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Measuring Environmental Performance Beyond the
Beans San Diego Countys EPIC Pilot Project
16th ANNUAL CIHC CONFERENCE December 4,
2006 presented by Michael Dorsey,
Chief Hazardous Materials Division County of
San Diego Department of Environmental Health
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DECLINING ENFORCEMENT LEVELS A SIGN OF SUCCESS
OR AN INDICATOR OF PROBLEMS?

• Environmental agencies are commonly criticized
  when the number of enforcement cases decline.
• The number of enforcement actions may decrease
  for a number of reasons, some positive and others
  negative.
• It may reflect lax government follow-up or a
  reduced number of inspections.
• It may reflect improved compliance by the
  regulated community.
• Without more information and better outcome
  measures, enforcement levels alone dont provide
  a complete picture of performance.

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ARE THERE BETTER WAYS TO MEASURE PERFORMANCE?

• Find and target environmental and non-compliance
  problems
• Motivate regulated parties to reduce their
  negative impacts on the environment
• Assess and depict program effectiveness more
  accurately and
• Communicate program effectiveness to EPA,
  Cal/EPA, federal and state legislatures, and the
  public.

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The Environmental Protection Indicators for
California (EPIC) Project
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Results-Based Managementrelies on.

• Measurements of outcomes/results as part of a
  system that tracks resources and activities
• A structure for reporting and analyzing the
  measurements
• Adjustments to planning and implementation
  efforts to meet our mission.

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UNIFIED PROGRAM EPIC PILOT PROJECT

• Measuring Unified Program Compliance Through
  Education
• Hazardous Waste Generator Program Hazardous
  Materials Business Plan Program and Medical
  Waste Management Program (San Diego County
  Department of Environmental Health).
• Underground Storage Tank Program (Sacramento
  County Department of Environmental Health).

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UNIFIED PROGRAM EPIC PILOT PROJECT (Cont.)

• Project Description
• Focus on a narrow set of indicators (selected
  violations) in an industry sector
• Establish a baseline
• Measure impact of educational outreach on
  compliance

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GOALS AND OBJECTIVES

• Goal Reduce non-compliance of Unified Program
  Agency violations through education and outreach.
• Objectives
• (1) Demonstrate that education and outreach can
  be effective tools in obtaining compliance from
  the regulated community and
• (2) Establish a risk-based inspection process
  that can be used to assist in directing resources
  to areas of high risk and non-compliance.

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PERFORMANCE MEASURES

• Reduce by 25 the top ten most common violations
  combined from the following categories by July 1,
  2006
• Hazardous Waste/Tiered Permitting
• Hazardous Materials Business Plans
• Medical Waste
• Reduce the top ten most common violations
  combined from the following categories by an
  additional 25 by July 1, 2007
• Hazardous Waste/Tiered Permitting
• Hazardous Materials Business Plans
• Medical Waste

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INCENTIVES

• Reduce inspection frequency for RD Laboratories
  and Biotechnology businesses from 18 to 36 months
  for FY 07-08.
• Institute a flat fee for Biological RD
  laboratories and Biotechs to reflect 36-month
  inspection frequencies for FY 07-08.
• UST Med Waste LQGs retain 12-month statutory
  inspection interval.

SNC status would trigger return to the
18-month inspection interval and a comparable
fee schedule.
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SNC STATUS

• Significant non-compliance (SNC) for this project
  is either
• One significant violation, or
• Three violations that cannot be corrected during
  an inspection.
• A combination of repeat minor violations and
  other violations.
• A facility in a SNC status will be inspected
  every 18 months instead of 36 months, and
• Permit fees will return to original fee schedule

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FUTURE TASKS

• Determine who qualifies for reduced inspection
  frequency
• Develop the flat fee structure
• Continually update the most common violation list
  and adjust outreach process
• Develop an continued education/certification
  process
• Publish the results of the project in an
  environmental journal
• Develop new topics for education and training
• Refine performance measures as needed.

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Building a Results-Based Management System
Plan Setting goals and objectives Formulating
strategies
Do Carrying out actions to accomplish objectives
Adapt Modifying plans or actions to improve
performance
Check Implementing the evaluation system