&EPA
United States Office of Enforcement and EPA 315-R-99-003
Environmental Protection Compliance Assurance November 1999
Agency
Environmental Management
Review (EMR) National Report:
Lessons Learned in Conducting
EMRs at Federal Facilities
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SEPA
This document was prepared by EPA's Federal Facilities Enforcement Office (FFEO)
in the Office of Enforcement and Compliance Assurance. The study was directed by
James Edward and Sarah Hart. Technical research, writing, editing, and document
design/layout support was provided by SAIC under EPA contract No. 68-C6-0027.
For additional copies of this document, please contact:
The Federal Facilities Enforcement Office (2261 A)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
Tel: (202)564-2510
Fax: (202)501-0069
Copies of the document also can be obtained on-line at the FFEO Web site:
http://www.epa.gov/oeca/fedfac/fflex.html
In addition, updates to the document will be available on-line.
Acknowledgment
The Federal Facilities Enforcement staff gratefully acknowledges the contributions of
EPA's Program Offices and the Regions in reviewing and providing comments on this
document.
Limitations of This Document
This document is written to serve as a basic reference. Due to the rapidly changing
area of environmental law, the reader is advised to consult the current version of the
relevant statute or regulation for the most accurate information. Where the actual text
of a statute, regulation, executive order, policy, guidance or other document differs
from the description of such documents contained in this document, the actual text of
the statute, regulation, executive order, policy, guidance or other document should be
followed. This document does not constitute rule making by the Agency and may not
be relied upon to create a right or benefit, substantive or procedural, enforceable at law
or in equity, by any person. The Agency may take action at variance with this
document and its internal implementation procedures.
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TABLE OF CONTENTS
Section 1 - Overview -3-
1.0 Introduction -3-
1.1 The Future of EMRs -4-
1.2 Purpose of this Report -5-
1.3 EMRs and Their Role in Compliance Assistance Activities -5-
1.4 EMRs and the CEMP -6-
1.5 EPA Position Statement on EMSs and ISO 14001 -8-
1.6 Lessons learned -8-
Section 2 - EMR Background -11-
2.0 Policy Development -11-
2.1 EMS Standards & Guidelines -12-
2.2 Benefits of an EMR -13-
Section 3 - EMR Pilot Program Methodology Assessment and Lessons Learned -17-
3.0 Goals of the EMR Pilot Program -17-
3.1 Different Regional Approaches to EMRs -18-
3.1.a EPAPhase 3 Audit Protocol Approach -21-
3.1.b EPAPhase 3 AuditProtocol/CEMP approach -21-
3.2 Lessons Learned -21-
3.2.a The IVRP did not result in enforcement actions or penalties at any
facility receiving an EMR during the pilot program -21-
3.2.b Difficult to Stay within the Selected EMR Scope -21-
3.2.c Ample preparation time is critical -22-
3.2.d Avoid surprises -22-
3.2.e Conduct pre-site visit meetings with site representatives -23-
3.2.f Post-EMR evaluations help build a better EMR program -23-
3.2.g Inform interview personnel of the EMR process as soon as possible . . -23-
3.2.h Neutral on-site escorts can facilitate candid discussions -23-
3.2.i Mixed EMR team with management and technical expertise worked
best -24-
3.2.J Produce report in a timely manner -24-
3.2.k Note that an EMR is a snapshot in time -24-
3.3 Federal facility comments/feedback on the Pilot Program -24-
3.4 How Lessons Learned Resulted in Changes in the EMR Policy -25-
27-
Section 4 - Summary of Federal Facility EMR Findings
4.0 Overview of findings and recommendations in EMR reports -27-
4.0.a Strengths of facility EMSs -27-
4.0.b Main areas for improvement of the facility EMSs -28-
4.1 Recommendations implemented by facilities -31-
Section 5 - Conclusion -33-
Appendices -35-
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APPENDIX A - EMR Case Studies -37-
APPENDIXB - Final EMRPolicy -47-
APPENDIX C - Process steps for a sample EMR -59-
APPENDIX D - EMR Tools and Related Compliance Assistance Resources -61-
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SECTION 1
OVERVIEW
This section provides background information on EMRs, explains the purpose of this
report, and provides the primary EMR Pilot Program lessons learned.
1.0 Introduction
Since its inception in 1970, the Environmental
Protection Agency (EPA) has used a variety of
methods to help regulated organizations
understand and comply with environmental
regulations. During the agency's formative
years, the regulated community primarily
sought explanations of the relatively new
regulations, as organizations reacted to changes
in the regulatory environment. However,
during the past decade, it has become
inefficient for organizations to simply react to
regulatory changes and issues of
noncompliance.
An EMR is "a review of an individual
facility's program and management
systems to determine the extent to which
a facility has developed and
implemented specific environmental
protection programs and plans which, if
properly managed, should ensure
compliance and progress towards
environmental excellence."
