&EPA
United States
Environmental Protection
Agency
______ ,_
Office Of Policy
{2128)
Washington DC 20460
Region 2
DEPP
New York. 10007-1866
Inspiring Performance:
The Government-Industry Team
Approach To Improving
Environmental Compliance
of
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Todd Whitman Department of Environmental Protection Kabert C, Shiftit, 11,
Cuj7iJ7ij.va;jo-j5cr
J999
Dear Interested Party:
pleased to transmit to you the final report of the New Jersey Chemical
Industry Project's Compliance Assistance Pilot. This two year pilot benefited from a
unique collaboration of industry, government and trade associations who sought to
improve existing compliance assistance resources.
As we are All quickly realizing, compliaoce assistance is an integral part of an
effective enforcement program. As we in New Jersey have seen, many companies today
try diligently to comply with the regulations, but have difficulty due to lack of resources
or technical expertise or simply because there ate so many regulations that apply to them,
Therefore, education has become an even more critical component of our jobs.
The New Jersey Chemical Industry Project was spearheaded by SPA'S Office of
Policy. The Project team included members of New Jersey's chemical industries and
DEP permitting aปd enforcement representatives. After bnalnstorming at team meetings,.
the Project team decided to implement four pilots in New Jerseyr effluent trading;,
hazardous waste exchange across facilities; flexible track for companies with superior
envfrontnental performance; and compEiance assistance,
For the compliance assistance pilot, EPA, DEP3 industry and trade associations
worked together over a two year period to assess existing compliance assistance resources,
survey the regulated community as to their compliance assistance needs, and develop and
distribute a unique package of Compliance Assistance Materials. These materials are on
the department's web page at www.state.nj .us/dcp/enforcement, At the conclusion of the
pilot, the team wrote a report to summarize the work they had done, but more importantly,
to highlight the lessons they had ^earned. Their goal in writing the report was to enable
other states and other DEP programs, to benefit from the countless hours they invested in
this project. Appended to the report are the survey findings^ on whicli tlie compllanoe
assistance materials were based.
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If you have any questions about this project,, please call Peg Haitim at (609) 9S4-
1767, Chuck McCarty at (609) 292-5565 or Catherine Tunis of USEPA at (202) 260-
269ฎ.
Attachment (I)
C: Marlen Dooley, Assistant Commissioner
Catherine Tunis, U5EPA, Office of Policy^ Planning and Evaluation
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INSPIRING PERFORMANCE:
The Government-Industry Team Approach
to Improving Environmental Compliance
Lessons from the New Jersey Chemical Industry Project-
Compliance Assistance Team
Final Report
May 1999
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PREFACE
The U.S. Environmental Protection Agency's (EPA) Office of Policy is working with the
New Jersey Department of Environmental Protection (NJ DEP), EPA Region 2, and a Stakeholder
group made up of industry, environmental group, union, and community representatives on a project
involving the batch chemical industry in New Jersey. This project, named the New Jersey Chemical
Industry Project, is an effort to assess current environmental protection strategies on a sector basis
and develop better approaches.
The batch chemical industry in New Jersey was identified as a good candidate to complement
the Office of Policy's work with a large continuous process chemical manufacturer. Several
members of the Chemical Operations Team of the President's Council on Sustainable Development
noted that many regulations seem to be written with large continuous process manufacturers in mind
and urged EPA to look at the special challenges in complying with these regulations faced by batch
chemical manufacturers. New Jersey is one of the top states for batch chemical manufacturing, and
the industry was willing to work with EPA to look for innovative ways to achieve enhanced, cost
effective environmental performance.
The New Jersey Proj ect started by asking what inspires batch chemical companies to achieve-
-or keeps them from achievingbetter environmental performance. From this information, the
Stakeholder group developed a list of 45 issues for possible pilot projects to test new environmental
protection strategies. The Compliance Assistance Pilot was developed as one of four pilot projects
selected by the Stakeholder group. The other pilots selected by the group include: effluent limit
trading between indirect dischargers, materials recycling, and flexible track for good environmental
performers.
A subset of the Stakeholder group formed the Pilot Team for the Compliance Assistance
Pilot, along with several additional facility and regulatory agency representatives with specific
expertise in compliance issues who were invited to participate. The Pilot Team developed an
extensive set of Compliance Assistance Materials (CAM) that includes plain language descriptions
for many of the NJ state environmental regulations and agency contact information, descriptions of
ongoing NJ DEP compliance assistance activities, applicability flowcharts for six key regulations,
and an extensive bibliography of compliance assistance resources published by NJ DEP, other
regulatory agencies and trade associations. The pilot culminated by posting the CAM on NJ DEP's
web site and in sponsoring two one-day workshops in which NJ DEP and industry experts presented
information on key compliance issues for the six key regulations. This report documents the lessons
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learned from this pilot project. We hope that this information will be helpful to others seeking to
establish compliance assistance efforts in other sectors or states.
Print copies of the CAM can be obtained through:
Chuck McCarty
New Jersey Department of Environmental Protection
Small Business Assistance Program
401 East State Street (PO Box 423)
3rd Floor, East Wing
Trenton, NJ 08625
telephone: 609-292-3600
These materials can also be viewed on NJ DEP's web site at:
http://www.state.nj.us/dep/enforcement/home.htm
The New Jersey Chemical Industry Project has prepared reports on the work of the Effluent
Trading Pilot Team and the Materials Recycling Pilot Team. The Effluent Trading report describes
our experience in implementing the first-ever trade of local pretreatment limits among indirect
dischargers and provides guidance on how trading of local limits can be established at other Publicly
Owned Treatment Works. This report is titled Sharing the Load: Effluent Trading for Indirect
Dischargers. EPA 231-R-98-003, May 1998.
The Materials Recycling report, titled Promoting Chemical Recycling: Resource
Conservation in Chemical Manufacturing, EPA 231-R-99-001, May 1999, describes five typical
batch chemical process scenarios that present opportunities to recycle materials, explains how the
hazardous waste regulations would apply to each scenario, and documents the environmental and
economic benefits that have been realized to date by the one scenario that has already been
implemented. The scenarios and regulatory interpretations may be helpful to other facilities with
similar processes that wish to improve their materials reuse and recycling, including facilities outside
of New Jersey. Because the New Jersey hazardous waste rules are the same as the federal rules, the
information in this report may be useful to facilities in other states where the Federal rules apply.
The Flexible Track Pilot Team has been working with EPA and NJ DEP to develop a
program that provides incentives to facilities that are good environmental performers to maintain and
improve that performance. The program is expected to be announced by NJ DEP in the summer of
1999, with the first applications to be accepted in the fall. The Team is also working with NJ DEP
and EPA to develop future enhancements for the Flexible Track program.
11
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For more information about the New Jersey Chemical Industry Project, the Compliance
Assistance Pilot, the Effluent Trading Pilot, the Materials Recycling Pilot, the Flexible Track Pilot,
or additional copies of this or other New Jersey Chemical Industry Project reports, contact:
Catherine S. Tunis
EPA Office of Policy
401 M Street SW (2128)
Washington, DC 20460
telephone: 202-260-2698
tunis.catherine@epamail.epa.gov
in
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ACKNOWLEDGMENTS
This project benefitted from the dedication, enthusiasm, creativity, and technical knowledge
of the participants on the Compliance Assistance Pilot Team of the New Jersey Chemical Industry
Project. Through the efforts of the Pilot Team, the expertise and perspectives of both industry and
regulatory agencies have been incorporated throughout the definition, implementation, and
documentation of this pilot project. The Team would like to extend a special "thank you" to the
many managers and staff at NJ DEP, NJ Department of Treasury, and EPA Region 2 who
contributed time reviewing the Compliance Assistance Materials and presenting the workshops.
This report was drafted by Sarah Holtz, Joshua Levine, and Eric Ruder of Industrial
Economics, Incorporated with a considerable amount of guidance and input from many of the Pilot
Team members representing regulatory agencies and industry. Specifically, the following Pilot
Team members contributed their ideas and suggestions: Barry Bochner, Fabricolor, Inc.; Alan
Bogard, Infineum USA L.P.; Joseph Gentile, CasChem; Peg Hanna, NJ DEP Office of Enforcement
and Compliance; Scot Mackey, Chemical Industry Council of NJ; Chuck McCarty, NJ DEP Small
Business Assistance Program; Barbara Mullis, TRICON Colors; Steve Scher, Scher Chemicals; and
Jim Sinclair, NJ Business and Industry Association. We would also like to thank the EPA staff
members who contributed to this report, especially those from the Office of Policy, Industry Sector
Policy Division; Office of the Small Business Ombudsman; Office of Enforcement and Compliance
Assurance, Chemical, Commercial Services, and Municipal Division; and Region 2, Division of
Enforcement and Compliance Assistance. The success of this pilot project is a result of valuable
contributions from the entire Pilot Team. A complete list of the Pilot Team members can be found
on page v.
IV
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NEW JERSEY CHEMICAL INDUSTRY PROJECT
THE COMPLIANCE ASSISTANCE PILOT TEAM
New Jersey Chemical Industry Project Stakeholders
Barry Bochner
Alan Bogard
Peter Downing
Sherry Edwards
Joseph W. Gentile
Peter Lederman
Jehuda Menczel
Barbara Mullis
Richard Rosera
Steve Scher
Catherine Tunis
Trish Zita
Additional Participants
Emily Chow
Kent Davis
Tom Detweiler
Gail French
Michele Glassburg
Peg Hanna
Sarah Henricks Holtz
Carl Koch
Joshua Levine
Ron Lockwood
Scot Mackey
Kathleen Malone
Chuck McCarty
Arnold Medbery
Cheryl Morton
Eric Ruder
Jim Sinclair
Marcus Zobrist
Fabricolor, Inc.
