Understanding Your Compliance History
As part of the Practice Greenhealth Environmental Excellence Awards application guidelines, Practice Greenhealth asks whether your facility has any current EPA compliance violations. Applicants with significant violations of environmental or worker health and safety laws/regulations are not eligible to win an award. The credibility of the Practice Greenhealth awards program is dependent upon not recognizing facilities with serious, unresolved environmental compliance or worker safety violations, even when they have done great work in other areas.
Many applicants assume that if they are not personally aware of any violations, their facility probably doesn’t have any, but this is not always true. In past years, some really great applications had to be turned down due to outstanding or significant environmental compliance violations
Practice Greenhealth conducts a compliance screen on all award applicants, but we also suggest that you spend some time as part of your award application process finding out if your facility might have environmental or worker safety compliance issues. If you find violations on record, please contact us with details so we can help you evaluate their significance or likelihood of creating a barrier to your winning.
Please Note: The term “facility” may indicate your entire institution (vs. a specific facility, lab, or clinic) for the purpose of enforcement or compliance screening. I.e., if your hospital is part of a state university, the university may have violations that show up as part of your record.
How does my facility determine its compliance history?
Practice Greenhealth recommends several key steps to uncovering and understanding any potential violations at your facility.
1. The most important step you can take is to ask around. Environmental compliance may be overseen by several departments, so you will need to reach out to Environmental Health & Safety, Environmental Services, Risk Management, Legal, Facilities Management, Engineering, Regulatory Affairs, and Plant Operations. (This sounds daunting but a group email may be enough to track down the information you need to begin the process.) Check with these departments to get any pertinent information, including:
- When was the most recent violation?
- What was the nature of any violation(s)?
- What steps were put in place to remedy any violation(s)?
- Was a fine assessed for this violation?
- When did the facility report to the regulatory body about this remedy?
- Has the facility fulfilled its obligations regarding this violation?
2. Alternately, you can use the EPA’s Enforcement and Compliance History Online (ECHO) to collect an environmental compliance history of the facility.
Follow these simple directions:
- In the box titled Compliance Searches, click on All Data.
- This will take you to a second screen. Under Geographic Location, pull down to your EPA Region and then enter your facility’s zip code and hit the Search button next to Geographic Location.
- Scroll down until you find the name of your facility and click on the facility link to get a Detailed Facility Report.
- As you review your facility data in the Detailed Facility Report, scroll down to the Three Year Compliance Status by Quarter.
- Use the Data Dictionary to determine what the fields mean. For example, Under Clean Air Act (CAA), you will find that the code C-INSP means the facility is “in compliance, based on inspection”.
What if we have a violation on record?
If your facility has a current violation in the past 12 calendar months, feel free to check with Practice Greenhealth to make sure you are still eligible for an award. Practice Greenhealth will consider and weigh the gravity, date of occurrence, and resolution status of violations and may still choose to grant an award.
Please contact Practice Greenhealth at 603-795-9966 or email Practice Greenhealth with any questions about compliance violations and Practice Greenhealth awards eligibility.
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