Measuring Environmental Performance: Beyond the Beans – San Diego County’s EPIC Pilot Project 16 th ANNUAL CIHC CONFERENCE December 4, 2006 presented by: Michael Dorsey, Chief Hazardous Materials Division County of San Diego Department of Environmental Health

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 don’t provide a complete picture of performance.

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.

Directive: OEHHA to collaboratively develop and maintain environmental indicators Project’s initial goals:  a process for identifying and selecting environmental indicators; and,  an initial set of indicators The Environmental Protection Indicators for California (EPIC) Project

Results-Based Management relies 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.

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).

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

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.

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

INCENTIVES Reduce inspection frequency for R&D Laboratories and Biotechnology businesses from 18 to 36 months for FY Institute a flat fee for Biological R&D laboratories and Biotechs to reflect 36-month inspection frequencies for FY 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.

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

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.

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