POST INSPECTION LETTER REINFORCES THE INSPECTION AND ENCOURAGES

POST INSPECTION LETTER REINFORCES THE INSPECTION AND ENCOURAGES COMPLIANCE September 29, 2005 Maggie Theroux 617 -918 -1613 EPA 1 New England theroux. maggie@epa. gov

What is the Purpose? • Reach every facility that we inspect • Provide compliance and “beyond compliance” info via the Attachment or the Region’s "Solutions" web site • Help facilities to improve their environmental performance at a time when they have an incentive to listen • Maximize the environmental impact of our inspections with. 10 FTE Please note: It is not a “close out” letter. 2

What type of Information is included in the Attachment? • Access to web resources for: – Compliance assistance – Sector specific information – Pollution prevention – Energy efficiency – Green buildings – Environmentally-preferable purchasing – Technology Connection – Environmental Management Systems – Recycling – Enhanced security 3

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EPA Internal Approval Process • Text of letter & attachment reviewed in FY’ 02 by: – Region 1 Assistance & P 2 manager & staff – Region 1 Enforcement management, attorneys, & inspectors – Regional Administrator – OECA 5

What is the Process? • Enter the facility inspection data & contact information into ICIS • Create an ICIS report & eliminate duplicates • Review the list of facilities 6

What is the Process? • Use the report to create the Letters which are signed by the A&P 2 manager • Send the Letter & Attachment to recently inspected facilities • Update the Attachment & web site every 6 months 7

Results • Sent 432 letters since November, 2002 • Received 3, 221 page requests on the “Solutions” web site Most popular information: P 2, Compliance Assistance, Sector Specific, & Recycling Measurement survey – 8/03 Received OECA Best Practice Award – ’ 04 Now being considered by other Regions • • 8

Measurement Survey – 8/03 • 7 out of 9 remember receiving the letter & reviewing the attachment • Some remembered visiting the web sites for CA info & regulations, & Sector Specific • 5 out of 9 knew they needed to make improvements & 4 of these were already making the changes 9

Measurement Survey – 8/03 • Overall, the results emphasized the importance of getting back in touch with inspected facilities. 10

Enforcement Issues Addressed • Limiting use of Enforcement 11 resources • Avoiding impression that we are pressuring facilities into making environmental improvements • Complicating penalty negotiations if companies argue that they are owed reductions due to actions taken

How can it be used by the States? • Customize the Letter & Attachment • Copy the "Solutions" web site • Make sure your inspection data entry system includes facility contact information • Add topics for specific sectors – UST example – 1, 689 page requests from 12/02 -6/04 12