Infmeum USA L.P.
Reach Associates
formerly, Synthetic Organic Chemical Manufacturers Association
currently at American Meat Insitute
CasChem, Inc.
New Jersey Institute of Technology
US EPA, Region 2
TRICON Colors
formerly, Pilot Chemical Company
Scher Chemicals
US EPA, Office of Policy
Chemical Industry Council/NJ
US EPA, Office of Enforcement and Compliance Assurance
NJ DEP, Office of Enforcement and Compliance
formerly, Chemical Industry Council/NJ
Industrial Economics, Incorporated
New Jersey Business and Industry Association
NJ DEP, Office of Enforcement and Compliance
Industrial Economics, Incorporated
US EPA, Office of Policy
Industrial Economics, Incorporated
US EPA, Region 2
Chemical Industry Council/NJ
US EPA, Region 2
NJ DEP, Small Business Assistance Program
US EPA, Office of the Small Business Ombudsman
formerly, Synthetic Organic Chemical Manufacturers Association
currently at Chemical Manufacturers Association
Industrial Economics, Incorporated
New Jersey Business and Industry Association
formerly, US EPA, Region 2
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TABLE OF CONTENTS
PREFACE i
ACKNOWLEDGMENTS iv
COMPLIANCE ASSISTANCE PILOT TEAM v
INTRODUCTION CHAPTER 1
Lessons From Pilot Team Activities 1-2
Benefits From Pilot Team Efforts 1-3
Future Activities 1-5
Structure of the Report 1-5
PROCESS AND PRODUCTS OF THE
COMPLIANCE ASSISTANCE PILOT PROJECT CHAPTER 2
Project Initiation 2-1
Define Pilot Team and Objectives 2-3
Research Industry Compliance Assistance Needs and
Existing Resources; Define the Scope of Pilot Activities 2-5
Develop Compliance Assistance Materials 2-8
Conduct Outreach Activities for Compliance Assistance Materials 2-10
FUTURE COMPLIANCE ASSISTANCE ACTIVITIES AND A
CONTINUING PARTNERSHIP BETWEEN NJ DEP AND INDUSTRY CHAPTER 3
Sustained Compliance Assistance Activities 3-1
LESSONS LEARNED: PREPARING COMPLIANCE ASSISTANCE
MATERIALS THROUGH A MULTI-STAKEHOLDER PROCESS CHAPTER 4
General Lessons 4-1
Getting Started 4-2
Process 4-4
Identifying and Developing Compliance Assistance Materials 4-4
Compliance Assistance Workshops 4-6
VI
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APPENDICES
TABLE OF CONTENTS (continued)
Appendix A:
Appendix B:
Appendix C:
Appendix D:
LIST OF EXHIBITS
Exhibit 2-1:
Exhibit 2-2:
Exhibit 3-1:
Summary of Available Information on Compliance Assistance Needs
Compliance Assistance Workshop Agenda
Flyer for the Compliance Assistance Pilot
Summary of Compliance Assistance Workshop Evaluation Forms
Timeline for Compliance Assistance Pilot Project 2-2
Applicability Flowchart - NJ Community Right to Know Survey 2-9
Regulations Suggested for Additional Compliance Assistance
Materials 3-3
vn
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INTRODUCTION CHAPTER 1
The goal of the Compliance Assistance Pilot was to facilitate compliance by providing
improved compliance assistance to New Jersey's batch chemical industry. This was achieved by
developing types of compliance assistance that would be most helpful to industry and have the
greatest potential to improve a facility's ability to meet its regulatory requirements. To achieve this
goal, the Pilot Team prepared a set of Compliance Assistance Materials (CAM), which includes the
following:
A list of 32 New Jersey environmental regulations.
Plain language summaries of 20 New Jersey environmental regulations.
Detailed applicability flowcharts for six regulations that can help determine how the
regulations apply to a facility.
Summaries of NJ DEP's compliance assistance programs and information on how
to take advantage of them, and
Information on how to obtain additional New Jersey and federal compliance
assistance resources, such as training materials and regulatory guides.
The CAM focuses on New Jersey regulations in an effort to complement EPA's Chemical
Industry Compliance Assistance Center, ChemAlliance, which is designed to help small chemical
manufacturing firms comply with federal rules. While the team chose to address topics that are
particularly relevant to the batch chemical industry, information in the CAM is not limited to batch
chemical facilities and should also prove useful to many other industries.
Once the Pilot Team finalized the CAM, it undertook several outreach activities to increase
industry's access to these materials. This included putting the CAM on the NJ DEP web site and
organizing two compliance assistance workshops.
The Pilot Team believes that the team approach used to develop the CAM and conduct
outreach activities was particularly valuable because it allowed efforts to be targeted toward
compliance assistance activities that industry finds most useful. The team approach also leveraged
agency resources available for developing the CAM and implementing outreach activities.
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The purpose of this report is to document the activities of the Compliance Assistance Pilot
in an effort to help sustain these activities in New Jersey and to encourage the transfer of this
experience to other states. In this chapter we summarize key findings from this pilot effort, including
lessons learned from pilot activities and potential benefits of the pilot. We also describe an ongoing
partnership between industry and NJ DEP aimed at continuing to help facilities improve their
environmental compliance.
LESSONS FROM PILOT TEAM ACTIVITIES
We have identified key lessons from each phase of the Pilot Team's efforts, including
defining the scope of the work, identifying and preparing the CAM, and conducting outreach
activities to publicize the CAM. We hope that these lessons will help guide future compliance
assistance efforts. These lessons are listed below and described in greater detail in Chapter 4 of this
report.
General Lessons
Lesson 1. Government and industry working together cooperatively can achieve an enhanced
outcome.
Lesson 2. Obtain agency understanding and commitment that resources will be provided to
sustain the compliance assistance activities initiated through this type of effort.
Lesson 3. Develop guidelines for open communication.
Getting Started
Lesson 4. Ensure that the project team has representation from all relevant parties and
maintains the flexibility to adjust the mix of participants to meet the demands of
specific project activities, if necessary.
Lesson 5. Recruiting a larger Pilot Team can reduce the time commitment for individual
members.
Lesson 6. Gain up-front commitment from team members that they will see the project through
to completion.
Lesson 7. Allocate sufficient resources for managing a multi-stakeholder process.
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Lesson 8. Gain full support of managers at the agencies implementing the regulations.
Process
Lesson 9. Communicate regularly and establish tasks and responsibilities.
Lesson 10. Consider alternative configurations of team task assignments.
Identifying and Developing Compliance Assistance Materials
Lesson 11. Research other compliance assistance efforts in order to identify potential activities
and products that fill gaps in, rather than duplicate, current resources.
Lesson 12. Identify and use an efficient method for determining what forms of compliance
assistance activities are most useful.
Lesson 13. Select compliance assistance activities according to available resources.
Lesson 14. Allocate sufficient time to prepare and finalize compliance assistance materials.
Lesson 15. Distribute workload across Pilot Team members.
Compliance Assistance Workshops
Lesson 16. When developing compliance assistance workshops, strike a balance between depth
and breadth according to facility needs and existing or planned compliance assistance
activities.
BENEFITS FROM PILOT TEAM EFFORTS
Pilot Team members and workshop participants have commented that they benefitted
significantly from Pilot Team activities. Pilot Team members have benefitted from the cooperative
nature of this effort that has created a positive, constructive relationship among representatives from
industry, NJ DEP, and EPA. Workshop participants have benefitted from increased accessibility to
compliance assistance information. We expect that Pilot Team activities will yield additional
benefits that can not yet be quantified, such as increased compliance with environmental regulations.
We describe both actual and potential benefits below.
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Actual Benefits
Enhanced communication and cooperation between industry and regulators.
Government and industry representatives worked jointly to define objectives, select
and prepare compliance assistance materials, and organize and participate in
compliance assistance workshops. This cooperative effort has helped create a
positive atmosphere in which industry representatives and NJ DEP can work together
to increase environmental compliance.
More efficient and effective delivery of compliance assistance. By working
directly with industry and trade association representatives in developing compliance
assistance tools, NJ DEP can better target its efforts to meet the most pressing needs
in terms of both topics to be addressed by and formats of compliance assistance. The
direct involvement of industry in developing the CAM and organizing and presenting
the workshops also meant that effective compliance assistance tools could be
developed with less agency resources.
Increased access to compliance assistance information and regulatory staff. In
the past, regulatory agencies did not appear to be a primary source of compliance
assistance. This proj ect worked to change that in New Jersey. The proj ect provided
workshop participants with the CAM, a list of NJ DEP contacts, and an opportunity
to hear NJ DEP staff and industry experts discuss keys to compliance. The Pilot
Team increased access to the CAM by posting it on the NJ DEP web site and
announcing it through flyers and notices in trade association newsletters.
Potential Benefits
Peace of mind for industry. With a greater understanding of environmental
regulatory requirements, facilities may have less concern over the potential to be
unknowingly out of compliance with some of the many environmental requirements
that apply to them.
Economic benefits for industry. With increased access to compliance assistance
information, industry may need fewer staff resources to track regulatory requirements
and comply with regulations. Also, to the extent that the CAM and compliance
assistance workshops lead to a higher degree of compliance, a facility may be subject
to fewer fines.
Enhanced environmental compliance. The Pilot Team anticipates that the
increased access to compliance assistance materials and access to NJ DEP staff may
improve environmental compliance. This will benefit the environment and the public
if the improved compliance results in fewer releases to the environment.
