Integrated Waste Management Enforcement Program:
Clarifying Goals and Performance Expectations Would Improve Enforcement Coverage
A Report from the City Auditor
Issued September 2023
http://www.sanjoseca.gov/auditor
1 Background
• The IWM Enforcement team enforces
Municipal Code and contractual requirements to resolve solid waste management issues. • Typical cases include dangerous
accumulation, improper set out of containers, illegal hauling, and other issues. • The team has five positions to respond to
complaints and conduct outreach with residents and businesses. 2 Example of Dangerous Waste
Accumulation, a Common Case Type
Finding I: ESD Should Clarify the Mission and Workload
Expectations of the IWM Enforcement Team
3 • A decline in public complaints
has contributed to lower workload.
• Work in other areas has
declined, including shifting enforcement of illegal dumping to Planning, Building and Code Enforcement. 0 400800
12001600
2018 2019 2020 2021 2022 2023*
Unauthorized haulerOtherNo collection serviceIllegal dumpingDangerous AccumulationContainer/other, setout Complaints and Caseload Have Changed Over Time
* Through June 30
Finding I: ESD Should Clarify the Mission and Workload
Expectations of the IWM Enforcement Team
4 • In the first half of 2023, each inspector was
conducting about 2.3 inspections per day, which is below expectations. • New responsibilities, such as outreach or
enforcement related to new legislation or existing ordinances, have been added to the team’s responsibilities.
RECOMMENDATIONS:
To focus and prioritize the team’s work, ESD should:• Clarify the mission and goals and create success metrics for the team.
• Set performance expectations for
inspectors and monitor inspector performance.
• Update procedures to clarify
expectations for inspector activities around illegal dumping and no service collection.
Finding 2: Proactive Cases Should Focus on Expanding
Coverage Citywide
• Proactive cases largely follow the same
geographic trends as solid waste complaints, resulting in a risk of underreported issues in some parts of the city. • Updated procedures would enable the team
to better reach communities that may have underreported solid waste violations, and tailor outreach materials appropriately. 5 RECOMMENDATIONS:
To better expand coverage citywide, ESD should:• Update the team’s proactive procedures to refocus the team’s work on areas with fewer complaints, using factors such as multi-family and commercial density.
Finding 3: Streamlining Administrative Tasks Would Give Inspectors More Time in the Field
• The software platform that the team uses is
outdated and was not designed for their needs, making data entry complicated and time consuming. • Clarifying expectations for other activities
can lead to efficiencies and maximize time in the field. 6 RECOMMENDATIONS:
To maximize the time that inspectors can spend in the field, ESD should:• Procure a new software solution that allows for more streamlined data entry and management. • Update procedures around
identifying responsible parties.
Conclusion
This report has seven recommendations to improve the City’s Integrated Waste Management (IWM) Enforcement Program’s service delivery.
We would like to thank the Environmental Services Department, along with the City Attorney’s Office and the City Manager’s Budget Office, and staff from Planning, Building & Code Enforcement and Parks, Recreation & Neighborhood Services.
The audit report is available at www.sanjoseca.gov/auditor Audit staff: Alison Pauly, Michael O’Connell Jr., and Maria Valle 7