Bakery Partnership Compliance Incentive Program
EPA finalized the Bakery Partnership Program in a federal register notice published on February 6, 2002. This innovative program will allow Baking Companies the opportunity to voluntarily audit their facilities for compliance with the Clean Air Act's National Recycling and Emission Reduction Program in exchange for reduced penalties.
The refrigerant recycling and emissions reduction regulation, found at 40 CFR 82 Subpart F, requires all bakery industrial process appliances containing 50 pounds or more of Ozone-Depleting Substance (ODS) refrigerants, to maintain records of leaks and proof that the leak was repaired within the time limits specified in the regulation. Leaking appliances that cannot be fixed must be replaced or shutdown. Fifty pounds of refrigerant could be used to fill a/c systems in 25 cars or fill 6 to 7 air conditioning units in an average size home.
Companies who wish to participate in this voluntary program, which offers reduced penalties in exchange for commitments to audit and phase out certain ODS refrigerants, must notify EPA no later than April 26, 2002. Participating companies will be required to phase out use of the more hazardous Class I ODS by July 15, 2003. In the meantime, the company must audit all appliances that use Class I and II ODS. Bakeries that elect to replace all their ODS systems with non-ODS systems by April 26, 2002, may possibly avoid all penalties under this agreement. Bakeries that install all non-ODS systems after that date but no later than July 15, 2004 (unless an extension is granted) are limited to penalties of $10,000 per appliance. Self-audits must be performed and reported.
This self-reporting program promises to cut penalties to minimal dollars for violating bakers across the country. While setting a new precedent for how to handle enforcement in this industry, this partnership program will result in massive clean-up of ODS promoting a healthier environment. There are almost 400 baking companies with over 1000 baking facilities in the U.S. In order to assist baking companies in conducting their own audits, an inspectors guide is provided on this web site.
For more information on the Bakery Partnership Compliance Incentive Program, you may contact Charlie Garlow at (202) 564-1088 or by email at firstname.lastname@example.org. For more information concerning EPA's Audit Policy, contact Leslie Jones at (202) 564-5123, email@example.com.
Federal Register Notice: Bakery Partnership Request for Comment (PDF) (11 pp, 82K, About PDF)
Federal Register Notice: Establishing Bakery Partnership Program (PDF) (10 pp, 79K, About PDF)
Region 4's Inspection Checklist - Industrial Process Refrigeration (PDF) (1 pg, 66K, About PDF)
EPA Industrial Process Refrigeration Compliance Guide