Part Four of a five-ingredient recipe for creating a successful stormwater program. This series of posts comes from Bill Robinson, Founder and President of Stormwater Risk Management, LLC (SRM) and ComplianceWise Technologies, LLC in Denver, Colorado. Bill also serves as Treasurer of the Mountain States Chapter of IECA.
In this series of posts, we’re talking about the Recipe for Compliance Program Success. You can see all of the “ingredients” in this series using the links in the next paragraph.
In previous posts in this series, we talk about the important ingredients of (1) making a corporate commitment to implement a (2) standardized stormwater management system and (3) provide the training and tools to enable employees to achieve clearly communicated system performance goals. With a standard management system in place, performance measurement is not only possible but is relatively easy to do and is critical to achieving desired results.
Remember that a well-designed management system will yield acceptable permit compliance when fully implemented. Developing a meaningful implementation measurement criteria is as simple as identifying the major elements of the management system that address the highest risks for regulatory enforcement.
For example, one of the most common reasons for penalty assessment is missing permit-required documentation. This also happens to be the easiest type of violation to prevent. Your management system should require all facilities to organize permit-required documentation in the same way according to the standard tabs provided. When these tabs are properly filled with facility-specific information, they should always meet minimum regulatory expectations. In this example, the company can now quickly measure and know whether the responsible parties met all expectations (good), some expectations (change?), or no expectations (bad). Checking and objectively scoring this aspect only takes a few minutes because everything should be easy to find. To keep it simple, we have found limiting the scoring to black and white, or gray is the best. This method usually provides enough information to make any needed course corrections.
In our method, we measure 12 key aspects of our standard compliance management system which the client has adopted. After many years of refinement, we have found that this is the right amount to measure for us to be able to guarantee a zero-enforcement goal for our clients, as long as their scores meet our minimum expectations. As regulatory focus regularly changes, we can easily change the focus of our system audit to match. It only takes us about 30 minutes to audit the client’s system implementation every month, regardless the size of the project. And because our system is digital, we can audit the system from anywhere with internet access.
With a simple, unbiased measurement system in place, a fair and effective accountability system can be put in place, which is the final ingredient in our recipe for a successful stormwater compliance management system. Accountability completes the loop back to corporate commitment and maintaining ongoing corporate involvement. I will discuss the importance of accountability systems in my next post.