allow for: modeling, 3D
mapping, statistical analysis, data acquisition, and data management. On-Scene
Coordinators use a variety of hardware, including PDAs, laptops, GPS, digital
cameras, scanners, and data monitors. This combination of tools allows for real
time coordination of office and field activities. The unique needs for: immediate
response; coordination of multiple individuals in different locations; and
communication from individuals who spend extended periods of time on-site,
provides the incentive for the Emergency Response Team to use technology in the
field.
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STATE AND LOCAL
Department of Environmental Resources Management (FL), Jerry Crawford (305-372-
6677), Tom Dratler (305-372-6462).
Since 2003, about inspectors at DERM have been using Tablet PCs with Excel as
an input form for air and water quality inspections. As of 2007, there are 70-75
inspectors using the tablets. They utilize the wireless technology that is part of
the Tablet, which allows them to work remotely, software and wireless
automatically transfers information from the state database into the form, uploads
or e-mail inspections for authorization, and access GIS to pinpoint locations. The
inspectors use software that was developed in-house through analysis of both
statue-based checklists and the workflow process. The software is frequently
updated, with more than one version created per year in the first several years.
While the program increases the accuracy of information because data clerks are
not needed for transcription, the software and workflow process requires a
significant amount of training. There is a separate training group for the technical
process. The state is working on incorporating the ability to print in the field.
This project has cost about $100,000 to date. While an official study on
efficiency has not been conducted, there is consensus that the program has
increased the number of inspections per year and the project has been worth the
cost.
Management and Information Services Department (Boston), Chris Burlingame (607-
635-4783).
In 2003, the Office of Neighborhood Services began using Tablet PCs to record
citizen comments on government PDF forms using LiquidOffice eForm. Also,
they have been testing wireless connectivity to submit the forms in real time. Mr.
Burlingame thought the Tablets were pricey, and may not be durable enough for
use by building and health inspectors. However, it has the advantage of using
Microsoft XP and other Microsoft products, and ease of use on a larger screen
than a PDA. Representatives from Cardiff, who created the software, said they
decreased the cost of processing for routing, approval, completion, and data entry
from $100-150 to just $7.
Source: http://www.fcw.com/geb/articles/2003/0707/wcb-boston-07-09-Q3.asD
Office of Planning and Environment (Washtenaw County, MI), Dan Myers (734-222-
6844).
In early 2005, Washtenaw started using laptops and PDAs to collect soil erosion
data for land and permit management. Using wireless technology, staff has real-
time access to the agency's database and to quickly shift their daily activities from
the office to the field, thus improving efficiency and providing faster results to
citizens. They use a complete software solution by Accela.
Source: http://www.govtech.net/magazine/channel story.php/94283
Department of Health (Washington, D.CJ, Denise Pope (202-442-5999).
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Since 2004, the department uses Tablet PCs with GIS to inspect the city's 30,000
health facilities for permits and licensing. The system allows remote access to
schedules and permit information, improving efficiency and improved tracking of
noncompliance.
Source:
http://www.govlech.nel/magazine/channel story.phtml?channel=14&id=89496
Department of Agriculture (CO), John Picanso. iohn.picanso@statc.co.us
The Colorado Department of Agriculture has been using Tablets for about three
years, and has upgraded their workflow process to use Microsoft Infopath forms.
Incorporating Infopath into the system, 35 inspectors save an hour per inspection
and conduct 20 more business and livestock inspections per week. The Tablets
are used heavily in the Colorado environment but they have not had to replace any
Tablets. The advantages of using this workflow process includes immediate data
entry (previously one week), decreased transcription errors, larger screens for
comments, paperless inspections, and ink technology. They want to deploy 50
more Tablets in the near future.
State Board of Barber Examiners (TX), Glen Parker (512-936-6333).
Since 2001, eight inspectors visit fifteen to twenty businesses per day to conduct
field inspections. They use PDAs with wireless technology to send their
inspection information to the main office. Although it took about one year to
work out the bugs, they have eliminated paper forms, reduced transcription errors
and duplicate data, saved time in the field, and been able to cut back on office
staff (saving $28,000 per year).
Source:
http://www.hansen.com/NEWS/lnthePress/GovTechSep01/Mobilelnsp.htm
City of Chicago, IL. Deborah McCann, Deputy CIO (312-742-0617).
