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Environment
Canada Develops Compliance Analysis and Planning Database
Contributed by Frank Barrett, Program Development Manager, Enforcement
Branch, Environment Canada
March 2003
Environment
Canada (EC) is developing a Compliance Analysis and Planning (CAP)
database to better assess compliance within EC's regulatory framework
and, further, to determine where EC should place priorities to improve
compliance. The CAP database will enable EC 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 EC 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 CAP database: data
capture, risk modeling and sampling methodology.
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Data
Capture
The
CAP database will integrate all existing EC information on
all facilities known to be subject to one or more regulations.
For each facility, the CAP 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 CAP
database will also capture the reported releases of each of
the key substances governed by regulations where this information
is already reported to EC. Facility locations and pertinent
information will also be made available in a GIS format to
EC's enforcement staff. No new information will be sought
from facilities for this initiative. Rather, the CAP 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 EC'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 CAP database will also enable EC to determine
where additional regulatory tools may be most warranted or where
various compliance promotion tools may be most effective. Over time,
EC 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 CAP 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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