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FUTURE ACTIVITIES
The completion of the CAM and the compliance assistance workshops represents the
culmination of the Compliance Assistance Pilot. However, another important goal of the pilot is to
create a framework for sustained cooperation between NJ DEP and industry in developing improved
tools for compliance assistance.
Pursuant to the Pilot Team's recommendations, NJ DEP and industry representatives have
formed an ongoing partnership, tentatively called the Compliance Assistance Working Group. A
number of industry representatives on the Pilot Team and participants in the compliance assistance
workshops have volunteered to participate in the Working Group along with NJ DEP staff. Industry,
NJ DEP, and trade association representatives are currently discussing the specific activities of the
group.
The goal of this continued partnership between government and industry representatives is
to maintain the CAM and evaluate the need for new compliance assistance products. Keeping the
information presented in the CAM up to date is key to ensuring that this information continues to
be a valuable resource for facilities and a valuable reference for NJ DEP. The Working Group may
also develop new compliance assistance tools to fill specific needs identified through feedback from
the regulated community. This could include such activities as identifying additional priority
regulations for developing applicability flowcharts, conducting additional compliance assistance
workshops as new materials are developed or as significant regulatory changes occur, and sending
periodic mailings of regulatory and bibliographic updates to industry.
STRUCTURE OF THE REPORT
The following chapters of this report document the activities of the Pilot Team, discuss
potential future compliance assistance activities, and highlight the lessons learned from this effort
to improve access to compliance assistance information. Chapter 2 describes the specific activities
undertaken by the Pilot Team, including preparing the CAM and conducting outreach efforts.
Chapter 3 describes future compliance assistance activities based on the continuing partnership
between NJ DEP and industry. In Chapter 4, we present key lessons learned from the Pilot Team's
efforts.
Four appendices to this report provide additional details on the Compliance Assistance Pilot
that may be useful for implementing similar efforts in other states or for other jurisdictions. These
include the agenda for the compliance assistance workshops, a flyer providing an overview of Pilot
Team activities, and a summary of the evaluation forms submitted at the workshops. We also
include a summary of research on compliance assistance needs conducted through this pilot project,
which is a compilation of compliance assistance needs identified by the Chemical Manufacturers
Association, EPA's Office of Enforcement and Compliance Assurance, and industry participants in
this pilot project and the overall New Jersey Chemical Industry Project.
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PROCESS AND PRODUCTS OF THE
COMPLIANCE ASSISTANCE PILOT PROJECT CHAPTER 2
The Compliance Assistance Pilot was launched in October 1996. Exhibit 2-1 charts the
progress of this effort over a two and one-half year timeline. During this period, the Pilot Team
defined the scope of its activities, identified specific industry needs for compliance assistance,
developed compliance assistance materials to meet these needs, and conducted outreach activities
within the regulated community to help facilities take advantage of these new materials. The Pilot
Team's work culminated in organizing two compliance assistance workshops that were attended by
more than 100 facility representatives. This chapter describes the specific activities undertaken by
the Pilot Team. Our hope in presenting this information is that others who wish to undertake similar
efforts to provide more effective compliance assistance can benefit from our experiences.
| 1. Project Initiation (October 1996) |
Compliance assistance was selected as one of four pilot projects for the NJCIP at its second
Stakeholder meeting, held in October 1996. During this meeting, the Stakeholders reviewed a list
of 45 issues they had identified concerning improvements in approaches to environmental regulation
of the batch chemical industry in New Jersey. Two of these issues, which involved seeking better
approaches to providing compliance assistance in the form of a compliance guidebook and
notification of regulatory changes, were combined into a single project and selected as a pilot by the
Stakeholders.
In choosing this pilot project, Stakeholders concluded that the primary barrier to compliance
was not the amount of information available for companies, but effective presentation and
dissemination of this information. A number of facility representatives felt that compliance
information was difficult to find and was sometimes prohibitively expensive to obtain. In addition,
they emphasized the need for simplified explanations of regulations. They suggested a two-fold
focus for the pilot project: (i) support and augment ongoing compliance initiatives, and (ii) devise
ways in which compliance information could be made more readily available for all companies.
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Exhibit 2-1
Timeline for Compliance Assistance Pilot Project
Activities
| 1 9 9 6 |
1997
1998
to
to
1. Project Initiation
2. Define Pilot Team and
Objectives
3. Research Industry
Compliance Assistance
Needs and Existing
Resources; Define the
Scope of Pilot Activities
4. Develop Compliance
Assistance Materials
5. Conduct Outreach
Activities for
Compliance Assistance
Materials
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2. Define Pilot Team and Objectives (October 1996-January 1997)
Pilot Team
The initial Pilot Team was comprised of representatives from EPA, NJ DEP, industrial
facilities, academia, and trade associations. In an effort to have all interests fully represented on the
Pilot Team and to ensure that the team would have the necessary expertise, additional representatives
from EPA's Office of Enforcement and Compliance Assurance (OECA), Office of the Small
Business Ombudsman and Region 2 Division of Enforcement and Compliance Assistance, as well
as NJ DEP's Office of Enforcement and Compliance and Small Business Assistance Program were
invited to join the project team.
Many of these new team members provided insight into current compliance assistance efforts
that were being undertaken in their respective organizations. For example, EPA's OECA had already
developed virtual compliance assistance centers on the Internet for four sectors; printing, automotive
service, metal finishing, and agriculture. They were also in the process of developing a compliance
assistance center for the chemical industry. In general, these centers are intended to assist small
companies in these sectors in the following ways:
Help companies understand regulations;
Identify where companies are having problems complying; and
Encourage companies to undertake pollution prevention activities.
Among the original members of the Pilot Team were representatives from two trade
associations the Chemical Industry Council of New Jersey (CIC/NJ) and the Synthetic Organic
Chemical Manufacturers Association (SOCMA) - who made valuable contributions to the pilot by
drawing from their experiences working with members to offer suggestions for the types of
compliance assistance that would be most helpful. Representatives from a third trade association,
the New Jersey Business and Industry Association (NJBIA) were subsequently invited to join the
Pilot Team and shared their expertise in organizing workshops. Representatives from all three trade
associations also helped identify additional company representatives interested in supporting specific
aspects of the pilot.
Unlike the Stakeholder group for the full NJCIP, the Pilot Team did not include
representatives from community or environmental groups. Non-governmental representatives from
the Stakeholder group did not choose to participate on this particular pilot project, and their
participation was not critical to the success of this pilot given its focus on developing compliance
assistance materials for industry; this did not pose any controversial issues.
In addition, EPA provided funding for contractor support. The contractor supported the pilot
in many different facets such as coordinating, planning, helping to facilitate and summarizing
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conference calls and meetings. In this way, EPA's contractor played an important role in sustaining
communication among Pilot Team members and in documenting the team's activities. Contractor
staff also compiled and analyzed information on compliance assistance, prepared drafts of materials
developed by the Pilot Team and formatted them to be posted on the NJ DEP web site. Without
contractor support, other members of the Pilot Team would have had to perform these tasks.
Overall, we were successful in establishing a Pilot Team with members that fully represented
the relevant constituencies for this compliance assistance initiative agencies that establish
environmental regulations, companies (both large and small) that need to comply with them, and
trade groups that assist industry. In forming the team, we obtained up-front commitments from
participants to see the pilot project through to completion. However, due to the length of the project,
there was some attrition of the original team members mostly related to changes in job status.
Approximately half of the original 13 Pilot Team members remained active in the pilot for the full
two and one-half years. We recruited replacements for team members, as well as some additional
participants to assist when the work load was particularly heavy or when special expertise was
needed.
The time commitment that each team member made to the pilot varied. On average the level
of effort for core team members who participated in the full range of pilot activities was
approximately one day per month over the duration of the pilot. There were 12 core team members,
including six from industry and trade associations, two from NJ DEP, three from EPA Headquarters
(Office of Policy and Office of the Small Business Ombudsman), and one from EPA Region 2. In
addition, three staff members from EPA's contractor each worked an average of five days per month
on the pilot project. There were times of increased activity when the core Pilot Team needed
additional help. For example, in organizing and presenting two compliance assistance workshops,
the team recruited six additional industry representatives and eight state regulatory staff (seven from
NJ DEP and one from the NJ Department of Transportation) to help prepare and present material.
Summing up the contributions of all Pilot Team members over the more than two-year life of the
pilot, the total effort was approximately the equivalent of four person-years, or an average of just
under two full time staff per year. In planning future efforts, it is important to keep in mind that the
level of effort required of any one individual can be moderated by the number of team members
recruited to help in any given activity.
Project Objectives
To help structure the pilot and maintain our focus, the team developed a "Project Plan" that
defined the project and outlined its goals, objectives, and milestones. We determined that the pilot
project would attempt to improve environmental compliance within the batch chemical industry by
identifying those forms of compliance assistance that are most beneficial to the industry and have
the greatest potential for helping companies improve their environmental performance. The goal of
this project is to make recommendations for improving the compliance assistance available to the
batch chemical industry in New Jersey and, if possible, provide specific tools to help facilities in this
industry better understand and meet their environmental requirements.
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3. Research Industry Compliance Assistance Needs and Existing
Resources; Define the Scope of Pilot Activities
(November 1996-July 1997)
Research Compliance Assistance Needs
The next phase of the pilot involved determining how the team could make the most valuable
contribution to meeting industry's needs for compliance assistance. We recognized that the universe
of possible activities was immense and that our resources were not. To help us focus our work, some
NJCIP Stakeholder and Tracker facilities provided information about their current commercial
compliance assistance resources and regulations for which they needed the most assistance.1 In
addition, SOCMA and CIC/NJ sought similar information from their members. Specific questions
asked of these facilities included:
What compliance assistance tools did they currently use (both government-sponsored
and commercial services)?