EPA's Final EMR Policy
December 1998
In increasing numbers, public and private
sector organizations changed their focus from
reactive to proactive, choosing to prevent
pollution at the source. With fewer resources
available to them, facility managers used
improved tools to address complex
environmental issues and to help ensure their
site's long-term environmental compliance.
Many environmental managers chose to revise
their management systems to proactively
address environmental issues. In conjunction
with this paradigm shift, EPA increased the
types and numbers of compliance assistance
activities offered. One new tool added to
EPA's compliance assistance tool kit for
federal facilities was the Environmental
Management Review (EMR). This report is
intended to give federal facility managers new
insights into the EMR process, describe how a
review can benefit managers, and provide
information on the results of and lessons
learned from EMRs conducted at federal
facilities during EPA's EMR Pilot Program,
which began in May 1996 and ended in
September 1998.
As defined in EPA's Final EMR Policy for
Federal Facilities., an EMR is "a review of an
individual facility's program and management
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systems to determine the extent to which a
facility has developed and implemented
specific environmental protection programs
and plans which, if properly managed, should
ensure compliance and progress toward
environmental excellence." The majority of
the EMRs conducted during the pilot program
did not review a facility' s entire environmental
management system (EMS); rather, the focus
was generally on selected portions of the
facility's systems. The facility staff and the
EPA Region determined how much of the
system was to be reviewed during each EMR.
1.1 The Future of EMRs
Given the increased interest in the pilot
program, EMRs are slated to be an integral
part of EPA's compliance and technical
assistance toolbox at federal facilities for
years to come. Agencies appreciated the
technical assistance, the ways in which EMRs
heightened environmental awareness at
facilities, and how the EMRs focused on
addressing environmental issues via a
systematic approach. EPA and the regulated
community alike recognize that it is more
efficient to identify and address environmental
matters before they become compliance issues.
While compliance inspections will continue,
EPA will also emphasize working
cooperatively with federal facilities, using
management system-based approaches, to
reduce the facilities' environmental impacts in
the most effective manner possible.
EMRs are not regulatory inspections.
However, when a facility volunteered to
participate in the EMR program, it also agreed
to abide by the program's Incidental Violations
Response Policy (IVRP). This policy
recognized that there may be circumstances
when an EMR incidentally uncovers violations
either through document review or while on
site. The IVRP described how violations
would be treated if they were incidentally
uncovered at a federal facility participating in
the EMR program. Although some of the
participants raised concerns about the policy,
there were no enforcement actions taken or
Agencies Receiving an EMR
During the Pilot Program
Air Force
Army (2)
Army Corps of
Engineers(2)
Army National Guard
Bureau of Indian
Affairs
Bureau of Prisons
Coast Guard (2)
Department of
Agriculture
Department of Energy
Department of the
Treasury
Environmental
Protection Agency (3)
Federal Aviation
Administration
Federal
Emergency
Management
Agency
Fish & Wildlife
Service (2)
National
Aeronautics &
Space
Administration
National Park
Service
Navy (2)
U.S. Postal Service
(3)
U.S. Mint
Veteran's Health
Administration
fines assessed as a result of EMRs conducted
during the pilot program.
EPA encourages agencies to participate in the
EMR program. The primary audience for this
report is the federal facility managers
responsible for ensuring compliance with
applicable environmental regulations. The first
step in becoming a participant is to contact the
appropriate EPA Regional Federal Facility
Coordinator. Appendix D provides contact
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information for those coordinators.
1.2 Purpose of this Report
To comply with Executive Order (EO) 12088
(Federal Compliance with Pollution
Standards), EPA's national and regional
federal facility programs supply technical
assistance to federal facilities to ensure cost
effective and timely compliance with
environmental regulatory requirements. EPA
initiated a pilot program in 1996 to determine
if EMRs were a useful tool for EPA staff to
add to their compliance assistance toolbox for
federal facilities.
EPA Regions 1, 6, and 10 conducted EMRs for
several years prior to the pilot program.
Twenty-nine reviews were conducted at
federal facilities in seven EPA regions during
the nationwide two and a half year pilot
program. Twenty different federal agencies
participated. The pilot program enabled EPA
personnel to apply the lessons learned from
conducting EMRs and, in turn, modify the
program to better suit the needs of future
participants.
Examples of Compliance
Assistance Activities
Activity
EMR
PPOA
Compliance Audit
Focus Areas
Management Activities
Processes & Materials
Compliance with
Environmental
Regulations
1.3
Provides background information on
EMRs;
Describes the essence of the EMR
Pilot Program;
Highlights the lessons learned from the
program; and
Forecasts the future of EMRs and their
role in EPA's compliance assistance
program.
EMRs and Their Role in Compliance
Assistance Activities
This report:
EPA compliance assistance information and
activities seek to ensure that the regulated
community understands its regulatory
obligations. An effective compliance
assistance program helps protect public health
and the environment by making it easier for
regulated entities to comply with applicable
regulations. EPA's compliance assistance
tools often include compliance audits,
pollution prevention opportunity assessments,
and EMRs.
