Enforcement and Data: One New York City Agency’s Vision for a Level Playing Field

By Shari Hyman • August 13, 2013

This guest-authored post was written by Shari C. Hyman, the Commissioner and Chair of the New York City Business Integrity Commission. The post is part of the Regulatory Reform for the 21st Century City project.

Since the mid-1990’s, the Business Integrity Commission (BIC) has occupied a unique position within New York’s vast law enforcement infrastructure. Empowered by a mandate to preserve a level playing field in both the City’s private sanitation and wholesale market industries, BIC has amassed a wealth of intelligence and information on organized crime activity and other forms of corruption in these unique sectors of the economy. This bank of knowledge, which routinely places us at the crossroads of local, state and federal investigations, serves as a key element in the rigorous licensing operations of BIC and is the meat and potatoes of BIC’s ongoing intelligence and auditing functions. Regulating 2,000 individual businesses means that effective data management is essential to provide quality service to the good actors and strategically plan to catch the bad ones. This post is an introductory snapshot. Future posts will provide a detailed look at lessons learned from those charged with forging our path to enable licensing and enforcement decisions driven by data.

Making Data Management Work for Us

BIC’s operations and its 81-person staff largely coalesce around one principal workflow — the licensing of haulers and wholesalers. The application review process is well-established, robust and thorough while the underlying case system is anything but, with 27 unaligned and inconsistent databases comprised of over 5,000 fields and 1 million pages of paper files.

Database Diagram
BIC’s data management system prior to NIMBUS implementation.

Within weeks of my becoming Commissioner, it was readily apparent that the agency was sitting on 20 years of information and data with no discernible way of using it effectively. Systems barely talked, cases lived in hard-drive silos and performance reporting was cumbersome. To effectively “de-silo” this information trove, further improve services and spark new opportunities for investigative work, a new approach to enterprise data management (EDM) was necessary. Wary of a large-scale, multi-year IT project, my primary objectives were cost-effectiveness and a quick build. I hired a Chief Program Officer and together we landed on the Salesforce CRM. Because of its reputed adaptability we could plot out a fully integrated, agency-wide cloud-based system on an aggressive 14-month timeline. The system would undergird agency operations, provide an application and reporting portal for all industry submissions and offer a fully-equipped mobile platform for in the field enforcement. To round out the enterprise strategy, we also successfully scanned nearly 500,000 pieces of our paper files and designed a secure but open document management system that leverages an easy-to-use inventory and file categorization system. In short, we fully expect to have an EDM system that provides data in a responsive and accessible manner to staff that is empowered to take advantage of the information at their fingertips.

Driving Enforcement With Data

Soon into my term, I realized that criminal activity in the waste business is not exclusive to activities by traditional organized crime families (think Gambino, Genovese, etc). In NYC, commercial waste is hauled by a BIC-licensed carter and taken to a permitted transfer station. For normal municipal solid waste, haulers are paid for their services, but with valuable commodity-driven waste they often don’t charge because they can recoup the profits at the dumping site. Because of the increasing value of waste, like paper, scrap metal and yellow grease, a different brand of opportunistic criminals has emerged in those that steal recyclable waste. Since the crime is fairly “anonymous” (who expects somebody to steal their garbage?) and easy to execute (you just need a van and a pair of hands), the returns can be fast and substantial. For example, paper sells at $75 - $100/ton and a pound of unprocessed yellow grease is worth nearly double what it sold for in 2000. As the regulator for the commercial waste sector, I was sympathetic to the “play by the rule” actors who were losing money, but wondered how to address such an invisible crime. With assistance from the Mayor’s Office of Analytics using a hotspot analysis, we cross-referenced our industry data on grease production with restaurant permit data and sewer back-up data from the Departments of Health (DOH) and Environmental Protection (DEP) to better target enforcement and predict illegal activity.

Brown Grease Nonreporters Map
Yellow Grease heat map that visualizes potential hotspots of unlicensed activity. The map captures data from BIC, DOHMH and DEP and is being used in ongoing enforcement efforts to tackle illegal activity in the grease hauling industry.

Since launching this partnership effort with DEP in the Fall of 2012, we have achieved an increase in violations by 30% while achieving a 60% reduction in manpower dedicated to grease enforcement. An added benefit is a newly cultivated information-sharing relationship with a non-law enforcement city agency (DEP), which provides enhanced intelligence about criminal behavior in the industry. We are confident that our new EDS system will offer us better ways to manage critical agency resources and point to ways we can deploy it for other industry subsectors.

Although there is still time before we are fully up and running (and we are excited to share those stories), this has already been an eye-opening and transformational experience for the agency. We are very confident that these approaches and systems will continue to generate gains for our law enforcement and regulatory activities while ensuring that we are making life easier for the good guys and tougher for the bad ones.

Learn more about BIC in our Annual Report.


About the Author

Shari Hyman

Shari C. Hyman was appointed Commissioner and Chair of the Business Integrity Commission by Mayor Bloomberg in November 2011.  Between 2006 and 2011, Commissioner Hyman served in multifaceted positions in the Bloomberg Administration.  Immediately prior to her appointment as Commissioner, she served as a Chief of Staff to the Deputy Mayor of Operations, Senior Counsel and Director of Business Acceleration where she focused on streamlining City operations to help small businesses, including the design and implementation of the New Business Acceleration Team (NBAT), a multi-agency program enabling new restaurant and retail owners to open their doors more quickly through a consolidated and coordinated inspection process. Commissioner Hyman also served as First Deputy Criminal Justice Coordinator in the Office of the Criminal Justice Coordinator as well as Director of the Mayor's Office of Special Enforcement (OSE), a multi-agency taskforce dedicated to handling quality of life issues city-wide where she garnered international attention for anti-counterfeiting efforts on Canal Street in operation “counterfeit triangle.” Commissioner Hyman also has extensive criminal justice experience having served as an Assistant District Attorney in the Manhattan District Attorney’s Office for over a decade.  Commissioner Hyman holds a JD from Northwestern University and a BA from Columbia University.