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Environment
Canada Develops Compliance Analysis and Planning
Database
Environment
Canada (EC) is developing a Compliance Analysis
and Planning database to better assess compliance
within Environment Canada's regulatory framework
and, further, to determine where Environment Canada
should place priorities to improve compliance.
The Compliance Analysis and Planning database
will enable Environment Canada to report on industry
compliance by facility, industry, sector, regulation
and size of company (i.e. small, medium, large).
It will also provide a powerful analytical tool
for Environment Canada to establish its regulatory
enforcement priorities.
In
a past newsletter, Environment Canada reported
on a research project it is currently conducting
to measure outputs, outcomes and environmental
indicators associated with enforcement activities
within the agricultural and mining sectors. See
David Pascoe, Environment
Canada: Outputs, Outcomes, and Environmental Indicators
 ,
INECE Newsletter No. 6, p. 10 (2002). In response,
EC launched a national initiative to build EC's
compliance and enforcement capacity, one that
will integrate existing databases to enable more
meaningful analyses of compliance data and, consequently,
better plan enforcement activities. There are
three key elements to the Compliance Analysis
and Planning database: data capture, risk modeling
and sampling methodology.
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Data
Capture
The
Compliance Analysis and Planning database
will integrate all existing Environment
Canada information on all facilities known
to be subject to one or more regulations.
For each facility, the Compliance Analysis
and Planning database will incorporate pertinent
data from various sources to describe the
facility and its regulatory requirements
pursuant to the Canadian Environmental Protection
Act (CEPA) and the pollution provisions
of the Fisheries Act (Sec. 36). For example,
industrial classification codes (NAICS &
SIC), facility size and geographic location
will be captured along with which regulations
apply to the facility and the related compliance
promotion and enforcement actions for each
regulation.
The
Compliance Analysis and Planning database
will also capture the reported releases
of each of the key substances governed by
regulations where this information is already
reported to Environment Canada. Facility
locations and pertinent information will
also be made available in a Geographic Information
Systems (GIS) format to Environment Canada's
enforcement staff. No new information will
be sought from facilities for this initiative.
Rather, the Compliance Analysis and Planning
database will integrate a myriad of facility-related
information that is already available through
numerous sources.
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Risk
Factors
Key
to the planning capabilities of the database
is the characterization of factors associated
with risks of the individual facility to
human health or the environment. These risk
factors include environmental indicators,
the facility's compliance history, length
of time since the last inspection, and information
on the facility or company obtained through
other sources. Each facility will be scored
on each of several calculated fields, such
as the total volume release of toxic substances,
the number of years since the previous site
inspection and the number of regulations
that apply to the facility. Through the
combination of these factors each facility
in the database will be ascribed a risk
factor score.
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Sampling
Methodology
Total
risk factor scores by industry sector; regulation
and other types of information (e.g. size
of firm) will help to inform national and
regional priorities for inspections. Once
these priorities are established, they will
be used to further weigh facility risk factors.
Annual inspection plans will be developed
through a statistical sampling plan based
in part on the total risk factor scores.
For example, a facility with 100 risk factor
points would be far more likely to be selected
for inspections as one with only 10 points.
In this way, all facilities subject to one
or more regulations could be subject to
inspection but the probability of a facility
being included in the next inspection cycle
will depend on its total risk factor score.
Specific sampling protocols will also incorporate
geographic clustering and regional inspection-resource
availability. The compliance results of
the sample will then be extrapolated to
the population, providing the estimate,
precision, and confidence level (e.g. 80%
compliance, + or - 10%, 19 times out of
20).
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Analyses
of regulatory and inspection coverage, as well
as compliance rates, will further contribute to
Environment Canada's establishment of enforcement
priorities. For example, industries with low inspection
coverage, size of facilities associated with low
compliance rates, or regulations for which compliance
rates have fallen could all lead to increased
enforcement efforts in the future. The Compliance
Analysis and Planning database will also enable
Environment Canada to determine where additional
regulatory tools may be most warranted or where
various compliance promotion tools may be most
effective. Over time, Environment Canada plans
to use this database to assess the contribution
of enforcement efforts, relative to other factors,
to industry-wide changes in pollution-related
practices and, ultimately, to improvements in
the environment.
The
Compliance Analysis and Planning database is expected
to be operational by Summer 2003 and will continue
to be enhanced over time. For more information,
please contact Frank Barrett, Environment Canada,
at Frank.Barrett@ec.gc.ca.
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