What are the benefits of being an Extraordinary Environmental Enterprise?
Facilities achieving Extraordinary Environmental Enterprise or E4 status are eligible for all of the benefits of the Exemplary Environmental Enterprise or E3 level, including recognition and technical assistance. In addition, as a result of legislation adopted by the 2005 General Assembly, on a case-by-case basis, E4 facilities may be eligible for "alternative compliance methods". Please contact Sharon Baxter at skbaxter@deq.virginia.gov for more information.

What must a facility provide to DEQ to achieve Extraordinary Environmental Enterprise status?
Participation in VEEP is on a facility by facility basis. The E4 level of the program was established by legislation adopted by the 2005 General Assembly that became effective on July 1, 2005 . As outlined in the legislation, in order to participate as an E4 facility, a facility must: (1) have implemented and completed at least one full cycle of an EMS as verified by an independent third party; (2) have a record of sustained compliance with environmental requirements; and, (3) have committed to measures for continuous and sustainable environmental progress and community involvement. Any facility that has been accepted into EPA's Performance Track will be deemed an E4 facility.

• Environmental Management System Implementation: The development and implementation of effective EMS is the primary goal of VEEP. DEQ does not prescribe the model or type of EMS or the structure of a facility’s environmental programs. However, DEQ is responsible for verifying that each facility accepted into VEEP meets the program criteria. Therefore, each E4 applicant is required to address key points related to its EMS :
  • The facility’s policy statement outlining its commitment to improving environmental quality, stressing compliance with environmental requirements, pollution prevention, training, communication and continuous improvement.
  • An evaluation of the actual or potential environmental impacts and aspects from current or future activities at the facility, including a comprehensive list of impacts and aspects, an explanation of the process used by the facility to determine its significant impacts and aspects, a summary of the most recent impact and aspect review process, and the facility’s schedule for reviewing and reevaluating its impacts.
  • Objectives and targets for addressing significant environmental impacts, including the facility’s goals (or objectives) for addressing its significant impacts and aspects and the projects or tasks that are planned to address each of the significant impacts and aspects (with an implementation schedule).
  • Description of the facility's pollution prevention program, including a comprehensive list of p2 projects and accomplishments, not limited to those which address its significant impacts and aspects and any environmental results and costs savings achieved from past projects if available.
  • Identification of the facility'senvironmental legal requirementsand a mechanism for tracking changes in environmental compliance requirements, including a system for learning about legal requirements and changes in regulations.
  • Description of how the facility defines, documents and maintainsroles, responsibilities and authoritiesfor its environmental management system, including assignments for projects, tasks or reporting responsibilities and upper management involvement or review.
  • Procedures for reporting and record keeping to document the status of EMS operations and activities, including a system for attractive tracking of the EMS .
  • Procedures for ensuring that all employees have the necessary training, including a systematic approach ensuring all employees have role in the EMS .
  • Emergency response procedures for responding to, reporting, mitigating and reviewing incidents, including emergency management program coordinated with local emergency response efforts.
  • Monitoring, investigative and corrective actions for noncompliance with environmental management system.
  • Voluntary self assessments (external or internal auditing system), which may include regular self-assessments, corrective action plans or third party audits.
  • Procedures to communicate with and inform external and internal audiences.
  • Unrelated Third Party Audit : E4 facilities are required to submit documentation showing that they have completed at least one full cycle of their EMS and that it has been reviewed and verified by an unrelated third party. DEQ defines the term to mean that the audit team leader, all team members and the auditing organization must be financially independent from the facility being audited, the auditors must be employed by a separate company than the corporation being audited, and the audit provider cannot have been involved in the development of the facility’s EMS . DEQ requires that third party auditors be qualified for their role in verifying the EMS . There are two categories of qualifications for auditors under VEEP, certification and experience.
• • • Certification: Consistent with EPA’s Performance Track Program, the audit team must be lead by someone who has been certified as an EMS Lead EMS auditor by one of the following organizations as meeting the organization’s certification requirements:
      • Board of Environmental, Health and Safety Auditor Certifications (BEAC)
      • Registratrar Accreditation Board (RAB) – Quality Society of Australasia International (RABQSA) - certification as ISO 14000 Lead Auditor
      • DEQ will also consider certifications from other certifying organizations that are equivalent to or more stringent than the requirements of the above organizations.
  • Experience: Consistent with the requirement’s of EPA’s Performance Track Program, a team leader is considered to be qualified to perform the audit by having the following training and experience in EMS audits:
  • • High school diploma
    • 40-hour RABQMS Accredited ISO 14001 Lead Auditor Training (course examination must have been passed)
    • Work experience in environmental management, environmental science and technology, environmental regulation or related fields as follows:
      • 5 years experience for Leads with high school degree
      • 4 years experience for Leads with college degree
    • Audit experience: 20 work-day equivalents of environmental auditing (including regulatory, compliance assistance, pollution prevention or EMS audits), which includes a minimum of four EMS audits.
      
• Record of Sustained Compliance : Facilities applying to any level of VEEP must have a record of sustained compliance. As defined by Section 10.1-1187.1 of the Code of Virginia, record of sustained compliance means that "the person or facility (i) has no judgment or conviction entered against it, or against any key personnel of the person or facility or any person with an ownership interest in the facility for a criminal violation of the environmental protection laws of the United States, the Commonwealth, or any state in the previous five years; (ii) has been neither the cause of, nor liable for, more than two significant environmental violations in the previous three years; (iii) has no unresolved notices of violations or potential violations of environmental requirements with Department or one of the Boards; (iv) is in compliance with the terms of any order or decree, executive compliance agreement, or related enforcement measure issued by the Department, one of the Boards, or EPA; and (v) has not demonstrated in any other way an unwillingness or inability to comply with environmental protection requirements. DEQ will conduct a review of each applying facility’s compliance record, including a review of EPA records as appropriate.

• Commitment to Continuous and Sustainable Environmental Progress and Community Involvement : E4 facilities are required to document that they have committed to continuous and sustainable environmental progress and community involvement. Each facility’s situation in terms of purpose, location and impacts may prove unique from other facilities.