What regulations were covered by the compliance services they listed?
What tools were offered by trade associations?
What additional compliance assistance materials would they like to see in the future?
and
What format would be most useful for presenting these materials?
The project team also considered information on compliance assistance needs from two
additional sources - the results of a 1994 Chemical Manufacturers Association's (CMA) survey of
its members designed to identify the regulations for which companies most needed compliance
assistance; and discussions with OECA staff about their understanding of the needs for compliance
assistance in the chemical industry, which is based on informal contact with representatives from
chemical companies and trade associations. Information form these contacts has helped OECA in
designing its Internet-based national chemical industry compliance assistance center, ChemAlliance,
which is available at:
http://www.chemalliance.org
Based on the information available from CMA and OECA, plus the results of our own
efforts, we concluded that chemical companies have difficulty understanding many NJ regulations
and that complying with these regulations is very time-intensive, especially for smaller companies
1 In addition to Stakeholder facilities, the NJCIP maintains contact with approximately 20 Tracker
facilities. These Trackers are actively interested in the NJCIP, but unable to commit to participating as full
Stakeholders. We keep them informed of project activities and they provide comments or input as
appropriate.
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that do not have staff specializing in environmental compliance. We concluded that companies' most
urgent needs are for information on:
What regulations apply to them;
How the regulations apply to them;
What they need to do to comply with the regulations; and
How they can stay abreast of regulatory changes.
The information collected also indicated that companies preferred receiving this additional
compliance assistance in the following formats:
Electronically searchable compliance information;
Plain language summaries of regulations/applicability flowcharts;
Training programs;
Confidential question and answer sessions; and
Regulatory alert services.
The task of gathering this information was difficult and, therefore, very time-consuming. In
retrospect, defining compliance assistance needs was one of the biggest challenges that the Pilot
Team encountered. Future efforts may be able to streamline this process by relying more on existing
information. Toward this end, Appendix A presents the detailed results of our findings based on
existing information and information that was collected from the NJ CIP Stakeholders and Trackers
under this pilot.
Define Scope of Pilot Activities
The project team decided that the pilot should focus on NJ state regulations and not attempt
to address federal requirements, largely because OECA had already begun to develop its Internet-
based national compliance assistance center for the chemical industry that was expected to focus on
federal regulations. We also decided to develop three compliance assistance products to help meet
the industry needs described above:
(1) A list of major state regulations that are relevant to batch chemical manufacturers,
along with short plain language descriptions and contacts within NJ DEP's
enforcement and permitting programs that facilities can call with questions;
(2) Applicability flowcharts for several key regulations that have significant impact on
batch chemical companies and appear to present particular compliance challenges for
facilities; and
(3) A working bibliography of available compliance assistance resources.
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In addition to these three major
tools, we decided to develop a
summary of NJ DEP compliance
assistance programs, a glossary of
acronyms, and a user survey. These
products were combined into a single
package of compliance assistance
materials (CAM). To make the CAM
more accessible, it was produced in
traditional print format and also posted
on NJ DEP's web site (see text box).
Printed copies of the Compliance Assistance Materials
can be obtained from:
Chuck McCarty
NJ Department of Environmental Protection
Small Business Assistance Program
401 East State Street (PO Box 423)
3rd Floor, East Wing
Trenton, NJ 08625
telephone: 609-292-3600
These materials can also be viewed on NJ DEP's web
site at:
http://www.state.nj.us/dep/enforcement/home.htm
Based on the resources of the
Pilot Team, we anticipated that it
would be possible to develop
applicability flowcharts for only a
limited number of New Jersey
regulations. Therefore, the team had to select priority regulations for which we would develop
flowcharts. The Pilot Team selected these regulations based on the following criteria:
Industry-reported difficulty in understanding how a regulation applies to them;
The regulation is not currently undergoing revision;
Requirements or applicability of the regulation have changed recently; and
No major changes in the regulation are anticipated in the near future.
Using these criteria, the team narrowed the list of 32 environmental regulations administered
by NJ DEP (including one administered by the NJ Department of Treasury the Spill Compensation
and Control Tax) down to the following six regulations for developing applicability flowcharts:
(1) Air Pollution Control: Subchapter 8, General Permits (N.J.A.C. 7:27)
(2) New Jersey Release and Pollution Prevention (N.J.A.C. 7: IK)
(3) Community Right-to-Know (N.J.A.C. 7:1G)
(4) Discharge of Petroleum and Other Hazardous Substances (N.JA.C. 7:1 E)
(5) Spill Compensation and Control Tax (N.J.S.A. 58:10-23.11, et seq.)
(6) Industrial Site Recovery Act (N.J.A.C. 7:26B).
The Pilot Team's work in defining the scope of its activities was a critical step in the project
during which we developed a clear vision of tangible compliance assistance materials that could be
useful to facilities. These materials served as the focus of the team's future efforts. Given their
perspective as potential users of the compliance assistance materials, input from industry
representatives on the Pilot Team was a key factor in defining the components of the CAM and in
selecting the six regulations for flowcharts.
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4. Develop Compliance Assistance Materials
(August 1997-June 1998)
The CAM was developed over a period of 11 months. This was accomplished through a
group effort that involved all members of the Pilot Team working together to compile the
information, write the materials, and review them for clarity and accuracy. The CAM consists of
many components (see text box) which are intended to be used together as a valuable resource to all
types of facilities, including batch chemical manufacturers.
Compliance Assistance Materials
Summary of New Jersey regulations
Summary of NJ DEP compliance assistance programs
Applicability flowcharts for selected New Jersey regulations
Bibliography of compliance assistance resources
Glossary of acronyms
User survey
The plain language summaries of the New Jersey regulations were largely drafted by NJ DEP
personnel who were most familiar with them. Along with the regulation summaries, NJ DEP staff
prepared a summary of the Department's current compliance assistance activities including the
Greens-tart program, the Small Business Assistance Program, the New Jersey Technical Assistance
program, NJ DEP's One-Stop, and the Hazardous Waste Welcome Wagon Initiative.
To facilitate the development of the applicability flowcharts, the Pilot Team established small
subgroups responsible for drafting the chart for each of the regulations. The teams were comprised
of EPA, industry, and trade association representatives, as well as staff from EPA's contractor who
played an integral role in formatting and finalizing the applicability flowcharts. An example of one
of the flowcharts is presented in Exhibit 2-2. The flowcharts were designed to assist a facility in
determining whether and how a regulation applies to them. As shown in the example, the charts
pose a series of questions that break a regulation into sub-parts. By carefully deciding the
appropriate response to each subsequent question, it is possible for a facility representative to
determine any necessary action(s) for complying with the regulation. For each flowchart there is a
cover sheet that includes the NJ regulatory citation, a short summary of the regulation, contact phone
numbers at NJ DEP, the date the flowchart was prepared, and the due date for any significant annual
reports.
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Exhibit 2-2
APPLICABILITY FLOW CHART
NJ COMMUNITY RIGHT TO KNOW SURVEY
N.J.A.C. 7:1G
(DEQ-094)
Note: Terms in quotations are defined in section A of Attachment (orN.J.A.C. 7:1G-1.2)
Is your 'Tacility" classified
under any of the SIC codes
in Table C of the CRTK
Survey? (See section B of
Attachment for list of SIC
codes)
If you were not mailed a
CRTK Survey, call the
DEP at 609-984-5338 to
obtain survey.
Were there any "Environmental
Hazardous Substances" (EHSs)
listed in Table A of the CRTK
survey instructions that are not
exempt from reporting present at
your facility for the reporting
year? (See section C of
attachment for list of exemptions)
(section 1.5 of CRTK survey
instructions).
Yes
Did any reportable EHSs meet or
exceed 500 pounds or the threshold
planning quantity, whichever is
less? (Section 1.5 of CRTK survey
instructions).
No
No
Yes
Did you use, store or produce at your facility any product
or substance for which OS HA requires a Materials Safety
Data Sheet (MSDS) for the reporting year in quantities of
10,000 pounds or more at any one time, or did the facility
have present any Extremely Hazardous Substances above
500 pounds or the Threshold Planning Quantity (See Table
A of the CRTK survey instructions), whichever is less?
(Section 1.5 of CRTK survey instructions).
No
Yes
Your facility is not
required to complete the
CRTK survey.
Did you use, store, or
produce at your facility any
product or substance for
which OSHA requires a
Materials Safety Data Sheet
(MSDS) for the reporting
year in quantities of 10,000
Ibs. or more at any one time?
(Section 1.5 of CRTK survey
instructions).
Only Part 1 of the
CRTK Survey must
be completed. Part 2
of the survey does not
need to be completed.
Yes
Part 1 of the CRTK Survey and Part 2
listing all reportable chemicals must be completed.
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All team members provided suggestions of information to be included in the bibliography
of compliance assistance resources. EPA's contractor compiled a listing of these resources and
checked the accuracy of the information. The list of resource documents was not limited to EPA or
NJ DEP material, but - in keeping with the multi-stakeholder approach - also included material
prepared by several trade associations. It was clearly stated in the bibliography that the presence of
these resources in the bibliography did not constitute an endorsement of them by EPA or NJ DEP.
This task required substantial effort, as contact information for the resources often changes and can
be difficult to track down.
This effort was coordinated through a series of bi-monthly conference calls and a full-day
meeting held in October 1997. At the meeting, individual team members presented drafts of the
different components of the CAM to the Pilot Team and received comments on how to improve the
drafts from the group. Discussions on format, content, and intended usage of the CAM contributed
to a well-organized and flowing presentation of materials.