In 2001, the City of Chicago implemented a mobile inspection solution from
Hansen Information Technologies, which integrated 500 users across fifteen
agencies, including the Department of Buildings, Fire Prevention Bureau and
Department of Public Health. The solution involves Pocket PCs, laptops, and
Tablets. Some activities will link with digital cameras, printers, and GPS.
Source:
http://www.hansen.com/news/InthePress/govtechianiiary02/govtech0102.htm
Health Department, (Volusia County, FL]_ Peter Thornton (386-822-6247), Regina
Harris (386-274-0699).
Peter Thornton (Volusia County, FL) described a thoroughly comprehensive and
integrated approach to information exchange and data management across the
county's entire public health mission. From a philosophical standpoint, he
advocated that regulatory agencies first think about the ideal and most expansive
possible uses of these new technologies and then set about designing an approach
to achieve these goals (rather than letting the.limitations of the technology dictate
the approach). The approach used by the county health department includes use of
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arc pad with extra memory, a wireless modem to synchronize data, and an
attached GPS device. The forms were created in house beginning in 2002 for use
on a Windows-based PDA. The forms were developed using a combination of
statute-based checklists and an analysis of the workflow process. The program
took only a few months to develop and implement, although the software has
undergone several revisions. The technology is used for inspections to pre-fill
forms—with the ability to take detailed notes if desired—and to upload
information to a database. The cost to outfit each inspector with the necessary
hardware and software was initially approximately $ 1,750, but that cost has
decreased as software upgrades have been less expensive than initial purchases.
As of 2007, inspectors in 7 different programs use the PDAs, and the agency has
experienced time savings and reduction in errors through the elimination of
duplicate efforts.
Source: 2004 National PDA Conference presentation summary.
Broward County Environmental Protection Department, Pollution Prevention and
Remediation Division. Jeffery Halsey (954-519-1486).
Since 2003, nine inspectors in the PPRD have used Tablet PCs to carry out 5,000
inspections annually. This data is collected in the field using proprietary
software, and uploaded to the main Oracle database on home internet connections.
The software integrates digital photos into reports, and allows printing in the field.
E-forms are sent to the state, quality controlled, then sent to EPA. This has
resulted in a 14% increase in the number of inspections, and a 40% decrease in
data errors. Additionally, the County is beginning to automate Building Code
Services, with 75 inspectors doing 10,000s of inspections on PDAs per year
starting in 2005.
Source: Environmental Compliance Consortium, Managing Environmental
Information Forum 2004 and 2005 presentations;
Source: http://www.complianceconsortium.org/Events/Events.asp
South Florida Water Management District. Jay Marshall (561-682-6950)
The District began experimenting with PDAs and self-designed inspection forms
in 1997. In 2001, they implemented a new program (M-Business Anywhere) with
web-based forms and checklists that were developed in-house by a programmer
over the course of a year. Currently, 45 field staff use the forms, which allow
them to spend more time in the field with no data re-entry, better efficiency, and
greater accuracy. In the firs six years, approximately 2,000 inspections were
completed per month with the new technology. New inspectors are required to
use the software, and they receive personal training along with the use of a web-
based technical manual. This workflow process is estimated to reduce program
costs by approximately $70,000 a year based on an initial software license of only
$10,000. The inspectors use GIS maps stored on memory cards for the PDAs.
Source: http://www.ianvwhere.com/success stories/sfwmd.html
Louisiana Office of Public Health. Curry Perkins (225-763-8775)
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In 2004, retail food inspectors began using Tablet PCs to document violations and
to replace the paper workflow process. Over 350 inspectors have been outfitted
with a Tablet PC, digital camera, and printer which cost $3,500 per person. The
software including the combining of forty different forms into one electronic
version cost $120,000. This does not include annual maintenance to the software.
The software generates reports and uploads them instantly from the field. While
some sanitarians have had trouble with the new technology, most think it is
excellent, making them more accurate and productive. The program has been
expanded to include building and premises, sewage and wastewater, and seafood
inspections. They also plan to replace all notebooks and desktops with Tablet
PCs.
City of New York Department of Health.
The Department of Health developed two systems to carry out restaurant (public
health) and lead inspections on Tablet PCs. The software allows inspectors to
cioate a standardized, focused inspection with code-based wording for violations.
