Understanding Your Compliance History

As part of the H2E Environmental Excellence Awards application guidelines, H2E asks whether your facility has any current EPA or OSHA (environmental-exposure- related) 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 H2E 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.

H2E 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?

H2E 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:

  • Go to http://www.epa.gov/echo/ (see screen shot to the right).
  • In the box titled “Compliance Searches”, click on All Facilities .
  • This will take you to a second screen. Under Geographic Location , pull down to your EPA Region and then type in 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 -- the button at the top right corner -- 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”.

3. For OSHA violations, you can check out http://www.osha.gov/pls/imis/establishment.html. Type in your facility name (it is helpful to use as basic a name as possible with no apostrophes, etc., and you may have to try a few variations.)

  • Leave other criteria alone, click submit and see if your facility shows up.
  • Try again and click circle next to Open , instead of Closed .
  • For help using this tool, contact OSHA at 1-800-321-OSHA, and ask about the IMIS database.

NOTE: H2E recognizes that there are many types of OSHA violations. H2E is primarily interested in violations that have an environmental connection regarding, for example, hazardous chemicals (Hazard Communications) and/or violations of Bloodborne Pathogens rules.

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 H2E to make sure you are still eligible for an award. H2E will consider and weigh the gravity, date of occurrence, and resolution status of violations and may still choose to grant an award.

Please contact H2E at 603-795-9966 or email H2E with any questions about compliance violations and H2E awards eligibility.

 

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