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I sometimes receive questions related to the number of inspections various types of facilities receive and average penalties which are assessed for violations. EPA’s Enforcement and Compliance History Online (ECHO) database is my favorite tool for collecting this type of data. It provides enforcement data for United States facilities regulated under the Clean Water Act (CWA), Clean Air Act (CAA), and the Resource Conservation and Recovery Act (RCRA). It includes permit data, inspection/compliance evaluation dates and findings, violations, and enforcement actions. I like that the site allows for searches by state, county, city, zip code, SIC, or facility name, so multiple sources in a specific area can be identified and displayed quickly on an interactive map.
ECHO provides specific facility data which is very useful, but it also allows users to track data trends. For example, if you want to know how many facilities there are in your state which report to EPA and how many inspections were performed, that data is compiled and can also be compared against the national averages. Just select the “Analyze trends” button from ECHO’s homepage. You can view national data or select a particular state. Many various reports are available including number of enforcement actions and average penalty assessed. Trend data is segregated by air, water, drinking water, hazardous waste and pesticides. The State activity and performance dashboards provide many useful charts (samples below).
This ECHO dictionary helps users interpret various codes and acronyms used on the site. ECHO is a great screening tool for data reported to EPA.
Some states are also building significant searchable environmental databases. Two that I use most are the Indiana Department of Environmental Management’s(IDEM’s) Virtual File Cabinet and Kentucky’s Energy and Environment Cabinet Department for Environment Protection e-search. If you need detailed compliance data for a facility, however, a freedom of information act (FOIA) request is still your best bet. Each state agency’s website typically has directions for submitting your request. There are many agencies and separate databases with available information so framing your request properly is essential to extract the desired data.
A local company engaged in manufacturing imported a small amount of a chemical substance defined under TSCA. Faced with a potential EPA enforcement action with penalties assessed for noncompliance under TSCA of up to $32,500 per day per violation, the company called SMG for help.
SMG analyzed the company’s current TSCA procedures and assisted the company in developing a proactive, cost-effective compliance procedure. SMG also facilitated a training program to educate employees about TSCA.
SMG worked with the company to develop mechanisms that assured adherence with the policies that were being implemented for compliance. Procedures to promptly correct any potential violations and prevent future violations were also put into place.
SMG was able to show that the company complied with the relevant TSCA regulations and was improving their TSCA policies and procedures to assure that future issues were less likely to occur. The company was not subjected to the proposed penalties and now has mechanisms in place to maintain TSCA compliance.