Creating a Culture of Environmental Compliance and Ethics at Your Utility

Recently, the Pittsburgh Water and Sewer Authority (PWSA) has undergone a transformation in many areas of its operation. In December 2020, PWSA entered into a Plea Agreement with the U.S. Department of Justice after an investigation established eight criminal counts related to past false statements and Clean Water Act violations which occurred under prior management. On September 14, 2021, PWSA was convicted on those charges and immediately entered into an Administrative Agreement with EPA's Office of Suspension and Debarment. This presentation will provide a review of the imposed requirements under the Plea and Administrative Agreements, demonstrating the far-reaching impacts to an organization when staff exhibit non-compliant behaviors. The aspects of an effective Environmental Compliance and Ethics Program, including policies, training, organizational changes, environmental compliance manual and auditing will be reviewed for attendees to consider for their own utilities. PWSA's current leadership has developed an Environmental Compliance and Ethics Program to prevent improper activities by 1) creating a culture of environmental compliance and ethics, 2) detecting non-compliant activities at an early stage, and 3) allowing for a swift response to those identified issues. There are five key components to PWSA's program: 1.Mission Statement and Core Values: These include the core value of 'Ethics and Integrity'. 2.Organizational Structure: Creation of an executive position focused on environmental compliance and ethics which reports directly to the CEO and Board. 3.Codes and Policies: Revision and creation of new Ethics, Conduct, Non-Retaliation, and Whistleblower codes and policies. 4.Environmental Compliance Manual: Creation of a document outlining regulatory obligations for water, wastewater, stormwater, chemical and fuel storage, waste management, and air quality which includes the use of auditing to confirm compliance. 5.Training: Creation of training policies, implementation of a cloud-based training platform, and conducting environmental compliance, ethics, and safety training for staff. These five key components will be discussed in detail and implementation tips and lessons learned will be shared with attendees. This information can be used by any size water utility to develop the foundation for their commitment to operating in accordance not only with the strict requirements of the law, but also in a manner that is consistent with high ethical and professional standards in the delivery of services to their customers.