State Review Framework (SRF)
Definitions of the Status of Identified Recommendations
July 2009
Office of Compliance
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW (MC 2221-A)
Washington, D.C. 20460
http://www.epa.gov/compliance/state/srf/index.html
To see a list of acronyms related to SRF: http://www.epa.gov/glossary/aaad.html

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Definition of Terms
Round 1 Elements:
Element 1: Degree to which state program has completed the universe of planned
inspections/compliance evaluations (addressing core requirements and federal, state, and
regional priorities).
Element 2: Degree to which inspection reports and compliance reviews documents
inspection findings, including accurate description of what was observed to sufficiently
identify violations.
Element 3: Degree to which Compliance Monitoring Reports are completed in a timely
manner, including timely identification of violations.
Element 4: Degree to which significant violations (e.g., significant noncompliance and high
priority violations) and supporting information are accurately identified and reported to EPA
national databases in a timely manner.
Element 5: Degree to which state enforcement actions include required corrective or
complying actions (injunctive relief) that will return facilities to compliance in a specific
time frame.
Element 6: Degree to which a state takes timely and appropriate enforcement actions in
accordance with policy relating t specific media.
Element 7: Degree to which a state includes both gravity and economic benefit calculations
for all penalties, appropriate using BEN model of similar state model (where in use and
consistent with national policy).
Element 8: The degree to which penalties in final enforcement actions include economic
benefit and gravity in accordance with applicable penalty policies.
Element 9: Degree to which enforcement commitments in the PPA/PPG/categorical grants
(SEAs), written agreements to deliver a product/project at a specified time are met and any
products or projects are completed.
Element 10: Degree to which the Minimum Date Requirements are timely.
Element 11: Degree to which the Mnimum Date Requirements are accurate.
Element 12: Degree to which the Mnimum Date Requirements are complete.
Element 13: Optional evaluation element could include program areas such as compliance
assistance, pollution prevention, innovation, incentive or self-disclosure programs, outcome
Updated 7/16/09

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measures, environmental indicators, relationships with Attorney General or other legal
offices, etc.
Finding: An observation of activities, processes, or policies that the metrics and/or the file
reviews show are being implemented by the state that have significant problems that need to be
addressed and that require follow-up EPA oversight.
Status:
Working: The recommendation is in progress, it is expected to be completed, and it is on
schedule to meet agreed upon completion date
Completed: The terms of recommendation have been implemented, the corrections have
been agreed upon, and the work attributed to the recommendation was completed
Being Negotiated: The region and the state still have to determine the timeline and the
procedures for implementing the recommendation, the timeline of recommendation cannot be
determined by the completion of the final report
Long Term Resolution: The recommendation cannot be completed without legislative fix,
policy change, or institutional arrangement that would have to go on to the future
Responsible Agency: The agency that administers the program. Mostly States, but is EPA
where EPA directly implements the program.
Updated 7/16/09

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