Once the Pilot Team completed final drafts of the CAM, the materials were reviewed by NJ
DEP enforcement and program staff. It was critical that our team had NJ DEP participants who had
enough authority/experience with their agency to know whom to call upon in the various program
offices for this technical review. The purpose of this review was for NJ DEP to check all of the
materials, especially our interpretation of the regulations in the flowcharts, for accuracy. The CAM
underwent multiple rounds of review within NJ DEP. This stage of the pilot was very time-
intensive, but was also necessary to ensure that the CAM was accurate and would serve as a reliable
guide for industry.
5. Conduct Outreach Activities for Compliance Assistance Materials
(April-October 1998)
As the team progressed in developing the components of the CAM, we began to discuss how
the CAM would be made available to the industry. The team focused on two main outreach
activities: placing the CAM on the Internet, and hosting two compliance assistance workshops for
industry representatives. To facilitate the process, the Pilot Team again divided into subgroups to
organize these efforts. The first activity that the team focused on was putting the CAM onto NJ
DEP's web site. Placing the CAM onto this web site meets many of the industry compliance
assistance needs that the team identified early in the project it is accessible, searchable, cost-
effective, and it provides links to other relevant programs, trade association sites, and bibliographic
resources. The CAM was placed on NJ DEP's web site under the Compliance and Enforcement
Division in August 1998. The CAM can be viewed at:
http://www.state.nj.us/dep/enforcement/home.htm
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The group agreed to hold two compliance assistance workshops for facility representatives
in October 1998. Along with the web site, these workshops helped publicize the CAM. To increase
opportunities for participation in the workshops across the state, it was decided to hold one workshop
in Newark, and the second further south in Trenton. The group agreed that these workshops would
distinguish themselves from typical "regulatory roundup" sessions by providing a name, a face, and
a phone number for state officials who commonly deal with regulatory and compliance issues. The
workshops also differed from typical workshops because it was sponsored and presented jointly by
agencies and industry. The workshops were intended to be technical and focused on the regulations.
Presentations addressed major issues associated with the regulations, such as:
How to comply with specific elements of the regulations;
Things inspectors may look for in determining whether the facility is in compliance;
Common compliance problems;
The relationship of the state regulation to any federal regulations;
Any new or upcoming changes in the regulations; and
Other information specific to the regulation, such as electronic compliance forms.
The workshops were structured around presentations on the six regulations highlighted in the
CAM with applicability flowcharts (see Appendix B for a copy of the workshop agenda). The
composition of the presentation panels reflected the cooperation between industry and NJ regulators
that was evident throughout this project. Panels included one or more NJ DEP representatives (or
in the case of the Spill Compensation Tax, a representative from the Department of Treasury) who
made an initial presentation about the regulation plus industry representatives who provided
additional insights from their perspective and helped identify effective approaches to compliance.
Pilot Team members shared responsibility for coordinating the logistics for the workshops.
We publicized the workshops through preparation of an announcement of the workshops and a flyer
that provided information on the overall compliance assistance pilot. The announcement and flyer
were sent to numerous trade associations to forward to their memberships, as well as to specific
publications and newsletters (see Appendix C for a copy of the flyer).
The workshops were held in Trenton, on October 20, 1998, and in Newark, on October 27,
1998. There were 39 participants in Trenton and 67 in Newark. The workshops received positive
feedback, with over 85 percent of the participants completing evaluation forms indicating that the
presentations improved their understanding of the regulations and 98 percent commenting that they
would recommend the workshops to a colleague (see Appendix D for a summary of workshop
evaluations).
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FUTURE COMPLIANCE ASSISTANCE ACTIVITIES
AND A CONTINUING PARTNERSHIP BETWEEN
NJ DEP AND INDUSTRY CHAPTER 3
The Pilot Team achieved its goal of increasing industry's access to compliance assistance
by developing the Compliance Assistance Materials (CAM) and conducting compliance assistance
workshops. However, another important goal of the pilot is to create a framework for sustained
cooperation between NJ DEP and industry, with the specific objectives of maintaining the CAM and
evaluating the need to develop new tools to further improve compliance assistance activities in the
future.
The benefits of continuing the activities initiated through this pilot are apparent from the
breadth of the industry representatives that participated in the October 1998 compliance assistance
workshops organized by the Pilot Team. The workshops were successful in reaching out to a
number of companies that do not usually attend environmental activities sponsored by NJ DEP or
trade associations. Helping these companies to become more knowledgeable about their
responsibilities under environmental regulations, and ultimately, to improve their environmental
performance, is a goal shared by both industry and NJ DEP.
Pursuant to the Pilot Team's recommendations, NJ DEP and industry representatives have
formed an ongoing partnership, tentatively called the Compliance Assistance Working Group.
Through this partnership, industry representatives and NJ DEP hope to maintain an open dialogue
on industry's compliance assistance needs and work jointly to identify and develop additional
compliance assistance tools to meet these needs. A number of industry representatives on the Pilot
Team and participants in the compliance assistance workshops have volunteered to participate in the
Working Group along with NJ DEP staff. Industry, NJ DEP, and trade association representatives
are currently discussing the specific activities of the group.
SUSTAINED COMPLIANCE ASSISTANCE ACTIVITIES
The objectives of the Compliance Assistance Working Group are to maintain the CAM and
suggest and/or develop new compliance assistance products based on feedback from the regulated
community. Maintaining the CAM is key to ensuring that these materials continue to be a valuable
resource for facilities. The group's goal is to keep the individual components of the CAM and the
NJ DEP compliance assistance web site up to date.
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The Working Group might also consider undertaking new compliance assistance activities.
Potential activities include:
Identifying additional priority regulations for developing applicability flowcharts.
Conducting additional compliance workshops as new materials are developed or as
significant regulatory changes occur.
Sending periodic mailings of regulatory and bibliographic updates to industry.
Using new vehicles to publicize the compliance assistance materials, such as placing
notices highlighting the CAM or other compliance assistance activities in trade
association newsletters.
Integrating the preparation of applicability flowcharts and plain language summaries
into the regulatory development process.
It is important for the Working Group to select future compliance assistance activities based
on both available resources and industry feedback. The group may obtain this feedback by
compiling user surveys from both the web site and printed CAM. Pilot Team members and
participants at the October 1998 compliance assistance workshops have already recommended
several regulations for future applicability flowcharts. These regulations are listed in Exhibit 3-1.
While the exhibit lists both state and federal regulations, the Working Group is likely to continue
focusing on state regulations in an effort to avoid duplicating efforts of EPA's National Chemical
Industry Compliance Assistance Center, ChemAlliance.
The Pilot Team considered three of the regulations presented in this table Water Pollution
Control Act, Toxic Catastrophe Prevention Act, and Air Pollution Control Subchapter 16 (VOC
RACT) as priorities for developing applicability flowcharts, but did not select them for the CAM
because either they were undergoing revisions or were too complex, and therefore too resource-
intensive for the group to address at that time.
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Exhibit 3-1
REGULATIONS SUGGESTED FOR ADDITIONAL
COMPLIANCE ASSISTANCE MATERIALS12
(Suggestions made by Pilot Team members and workshop participants)
State Regulations
Water Pollution Control Act* (9)
Toxic Catastrophe Prevention Act* (5)
Underground Storage Tanks (4)
Air Pollution Control, Subchapter 16: VOC RACT*
Federal Regulations
Resource Conservation and Recovery Act3 (5)
Occupational Safety and Health Administration Regulations (4)
Toxic Substances Control Act (2)
Clean Air Act Title V (2)
Clean Air Act Risk Management Plans (1)
Federal Insecticide, Fungicide, and Rodenticide Act (1)
Notes:
1) An asterisk indicates that the Pilot Team ranked the regulation as a priority for developing
applicability flowcharts. The team did not select these regulations because they were undergoing
NJ DEP revisions, or the effort to develop a flowchart was considered too resource-intensive at
the time.
2) The numbers in parentheses indicate the number of compliance assistance workshop
participants suggesting a particular regulation. If no number is listed, the regulation was not
suggested by workshop participants.
3) The New Jersey Chemical Industry Project's Materials Recycling Pilot Team has prepared a
report that identifies five likely materials recycling scenarios for the batch chemical industry and
explains how the hazardous waste regulations, which in New Jersey are the same as federal
regulations, apply to these scenarios. The goal of the Materials Recycling Pilot is to promote safe
and economical recycling of materials produced by batch chemical manufacturing processes by
encouraging the use of non-product output from one process as an input in the same or another
process. The report is: "Promoting Chemical Recycling: Resource Conservation in Chemical
Manufacturing" EPA 231-R-99-001, May 1999.
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LESSONS LEARNED:
PREPARING COMPLIANCE ASSISTANCE MATERIALS
THROUGH A MULTI-STAKEHOLDER PROCESS CHAPTER 4
The Compliance Assistance Pilot Team undertook a number of activities to develop the
Compliance Assistance Materials (CAM), including defining the scope of the pilot, identifying and
preparing the CAM, and conducting outreach activities to publicize these materials. We present key
lessons learned from these activities in the sections below. While many of these lessons may appear
intuitive, the process of gathering together a diverse set of stakeholders and agreeing on each step
along the way can be complex and time-consuming. Yet when done carefully, the products provided
are considerably more valuable because they directly address industry's compliance assistance needs.
We hope that these lessons help guide future compliance assistance efforts so that they will be as
cost-effective as possible.