It allows them to capture signatures and print violations on site, improving
efficiency, productivity, data quality, and revenue from fines.
Source:
http://vvww.dsii.net/us/AboutUs/SuccessfulStory/tabid/932/ctl/Editymid/Consultin
g/PublicSeetor/tabid/1023/Default.aspx
Rhode Island Department of Environmental Management. Terrence Gray (401-222-4700
ext. 7100), Ronald Gagnon (401 -222-6822 ext 7500)
Five inspectors began testing Tablet PCs in the field for UST inspections in June
2005. Contractors developed a single inspection template, from the previous ten-
page paper checklist, using Microsoft's Infopath software. Inspectors identify
their inspection site from a database list and the system will auto-fill pre-
inspection information regarding that site. During the site inspection, inspectors
have access to all the references and site history they need. They can collect the
inspection data, including digital photos and GPS, electronically and create site
diagrams on the form for future inspectors. The data can be uploaded to the main
Oracle database, allowing for immediate follow-up for legal action, if necessary.
The new system, which was partially funded by a Microsoft grant, is expected to
save Rhode Island DEM about $200,000 per year compared to the paper process.
Mr. Gray said that there was interest from other state agencies, but mentioned that
the EPA region was not as interested. Also, Mr. Gray suggested that as a member
of ASTSWMO, he could tap into waste management officials if EPA wanted to
promote more technology use among the States.
Source:
http://www.microsoft.com/casestudies/casestudv.aspx?casestudvid=53916
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FOREIGN
London Borough of Lewisham. Simon Berlin, Head of e-Government. (Tel: 020 8314
6000).
Since October 2003, 200 inspectors have been collecting tax data on Tablet PCs
using Microsoft Office Infopath. This automated process has increased the
proportion of their time spent in the field from 50% to 80%. Meanwhile,
processing of applications can be completed in one hour instead of 48 hours, and
costs of each inspection are reduced by up to 30 percent. Additionally, inspectors
no longer had to carry reference materials, and the automated data entry reduced
errors.
Source:
http://www.microsoft.com/casestudies/casestudv.aspx7case.studvids52258
Hong Kong Environmental Protection Department
In February 2000, inspector teams began using PDAs for inspections of 70
chemical-waste collectors and their 200 vehicles. The teams save 1.5 man-hours
per day, with an increase in productivity of 10%. This complete solution has
direct integration into the back-end database, allowing for easy report generation
and viewing, as well as reduced paper waste, data duplication, and data entry
errors.
Source: http://www.palm.com/au/solutions/studies/hk edp.html
Ministry of Public Safety and Solicitor General, Commercial Vehicle Safety and
Enforcement. British Columbia. Rob Kroeker (250-953-4024).
In the summer of 2005, the ministry conducted a pilot program using ruggedized
Tablet PCs for its 35,000 annual roadside inspections. The wireless solution
makes data accessible in minutes, compared to the two weeks it took to complete
the forms in the field, forward them to the regional office, and then forward them
to the central office for data entry.
Energy Regulator. Canada.
An unnamed Canadian energy regulator is using rugged Tablet PCs with GPS and
a GIS interface to help cut preparation time for inspections of oil wells, gas plants,
and pipelines. They no longer have to carry binders of reference documentation,
and they can collect consistent data, with ability to reference historical
information.
Source:
http://www.xploretech.com/public/Mobile CaseStudv FinalDraft()41904.pdf
UN World Food Programme, Zimbabwe.
In July and August 2002, the UN deployed inspectors with 35 PDAs to collect
more than 2,500 survey responses. The software was a custom Microsoft Survey
Application, which created standardized lists and options to ensure accuracy and
consistency. Analysis could be done in one day instead of two weeks, and even
novice inspectors were able to use the hardware.
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Source:
http://www.micro.soft.com/casestudies/cascstudv.aspx7casi>siudvid=51485
Cambridgeshire County Council, UK. (011-44-845-045-5201).
The Council uses Tablet PCs with Microsoft Infopath for health care workers
during patient visits. This allows for a team approach to patient care by creating a
single record with information sharing among the back-end systems of several
care agencies. The solution is expected to save 3 million pound by eliminating
assessment duplication, and reduce administrative costs by 850,000 pounds. The
ratio of time spent on administrative duties to assessment duties shifted from
70/30% to 30/70%.