Compliance audit teams review a facility's
activities and processes and determine if any
of the activities or their by-products meet the
applicable environmental regulatory
requirements. The subsequent audit report
identifies the compliance gaps.
During a pollution prevention opportunity
assessment (PPOA), the technical assistance
providers review a facility's processes,
focusing on material inputs and wastes
generated, and work with the facility personnel
to develop a list of projects that reduce or
eliminate waste at the source.
Alternatively, an EMR focuses on the ways in
which a federal facility manages its activities
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to decrease or eliminate the site's
environmental impact, and how environmental
considerations are formally woven into its
processes and activities. It focuses on the
system of policies and procedures the facility
consistently uses to address environmental
issues and maintain compliance with
environmental regulations. The team reviews
documents and interviews facility personnel to
better understand the existing environmental
management system (EMS), analyzes the
system to identify and describe its strengths
and areas for improvement, and recommends
ways to enhance the effectiveness of the
system. While the areas of focus may differ,
all three of these compliance assistance
activities benefit the federal community by
assisting facility environmental management
efforts.
1.4 EMRs and the Code of
Environmental Management
Principles
The Code of Environmental Management
Principles for Federal Agencies (CEMP),
developed by EPA in response to Executive
Order (EO) 12856 (Federal Compliance with
Right-to-Know Laws and Pollution Prevention
Requirements), is a collection of five broad
principles (management commitment,
compliance assurance and pollution
prevention, enabling systems, performance and
accountability, and measurement and
improvement) and underlying performance
objectives that federal agencies can use as a
guide to move toward effective environmental
management.
Environmental management systems can be
based on and compared to different sets of
standards or guidelines. As the list below
demonstrates, a variety of EMS standards or
guidelines exist worldwide. Some of these are
used to develop systems for federal facilities
throughout the United States:
Generic Protocol (Phase 3) for
Conducting Environmental Audits at
Federal Facilities
Code of Environmental Management
Principles for Federal Agencies
(CEMP)
International Organization for
Standardization (ISO) 14001
International Chamber of Commerce's
(ICC) Business Charter for Sustainable
Development
Chemical Manufacturer's
Association's Responsible Care
Guidelines
Protocols for Conducting
Environmental Management
Assessments of DOE
Organizations
EMR participants should take steps to
ascertain which standard or guideline should
be used during the system review. The facility
needs its parent agency or personnel at
headquarters to determine if one guideline
would be better than the rest. Federal facilities
should also keep in mind that 16 agencies
endorsed the CEMP, which may make the
CEMP the best choice for use in developing an
EMS. Lastly, each facility should determine
which one of the guidelines best matches the
site's existing management system structure.
Each standard or guideline examines a system
from a slightly different point of view and
emphasizes different parts of a management
system. Later in this report (Section 2.1), there
is an outline on the approach for three of the
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primary standards. For example, the Generic
Protocol (Phase 3) for Conducting
Environmental Audits at Federal Facilities1
touches on but does not focus on a system's
ability to address emergency management
issues, however, the Implementation Guide
for the Code of Environmental Management
Principles for Federal Agencies2 has an entire
section devoted to emergency preparedness.
Differences such as this do not make one
standard superior to another; they simply
provide examples of the various lenses through
which one can view an EMS.
In early September and October 1996, the
International Organization for Standardization
published the first five standards in the ISO
14000 series of environmental management
system standards. On September 1, 1996, ISO
officially published ISO 14001,
"Environmental Management Systems -
Specification with Guidance for Use." The
ISO 14001 standard specifies requirements for
establishing an environmental policy,
determining environmental aspects & impacts
of products/activities/services, planning
environmental objectives and measurable
targets, implementing and operating programs
to meet objectives & targets, establishing a
program for checking and correcting
environmental programs, and conducting
management system reviews.
1 This document (EPA Document No.
300-B-96-012 A&B) can be obtained by
contacting the U.S. EPA Federal Facilities
Enforcement Office at 202-564-2461.
2 This document (EPA Document No.
315-B-97-001) can be obtained by contacting the
U.S. EPA Federal Facilities Enforcement Office at
202-564-2461.
Standards and Guidelines By Which
U.S. EMSs Are Developed
Federal Facilities Phase 3 Protocol for
Conducting Environmental Audits at
Federal Facilities
CEMP
ISO 14001
International Chamber of Commerce's
(ICC) Business Charter for Sustainable
Development
Chemical Manufacturer's Association's
Responsible Care Guidelines
Protocols for Conducting
Environmental Management
Assessments of DOE
Currently, federal facility EMRs are based on
either the Generic Protocol (Phase 3) for
Conducting Environmental Audits at Federal
Facilities or the CEMP. Thus, EMR teams
used either one of the two standards or a
combination of the two to guide them through
the review process. Section 2.1 of this report
provides details on the linkages between the
two standards, and Section 3.1 describes the
different methods and standards used by the
EPA regions.
