FINAL June 27, 2003
Unifying EPA's Small Business Activities:
A Strategy to Meet the Needs of Small Businesses
Introduction
Small Businesses are increasingly playing an important role in the U.S. economy, accounting for
99.7% of all businesses in the U.S. and 51% of private-sector output. This is a trend that we
anticipate will continue as the U.S. economy grows, with small businesses playing a lead role in
this growth in many sectors.
Because of the vast number and types of small businesses, their environmental performance is
critical to the success of EPA's mission of protecting human health and the environment.
Meeting this mission involves the actions of small businesses to address high priority
environmental issues and reduce environmental impacts to air, water, and land. To effectively
influence the operations of small businesses to achieve these environmental goals, EPA intends
to integrate a small business focus in all of our core functions.
EPA's activities related to small businesses are as diverse as EPA itself. They range from
drafting and revising regulations and guidance, to research and development, to providing
assistance in understanding environmental requirements, policies, and good environmental
practices, to offering incentives for good performance, to enforcement when needed. EPA
intends to ensure that our small business efforts meet the needs of small business operations and
that the tools we develop are clear, concise and presented in a user-friendly format.
EPA began the process of revising its 1984 Small Business Strategy with a clear mission: to
highlight policies and approaches that advance the protection of public health and the
environment in ways that are relevant to small businesses. The strategy was developed based on
a series of interviews within EPA and with focus groups, states, industry representatives, and
other interested stakeholders to better understand the current issues and obstacles facing small
businesses.
Small businesses stated that they face many challenges in their attempt to be good, responsible
environmental stewards. The biggest concern small businesses expressed to the Agency is that
they do not know what requirements apply to them, whom to contact, or how to comply. If and
when they do find out what is required, they stated that they are frequently confused by
duplicative, overlapping or conflicting requirements, many of which have been designed for
larger entities with no down-scaling options. Because small businesses fear being targeted, they
are reluctant to call environmental agencies for more information. Small businesses stated that
they need short, clear, concise, easy-to-read and easy-to-fmd information both in hardcopy and
on-line. Additionally, many small businesses believe that the cost of compliance for them
provides a disadvantage compared to the same costs applied to large entities.
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FINAL June 27, 2003
The findings of these interviews and meetings form the basis for the revised Strategy. EPA is
attempting to lessen the regulatory burden that is placed on small businesses without sacrificing
environmental protection. EPA also continues to seek and develop innovative ways to help small
businesses strengthen their environmental performance, achieve cost benefits from more efficient
use of resources, and reduce the environmental impacts in their communities.
EPA's Vision for Meeting the Needs of Small Businesses: Unifying Actions
and Coordinating Activities to Strengthen Environmental Results
The revised Strategy set forth in this document will guide EPA in future efforts to understand the
operations and needs of small businesses, to develop and implement programs and policies that
consider their effect on small businesses, and to work effectively with small businesses to
improve their environmental performance. The revised Strategy is intended to unify EPA's
diverse programs in a coordinated approach to small business issues, assistance, and the
environmental performance of small businesses. Because small businesses are local and assisted
by programs in the states, partnerships between EPA and the states are essential. This approach
will be used to reach five key goals:
• Coordinate approaches within EPA, and strive to coordinate with other federal
agencies, consistent with the goals of the President's Management Agenda for e-
government initiatives (http://www.whitehouse.gov/omb/egov/), so that small businesses
can better understand and meet their environmental responsibilities. Businesses often
face an array of different approaches and requirements for environmental, health, and safety
protection. A goal of the revised Strategy is to promote coordination among EPA Offices,
and to work with other federal agencies, to develop effective, less burdensome, and non-
duplicative programs to strengthen environmental performance by small businesses.
• Build better understanding within EPA of the diversity, needs, and most effective ways
to work with small businesses. It is important for EPA managers at all levels and their
staffs to have a clear view of the numbers and types of small businesses they regulate as well
as the challenges they face. This understanding will help EPA develop programs and
procedures that strengthen the environmental performance of small businesses in less
burdensome and more cost-effective, safer, and cleaner ways.
• Emphasize partnership and stakeholder involvement. Recognizing that resources are
shrinking, strengthen the current network within the Agency, states, tribes, and local
governments for providing information and assistance to small businesses. This same
network can be used for obtaining sufficient small business input so that EPA can better
design programs and regulations to address their current needs. Establishing diverse
partnerships will help increase EPA's credibility with and reduce mistrust by small
businesses. Explore partnerships to develop appropriate and cost-effective compliance
assistance tools and mentoring programs.
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Strengthen the environmental performance of small businesses. As EPA works to
implement current approaches or develop new approaches, we must remember that protecting
human health and the environment is our top priority. We will strive to achieve measurable
environmental improvements by working with small businesses to help them improve their
environmental performance while increasing their competitiveness, and to remove regulatory
and other barriers to better performance.