Source:
http://www.microsoft.com/casesuidies/casestudv.aspx?cascsiu(lyid=5385<>
New Zealand Ministry for the Environment. Michael LeRoy-Dyson.
michael.leroy-dyson@mfe.govt.nz
For the past several years, the Ministry has been testing PDA use by inspectors.
Their current system produces draft letters and allows access to site history in the
field. They can also print or e-mail letters as required. However, they have found
the screen size of PDAs to be limiting. They hope to have a system that will pre-
download inspection items, record findings, integrate digital photos, print out
forms, and download real-time information. Two other "state type" agencies
currently use Tablets for similar functions, with 50 to 100 in the field. They hope
that all their field staff will be using new technologies over the next year, as they
"see the cost savings and increased efficiencies possibilities of far outweighing
any of the disadvantages or hard/software costs. He desires and sees room for
collaboration in progressing toward field technology implementation.
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EPA SURVEY RESULTS
SUMMARY OF EPA HARDWARE USAGE BY REGIONAL PROGRAM
Note: This table reflects responses collected by 12/23/05 during an internal EPA survey. Numbers reflect the number of inspectors using that technology in the field. The numbers do not
necessarily reflect sole possession of that equipment, as some equipment is shared. An 'X' reflects that use was reported, but no specific number was given. The percentages at the end
represent the percentage of programs of those that responded use that type of technology.
Region
Program
l)i\ision
Laptop
PDA
Tablet
GPS
Satellite
Digital
Voice
Recorder
Digital
Camera
Wireless/
Bluetooth
1
CAA
OES
o
0
o
0
X
o
X
0
1
RCRA
0
o
o
0
o
0
5
0
1
CWA
OES
0
0
0
0
X
0
X
0
2
CWA
3
0
0
6
4
0
15
2
2
CAA
5
0
0
0
0
0
22
0
2
RCRA
0
1
0
2
0
0
7
0
2
SDWA
5
6
0
7
1
0
5
5
2
FIFRA
0
0
1
5
1
0
6
1
2
AHERA
0
0
0
0
0
o
0
3
CWA
OECEJ
0
0
0
X
0
0
X
0
3
CAA
OECEJ
0
0
0
0
0
0
X
0
3
RCRA
OECEJ
0
0
0
X
0
0
X
0
3
SDWA
OECEJ
0
X
0
X
0
0
X
0
3
TSCA
OECEJ
0
0
0
0
0
0
X
0
3
FIFRA
OECEJ
0
0
0
0
0
0
X
0
3
EPCRA
OECEJ
0
0
0
0
0
0
X
0
3
OPA
OECEJ
0
0
0
0
0
0
X
0
3
CERCLA
OECEJ
0
0
0
0
0
0
X
0
4
CAA
OEA
1
0
0
0
1
1
1
1
4
RCRA
OEA
0
0
0
0
2
0
2
2
4
RCRA
UST
0
0
0
0
0
0
1
0
4
CERCLA
SEIMB
X
X
0
X
X
X
X
0
4
CWA
WMD/WPEB
12
0
0
12
4
0
16
12
4
SDWA
WMD/WPEB
6
0
0
6
1
0
6
6
4
RCRA
Waste
X
0
0
X
0
0
X
0
4
CWA
OEA
2
0
I 0
0
2
0
2
0
5
CAA
ARD
20
0
5
0
10
0
10
20
5
SDWA
Drinking Water
0
1
0
1
0
0
1
0
11/28/2007 113
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Region
Program
Division
Laptop
PDA
Tablet
GPS
Satellite
Digital
Voice
Recorder
Digital
Camera
Wireless/
Bluetooth
5
TSCA
WPTD/PTB
0
0
X
0
0
0
X
0
5
SDWA
UICB/Water
0
6
0
8
2
0
2
0
6
CAA
CAA 112r
0
0
0
1
0
0
3
0
6
CAA
Enforcement
3
0
0
0
0
0
5
0
6
CWA
6EN-AS
7
0
0
0
0
0
7
7
6
FIFRA
Pesticides
0
0
0
0
0
0
3
0
6
OPA
311 Oil Program
X
X
X
X
X
X
X
X
6
RCRA
Enforcement
0
0
0
3
8
0
18
0
6
RCRA
UST
0
0
0
0
0
0
1
0
6
CWA
6WQ-EM-Wetlands
0
0
0
0
0
0
8
0
7
EPCRA
X
0
0
X
0
0
X
0
7
TSCA
0
0
0
0
0
0
X
0
8
CWA
NPDES
