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Phase 5: Implement Program
- Introduction
- Roadmap
- ERP Resources and Contacts
This phase specifically represents the implementation of the certification phase of ERP.
Conduct Compliance Assistance Workshops
Industry workshops are an effective means for promoting, educating, and explaining the certification program just prior to and during the implementation phase.
Questions to consider
- Have you publicized the workshops so that all interested facilities are aware that they are occurring and have the opportunity to attend?
- Can you invite guest speakers from industry to attest to the value of the program?
- Can you offer hands on demonstrations to show facilities best management practices and how to prevent pollution?
Resources to consider
Send Out Certification Package
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).
Questions to consider
- If the program is mandatory, are you tracking receipt of self-certification packages so you can verify that facilities received these materials?
- Have you included clear instructions for how to fill out and return the forms?
- Have you specified when self-certification forms must be returned?
Resources to consider
- Florida's Auto Repair Data Management Plan [Cached version] (PDF, 36 pages, 2,190 KB, About PDF), which includes a section on mailing certification packages
Collect Self-Certification Data, Return-to-Compliance Plans, and Non-Applicability Forms and Evaluate Results
Once facilities submit their certification packages, you can analyze the results and follow up as planned in Phase 4. While you may not choose to use self-certification data as the core basis for measuring facility performance (at least in the early stages of ERP, when the reliability of this self-reported data has not yet been established), you may wish to study patterns in the self-certification data.
Questions to consider
- Are there common characteristics that facilities in the sector share (e.g., facility size, types of equipment, processes used)?
- Are there common issues for which facilities are reporting that they are out of compliance?
- What types of pollution prevention and Best Management Practices do facilities say they are implementing?
Resources to consider
Conduct Targeted Inspections
This step involves targeted follow-up activities that focus on facilities that did not respond to the self-certification package, whose responses contained irregularities or conflicting, or that reported compliance problems. Follow-up activities could include letters, phone calls, inspection, and/or enforcement activities.
Phase 5: Stakeholder Involvement
Internal
- Debrief with inspectors to understand lessons learned through targeted and post-certification inspections.
External
- Continue to publicize ERP among key stakeholders (e.g., community groups, local media, regulated facilities in the target sector, sector trade associations, suppliers, and customers).
- Provide technical assistance and outreach, including workshops, for the targeted ERP sector.