1.5 EPA Position Statement on EMSs
and ISO 14001
On March 12, 1998, EPA published in the
Federal Register (63 FR 12094) its Position
Statement on EMS and ISO 14001. In that
Position Statement, EPA encourages:
The use of EMSs that focus on
improved performance, compliance,
source reduction, and system
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performance;
Organizations to maintain
accountability for the performance
outcomes of their EMSs through
measurable objectives and targets;
The development of EMSs through an
open and inclusive process with
relevant stakeholders;
Dissemination of information on the
actual performance of EMSs to the
public and government; and
The review of EMSs to achieve
superior environmental performance.
The Position Statement quotes verbatim from
the North American Commission on
Environmental Cooperation (CEC) Council
Resolution #97-05 which states that, "adoption
of EMSs based on ISO 14001 may foster
improved compliance and performance, but
does not constitute or guarantee compliance or
in any way prevent governments from taking
enforcement action where appropriate." At
this time, EPA does not base any regulatory
incentives solely on the use of EMSs, or
certification to ISO 14001.
The Federal Register notice also solicits
comment on the categories of information and
data that will be gathered through ISO 14001
pilot projects, including environmental
performance, compliance, pollution
prevention, environmental conditions,
costs/benefits to implementing facilities, and
stakeholder participation and the effect that
such participation has on the public credibility
of EMS implementation.
1.6 Lessons Learned
During the course of the pilot program, many
lessons were learned about the EMR process
itself, and common strengths and weaknesses
of environmental management systems at
federal facilities. The information below
highlights what is explained in greater detail
throughout the rest of this report.
EMR Process Lessons Learned
The IVRP did not result in enforcement
actions or penalties at any facility
receiving an EMR during the pilot
program,
It is difficult to stay within the selected
EMR scope,
Ample preparation time is critical,
Avoid surprises,
Conduct pre-site visit meetings with
site representatives,
Post-EMR evaluations help build a
better EMR program,
Inform personnel to be interviewed of
the EMR process as soon as possible,
Neutral on-site escorts can facilitate
candid discussions,
Combine management and technical
expertise in an EMR team for best
results,
Produce reports in a timely manner,
and
Note that an EMR is a snapshot in time.
Common EMS strengths among federal
facilities
Personnel acknowledge their
environmental responsibilities and are
committed to protecting the
environment;
Field staff routinely review facility
environmental performance;
Agencies participate in cooperative
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environmental programs with other
organizations; and
Environmental considerations are
incorporated into most planning
processes.
Common EMS areas for improvement
among federal facilities
Agencies and facilities lack adequate
environmental staff and formal, annual
training plans and mechanisms to track
individual training needs and
accomplishments;
Facilities lack formal environmental
management programs;
Facilities lack facility-specific
environmental policies, goals,
objectives, or targets;
Facilities lack commitment to going
beyond compliance; facilities seek
only to meet compliance requirements;
Work being done does not match job
descriptions and performance
evaluations;
Lessons learned (positive and
negative) are not shared with other
federal facilities, let alone with
facilities within the same agency;
Line and staff personnel are not asked
for their opinion during the policy
development process;
Tenant organizations are not held
responsible for adhering to a site's
EMS; and
Management is not aware of the work
being done to minimize the site's
impact on the environment.
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SECTION!
EMR BACKGROUND
This section discusses the development of the Final EMR Policy, shows the relationships
between different EMS standards and guidelines, and describes the benefits and the future
ofEMRs.
2.0 Policy Development
Following a six-month development effort, the
EMR Workgroup, which included staff of the
Federal Facilities Enforcement Office (FFEO),
the EPA Assistant Administrator for
Enforcement and Compliance Assurance, and
Federal Facility Coordinators from eight EPA
regions, issued the Interim EMRPolicy on May
31, 1996. Prior to issuance, the Interim Policy
was formally reviewed by staff of the Office of
Enforcement and Compliance Assurance
(OECA) and the Regions.
The EMR Pilot Program began shortly
thereafter to test the policy and guidance at
individual federal facilities. Twenty-nine
EMRs were conducted by seven Regional
offices during the pilot program. Comments on
the draft Final EMR Policy and guidance were
received from OECA and regional offices, and
revisions were made based on the concerns
raised. A list of the major changes made to the
Interim EMR Policy is included below, and
those changes are further explained in Section
3.3 of this report.
Changes Made To The
Interim EMR Policy
Facilities must disclose within 10
days violations incidentally
discovered through the EMR
process.
EPA will generally not conduct
inspections at the participating
facility for six months after the
EMR.
The facility must submit only one
report to EPA.
Only EPA 's signature is needed on
the EMR confirmation letter.
EPA can take various enforcement
responses in response to discovered
violations.
EMR's relationship to ISO 14001
and the Code of Environmental
Management Principles (CEMP)
The Final EMR Policy (Appendix B)
incorporates the lessons learned from the pilot
program reviews.
