Measuring Environmental Performance:
Beyond the Beans – San Diego County’s
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
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 noncompliance 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.
The Environmental Protection
Indicators for California (EPIC)
Project
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
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 07-08.
Institute a flat fee for Biological R&D 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.
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
Plan
Setting goals and objectives
Formulating strategies
Adapt
Do
Modifying plans or actions to
improve performance
Carrying out actions to
accomplish objectives
Check
Implementing the evaluation
system