0
0
0
6
6
0
6
0
8
RCRA
Enforcement
0
0
0
1
1
0
0
0
8
SDWA
Enforcement
0
3
0
5
0
0
5
5
9
CAA
Air
0
0
1
0
0
0
7
0
9
CWA
CWA
0
0
0
X
X
0
X
0
10
CWA
OCE
3
X
0
4
1
0
4
0
10
CAA
OCE
6
0
0
2
2
1
7
0
10
TSCA
OCE
4
0
0
4
2
0
8
0
10
FIFRA
OCE
1
0
0
1
0
0
3
0
10
EPCRA
OCE
X
X
0
X
X
0
X
0
10
OPA
OCE
X
X
0
X
X
0
X
0
10
CERCLA
OCE
2
X
0
2
2
0
2
0
HQ
TSCA
OC/AqD
0
0
0
0
0
0
0
0
HQ
FIFRA
OC/AqD
0
0
0
0
0
0
0
0
HQ
CAA
OECA/ORE/AED/MSEB
4
0
0
6
0
0
8
4
NEIC
CWA
OECA/OCEFT/NEIC
6
0
0
6
4
1
6
0
NEIC
CAA
OECA/OCEFT/NEIC
10
2
0
1
3
1
6
0
NEIC
RCRA
OECA/OCEFT/NEIC
1
0
0
1
5
1
5
0
NEIC
TSCA
OECA/OCEFT/NEIC
1
0
0
1
1
1
1
0
NEIC
EPCRA
OECA/OCEFT/NEIC
4
0
0
0
0
0
4
0
NEIC
CERCLA
OECA/OCEFT/NEIC
1
0
0
1
1
1
1
0
%Use
45.9
21.3
8.2
55.7
47.5
14.8
95.1
19.7
11/28/2007 114
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SUMMARY OF SOFTWARE USAGE BY REGION
Note: This table reflects responses collected by 12/23/05 during an internal EPA survey. A 0 response represents no special software reported.
Region
Program
Ta r«etin«
Scheduling
Research
CIS
Data
Collection
Reference
Data
Analysis
Report
Writing
T rend
Analysis
Other
Contact
1
EPA Databases
0
0
ArcGIS
0
Intranet
0
0
0
0
Steven Rapp
2
GIS/RMP/
Internet
Spreadsheet/
GIS
0
ArcGIS
Custom
Checklists/
oneNote
EPA Database
RMP
Spreadsheets
Dave
Bernstein/
Hillenbrand
3
0
0
0
0
0
0
0
0
0
0
4
Envirofacts
Spreadsheet
ArcGIS
Voice
Recognition
e-CFR
Spreadsheet
0
0
0
5
Registration Database
Database
0
Maps &
Streets
Checklists/
NotePad
Access
Database
Access VBA
0
0
0
Constantinos
Loukeris
6
Customized Database/
GIS
0
Customized Database
0
0
0
Database
0
SQL
SQL
Bob
Goodfellow/
Don Smith
7
0
0
0
0
0
0
0
0
0
0
8
0
0
0
0
Customized
Database
(UIC)
0
0
Checklists
0
0
9
OTIS
0
0
0
0
Cyber Regs
0
0
0
0
10
0
0
0
Arc IMS
0
0
0
0
0
0
Phil Wong
HQ
TSCA
Customized Database
0
Customized Database
0
0
0
0
0
0
0
Francisca
Liem
HQ
CAA
Database/
Spreadsheet
Database/
Spreadsheet
Database/
Spreadsheet
0
Database
0
Spreadsheet
Database
Contracted
0
John Connell
NEIC
CAA
Customized
Database
Customized
Database
COTS
COTS
Customized
Database/
COTS
EPA
Databases/
CyberRegs
Customized
Database
Customized
Database
Customized
Database
COTS
Valerie James
11/28/2007
115
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11/28/2007
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BETTER USE OF TECHNOLOGY IN COMPLIANCE MONITORING ACTIVITIES
FIELD ACTIVITY COMPLIANCE TECHNOLOGY STRATEGY
(FACT STRATEGY)
APPENDIX B
NUMBER OF INSPECTION PROGRAMS AND INSPECTION TYPES
11/28/2007
117
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11/28/2007
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APPENDIX B
NUMBER OF INSPECTION PROGRAMS AND INSPECTION TYPES
INSPECTION PROGRAMS AND INSPECTION TYPES
Stal
tutory and Regulatory Compliance Programs Where OC Has Some Role *
Statute
Regulatory Compliance Program
CAA
New Source Performance Standards (NSPS) and State Implementation Plans (SIP)
Prevention of Significant Deterioration (PSD) and New Source Review (NSR)
National Emission Standards for Hazardous Air Pollutants (NESHAPS) Air Toxics
Stratospheric Ozone including chlorofluorocarbons (CFCs)