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MR Background
2.1 EMS Standards & Guidelines
As noted earlier, there are numerous standards
and guidelines used by organizations to guide
them through the EMS development process.
The Generic Protocol (Phase 3) for
Conducting Environmental Audits at Federal
Facilities breaks a system into seven parts, or
disciplines:
1. Organizational Structure
2. Environmental Commitment
3. Formality of Environmental Programs
4. Internal and External Communications
5. Staff Resources, Training, and
Development
6. Program Evaluation, Reporting, and
Corrective Action
7. Environmental Planning and Risk
Management
The Code of Environmental Management
Principles (CEMP), developed by EPA in
response to the President's Executive Order
(EO 12856) and in conjunction with personnel
from 16 federal departments and agencies,
breaks environmental management into five
primary components of an effective EMS:
1. Management Commitment
2. Compliance Assurance and Pollution
Prevention
3. Enabling Systems
4. Performance and Accountability
5. Measurement and Improvement
Lastly, the ISO 14001 standard views an EMS
from a different set of five areas:
1. Environmental Policy
2. Planning
3. Implementation and Operation
4. Checking and Corrective Action
5.
Management Review
Even though the primary EMS standard and
guideline headings are not an exact match,
there are a great number of similarities among
the standards and guidelines. Table A
provides information on the correlation
between the EMR protocols, ISO 14001
sections, and the CEMP.
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E,
MR Background
TABLE A
CORRELATION BETWEEN EMR DISCIPLINES, THE CEMP PRINCIPLES, AND SECTIONS OF ISO 14001
EMR DISCIPLINE
Organizational Structure
Environmental Commitment
Formality of Environmental
Programs
Internal & External
Communications
Staff Resources, Development,
and Training
Program Evaluation, Reporting, &
Corrective Action
Environmental Planning & Risk
Management
CEMP PRINCIPLE
1
1
2&3
3
3&4
3&5
2&3
ISO 14001 SECTION
3
1
1,3, & 4
3
3
4&5
2&3
2.2 Benefits of an EMR
A facility will discover that its EMS becomes
a much more powerful management tool if
continuous improvement is woven into the
management system's framework. A system
should be dynamic, with procedures, policies,
job descriptions, and performance reviews all
changing as the organization evolves. There
are numerous ways to update a facility's
management system; two of the more common
are: 1) an annual internal EMS review and
revision, and 2) an annual review conducted by
an outside party. An EMR is an example of the
second method (the EMR process steps are
located in Appendix B).
By working collaboratively with EPA, a
facility can obtain many benefits from a review
of its system. The first benefit is that it is a
voluntary and inexpensive way to determine
the health of a facility's EMS. A compliance
inspection is a reactive, mandatory method
used by EPA to address a facility's
environmental problems. However,
Benefits of an EMR
It is a collaborative & inexpensive
means to enhance a facility's EMS
An outside party can discover issues
overlooked by busy facility staff
EPA 's wealth of regulatory and
technical environmental expertise is
made available to the facility
The facility benefits from EPA 's
ability to facilitate root cause
analysis exercises
It can lead to long-term
environmental
compliance and enhanced
management accompanied by
resource reduction
It provides feedback on the
effectiveness of a facility's system,
benchmarks the facility's
performance, and identifies
opportunities for improvement.
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MR Background
volunteering for a free EMR creates a
partnership between the facility and EPA. In
fact, EPA officials view the reviews as a way
to work together with facility staff to enhance
the way they have chosen to systematically
address environmental issues. The partnership
created or improved by the EMR often helps
break down communications barriers and
provides evidence that EPA is no longer
simply a command-and-control organization.
EPA views federal facilities as customers and
believes that EMRs are yet another useful way
to partner in the effort to reduce the
government's environmental impact. EPA has
transitioned from a command-and-control
agency to one encouraging collaboration and
cooperation with other agencies.
Second, it is relatively easy for a facility to
overlook an EMS's deficiencies, especially if
there are no current noncompliance issues
attributed to them. Many organizations find
that a management system review conducted by
an outside party uncovers areas of the EMS
that could be improved, even after an internal
review did not reveal such problems.
A third benefit to the facility is the opportunity
to take advantage of EPA's regulatory and
technical knowledge in a non-threatening
environment. Granted, the official scope of an
EMR is generally confined to the review of
management systems that are designed to
address environmental matters. However,
while the EPA team is on-site, facility
personnel are encouraged to open the lines of
communication by asking questions about
environmental issues, e.g., compliance issues
and pollution prevention opportunities, in
order to tap into the wealth of environmental
knowledge and expertise available to the
facility. In addition, the on-site portion of the
review facilitates discussions between the
Regional Federal Facility Coordinator and the
facility personnel. These conversations often
introduce facility personnel to many of the
initiatives, conferences, and outreach activities
offered by EPA of which facility staff are often
unaware.
Fourth, in addition to uncovering deficiencies
not yet discovered, an EMR team also can help
the facility work through root cause analysis,
identifying underlying causal factors which
may contribute to environmental program
deficiencies. For example, it is generally easy
to find that a staff member has not been
properly trained on environmental matters.
