Elise Rothschild, REHSDivision Chief
Environmental Management Department
A Look at Streamlining Environmental Health
Programs
HELP... Everyone wants my Data!
Environmental Management Department
Digital World
Environmental Management Department
Impacts to Government
Environmental Management Department
Businesses and CUPAs must use the internet to file required program information into statewide electronic reporting system CERS (California Environmental Reporting System) in by Jan 1, 2013.
Businesses can opt to use the CUPA’s local reporting web portal. Hazardous materials regulatory activities which include:
• Filed chemical inventories , underground and aboveground storage tanks, and hazardous waste generation program information.
• Includes inspection , violation and enforcement data. 3 year electronic reporting fee of $25.00 for regulated businesses.
This was collected by the CUPA and forwarded to CAL EPA. CAL EPA provided funds to CUPAs as grants to help pay for costs associated with this transition.
Mandated Electronic ReportingAB 2286 (2009)
Environmental Management Department
State of California Sacramento is one of
58 Counties in California
62 Environmental Health Departments
200,000+ businesses 83 CUPAs – Certified
Unified Program Agencies (Regulate Hazardous Materials and Wastes Storage)
146,000+ businesses
Environmental Management Department
Environmental Compliance Division
▶Hazardous Materials Business Plans and Storage
▶Hazardous Waste Storage and Generation
▶Underground Storage Tanks
▶Above Ground Storage Tanks
▶California Accidental Release Prevention Program/Risk Management Plans (CAL-ARP)
▶ Incident Response
▶ Industrial/Commercial Storm Water Inspection
▶Septic Systems
▶Land Use Evaluations
(Water/Waste)
▶HazMat Land Use
▶Cross Connection Control Program
▶Public/Private Small Water Systems
▶Solid Waste Facilities
▶Medical Waste
▶Business Recycling
▶Multi-Family Recycling
▶Recycled Water
▶Wells
▶Abandoned Wells ID Program
▶Toxic Site Cleanup Program
Cross-Connection Control Program
(CCCP)
Environmental Management Department
Federal Safe Drinking Water Act (SDWA) • Authorized national regulations to ensure safe drinking water
served by public water systems.
• States must adopt drinking water regulations that are as stringent as the federal rules.
State of California• California Health and Safety Code (CHSC) and Title 17 of the
California Code of Regulations (17 CCR) were adopted in 1987.
Regulatory Background
Environmental Management Department
Requirements 17 CCR Section 7584 requires public water suppliers to adopt
operating rules or ordinances to implement their CCCPs.
• Conduct surveys of premises to identify hazards
• Include provisions detailing backflow protection
• Have staff trained in cross connection control to oversee CCCP
• Maintain records of locations, tests and repairs of devices
• Report to the California Department of Public Health (CDPH) a summary of their program data.
• May delegate their program to the representative of the local health officer.
Environmental Management Department
What is Backflow?
Environmental Management Department
Work with 10 Public Water Agencies
1987 – less than 1,000 backflow devices
15,000 devices now managed
How can we create better efficiencies using technology?
Delegation of Cross Connection Program - EMD
Environmental Management Department
Old Paper-Based Workflow
Environmental Management Department
ChallengeBefore the Portal…
Over 4,000 annual staff hours spent on paper – based processes
Several thousands of printed pieces of paper for operators, water agencies and internal recordkeeping
Program cost recovery becoming difficult
Environmental Management Department
How Does A Web Portal Work?
Environmental Management Department
Eliminates the transfer of information from paper into a database.
Portal guides regulated community to submit information directly through portal which is then transferred into a database.
Regulated community can review their own submitted information and make updates or changes directly.
Advantages of A Web Portal
Environmental Management Department
Developed New Web Portal
Environmental Management Department
Test Report Entries
Proof of Test Result SubmittalOnline Test Result Entry
Backflow Test Assembly Report
Online Backflow Test Assembly Report
Environmental Management Department
Tester Certification RecordsCertification Management View Records
Environmental Management Department
Pay fees onlinePurchase Annual Testing TagsOnline Tester Registration
Environmental Management Department
Streamlined Testing Letter Process Simplified letter format Reminder Letters and
Test Reports are “auto-imaged”
Improves owners’ ability to track and manage testing compliance
Environmental Management Department
Benefits
Testers “One stop shop” – registration,
test reports and program fee payment all online
Proof of electronic test report submittal
Water Agencies Access to real-time testing
information
Online recordkeeping for California Department of Public Health (CDPH) reporting
Environmental Management Department
Cost Savings
9 Trees Saved Annually 7,800 gals of
water saved annually
Hazardous Materials Business Plans
California’s Conversion from Paper
to Electronic Reporting
Environmental Management Department
Federal Emergency Planning and Community Right To
Know ActEPCRA 1986
24
Sara Title III US 42 CHP 116 subchapter 11
§11021 and §11022 (§311 and §312)
29 CFR Section 1910.1200 (c) definition of a hazardous
chemical (Fed Hazard Communication)
California Health and Safety Code (H&SC) Chapter 6.95
§25500
California Health and Safety Code (H&SC) §25501
definition of a hazardous material
California Community Right To Know Law 1986Hazardous Materials Reporting
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Must file SDS (MSDS) with LEPC, SERC, and local Fire Department.
SDS (MSDS) must identify the hazard categories for each substance: Acute , delayed and chronic health hazards, fire, reactive or sudden release.
Stores 10,000 lbs of hazardous chemical or 500 lbs of an extremely hazardous chemical must file a Tier II Report with the LEPC, SERC, and local Fire Department
Must file a hazardous materials businesses plan with the local CUPA.
SDS (MSDS) must be available to the employees of the businesses.
Reportable quantities of 55 gallons, 500 lbs of a solid or 200 ft3 of a compressed gas.