Instill the concept of environmental stewardship in small businesses. The foundation of
EPA's work in protecting the environment is a framework of regulations. This framework
has led to tremendous progress in improving environmental quality. But regulations cannot
solve all environmental problems. As a result, EPA continues to pursue voluntary programs
as opportunities to work with businesses to address environmental problems. EPA
encourages small businesses to seek pollution prevention alternatives and to go beyond
compliance, which can involve less costly solutions, preserving resources, using less
environmentally damaging materials, participating in voluntary environmental programs, and
working together with other businesses to implement business practices, products and
services that promote environmental stewardship.
Building a Strategic Framework
EPA will approach its vision by using a strategic framework designed to meet the needs of small
businesses. This involves learning more about small businesses and to use this expanded
knowledge base to unify and coordinate its programs and activities to efficiently and timely meet
the needs of small businesses. The strategic framework is structured around five types of
activities or building blocks that complement each other in building a solid foundation:
Outreach activities. Through current activities and actions, as well as new and innovative
outreach vehicles identified through this process, EPA plans to continue developing an accurate
understanding of the needs of the small business community. Outreach activities would also
allow the small business community to develop a better understanding of and relationship with
EPA.
Building a knowledge base. Through analysis and communications resulting from outreach,
EPA will expand its knowledge base about small business operations, issues and needs. In
addition to understanding the needs of small businesses, EPA should strive to better understand
the collective impact of small businesses on the environment and public health, as well as the
environmental impacts of key small business sectors. This will help EPA efficiently identify
opportunities for environmental improvement. Through this process, EPA will learn about small
businesses and small businesses will learn about EPA.
Setting priorities. This expanded knowledge base will help EPA set priorities for meeting the
needs of small businesses, while gaining environmental improvements. It will also guide the
development of regulations, policies, and other initiatives so that they are timely,
complementary, and customized to the needs of the relevant small business sectors.
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Unifying, coordinating, and innovating. An ever-present theme of this strategy will be to
unify and coordinate programs and activities by sharing information and leveraging resources
within EPA. An additional objective is to explore ways to also coordinate and leverage
resources between EPA and other federal agencies for exploring and developing innovative
approaches to assist the small business community.
Measuring and evaluating. EPA will strive to develop ways to measure and evaluate the
results of its efforts to serve the small business community, to measure performance gains, and to
achieve environmental improvements. Elements of the small business knowledge base should
serve as a baseline against which environmental improvements can be measured.
The revised Strategy focuses on four major elements aimed at unifying EPA's small business
activities: (1) Strengthen the Agency's Advocacy Roles; (2) Expand Small Business Involvement
in the Regulatory Process; (3) Develop and Evaluate Small Business Focused Compliance
Assistance Tools and Resources; and (4) Promote Programs that Reward Environmental
Leadership. These elements directly support EPA's vision for meeting the needs of small
businesses.
Strengthen the Agency's Small Business Advocacy Roles
To appropriately and adequately meet the needs of small businesses, EPA 's policy is to ensure
that those needs are represented and supported throughout the Agency. EPA plans to strengthen
the advocacy role of the Small Business Division by educating EPA management and staff on
small business issues, increasing our regulatory involvement and reporting efforts, expanding
our outreach programs, and addressing barriers to better environmental performance.
• Educating and training of EPA staff. Foster a sense of responsibility within the Agency by
educating and training EPA management and staff as well as working with state and local
counterparts to increase awareness of small business needs and mechanisms for
strengthening small business environmental performance.
• Reporting and information sharing. Develop and coordinate reporting of EPA's efforts
and initiatives to serve the small business community, culminating in a Small Business and
the Environment Annual Report. Led by the Small Business Ombudsman, reporting and
information sharing will increase the awareness of small business needs within EPA and will
unveil potential future opportunities to work with small businesses.
• Strategic planning and regulatory opportunities. Integrate small business issues into the
Agency strategic planning process, by creating opportunities for small businesses to present
their concerns to EPA and for EPA to address and reduce performance barriers for small
businesses in general, or for different types of small businesses. Additionally, increase active
participation by the Small Business Division and other offices in the regulatory development
process representing small business issues and concerns within the Agency.
• Working with states and the public. Strengthen partnerships with states, tribes, and trade
associations. Develop opportunities for input from the small business community on the
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regulatory process and other programs and policies. Also, increase their awareness of the
regulatory process and their overall environmental awareness.
• Creating and invigorating networks. Develop and convene small business forums and a
national summit that will serve as networking opportunities on a national level and raise the
level of awareness of and about the small business community.
• Marketing and outreach. Coordinate and expand marketing and outreach efforts to
enhance awareness of the nationwide Small Business Assistance Program and services
available to small businesses, technical assistance providers from all involved agencies, and
the public at large.
Expand Small Business Involvement in the Regulatory Process
EPA plans to continue expanding current mechanisms and developing new approaches that
allow small businesses to become more involved in the regulatory process. This will involve
enhancing the culture at EPA and providing the ability for small businesses to become more
engaged in the process.