However, it takes more time and effort to
determine that the root cause of the problem is
a faulty training schedule database. EPA's
management system review experience,
combined with the facility personnel's
background knowledge of the facility's EMS,
produce a strong team that can efficiently
identify a deficiency's origin. Facilities
become better equipped to proactively identify
and minimize environmental impacts, in the
context of shrinking budgetary allocations.
With a trend toward downsizing in the
government, facility managers need better tools
to handle complex issues when resources
decrease. EMRs enable a facility to optimize
its system, which in turn helps to ensure long-
term environmental compliance and
improvements in environmental issue
resolution.
Another benefit is that EMRs often provide
feedback on the effectiveness of a facility's
environmental management system. It can help
a facility establish baselines so that it can
benchmark its performance, and identify
opportunities for improvement.
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MR Background
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15
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jMR Pilot Program Methodology Assessment and Lessons Learned
SECTIONS
EMR PILOT PROGRAM
METHODOLOGY ASSESSMENT AND LESSONS LEARNED
This section describes the goals of the EMR Pilot Program, describes the different
approaches to conducting EMRs, explains the lessons learned, and identifies the major
changes to the EMR Policy.
3.0 Goals of the EMR Pilot Program
EPA is always searching for better ways to
serve its customers. After passage of the
Pollution Prevention Act of 1990 and the
signing ofExecutive Order 12856 in 1993, the
agency focused its efforts on creating programs
to help federal facilities conduct PPOAs,
develop pollution prevention plans, train
personnel, and implement projects. In a
similar fashion, EPA developed the EMR Pilot
Program in response to the growing interest in
environmental management systems. During
the mid-1990s, environmental experts
worldwide were touting the advantages of the
facility environmental management system. In
response to international interests, ISO 14001
was drafted and the standard became final in
September 1996. On a parallel path, EPA
issued the Interim Final EMR Policy and began
the EMR Pilot Program in May 1996.
EMRs were conducted at federal facilities in
the early 1990s in EPA Regions 1, 6, and 10.
In addition, one of the recommendations in the
1994 Civilian Federal Agency (CFA)
Environmental Task Force Report was that
EPA provide more on-site compliance
assistance via a comprehensive EMR program
in all ten EPA Regions.
One of the goals of the pilot program was to
determine how federal facilities would react to
a nationwide review program. It was unclear
how receptive they would be and how willing
they would be to voluntarily grant EPA access.
The facilities targeted for the pilot program
were generally smaller sites, which may not
EMR Pilot Program Goals
Determine types/sizes of facilities
where EMRs are most effective
Determine federal facility's
reaction to/willingness to
participate in the program
Determine if future EMRs had to
include the entire facility EMS
Test different EMR methodologies
Gain experience and incorporate
lessons learned into the Final EMR
Policy
have the resources to develop an EMS on their
own. Since some of the CFA sites had limited
experience interacting with EPA prior to the
EMR Pilot Program, another goal was to
determine how they would react to EPA's
outreach efforts.
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jMR Pilot Program Methodology Assessment and Lessons Learned
A third goal of the pilot program was to
ascertain whether or not a facility's EMS could
be reviewed discipline-by-discipline.
Depending on the size and complexity of the
facility, a comprehensive management system
audit could take more than a week to complete
and cost more than double of what a traditional
EMR costs. As noted earlier, the majority of
the pilot program EMRs did not review entire
systems, instead they focused only on certain
management systemdisciplines (e.g.,
Communications, Environmental Commitment).
Closely related to the third goal was the fourth
Questions To Be Answered
By The Pilot Program
What should be the process for
conducting EMRs?
How would the Incidental Violation
Response Policy (IVRP) affect the
program and its acceptance?
Upon which standard (i.e., the
Federal Facilities Phase 3 Protocol
for Conducting Environmental
Audits at Federal Facilities, the
CEMP, or ISO 14001) should the
EMRs be based?
What should be the format of the
follow-up reports?
Who should sign the confirmation
letter (and should there even be a
confirmation letter)?
goal, which was to test different EMR
methodologies to determine if one methodology
was more successful than another. Section 3.1
further explains the different approaches used
by EPA Regional Federal Facility
Coordinators.
A final goal of the pilot program was to
identify areas within the interim EMR policy
that could be improved upon in order to craft a
more complete final policy. That goal was
achieved by identifying the pilot program's
lessons learned and using them to develop the
final policy. The team charged with interim
policy development relied on the experience
gained from the limited number of reviews
conducted in the early 1990s and the
experience gained from being part of the ISO
14001 development process. However, there
were still questions to be answered: What
should be the process for conducting EMRs?
