BasicsBenefitsData Wild Card Compliance

Who Runs The ISGP? Basics for 100

Back to Game The ISGP is run by a six person Oversight Committee comprised of industry (2), regulator (2), service provider (1) and vendor (1).

Who Makes Decision Of Providing Benefits? Basics for 200

The ISGP Oversight Committee has the responsibility of recommending benefits for participants. The Oversight Committee will coordinate with parties offering benefits (i.e. POTW and IDNR) Back to Game

How Much Time Does A Participant Have To Achieve The ISGP Goals? Basics for 300

There is no time limit established. Higher level benefits are only available to participants making significant progress in reaching the ISGP goals. The faster the goals are reached, the sooner the participant can enjoy the associated benefits. Back to Game

What Happens If A Participant Decides To Drop Out Of The ISGP? Basics for 400

Back to Game The ISGP is a voluntary program, therefore are no requirements or penalties for dropping from the ISGP. Participant name and associated information will be removed from the database and ISGP benefits will no longer be readily available.

Will The ISGP Ever Change It’s Goals Or Procedures? Basics for 500

Back to Game The Oversight Committee has the responsibility for maintaining the ISGP. The ISGP can be modified by the Oversight Committee if the need arises.

Are All ISGP Benefits Available To All Participants? Benefits for 100

Most benefits are available to all ISGP participants. However, some of the benefits are to be provided by the POTW. These benefits will only be available if your local POTW agrees to offer the benefits. The ISGP Oversight Committee will coordinate with participant’s POTW in an effort to offer the maximum available benefits. Back to Game

What Is The ISGP Performance Ladder? Benefits for 200

Back to Game The ISGP Performance Ladder is a tool to provide higher level recognition and benefits as a participant increases progress toward the ISGP goals. The ISGP Performance Ladder consists of Bronze, Silver and Gold levels.

Must A Participant’s POTW Sign Up For the ISGP Before Benefits Can Be Received? Benefits for 300

No. However, some benefits may not be available without POTW participation (i.e. reduced monitoring to federal minimums). Back to Game

Benefits for 400 Must A Participant Make Progress On All Of The ISGP Goals Before They Can Move Up The Performance Ladder?

No. Progress on each of the ISGP goals is determined and an average calculated. The average is used to determine placement on the Performance Ladder. Back to Game

Benefits for 500 Will A Participant Automatically Receive The Low Inspection Priority Benefit Upon Achieving Gold Level Status?

Prior to receiving the Low Inspection Priority benefit, the participant must complete and submit the “ISGP Request for Low Inspection Priority” form. The benefit becomes available to the participant upon IDNR signing the form. Back to Game

True or False. Participants In The ISGP Will Have Facility Information and Submitted Data Provided To EPA Inspectors. Compliance for 100

Back to Game False. Facility information will be maintained by IDNR Pollution Prevention Services and submitted process data will be maintained by the National Metal Finishing Resource Center (NMFRC). EPA inspectors do not have access to the NMFRC database.

True or False. A Facility Must Be In Compliance Before It Can Sign Up For The ISGP. Compliance for 200

False. However, some benefits will not be available until compliance has been achieved. Back to Game

Compliance for 300 What Happens To A Participant On The Performance Ladder That Is Inspected And Found In Violation?

All cases are reviewed by the ISGP Oversight Committee and addressed on a case-by-case basis. Major violations may result in the participant placed in the Bronze level (entry level) until compliance has been achieved. Serious unresolved compliance issues may result in dismissal from the ISGP. Back to Game

Compliance for 400 Will The Low Inspection Priority Benefit Prevent The “Regulators” From Inspecting A Participant?

No. The Low Inspection Priority benefit will reduce the chance of a “random” inspection. But, the enforcement agencies will still have authority to inspect…especially for programs requiring mandatory inspections or situations where human health or the environment may be at risk. Back to Game

Compliance for 500 What Penalties Are Assessed Against Participants Not Achieving ISGP Goals?

There are no penalties associated with the ISGP. All participant progress is voluntary. However, participants will not be eligible to receive all benefits unless significant progress has been made. Back to Game

Data for 100 What Must A Participant Do To Begin Receiving ISGP Benefits?

Participant must complete and submit the ISGP Statement of Commitment to begin receiving “entry level” benefits. The ISGP Worksheet (which establishes baseline and identifies progress toward ISGP goals) must be completed and submitted before participant can become eligible for higher level benefits. Back to Game

Data for 200 Who Maintains ISGP Worksheet Data?

All data from the ISGP Worksheets are maintained by the National Metal Finishing Resource Center. As a service to ISGP participants, the IDNR Pollution Prevention Services will review worksheets to ensure completeness before forwarding to the NMFRC. Back to Game

Data for 300 What Is The Baseline For The ISGP Goals?

Each participant will establish their own baseline. This is done by selecting a baseline year (up to five years ago) and including the information on the ISGP worksheet. The baseline data will then be used to determine participant’s progress. Back to Game

Data for 400 What Does IDNR and IWRC Do With Information Collected During The Free Assistance Visits?

Information collected will only be used to assist the participant. Iowa Code requires that confidential process or business related information will be protected and held as confidential. Back to Game

Data for 500 Does EPA Receive A Copy Of The Participant’s Worksheet?

Back to Game No. Only the INDR Pollution Prevention Services and the National Metal Finishing Resource Center will have access to the worksheet data.

Wild Card for 100 True or False. The ISGP Was Created By The U.S. EPA.

False. The U.S. EPA initiated discussions with the stakeholders. But, the ISGP was developed by a group of stakeholders consisting of industry, POTWs, service providers, IDNR and the U.S. EPA. Back to Game

Wild Card for 200 Is There A Fee Required To Participate In The ISGP?

No. The ISGP is offered at no cost to the participant. Back to Game

Wild Card for 300 Is The ISGP Only Open To Metal Finishers?

No. Anyone with an interest in achieving the ISGP goals or assisting the participants in achieving the goals is welcome to sign up. Back to Game

Wild Card for 400 Why Are EPA, IDNR and the POTWs Interested In The ISGP?

Each of the regulatory agencies involved are interested in environmental protection. By helping metal finishers to reduce waste and operate more efficiently, environmental benefits are realized. Back to Game

Wild Card for 500 Participants With An EMS Can Receive A 20% “Credit” Toward Higher Level Benefits. Why The Emphasis On EMS?

Back to Game Participants with an Environmental Management System in place have made a commitment to improvement and may have previously addressed many of the waste reduction and conservation opportunities, making it difficult to achieve the ISGP goals. The “credit” levels the playing field with participants that may not have addressed waste and resource conservation issues.