Wood Heaters compliance and enforcement program
112 (r) General Duty Clause (GDC) and Risk Management Plans (RMP)
Asbestos Demolition and Renovation (D&R)
Acid Rain inspection and trading programs
CWA
National Pollutant Discharge Elimination System (NPDES)
Pretreatment of wastewater (Industrial Users)
Biosolids (POTW sludge)
Oil Pollution Act (OPA) - Section 311
Industrial Stormwater: includes Concentrated Animal Feedlots (CAFOs) and all other non-
municipal stormwater permits
Municipal Stormwater: Combined Sewer Overflows (CSOs), Sanitary Sewer Overflows
(SSOs)
Wetlands (Section 404)
Wastewater Trading Programs
RCRA
Subtitle C - Hazardous Waste
Subtitle I - Underground Storage Tanks (UST)
Recycled Oil
Mercury Containing Battery Recycling Management Act (MCBRMA)
Import/Export Program
TSCA
Core TSCA: Sections 4,5 and 8
Polychlorinated Biphenyls (PCBs)
11/28/2007 119
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Asbestos disposal
Statute
Regulatory Compliance Program
Asbestos Hazard Emergency Response Act (AHERA)
Lead Paint
State Grants management
Import/Export Program
Good Laboratory Practices (GLPs)
FIFRA
State Grants management
Worker Protection Standards (WPS)
Traditional pesticides program
Biotechnology pesticides program
Anti-microbial pesticides program
Import/Export program
Good Laboratory Practices (GLPs)
SDWA
Underground Injection Control (UIC)
Public Water Supply Supervision (PWSS)
EPCRA
Section 313 program
Non-313 program
* Does not include CERCLA statutory programs
11/28/2007
120
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EXAMPLE OF INSPECTION REPORT FORMS
4% Un»od EfNti'tnmantal FYntadi.-fi Aiprcy
ORjA Washrxyon. D C 234*3
Water Compliance Inspection Report
Sectbn A: National Data System Codino 1 i.e . PCS)
Trancaclkxn Code
pti'»mttrmator»
Name. Address or ReeixrraiHe CfiaalTit» Phone and Fan Number
Garataortod
LJ Vow LJ No
Section C: Areas Ev aluated During Inspection (Chtdt oriy thos* areas o/&uat»d)
Permit
Records Fte ports
Facility Stle Rwim
Etiiusnti'Rvcmirq w aters
Flew Measurement
Self-Maritonng Program
Compliance SchMUae
Laboratory
OperatcrB & Maintenance
Sludge Handing'Diapoiat
Frslraalrrwnl
Paiunon Prevention
Sfann Water
Ccmbned Sewer overflow
Santary Sewer Overflow
MS4
Section D: Summary of Findings'Comments
/Attach additional sheets of narrative and checklists. in dud no Sintle ^yentViotation codes ai nBCQBsarv)
SEVOocmb
~ ~~~~
~ ~~~~
n en hd q en
~ ~ODD
SEV Description
signature ol Management OA Reviewer
Apsncy.'omat Phone and Pbk Numbers
Data
Section C identifies 16 CWA areas subject to inspection
11/28/2007 121
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INSTITUTIONS
Sriiimi A: Niitima) Dutn S%*fcrui < odtnfi iLf., f*.Si
( Mlttrnti I: Tramu«.1i<>ii ( oii*•»» «»t IvL'i* VII m»fvcuu»-. « ill Iv t. > »< unk'v > llva- i ¦ an »*n> m ui IK.- thila i»i *•.'f<.'d
i Mlnnirt* .Ml: MMIfcS IVrrnil N««. I jioi ill- i.iciIhvs M'DI S |vnnu nunikM Hind ctuii* k-r in|vrmn iiuiuKm uxhciit- - |vniut rvjv J»«r i =uii|vniiniciL
i» .-s'tki .il | vimii t*it >}.>. A'.//.. cA.v >v* 'a*'i» 'i.. • w'-.