How would the Incidental Violation Response
Policy (IVRP) affect the program and its
acceptance? Upon which standard should the
EMRs be based - the Federal Facilities Phase
3 Protocol for Conducting Environmental
Audits at Federal Facilities, the CEMP, or
ISO 14001? What should be the format of the
follow-up reports? Who should sign the
confirmation letter (and should there even be a
confirmation letter)? EPA's plan was to
answer these and other questions by conducting
EMRs and basing its answers on facts rather
than supposition. EPA took full advantage of
the nationwide program by allowing each
Regional Federal Facility Coordinator to
determine the ways in which EMRs would be
conducted in the region. By providing regions
with thi s flexibility, EPA could then understand
the strengths and identify the weaknesses of
each unique approach.
3.1 Different Regional Approaches to
EMRs
Each Regional Federal Facility Coordinator
had a slightly different vision regarding how
EMRs should be conducted. The matrix in
Table B summarizes the methodologies used by
each region during the pilot project. Once
again, the pilot program provided an
opportunity to use different review
methodologies and use the lessons learned
from the different approaches to formulate the
final EMR policy.
Some of the facilities that were asked to
participate in the pilot program were
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jMR Pilot Program Methodology Assessment and Lessons Learned
concerned about the IVRP. It should be noted
that no enforcement actions were taken and no
fines were issued under the IVRP during the
pilot program. However, EMRs were
instrumental in highlighting ways in which
facilities could improve their processes and
potentially reduce their environmental
liabilities. During the course of the interview
and document review process, EPA teams
helped facilities identify potential
environmental problems. In addition, the EMR
assisted EPA personnel in focusing on which
compliance assistance tools and activities
would most benefit the facility in the future.
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'MR Pilot Program Methodology Assessment and Lessons Learned
TABLE B
REGIONAL EMR METHODOLOGIES
Region
Region 1
Region 2
Region 3*
Region 4
Region 5
Region 6
Region 7*
Region 8
Region 9
Region 10*
Protocol Used
Combination of the
EPA Phase 3 audit
Protocol and the
CEMP
Developed a unique
protocol for the USPS3
based on EPA Phase 3
audit Protocol
N/A
Combination of the
EPA Phase 3 audit
Protocol and the
CEMP
EPA Phase 3 audit
Protocol
EPA Phase 3 audit
Protocol
N/A
EPA Phase 3 audit
Protocol
EPA Phase 3 audit
Protocol
N/A
Average
On-site
Time
One day
Two days
N/A
Two days
Two days
Two days
N/A
Two days
Two days
N/A
Average
Number of
Disciplines
Reviewed
All (5)
1
N/A
All (5)
2
3
N/A
3
3
N/A
Number of
Pilot EMRs
12
3
N/A
3
2
5
N/A
2
2
N/A
IVRP
Incidents
None
None
N/A
None
None
None
N/A
None
None
N/A
* Regions 3, 7, and 10 did not conduct EMRs during the 2.5 year EMR Pilot Program. However,
Region 10 conducted one EMR in FY 93.
3 As requested by the customer, EPA Region 2 created a new discipline (Environmental Policy
Implementation) based on the seven existing EPA Phase 3 Audit Protocol disciplines, for the United States
Postal Service (USPS) EMRs.
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jMR Pilot Program Methodology Assessment and Lessons Learned
3.1.a EPA Phase 3 Audit Protocol
Approach
The column labeled "Protocol Used" in Table
B indicates the type(s) of protocol used by
each EPA region. Of the seven EPA Regions
participating in the EMR Pilot Program, five
used the Generic Protocol (Phase 3) for
Conducting Environmental Audits at Federal
Facilities as the basis for their review, while
the other two Regions elected to use a protocol
that was a hybrid of the Generic Protocol
(Phase 3) for Conducting Environmental
Audits at Federal Facilities and the CEMP. In
general, those Regions opting to solely use the
Generic Protocol (Phase 3) for Conducting
Environmental Audits at Federal Facilities
elected to limit the review to two or three of
the seven disciplines. All but one of the EMRs
were conducted with the understanding that the
facility already had an environmental
management system and the EPA team was
tasked to critique it. However, one facility
told the team prior to its on-site arrival that the
facility did not have an EMS; this facility
asked EPA to assess the facility's processes
and recommend how the facility should create
a management system.
3.1.b EPA Phase 3 Audit Protocol/CEMP
approach
Two regions (Regions 1 & 4) chose to create
and use a protocol that was a hybrid of the
Generic Protocol (Phase 3) for Conducting
Environmental Audits at Federal Facilities
and the CEMP; this approach split an EMS into
five disciplines. In addition, these regions also
reviewed each facility's entire system, instead
of focusing on certain parts of the EMS. By
giving the regions flexibility in the EMR
methodology they used, EPA was able to
determine the strengths and weaknesses of the
different approaches.
3.2 Lessons Learned
One of the primary goals of the EPA pilot
program is to determine how the program
could be optimized and where EMR team
members should look for potential pitfalls.
The 29 pilot program reviews not only
identified areas for program improvement, but
also highlighted potential problem areas in the
EMR process of which team members should
be aware. The following, in no particular
order, describes these areas.
