Low Priority for Routine Inspections

Air Incentives Water Incentives Waste Incentives Coordination with State Programs

As Performance Track grows and develops, individual facilities are being recognized as strong performers with public records of environmental results and future performance goals. One element of that recognition is reflected by the vigorous implementation of program regulatory and administrative incentives that reward Performance Track members for their environmental leadership, top performance, and commitment to continued compliance.

Performance Track compliance commitments are backed by participating facilities' environmental management systems (EMSs) that require periodic EMS and compliance audits as well as an annual certification of compliance. In recognition of these and other program elements, facilities in Performance Track are considered to be a low priority for routine inspections. These routine inspections comprise the majority of EPA inspections, and generally occur when there is no specific reason to believe that a violation exists at a specific facility.

EPA provides this low inspection priority status since the performance- and compliance-focused EMSs implemented by Performance Track members, coupled with periodic auditing, should prevent non-compliance at Performance Track facilities. As a designated low inspection priority facility, members save the resources and time regularly spent preparing for and responding to inspection requests. In limited situations, EPA could inspect Performance Track facilities where the Agency has information that serious problems may exist. Examples of such problems are criminal activity, major compliance problems in a priority area of concern to the Agency, or endangerment.

EPA remains committed to ensuring full implementation of our promise that Performance Track facilities are treated as low priority for routine inspections. Senior enforcement officials in each Region (the Deputy Regional Administrator or Division Director as appropriate) are responsible for ensuring that this policy is implemented and incorporated into internal planning and accountability processes, as well as in planning with states and localities. Although the Performance Track policy regarding low priority for routine inspection is limited to federal inspections, EPA encourages state enforcement programs to honor this policy as well.

Review EPA memos detailing this policy initiative:
Performance Track/Office of Policy, Economics and Innovation Memo – January 19, 2001 (PDF, 46 KB, 4 pp).
Performance Track/ Office of Enforcement and Compliance Assurance Memo - April 23, 2002 (PDF, 273KB, 2pp)
Performance Track/ Office of Enforcement and Compliance Assurance Memo - October 29, 2003 (PDF, 1MB, 7 pp)

Low Priority for Routine Inspections

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