elise rothschild, rehs division chief environmental management department

Elise Rothschild, REHSDivision Chief

Environmental Management Department

A Look at Streamlining Environmental Health

Programs

HELP... Everyone wants my Data!


Digital World


Impacts to Government


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)


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 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)


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


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.


What is Backflow?


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


Old Paper-Based Workflow


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


How Does A Web Portal Work?


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


Developed New Web Portal


Test Report Entries

Proof of Test Result SubmittalOnline Test Result Entry

Backflow Test Assembly Report

Online Backflow Test Assembly Report


Tester Certification RecordsCertification Management View Records


Pay fees onlinePurchase Annual Testing TagsOnline Tester Registration


Streamlined Testing Letter Process Simplified letter format Reminder Letters and

Test Reports are “auto-imaged”

Improves owners’ ability to track and manage testing compliance


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


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


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

Environmental Management Department 25

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


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


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


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


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


Plans had to be logged... Paper Review…

And sent to Imaging.CDs of HMPs sent to

Fire

4,328 annual submissions


New Workflow


CUPAs Collect Electronic DataMultijurisdictiona

lBusinesses(i.e. AT&T)

CERS

CUPADatabas

eEMD Portal

Local Businesses


▶ Regulatory Program Status

▶ Identifies which regulatory programs the business falls under

Business Activities Information


Identifies business owner, business operator, environmental contact, and emergency contact

Business Owner/Operator Information


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


Local agency reporting phone numbers

Contingencies for an emergency or a release

List of emergency equipment onsite

Employee training

Emergency Response Plan –Training Information


Site Map


HMBP data and inspection and enforcement data from CUPAs will be consolidated into the statewide database CERS

California Environmental Reporting System (CERS)


Forms filled out online.

HMBP PortalGenerates printable PDF version

of familiar paper forms.


Accept / Decline a Plan

▶ Business receives an email letting them know the status of their plan and a list of corrections required, if any.


Step by step user guide created. Available online for businesses to use as needed

Sacramento County’s Outreach and Education Efforts


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


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


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


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


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


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


Technology Partner

EnvisionConnect•Back-Office

•Inventory, Billing, Reporting, etc.

EnvisionConnect Remote

•Field Inspection

EnvisionConnect Portal

•Public-Facing Services

elise rothschild, rehs division chief environmental management department

Documents

drinking water regulations

program data

public water systems

public water suppliers

public health agencies

unified program agencies

required program information

california code of regulations