< iilnnink 12-P: Irfrpritinn llak. In%ctt lit* •.liu* »• si* nnul" m-< riv IkiIiIx I «• ilr w;>i ui.nilvJ.i\ l. nn* > i -I' I * r ~' I -(V.t>K*it'l
( nlunm IK: li*pnlj*~ »»i* lit' tub luk»vHvl<%< m ih» ivfv *i m pi'ilnii
\ U'riuriiuiiu' \«i*jti u iu inspechonwilfi PretreatmeolAudil ! Prelrealnwni Compliance iCvsrs^hb
I > I ..Olfli.i-. Z Slutte • RoedKls 'J1 Follow-ip lenwcementi
l' Diixi.-ik * Comt?dSt>,»« o.'erlfcin-sampIrM | siwm .vater-ODrelruDnco-Saniplirfl
l 11™.'in.i'ui.i-.iiu* Upi 4 comttned Sewer o«rto»-Non-Sairplno . ... . _ , _
<; MMK'jiimMii r \udii. ~ Sanaa? a«*« Cvertfcw-Sarnplin; I Sl«m Water-CorelruidcrvNorvoarnplna
I InJu-irui I wfi II i 41 Sanaay s»*« Ov«rtfcw-Ncn-Samplnq SlcG:oslrucCor> Gtjnplna
l r,„viu,i. • CAFO-samplno
M Mull int.- Iu - CAFONJi>Sair*4ing Slc Grasiruction-
N spa 2 mj samcang lnsf»:i»:n N01*" _ mpllna
0 CoiTiTliartzf Evaluaaai. cversitfit. 3 IU l*fcfvSamplm:] inspecacn < Stomi Wat^r-MS4-ta/nclir>3
P Pialieatmenl Com^iart^ Inspection 4 MJ Toiics inspscaon . st«m iVafcr-M-vi-Min-Sairolina
fl Reccmaesarc* 5 iu sampling insvccttorvMin PMimaiimnt J«L iTl,
s Comdiarca Samplng C. iu urn-Sampan? inspocacnwith Preaeaanent ~lccm tvalet-Mj4-AiMlt
7 IU Tones Aim PrelieGlmenl
Column 19: lns|»ctoi Cock> Uss orv ol it* coctes llsi#d ImIcw lodesciltw ih: Facing Tvi» llv on* ch il» coo^s t»low to (fettill* tlv lacllHs'
1 — Mumc*bcfncnitorinn
Column 72: Ouallrv Assuianc« Data Inspection Enter -3 ir Ifw irepeclDnwas inducted as Idlcwup on quality assirance sarapte results Enter N
oineivtise
Col u mns 7 3-30: mess columns are reserved ror regicnal^ defiiwd nfoimatrrfi
Section B Facllltv Data
This section it Ml^ejplanalcfv «tc*pl rot 'Otnsr Faciliv Data • *ricfi inay induse newinlcrmauonnotin tne permit or PCS ' efcoW abstracl lh» pamnent inspection flndin® not le^taos the naTatve reparl Peference a
list olattacfnents 3uch as, competed ctwcWBts taken from the NPDES Compliance Inspection Manuals am prelrealnient pjWarce (fccuirwnts ncludrg
elRutrtl data A llan sameting has been dam. Use e«lra sheets as rwcessary
-Footnote In addiBcn to the nspectton types isted at»e urtdet column 1 & a state mar»- conbnue toiBe&vs ttlo»ina wet WBatrer and CAPO inspection
IH»l until lh» state e brought irto ICIS-NPDES K: CAFO. V SSO V: CSO. W : Stoim Water & MS4 stales may also use ihe nr* wet weather. CAFO
and l.t-4 irvpeclnrc bv*i saown n cdumn 19 ot Ills lam. The EPA redone are requmd to use Ihe newwet weather CAFO. and MS4 inspection types
lei inspeclnns with an irefoctcndale iDTlN. on or alter Jtty 1.2CB6
Column 18 identifies 38 inspection types in the CWA program
11/28/2007
122
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