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POST INSPECTION LETTER
REINFORCES THE INSPECTION AND ENCOURAGES COMPLIANCE
September 29, 2005
Maggie Theroux
617-918-1613
EPA
Page 1
New England
[email protected]
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.
Page 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
Page 3
Page 4
EPA Internal Approval Process
• Text of letter & attachment reviewed
in FY’02 by:
– Region 1 Assistance & P2 manager &
staff
– Region 1 Enforcement management,
attorneys, & inspectors
– Regional Administrator
– OECA
Page 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
Page 6
What is the Process?
• Use the report to create the Letters
which are signed by the A&P2 manager
• Send the Letter & Attachment to
recently inspected facilities
• Update the Attachment & web site
every 6 months
Page 7
Results
• Sent 432 letters since November, 2002
• Received 3,221 page requests on the
•
•
•
•
“Solutions” web site
Most popular information: P2, Compliance
Assistance, Sector Specific, & Recycling
Measurement survey – 8/03
Received OECA Best Practice Award – ’04
Now being considered by other Regions
Page 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
Page 9
Measurement Survey – 8/03
• Overall, the results emphasized the
importance of getting back in touch with
inspected facilities.
Page 10
Enforcement Issues Addressed
• Limiting use of Enforcement
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
Page 11
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
Page 12