GENERAL LESSONS
Lesson 1. Government and industry working together cooperatively can achieve an
enhanced outcome. Government and industry representatives worked jointly in the
context of this pilot project to define objectives, select and prepare compliance
assistance materials, and organize and participate in compliance assistance
workshops. Industry input at all stages of the project was critical in producing
materials that are targeted to meet their specific compliance assistance needs. The
regulatory expertise of government representatives ensured that the materials were
comprehensive and accurate. Participants in the compliance assistance workshops
considered the materials highly valuable, reflecting the success of the Pilot Team in
combining input from government and industry representatives.
In a broader context, outcomes similar to those achieved through this pilot project
can significantly contribute to ongoing efforts within many state agencies to
complement enforcement activities by placing more emphasis on helping companies
comply with environmental requirements. A cooperative project between
government and industry such as this can improve relationships; it enables industry
to recognize agency efforts to help them comply in a positive light, as opposed to
agency efforts to "catch them" doing something wrong. Furthermore, the
relationships developed between government and industry can serve as a foundation
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for cooperatively developing other innovative approaches to environmental
protection.
Lesson 2. Obtain agency understanding and commitment that resources will be provided
to sustain the compliance assistance activities initiated through this type of
effort. The relevant agency should commit to provide resources for keeping the
materials prepared through the project up to date, continuing cooperative efforts with
industry to identify helpful compliance assistance activities, and integrating
compliance assistance tools into the development of regulations (e.g., preparing plain
language summaries and applicability flowcharts when regulations are written).
While it may be difficult to get this commitment before the compliance assistance
materials have been developed, the agency can make a commitment to evaluate the
effectiveness of the activities, maintain them, and develop additional materials
accordingly.
Lesson 3. Develop guidelines for open communication. At the outset of the New Jersey
Chemical Industry Project, team members agreed to communicate openly and
honestly and to listen and respect all Stakeholder perspectives. This commitment
extended to the activities undertaken by the Compliance Assistance Pilot Team and
contributed to the high degree of cooperation among team members from government
and industry.
GETTING STARTED
Lesson 4. Ensure that the project team has representation from all relevant parties and
maintains the flexibility to adjust the mix of participants to meet the demands
of specific project activities, if necessary. Our initial Pilot Team, which was drawn
from the larger New Jersey Chemical Industry Project Stakeholder group, included
representatives from industry, EPA headquarters, EPA Region 2, academia, and
several trade associations. To augment the Pilot Team's compliance assistance
expertise and obtain input on current EPA and NJ DEP compliance assistance
activities, we invited representatives from EPA's Office of the Small Business
Ombudsman, EPA's Office of Enforcement and Compliance Assurance (OECA), NJ
DEP's Office of Enforcement and Compliance, and NJ DEP's Small Business
Assistance Program to join the team. While stakeholders representing community
and environmental groups did not choose to participate in this pilot, we considered
the team's composition to be appropriate given its focus on developing compliance
assistance materials for industry.
We augmented the Pilot Team for some tasks that required additional expertise and
a greater level of effort. While Pilot Team members had experience with chemical
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and regulatory issues, none had experience organizing workshops. The New Jersey
Business and Industry Association joined the Pilot Team to help organize and
publicize the compliance assistance workshops. Additional representatives of the
Chemical Industry Council of New Jersey joined the Pilot Team to help identify
industry panelists for the workshops. Trade associations such as these also can be
instrumental for identifying industry representatives and others to participate as Pilot
Team members at the outset of the project.
Lesson 5. Recruiting a larger Pilot Team can reduce the time commitment for individual
members. Some of the tasks undertaken by the Pilot Team, including organizing the
compliance assistance workshops and developing the CAM, required substantial
effort from many of the Pilot Team members. It is possible to decrease the level of
effort required for each team member by recruiting additional members. If the team
becomes too large, however, organization and decision-making may become less
effective.
Lesson 6. Gain up-front commitment from team members that they will see the project
through to completion. Pilot Team members made a commitment to complete the
project, and while we experienced some attrition among team members primarily due
to job changes, we maintained a core group throughout the project. To ensure
continuing participation, we encouraged team members to make varying levels of
commitment according to their interest and availability. For example, two industry
representatives agreed to co-chair the pilot. The co-chairs helped to develop the
project workplan, set agendas for and facilitated portions of the conference calls, and
participated in all Pilot Team activities. The level of effort of other Pilot Team
members ranged from participating in all activities, including conference calls,
preparation of the CAM, and workshops, to participating in only some of these
activities.
Lesson 7. Allocate sufficient resources for managing a multi-stakeholder process. EPA
provided funding to hire a consulting firm to facilitate the Pilot Team's efforts. The
contractor's activities included preparing agendas and supporting materials for all
conference calls and meetings, as well as helping to facilitate and summarize them;
undertaking a variety of research tasks; and distributing all materials to Pilot Team
members. The contractor also drafted much of the CAM. Without this contractor
support, the project activities would have taken significantly longer to complete.
Future efforts may want to consider hiring an outside consultant to perform these
activities so that they are completed in a timely fashion. As an alternative, agency
representatives or Pilot Team members may volunteer to provide these services,
although this will increase their responsibilities and time commitments significantly.
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Lesson 8. Gain full support of managers at the agencies implementing the regulations.
Obtaining early support of managers at the participating regulatory agencies is
important so that adequate staff resources will be allocated to the project, and
activities related to the project will be considered part of their primary
responsibilities. However, gaining this support may be difficult before concrete work
products are developed, and an initial hesitancy does not mean that full support will
not be granted later in the process. While NJ DEP managers were cautious about
committing staff time at first, they recognized the value of the effort once they saw
initial drafts of the CAM and became enthusiastic about finalizing the materials,
putting them on the NJ DEP web site and presenting them at the workshops.
PROCESS
Lesson 9.
Communicate regularly and establish tasks and responsibilities. Pilot Team
members participated in conference calls once or twice every month. EPA's
teleconferencing system provided a valuable resource for these calls. The system
made it easy to organize calls and provided convenient call-in access for conference
call participants. To ensure that team members had a record of key decisions made
on the conference calls as well as a list of tasks agreed upon, the EPA funded
contractor summarized each of these conference calls, formed task lists with
responsibilities, and distributed these materials to the Pilot Team. Team members
also participated in two face-to-face meetings one to present and review the first
draft of the CAM and a second to plan for the compliance assistance workshops.
This regular pattern of communication provided continuity, which helped the project
to move forward productively.
Lesson 10. Consider alternative configurations of team task assignments. We chose to have
industry representatives and contractors prepare initial drafts of the CAM. This
required multiple drafts, as we learned to interpret and present the regulations
accurately. An alternative approach would be to have agency program experts
prepare initial drafts of materials and industry participants review them for clarity.
IDENTIFYING AND DEVELOPING COMPLIANCE ASSISTANCE MATERIALS
Lesson 11. Research other compliance assistance efforts in order to identify potential
activities and products that fill gaps in, rather than duplicate, current resources.
By researching other compliance assistance efforts, we discovered that OECA was
in the process of developing a national chemical compliance assistance center. To
avoid duplicating this effort, the team agreed to focus the pilot on New Jersey
regulations. Also, the expertise of a Pilot Team member from the Synthetic Organic
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Chemical Manufacturers Association (SOCMA) in preparing applicability flowcharts
helped the team to focus on this type of compliance assistance tool.
Lesson 12. Identify and use an efficient method for determining what forms of compliance
assistance activities are most useful. The group initially attempted to identify
compliance assistance needs by developing a list of questions for participating
facilities. Based on the limited feedback received, it appears that these facilities may
have been reluctant to provide this information directly to government
representatives. Future efforts may want to task trade associations with obtaining this
information from their members, thus providing facilities with anonymity.
As another alternative, future efforts may be able to identify useful compliance
assistance activities by relying solely on the input of agency and industry
representatives participating in the project and reviewing results of previous efforts
to collect information on industry's compliance assistance needs. To facilitate this
approach, we present a summary of existing information on compliance assistance
needs in Appendix A, including information from our own attempt to solicit industry
feedback, the compliance assistance survey implemented by the Chemical
Manufacturers' Association (CMA), and OECA's informal contacts with chemical
industry representatives.
Lesson 13. Select compliance assistance activities according to available resources. The
Pilot Team developed several types of compliance assistance materials, in part
because of the available contractor support. Projects with tighter resource constraints
may want to limit the types of compliance assistance materials prepared and the
number of regulations covered. Also, it is important to consider the relative level of
effort required to develop the different types of materials. In the case of this pilot,
compiling the working bibliography required a significant level of effort, and
facilities may have been able to find many of these materials on their own. Projects
with tighter resource constraints may want to focus efforts on preparing materials for
specific regulations, such as the applicability flowcharts and plain language
summaries.
Lesson 14. Allocate sufficient time to prepare and finalize compliance assistance materials.
The total time required to prepare the compliance assistance materials includes not
only initial preparation time, but review and production time. For example, we
developed the draft applicability flowcharts in three months. However, it took eight
additional months for the Pilot Team to develop supplementary information for the
CAM, for NJ DEP to review the draft CAM, and for the Pilot Team to finalize the
materials. It also took an additional month to get the CAM printed and distributed
to the workshop sites.
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Lesson 15. Distribute workload across Pilot Team members. The team divided into small
working groups to prepare the six applicability flowcharts. This division of
responsibilities helped expedite the development of the CAM and reduce the overall
burden for individual team members by spreading the responsibility for preparing
materials across the team.
