|What is the Environmental Results Program (ERP)?
The Environmental Results Program (ERP) is an innovative approach that relies on closely linked compliance assistance components to address obligations and improve environmental results. These components provide tools to owners and operators of regulated facilities to more effectively meet or exceed environmental requirements and enable regulators to reach verifiable environmental results. ERP combines compliance assistance, self-audit/certification, and statistically-based compliance evaluations and performance measurement in order to strengthen or replace an existing regulatory structure.
In ERP, regulatory agencies inform industry representatives about identifying and responding to their environmental requirements, as well as voluntary best practices they can use to alleviate potential impacts. Facilities can then choose to self-evaluate and certify compliance. By conducting "before and after" inspections and applying statistical analysis, regulators can identify successful approaches that increase regulatory compliance, can reduce permitting, inspection, and enforcement resource allocations, measure environmental performance, and institute lasting improvements.
ERP was developed by Massachusetts in 1997 to improve compliance within its dry cleaning sector. Prior to adopting ERP, Massachusetts only had data on 10 percent of its state-regulated dry cleaning population. The self-certifications and follow-up inspections that are part of the data-rich ERP process helped the state to bring the remaining 90 percent of the dry cleaning population into the regulatory fold.
The ERP approach applies three tools to enhance and measure environmental performance:
- Compliance Assistance
Compliance assistance tools consist of plain language, sector-specific handbook and introductory workshops which educate facility owners/operators about their environmental obligations. Written from the facility operator's point of view, the handbook describes environmental requirements based on the facility's processes and guides the user through a self-audit for compliance, as well as techniques for pollution prevention, health, and safety best practices.
Based on the results of working through the ERP compliance assistance handbook and completing a self-audit, facilities either certify compliance, or develop a Return-to-Compliance plan if problems are found. Self-certification, which covers multi-media (all air, water, and waste) performance standards for the business sector, is signed by senior officials at the facilities. Self-certification creates personal accountability for compliance with the facility owners or operators. Penalties may be assessed for false, inaccurate, or misleading statements.
- Performance Measurement
Measuring performance is critical to evaluate the effectiveness of ERP and to assure regulatory compliance. ERP uses industry-specific Environmental Business Practice Indicators (EBPIs) linked to selected regulatory requirements and pollution prevention to track performance. Regulators use statistical sampling methods to measure compliance with pre- and post-certification facility checks as well as targeted inspections for non-compliant facilities. Performance measures are collected and analyzed at the company level enabling regulators to determine the effectiveness of compliance assistance approaches.
Field Guide to Environmental Compliance 2012
O&G E&P Site Inspection Water Checklist
O&G E&P Site Inspection Air Checklist
For more information on Environmental Results Program, please visit the EPA's ERP page at http://www.epa.gov/erp/index.htm.