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Phase 4: Initiate Program
- Introduction
- Roadmap
- ERP Resources and Contacts
This phase includes the final steps necessary to prepare for ERP, the initial steps of program roll-out, and initial adjustments to the program.
Train ERP Inspectors and Data Entry Staff
Whether you use seasoned inspectors or volunteers, all of the inspectors should be trained so that they are evaluating all of the questions on the checklist the same way. This will help ensure accurate interpretation and analysis of program results. Data entry personnel should also be trained, with an emphasis on ensuring accuracy and consistency in data entry.
Questions to consider
- Do inspectors have substantive expertise in the issues covered on the inspector checklist? If not, they will need additional training to understand the environmental and compliance issues at hand.
- Is it possible to conduct a "dry run" of an inspection at an actual facility? This step can help identify unanticipated problems in the inspector checklist and can help make sure that the questions inspectors ask will be understandable to facilities.
- Do you have a feedback loop set up to coordinate responses to questions or concerns that come up in the course of inspections or data entry?
Conduct Pre-Certification ("Baseline") Inspections and Assess Results
Baseline inspections are inspections of a set number of randomly chosen facilities to assess performance and compliance before ERP begins. This step involves performing baseline inspections, entering baseline data into the relevant ERP database, and analyzing the results, according to the statistical methodology you have prepared. Once you have analyzed baseline results, it is a good idea to revisit program goals and assumptions to make sure they are supported by baseline data. If not, you may need to make adjustments to the scope of your ERP. In some cases, you may wish to select a different target sector if baseline results are very different than expected.
Questions to consider
- When conducing baseline inspections, do you want to hand out a brochure or other materials to familiarize facilities with ERP and to encourage participation in workshops and the self-certification process?
- Do you want to invite the facilities you inspect to participate in the program as reviewers of self-certification materials?
Resources to consider
Develop the Certification Package and Workshop Materials
The certification package includes the self-certification form, non-applicability form, return-to-compliance form, and compliance assistance materials (including compliance assistance workbook, and/or fact sheets). These materials will be influenced by the decisions you have made so far and the results of the baseline inspections. In addition, at this stage you should plan for compliance assistance workshops and develop workshop materials.
Questions to consider
- Are materials available from other states/EPA in this sector that you can adapt?
- What compliance assistance techniques will you use (e.g., workbook, fact sheets, workshops, etc.)? Where appropriate, use internal and external stakeholders to assist in the development and evaluation of these materials.
- Will you send out a full certification package each year or only updates? If you elect to send only updates each year, consider using a three-ring binder for the workbook to enable facilities to easily replace out-of-date material.
- How much detail do you want to include in your compliance assistance materials? How important is the length of compliance assistance materials?
- Can you include "red-flag" questions to check for data reliability on self-certification forms?
- Will the form have only high-level questions with supporting questions in the workbook, or will the self-certification information be more detailed and serve as a stand-alone document?
Resources to consider
- Tool 1: Self-Certification; Tool 2: Compliance Assistance; Tool 3: Performance Measurement; Compliance Assurance and Enforcement Under ERP; How ERP's Materials Are Linked
[Cached version] (PDF, links to page 7-14 of a 154 page document, 620 KB, About PDF)
(Excerpt from The Massachusetts Environmental Results Program: User's Guide for Government Agencies (March 2002)) - Self-Certification Forms
- Instructions for Self-Certification Form
- Non-Applicability Forms
- Return-to-Compliance Plan forms
- Other available forms
- Compliance Assistance Workbooks
- Compliance Assistance Workshop Materials
- Compliance Assistance Fact Sheets
Develop Follow-Up Plan for After the Self-Certification Period
As you develop the certification package, it is important to plan how you will collect and respond to this data. In particular, you need to develop a strategy for following up with facilities that do not respond to the self-certification package, say they do not fit within the definition of the program, or certify they are out of compliance. Your approach will vary depending on whether your program is mandatory or voluntary.
Questions to consider
- How will non-responders be addressed?
- How will non-applicable responders be addressed?
- How will facilities out of compliance be addressed?
Phase 4: Stakeholder Involvement
Stakeholder involvement during program initiation should focus on outreach about the program to its universe and related stakeholders.
Internal
- Debrief with inspectors to understand lessons learned through baseline inspections.
- Maintain contact with other agencies and divisions.
External
- Publicize ERP among key stakeholders (e.g., community groups, local media, regulated facilities in the target sector, sector trade associations, suppliers, and customers).
- Request stakeholder feedback in the process of developing program materials. It is particularly important to elicit feedback from facilities in the sector on the compliance assistance workbook and workshop materials. Industry representatives can play a valuable role in reviewing and field testing the certification package before it is finalized.