COMPLIANCE ASSISTANCE WORKSHOPS
Lesson 16. When developing compliance assistance workshops, strike a balance between
depth and breadth according to facility needs and existing or planned
compliance assistance activities. In part because NJ DEP already holds day-long
compliance assistance workshops for several individual regulations, our compliance
assistance workshops covered all six of the regulations for which we prepared
applicability flowcharts. For each of these regulations, the workshops provided an
overview of the applicability flowchart, a summary of the regulation, a description
of common compliance problems, an analysis of any interaction with federal
regulations, and information on contacts that facilities can call with questions.
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NEW JERSEY CHEMICAL INDUSTRY PROJECT
APPENDIX A
SUMMARY OF AVAILABLE INFORMATION
ON COMPLIANCE ASSISTANCE NEEDS
In determining which activities to focus on, the Pilot Team needed to establish an
understanding of the New Jersey batch chemical industry's need for compliance assistance. To
whom do companies in the industry presently turn for answers to their questions concerning
regulations? What kinds of compliance assistance tools would be most useful to them? What might
be the most effective vehicles for disseminating information on how to meet environmental
requirements? This is an important and potentially time-consuming task for any effort to provide
compliance assistance. To aid future efforts, we have compiled the information on compliance
assistance needs that we relied on in defining the scope of this pilot. By presenting this information,
we hope that others who embark on similar efforts will not need to devote the same level of
resources to the task of gathering information on what types of compliance assistance are most
needed.
We attempted to identify these compliance assistance needs by asking participating facilities
about current commercial compliance assistance resources, as well as regulations that pose the
greatest compliance challenges. In addition, the Synthetic Organic Chemicals Manufacturers
Association (SOCMA) and the Chemical Industry Council of New Jersey (CIC/NJ) sought similar
information from their members.
We augmented our own inquiry by reviewing information reported in the Chemical
Manufacturers Association's (CMA) Compliance Assistance Survey (December, 1994) and through
discussions with U.S. EPA Office of Enforcement and Compliance Assurance (OECA) staff about
their understanding of the need for compliance assistance in the chemical industry.
CMA's Compliance Assistance Survey included a sample of 47 companies at the corporate
level and 65 companies at the facility level. CMA also provided some demographic information that
allowed the team to look at differing needs between larger and smaller facilities.
In their efforts to develop more effective compliance assistance tools, OECA staff have had
informal discussions with representatives of chemical manufacturers and trade associations.
Information from these stakeholders has been helpful in the development of OECA's Internet-based
national chemical industry compliance center, ChemAlliance, which is available at:
http://www.chemalliance.org.
Below, we present a summary of the information that we gathered on the compliance needs
of the chemical industry as reported by facility representatives. It represents a compilation of
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insights from the various sources that we considered, including information from facilities
participating in the NJCIP, SOCMA and CIC/NJ member companies, CMA's survey of member
companies at the corporate and facility levels, and OECA staff's informal contacts with chemical
industry representatives. There were many overlaps and similarities in the results of these efforts.
Barriers to Regulatory Compliance
The most frequently cited reasons for difficulty in complying with regulations are:
(1) Insufficient/inadequate resources, including staffing and funding at
facilities and compliance guidance from agencies;
(2) Unsure which regulations apply to the company;
(3) Unclear whether a regulation applies to the company and, if so, how
it applies;
(4) Employees don't understand what to do; and
(5) Insufficient self-auditing program.
Interpretation and Applicability of Regulations. It is often difficult for companies
to get clear, consistent interpretation and information on applicability from the
appropriate agency. Some facility representatives feel the need to document
conversations with agency representatives because they are concerned that the
interpretation that a company will be held to for enforcement purposes may differ
from the one offered by the agency representatives during informal conversations.
In addition, industry representatives commented that agency staff interpretations
differ from one facility to the next, even for facilities with similar situations.
Time-Consuming Nature of Addressing Regulations. It is very time-consuming
for facility staff to manage large volumes of information and to read and interpret
regulations.
Staying Abreast of Regulatory Changes. This is not as important an issue for
companies that are members of trade associations and have access to regulatory
updates issued by them. In fact, in areas where there is a particularly strong and
active state trade association, member companies' needs for accessing, exchanging,
and retrieving regulatory information are generally being met. However, a large
fraction of the chemical industry, especially smaller companies, do not belong to
trade associations and have difficulty accessing this essential information.
Assistance at the Local Level. There is a substantial need for state- and county-
specific compliance assistance.
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Compliance Tools Currently in Use
The compliance tools most commonly used by chemical manufacturers include
seminars, newsletters, and fee-based services. Companies also indicated that an ideal
format for receiving compliance assistance would be a telephone call to a staff
expert. In addition, while some of the facility representatives indicated that they
would most like to see assistance given over the Internet, others, primarily those from
smaller businesses, indicated that this would be the least desirable way to receive
assistance.1 Even with the recent increase in access to the Internet, simply posting
compliance assistance information on agency web sites would not be useful to some
small businesses since they do not universally have access to this resource.
Utilization of Information/Assistance Sources
Available information from industry representatives suggests that small facilities use
various assistance/information sources. The primary sources of information and
assistance for the industry are state and national trade associations, "peer-to-peer"
networks, and the supplier/distributor chain. Regulatory agencies do not appear to
be a primary source of compliance assistance. This may be due to the fact that
compliance assistance programs at the local, state and federal levels were relatively
novel when we compiled this information in the early stages of this pilot (early
1997). Industry representatives also said that they rarely used technical assistance
programs, which may be a reflection of these programs not focusing their assistance
efforts on the chemical industry.
Most Commonly Requested Forms of Compliance Assistance
The compliance assistance services and activities that are of greatest interest to
companies include:
(1) Compliance guidance materials that provide plain language interpretations
of each regulation. These should include concise summaries, checklists, and
flowcharts.
(2) The ability to receive information confidentially, without fear of
enforcement actions.
(3) A regulatory alert service that provides timely notification of
new/upcoming regulations and a monthly list of regulatory due dates.
1 It is important to note that this research was compiled in early 1997 when relatively few small businesses
had access to the Internet. This situation is changing rapidly and many facility representatives would now
like to see assistance given over the Internet.
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(4) Training courses on specific regulatory topics geared to help those at the
plant level.
(5) Protocols, procedures, and checklists for plant self-audits to evaluate
regulatory compliance and identify areas for improvement.
(6) An electronically searchable clearinghouse of regulations, interpretative
memoranda, EPA/state policies, etc.
(7) Comparative information between federal and state regulations that
identifies the specific requirements at each regulatory level and helps to
determine how to comply with them simultaneously.
(8) Database of regulatory contacts, assistance programs, hotlines, etc.
(9) Electronic List-server through which users could post questions and
exchange information.
(10) Mechanism for providing feedback to regulatory agencies on troublesome
and/or confusing regulations.
(11) Catalogue of training requirements contained in federal regulations
relevant to the chemical industry.
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NEW JERSEY CHEMICAL INDUSTRY PROJECT
APPENDIX B
COMPLIANCE ASSISTANCE WORKSHOP AGENDA
Environmental Regulatory Compliance In New Jersey:
What Business Needs To Know
8:00 to 9:00 Registration and Coffee
9:00 to 9:30 Introduction and Overview of Website
9:30 to 10:15 Air Subchapter 8 Session
10:15 to 10:30 Break
10:30 to 11:15 Pollution Prevention Session
11:15 to 12:00 Community Right to Know Session
12:00 to 1:00 Lunch
1:00 to 1:45 Discharge of Petroleum and Other Hazardous Substances Session
1:45 to 2:30 Spill Tax Session
2:30 to 2:45 Break
2:45 to 3:30 ISRA Session
3:30 to 3:45 Closing Remarks
3:45 to 4:15 Demonstration of NJ DEP Compliance Assistance Webpage and
Informal Discussions with NJ DEP and EPA Region 2 Staff
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NEW .JERSEY CHEMICAL INDUSTRY PROJECT
APPENDIX C
Flyer For the Compliance Assistance Pilot
About the New Jersey Chemical Industry Project
For over two years, a unique partnership of industry, environmental groups, trade
associations, unions, community representatives, the U.S. Environmental Protection Agency (US
EPA), and the New Jersey Department of Environmental Protection (NJ DEP) has collaborated
on a project centered on the environmental performance of the batch chemical manufacturing
industry in New Jersey. This effort is one of several ongoing sector-based projects within EPA's
Industry Sector Policy Division.
The New Jersey Chemical Industry Project began by asking the Stakeholders what inspires
companies to achieve - or keeps them from achieving - better environmental performance.
Based on the answers and subsequent research, the group chose to implement four pilot projects:
materials recycling across and within facilities, flexible track for good environmental performers,
trading effluent limits, and this pilot, which is concerned with compliance assistance.
About the Compliance Assistance Pilot
The goal of the Compliance Assistance Pilot is to improve environmental compliance,
especially within the batch chemical industry, by identifying the forms of compliance assistance
that are the most helpful to industry and have the greatest potential to improve the environment.
To meet this goal, the pilot team has prepared Compliance Assistance Materials (CAM),
which focus on New Jersey environmental regulations. While we chose topics that apply
primarily to the batch chemical industry, they are useful to many other industries as well. The
CAM contain the following:
> Plain language summaries of 20 New Jersey environmental regulations.
> Detailed "applicability" flowcharts for 6 regulations that can help determine
how the regulations apply to a facility.
> Summaries of NJ DEP's compliance assistance programs and information on
how to take advantage of them.
> Information on how to obtain additional New Jersey and Federal compliance
assistance resources, such as training materials and regulatory guides.