• Small business friendly culture. Foster and encourage a more small business friendly
culture within EPA, which is intended to improve relationships with small businesses and
increase opportunities for meaningful interactions.
• Involvement in the regulatory processes. Encourage involvement of small businesses in
various stages of the rule development process, including pre-rule development. This may
involve more interaction with trade associations and other small business entities, developing
plain language factsheets on proposed rules, as well as factsheets, compliance guides and
checklists on final rules, and enhancing opportunities for small businesses to comment on
proposed regulations.
• Evaluation and assessment. During the implementation of a rule, evaluate compliance
assistance tools that could be used to address the unique needs of small businesses. Assess
the programs and projects that best serve the small business community. Continually strive
to increase the effectiveness of the other programs and projects to a comparable level.
• Innovative approaches. Promote the use of alternative, less burdensome permitting
approaches for small businesses through the rulemaking process to the extent possible within
the statutory requirements and provide assistance to promote compliance with these
requirements. Many small businesses are good at thinking outside the box, finding
innovative approaches to problems and learning how to do "more with less." EPA will be
able to capitalize on these characteristics and work with small businesses to create
innovative, less burdensome approaches for regulations.
• Regulatory Flexibility Act (RFA) process. Facilitate the involvement of small businesses
in the RFA process by increasing current interaction with trade associations and other small
business entities and informing them of opportunities to participate.
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Evaluate and Develop Compliance Assistance Tools and Resources
In today's economy, small businesses face many regulatory challenges and requirements. EPA
will assist small businesses to meet these challenges by evaluating current tools and resources
considering their effectiveness, by developing and adapting innovative compliance assistance
tools and resources, and by developing assistance tools that are tailored to meet the needs of
different types of small businesses. EPA will also strive to develop tools to measure performance
gains. These efforts will be used to set priorities for developing mentoring programs, web-based
expert systems where appropriate and possible, plain language factsheets, and compliance
guides.
• Appropriate use of resources. EPA continues to place efforts and resources into assisting
small businesses in ways that are beneficial to both small businesses and the environment.
Like small businesses, EPA believes it is important to continue to find innovative ways to
utilize its resources in an efficient manner and coordinate its activities to capitalize on current
work and prevent duplication of efforts within EPA.
• Innovative tools. Continue to provide small businesses proven resources such as plain-
language compliance guides, checklists, and factsheets, while also developing innovative
approaches to assist more small businesses and increase their involvement in the
development of innovative tools.
• Technology-based tools and resources. Due to the nature of small businesses, continue to
provide hard-copy tools to aid in compliance assistance, while continuing to develop simple,
on-line, interactive expert systems, clearinghouses, web-based tools, and user-friendly
software, as appropriate and possible, to help small businesses with compliance and reporting
requirements.
• Stewardship and prevention approaches. Formulate policies that encourage small
business environmental compliance, environmental stewardship beyond compliance, and
adoption of pollution prevention alternatives.
• Mentoring and other non-traditional programs. Use non-traditional delivery methods to
reach small businesses such as mentoring programs by EPA and other agencies, by trade
associations, and business-to-business.
Promote Programs that Reward Environmental Leadership
Rewarding small businesses that take leadership roles and developing innovative approaches to
environmental regulations and non-regulatory environmental programs will serve as a catalyst
to other small businesses to become more environmentally conscious. There are many
opportunities to adapt and promote current EPA programs to the small business community.
Additionally, there may be opportunities to develop new programs that are specially tailored
towards small businesses.
• Environmental management systems. Expand the development and implementation of
environmental management systems by small businesses. EPA encourages the use of
environmental management systems through resources and guides it has developed.
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Recognition programs. Reward small businesses that go beyond compliance; EPA Program
and Regional Offices for outreach, education, and compliance assistance efforts for small
businesses; and programs external to EPA that assist small businesses.
Pollution prevention. Identify and promote cost-effective pollution prevention practices
that can be implemented by small businesses. Develop partnerships that promote cleaner,
cheaper, and smarter business practices.
Voluntary programs. Develop strategies to encourage small businesses to go beyond
compliance by participating in EPA's voluntary programs.
Research and development. Expand the reach of the Small Business Innovation Research
(SBIR) and the Environmental Technology Verification (ETV) Programs through the
development of partnerships with existing state and federally funded technical assistance
programs.
Meeting Future Challenges
The Strategy and its associated implementation plan will occur within the context of a changing
world. EPA will need to identify and address the economic, social, and political trends that
affect both small businesses and EPA while adapting our approaches to maintain effectiveness.
These trends will include traditional challenges such as evaluating existing tools, finding the
most effective techniques, and providing assistance with fewer resources. These trends will also
include new challenges such as homeland security and changing threats to the environment. For
the Strategy to be successful in continuing to meet the needs of small business, it needs to be
regularly measured and evaluated.
Christine Todd Whitman
Administrator
U.S. Environmental Protection Agency
Date:
JUN 27 2003
EPA Small Business Division
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