REGULATORY AFFAIRS MANUALSERIES 100

EPCRA REPORTING GUIDANCE PROGRAM 100.03

Appendix 4:
Notices of Violations, Exceedances, and Citations

D3-4. Notices of Violation, Exceedances, and Citations

Metric Definition

Metric Owner

Jeff Felder

Subject Matter Experts

Jeff Felder

Tom Tisa

Objective

One of five components of the ESH Index Metric – To ensure employee safety, compliance to laws, and provide an environment friendly work zone

Definition

Total # of violations, exceedances, and citations v. legal standards and permit terms and conditions

  • Notices of violation – formal violations from outside agencies
  • Includes:
  • All reported notices of violation
  • Excludes:
  • Unreported notices of violation
  • Exceedances – incidents identified by Regulatory Affairs, or other Fisher employees
  • Includes:
  • All reported exceedances
  • Excludes:
  • Unreported exceedances
  • Citations – citations issued by outside agencies
  • Includes:
  • All reported citations
  • Excludes:
  • Unreported citations
Metric Creation

Metric Gathering Process

  • Metric is provided by Regulatory Affairs
  • Data point needed for metric – total # of NOV’s, exceedances, and citations by month

Estimated Time to Create Data Each Month

  • Metric is provided by Regulatory Affairs
  • Metric will be reported monthly, however Regulatory Affairs will only provide the data quarterly, with a one month lag

Calculation

  • Total # of violations, exceedances, and citations
  • Each will be counted independently as an incident – it is possible for an exceedance to lead to a notice of violation that leads to a citation – this would be 3 hits, not 1

Target

  • Agreed to by Jeff Felder
  • Green = 0
  • Yellow > 0 <= 3
  • Red > 3

Drill Down Capabilities

  • Regulatory Affairs has detail by location

Historical Data Availability

  • Metric dates back to 1/1/01

Trend Line Display

  • N/A
Component Details
Component / Data Source / Drill? / Data Timing and Availability / Historical Retrieval Time / Inclusions/Exclusions / Targets / Trend Line / Calculation
NOV’s, citations, exceedances / Self Reported – Regulatory Affairs / By location / Quarterly – one month lag – 5th work day / Metric dates back to 1/1/01 / - Includes all reported occurrences
- Excludes occurrences that are not reported / See target section / N/A / Total count of NOV’s, citations, and exceedances per month
Comments

Drawbacks / Shortcomings of Data

  • Data is self-reported – metric does not include occurrences that are not reported
  • Regulatory agency activity lags occurrences
  • Due to self-reporting, the metric will be reported monthly, but submitted to OSG quarterly with a one month lag

Known Plans for Improvement or Other Future Changes

  • None

Miscellaneous Comments

  • None

How will exceptions be analyzed?

  • Questions have to be deferred to the Regulatory Affairs team
Migration Plan to Phase II

Need to upload spreadsheet to common data repository for extraction to electronic dashboard

Effective Date: August 2004Rev. # 1Mandatory  Discretionary 

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