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A printed version of the CAM may be obtained by contacting NJ DEP's Office of Pollution
Prevention and Permit Coordination at 609-292-3600 or Office of Compliance Assistance at 609-
633-0727. It is also available on the NJ DEP web site at:
http://www.state.ni.us/dep/enforcement/home.htm.
In addition to the CAM, the compliance
assistance web site provides links to other
relevant NJ DEP, EPA and trade association web
pages.
Another aspect of this effort is the organizing
of workshops in which experts from NJ DEP and
industry address common compliance problems
for the 6 selected regulations and present the
applicability flow charts. In addition, experts
from US EPA are available to discuss associated
federal regulations. The workshops also include
information on how to use the compliance
assistance web page and how to stay current with
regulatory developments.
Applicability Flowcharts
t Release and Pollution Prevention
t Community Right to Know
t Industrial Site Recovery Act
t Air Pollution Control Act, Subchapter
8
t Discharge of Petroleum and Other
Hazardous Substances
t Spill Compensation and Control Tax
Future Efforts
NJ DEP has made a commitment to keep the compliance assistance materials current as
additions or changes to State environmental regulatory requirements occur. NJ DEP is also
interested in continuing to work with industry and others to make additions to the CAM based on
suggestions from the public, including summaries and applicability flowcharts for additional
environmental regulations affecting the batch chemical or other industrial sectors. If you have
suggestions for additions to the Compliance Assistance Materials or would like to participate in
preparing additional materials, please contact NJ DEP's Small Business Assistance Program at
609-292-3600 or Office of Compliance Assistance at 609-633-0727.
Compliance Assistance Pilot Team Members
> Chemical Industry Council/NJ
> New Jersey Business and Industry
Association
> New Jersey Institute of Technology
> Synthetic Organic Chemical Manufacturers
Association, Inc.
> CasChem, Inc.
> Fabricolor Incorporated
> Fidelity Chemical Products Corp.
> Scher Chemicals, Inc.
> Tricon Colors, LLC
> NJ Department of Environmental
Protection
> US Environmental Protection Agency
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Contacts
For further information on the Compliance Assistance Materials and other related activities
at NJDEP and US EPA:
Chuck McCarty
Small Business Assistance Program
NJDEP
PO Box 423
401 East State Street
Trenton, NJ 08625
Phone: 609-292-3600
Fax: 609-777-1330
Email: cmccarty@dep.state.nj.us
Ron Lockwood
Compliance Assistance and Program Support Branch
US EPA Region 2
290 Broadway, 21st Floor
New York, NY 10007-1866
Phone: 212-637-3413
Fax: 212-637-4035
Email: lockwood.ronald@epamail.epa.gov
Peg Hanna
Office of Compliance Assistance
NJDEP
PO Box 422
401 East State Street
Trenton, NJ 08625
Phone: 609-633-0727
Fax: 609-292-1803
Email: phanna@dep.state.nj.us
Arnold Medbery
Office of Small Business Ombudsman
US EPA, Mail Code 2131
401 M Street, SW
Washington, DC 20460
Phone: 800-368-5888
Fax: 202-401-2302
Email: medbery.arnold@epamail.epa.gov
For information on the NJ Chemical Industry Project and EPA's other Sector-Based Projects:
Catherine Tunis
US EPA, Mail Code 2128
401 M Street, SW
Washington, DC 20460
Phone: 202-260-2698
Fax: 202-260-8662
Email: tunis.catherine@epamail.epa.gov
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NEW .JERSEY CHEMICAL INDUSTRY PROJECT
APPENDIX D
Summary of Compliance Assistance Workshop Evaluation Forms
Workshop Details
Date
Location
Attendees
(excluding team members
and presenters)
Evaluation Forms
Submitted
Trenton
October 20, 1998
Masonic Temple
39
28
Newark
October 27, 1998
New Jersey Institute of
Technology
67
39
(Note that not all respondents completed all questions)
Workshop Evaluation Forms
I. How would you describe the impact of the panel presentations on your
understanding of the applicability of New Jersey regulatory requirements for the
selection of regulations?
Air Subchapter 8
Release and Pollution
Prevention
Community Right to Know
Discharge of Petroleum and
Hazardous Substances
Spill Tax
Industrial Site Recovery Act
Significant
Improvement
30
29
18
21
22
16
Some
Improvement
30
30
41
31
23
14
No
Improvement
5
8
8
6
5
4
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Comments on Presentations
Several respondents offered suggestions for improving the presentations. These suggestions are
summarized in the following table. ( ) indicates number of responses if more than one
Presentation
Comments
Air Subchapter 8
Excellent handout.
May have been too technical for an overview.
Don't spend a lot of time going through applicability slides, focus
more on permits.
Unfocused.
Could have made better distinction between Title V facilities and
smaller facilities.
Release and Pollution
Prevention
Excellent handout.
Didn't feel it was explained well.
Not enough panel participation, questions, etc.
Community Right to Know
General information, but everyone needs to know it.
Not enough panel participation, questions, etc.
Poor presentation.
Discharge of Petroleum and
Hazardous Substances
Good overview.
Good presentation, just nothing new.
Should have mentioned Spill Compensation and Control Act.
Too fast and not enough depth (Trenton).
Difficult to understand at times (Newark).
Spill Tax
Excellent presentation (2).
Good info, but could have been tucked into DPCC session.
Department of Treasury should have had graphs and handouts.
Should not read straight from tax code (3).
Industrial Site Recovery Act
Informative.
Good overview.
II. The workshop's pace was:
Too fast
3
Too slow
0
About right
49
Variable
13
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III. Was there sufficient time allotted for questions after each panel presentation?
Yes
65
No
1
IV. What were the most useful or relevant aspects of the workshop?
( ) indicates number of responses if more than one
Presentations:
Air Subchapter 8 (9)
Community Right to Know (6)
Discharge of Petroleum and Hazardous Substances (4)
Release and Pollution Prevention (3)
Spill Tax
Industrial Site Recovery Act
Other:
Compliance Assistance Materials (9)
Where to go to get information and contacts (7)
Panel performance, question and answer sessions (4)
Web site demonstration (4)
Abundance of handouts (4)
Helpful to bring business and regulatory agencies together (4)
Information conveyed in easy to understand manner (3)
The quality of the presentation materials/overheads and the
intermediate level of the presentation. Excellent overview of key
areas. Well balanced and relevant (3)
Mention of recent regulatory changes (2)
Binder with enclosed presentation slides and note-taking space (2)
Flowcharts
Better understanding of regulations for our new facility
"One-stop knowledge" - having all the regulations covered in one
program
Compliance "challenges" included in presentations
Criteria for coverage and non-coverage
Finding that we are exempt from most requirements
V. What were the least useful or relevant aspects of the workshop?
( ) indicates number of responses if more than one
Presentations:
Spill Tax (14)
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Discharge of Petroleum and Hazardous Substances (3)
Industrial Site Recovery Act (2)
Other:
Community Right to Know (2)
Most of the presentations were too broad in scope. Perhaps a seminar
focusing on specific industries and how these issues apply to them would be
more useful (3)
Presenter's reading directly from the regulations or overheads (2)
Web presentation too long - sufficient to give URL/ address (2)
Generalizations
The delivery of some of the information was hard to follow.
Presentations covered subjects that my business doesn't address.
Topics covered large facilities and are not applicable to me.
VI. Would you recommend the Compliance Assistance Materials to a colleague?
Yes
60
No
1
VII. Are there other environmental regulations affecting your business that you
would like to see addressed in the Compliance Assistance Materials in the
future?
( ) indicates number of responses if more than one.
Water/discharge (9)
Hazardous waste generation (5)
Risk Management Plans (5)
Toxic Catastrophe Prevention
Act(5)
Underground Storage Tanks (4)
OSHA Standards (3)
Emergency Response Planning (2)
Toxic Substances Control Act (2)
Air Permits
Federal Insecticide, Fungicide, and
Rodenticide Act
Coordination between EPA
regional offices and NJ programs
(e.g., DPCC/SPCC plan formats
and cross-referencing).
MACT (pharmaceuticals)
Handling waste
Remediation/ investigative
sites
Oversight Rules
Technical Rules
29CFR
National Resource Damages
DOT Hazardous Materials
Shipping
ISO 14000
Avoiding problems with field
inspectors.
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VIII. Do you have suggestions for improving the Compliance Assistance Materials
(CAM) and Workshops?
Compliance Assistance Materials/Binders
( ) indicates number of responses if more than one
Organize CAM in order of presentations or tell people where things should go
if changes are made (2)
Copies of presentations included in book are difficult to read (2)
Obtain a NJ DEP commitment to keep the CAM up to date.
Should include Appendix A with DPCC regulations.
Expand the scope.
Include a list of abbreviations (Note - glossary of acronyms is included in the
CAM).
Verify information on programs - some may be incorrect.
CAM is "considerably enough."
Color coding for different sections of the CAM might organize it better.
It would be very helpful if the DEP could provide "model" documents for
certain submittals (e.g., SPCC plan; P2 plans).
Industrial Site Recovery Act overheads should be included (and copies should
be sent to participants).
Workshops
( ) indicates number of responses if more than one
Have an all day session on Air Sub Chapter 8.
More detailed information on permit limits.
Future presenters should better integrate the CAM into their presentations.
Screen the presentations prior to the session.
Do not read overheads.
Use more real world examples or case studies.
Where possible, be more specific.
Ask/ survey attendees prior to seminar as to specifics of materials in question.
Web presentation needs to face audience.
These courses are valuable and an offering in South Jersey would be
appreciated (Trenton).
IX. Would you be willing to participate in a follow-up focus group to discuss further
the revision or development of additional compliance assistance materials?
Yes
12
No
38
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