FED EPCRA Reporting Requirements California Reporting Requirements
Environmental Management Department
Business that handles a hazardous material or mixture containing a hazardous material that has a quantity at any one time (during the reporting year) equal to or greater than
Total weight of 500 lbs Total volume of 55 gallons 200 cubic feet of a compressed gas Shall submit its business plan to the local CUPA .
Definition of CHSC Division 20 Chapter 6.95 Article 1 §25503.5
26
Environmental Management Department
The federal reporting requirement applies to larger facilities with dedicated staff to manage regulatory requirements. In California, many “mom and pop” businesses that would fall under federal reporting requirements are regulated under California requirements.
Is California the first State to enact Electronic Reporting?
Reportable Quantities
Federal Requirement California Requirement
10,000 lb or Threshold Planning Quantity of an Extremely Hazardous Substance
55 gal for a liquid, 500 lb for a solid, 200 ft3 for a compressed gas
Typical Business Subject to Reporting
Requirements
– Anhydrous Ammonia Plants– Propane Plants– Agriculture Processing Plants– Energy Producing Sites– Oil Producing Sites– Bulk Fuel Plants
– Auto Repair / Auto Body Repair Shops
– Dry Cleaners– Office Buildings with a diesel fueled
backup generator– Manufacturing Facilities
Environmental Management Department 28
California Hazardous Materials Regulatory Structure
Cal-EPA
DTSC• Hazardous Waste• Tiered Permitting
(Treatment of Hazardous Waste)
SFM• Aboveground
Tanks
SWRCB• Underground
Tanks
Cal-OES• Hazardous
Materials Business Plan (EPCRA)• Cal-ARP (RMP)
CUPA
Environmental Management Department 29
California Businesses Affected
Business Plan CalARP UST AST HazWaste
Source Data: Cal EPA 2012 Annual Summary Reports
Total Regulated Businesses 146,000
Business Plan Program 123,983
Cal ARP Program 2,166
UST Program 14,513
AST Program 11,993
Hazardous Waste Program87,689
Environmental Management Department
Plans had to be logged... Paper Review…
And sent to Imaging.CDs of HMPs sent to
Fire
4,328 annual submissions
Environmental Management Department
New Workflow
Environmental Management Department
CUPAs Collect Electronic DataMultijurisdictiona
lBusinesses(i.e. AT&T)
CERS
CUPADatabas
eEMD Portal
Local Businesses
Environmental Management Department
▶ Regulatory Program Status
▶ Identifies which regulatory programs the business falls under
Business Activities Information
Environmental Management Department
Identifies business owner, business operator, environmental contact, and emergency contact
Business Owner/Operator Information
Environmental Management Department
One form for each hazardous material or hazardous waste on site in reportable quantities (55 gal, 200 ft3, 500 lb).
Some materials are exempt or have higher reporting thresholds
Chemical Inventory Information
Environmental Management Department
Local agency reporting phone numbers
Contingencies for an emergency or a release
List of emergency equipment onsite
Employee training
Emergency Response Plan –Training Information
Environmental Management Department
Site Map
Environmental Management Department
HMBP data and inspection and enforcement data from CUPAs will be consolidated into the statewide database CERS
California Environmental Reporting System (CERS)
Environmental Management Department
Forms filled out online.
HMBP PortalGenerates printable PDF version
of familiar paper forms.
Environmental Management Department
Accept / Decline a Plan
▶ Business receives an email letting them know the status of their plan and a list of corrections required, if any.
Environmental Management Department
Step by step user guide created. Available online for businesses to use as needed
Sacramento County’s Outreach and Education Efforts
Environmental Management Department
Environmental Management Department
Total regulated businesses: ~5,000 ~4,000 businesses have submitted a complete
HMBP ~400 HMBPs in pending status awaiting review ~400 HMBPs submitted, reviewed, sent back for
corrections ~200 facilities have made no effort to make an
electronic submission
Compliance Rates in Sacramento County
Environmental Management Department
The 200 current facilities with no attempt at electronic submission are receiving phone calls or inspections in an attempt to attain compliance
Enforcement action and penalties are the final step
Consequences of Non-Compliance
Environmental Management Department
Benefits of E-Reporting Database with chemical inventory information, etc Ease of use for businesses and regulators Statewide consolidation of data Consultants and Operators can access from anywhere Easier to update / annually re-certify HMBP Review of plan is done online, and business gets an email
notification of submission status, or can log on to check status at any time
Sharing of information with other regulatory departments Goal - Fire Responders can access actual data
Environmental Management Department
Start Ups Project Management –
Strategic Planning/Implementation
Software Vendor – Decade Software
IT Staff’s understanding of programs
Staff Resources
Student Interns
CollaborationCUPA Forum Board
CAL-EPA Unified ProgramSteering Groups
TAG Groups
Outreach/Training – Mom and Pop
Businesses
Environmental Management Department
Back log of electronic submittals vs staff resources. Staff ability to adapt to use of technology. Network may not support newest version of
software. IT capability and program knowledge. Legislative changes impact design of portal.
Challenges
Environmental Management Department
Leveraging TechnologyOther Implemented Technologies
Costs
Time/Effort
Regulatory Fees
▶ Field Inspection Tablets▶ Smart Phones ( Data / Video / Pictures )▶ Mobile Apps – Restaurant Inspections,
Incident Response ▶ Voice Over IP▶ Document Imaging, Indexing &
Distribution
▶ Electronic Public Access (Public Website)
▶ Web Portal – streamline other EH Programs
▶ Online Payments Now Available▶ Facebook
Environmental Management Department
Technology Partner
EnvisionConnect•Back-Office
•Inventory, Billing, Reporting, etc.
EnvisionConnect Remote
•Field Inspection
EnvisionConnect Portal
•Public-Facing Services