Small Business Criteria
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Definition of "Small Business"
To promote participation by small facilities in Performance Track, EPA has changed the small facility designation to include any facility with fewer than fifty full-time employees. This provision would encourage small facilities in larger companies to participate in Performance Track. This program change replaces the Small Business Administration criterion that previously applied to small facilities seeking membership in Performance Track. The requirement for small facilities to a) demonstrate past achievements in one environmental aspect from any category and b) commit to two future environmental performance improvements remains unchanged.
Small businesses have been active participants in innovative programs such as the EPA Sustainable Industries Progam, Design for the Environment, voluntary partnership programs, and EMS projects with local governments. Qualified small businesses, facilities, and local governments are encouraged to participate in the National Environmental Performance Track as well.
Based on input from small business representatives, certain provisions were designed to meet their special needs:
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Environmental
Management Systems. EPA recognizes that
the scope and level of formality of the EMS will vary,
depending on the nature, size, and complexity of the
facility. EPA's experience with a wide variety of
programs suggests that these EMS elements are within
the capability of small facilities and can be met
through a variety of approaches. To help small
facilities implement an EMS, EPA will make guidance
documents and assistance materials available.
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Continuous Improvement. Small
businesses have the option of documenting improvement
for at least
one environmental aspect from any category. In
making future performance goals, small facilities
should select at least
two aspects from
two or more categories.
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Public Outreach and
Performance Reporting. There is no
standard set of outreach activities beyond the the
Annual Performance Report. Each facility's approach to
community reporting beyond the annual performance
report will depend on its size, scale of operations,
and setting. At a minimum, a small facility should be
able to document that it has designated a point of
contact with direct access to facility management and
has adopted procedures for responding to questions or
concerns of local residents.
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Sustained Compliance. Small facilities
need to have a record of sustained compliance in the
same manner as other facilities participating in
Performance Track.
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Annual Performance Reporting to EPA.
EPA is considering providing specialized assistance in
this area for small facilities. A facility should
maintain onsite the supporting documentation used to
prepare its Annual Performance Report and make this
documentation available to EPA upon EPA's request.
EPA has held numerous discussions with representatives of small business interests and is encouraging participation by qualififed small businesses and their facilities.