3.2.a The IVRP did not result in
enforcement actions or penalties at
any facility receiving an EMR during
the pilot program
Some facilities raised concerns about the IVRP
prior to the EMR team going onsite. The
primary concern was that by voluntarily
allowing an EPA representative onsite, the
facility would increase the likelihood of
incurring a fine or having an enforcement
action brought against it. However, there were
no cases where the IVRP was invoked, and no
enforcement actions, fines, or penalties were
issued during the pilot program. These data
underscore the point that an EMR is not an
enforcement inspection and does not increase
a participant's environmental liability.
3.2.b It is difficult to stay within the
selected EMR scope
It was difficult to stay within the confines of
the EMR scope in instances where only partial
EMS reviews were conducted. For example,
in one review, two disciplines (Organizational
Structure and Communications) were the focus.
However, after reviewing certain documents
and interviewing a few key personnel, it
became apparent that a lack of formality in
environmental programs was one root cause
for the problems in the two focus areas. Thus,
the EMR was altered in mid-course, with a
third discipline added to the scope to help
benefit the facility as much as possible.
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jMR Pilot Program Methodology Assessment and Lessons Learned
In addition, it takes a great amount of effort to
stick to the EMR scope because there is
overlap among the seven disciplines. For
example, questions concerning training
(discipline number five) link with questions
pertaining to environmental commitment
(discipline number two). If there is a lack of
environmental commitment, then often there are
lapses in the facility's environmental training
regimen. In this instance, the team must decide
whether to ask questions pertaining to the
facility's lack of environmental commitment
(out of the scope's boundaries), or stick to the
prescribed disciplines for review and risk
doing a disservice to the customer. Since the
final policy did not change on this matter in that
it still describes an EMR as a partial system
review, team members should be flexible and
willing to alter the scope of the review if it is
agreeable to all parties involved (i.e., the
facility and the EMR team).
3.2.c Ample preparation time is critical
Since the EMR is usually something facility
personnel have to do in addition to their daily
duties, it is best to start the review process two
months prior to the on-site visit. Facilities
unfamiliar with environmental management
reviews need extra time to understand the EPA
program's goals and objectives, answer the
pre-site visit questionnaire (see Appendix D
for a sample questionnaire developed by
Region 1), gather relevant documentation and
send it to the EMR team, assist in the creation
of an interview list, and confirm the
availability of the potential personnel to be
interviewed.
It is also beneficial for everyone involved if a
list of milestones is developed prior to
commencement of the EMR process; this helps
reduce confusion regarding submittal dates.
Lessons Learned
The IVRP did not result in
enforcement actions or penalties at
any facility receiving an EMR
during the pilot program
It is difficult to stay within the EMR
scope
Ample preparation time is
critical/create milestones
Avoid surprises
Conduct pre-site visit meetings with
site representatives
Post-EMR evaluations help build a
better EMR program
Inform personnel to be interviewed
of the EMR process as soon as
possible
Neutral on-site escorts facilitate
candid discussions
Combine management and technical
expertise in an EMR team for best
results
Produce report in a timely manner
Note that an EMR is a snapshot in
time
3.2.d Avoid surprises
Trust is a key issue in EMRs. The facility has
volunteered access to its site. It is very
important to obtain facility buy-in to the EMR,
and to ensure the facility is not surprised by
any part of the review process. For example,
the facility should know well in advance which
federal and state EPA staff is anticipated to
participate. In addition, the EMR's scope
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jMR Pilot Program Methodology Assessment and Lessons Learned
should be well established prior to the team's
arrival, and should be changed only after
consulting with appropriate facility personnel.
If substitutions or changes must be made close
to the on-site visit date, the facility must be
given the chance to veto the change or cancel
the review. Surprising a facility can lead to a
long-term distrust of EPA and its associated
activities, which is the exact opposite of the
EMR program's intentions.
3.2.e Conduct pre-site visit meetings with
site representatives
Each federal agency has its particular mission
and each facility is unique. It is important that
EMR team members understand both the
agency's mission and the facility's daily
activities (especially those activities linked
with potential or actual environmental impacts)
prior to arriving for the on-site visit.
Gathering and reviewing this vital information
prior to the on-site visit allows the team to
focus on confirming through document review
and interviews what they know should be
happening. In addition, site representatives are
usually the people supplying the team with the
information; the time spent talking with team
members about the facility eases facility
personnel's anxiety and gives the facility staff
a sense of ownership of the review EMR
process.
3.2.f Post-EMR evaluations help build a
better EMR program
Continuous improvement concepts should also
be built into the EMR process. After
conducting the review, EPA Federal Facility
Coordinators should solicit facility's responses
to the management review process. For
instance, EPA could encourage facilities to
incorporate their thoughts on the value of the
EMR into the six-month facility report
submitted to EPA, or the participants could fill
out a post-review evaluation form (see
Appendix D for a form used in EPA Region 8).
The ensuing comments and insights can identify
which elements of the EPA program are
strongest and which could be improved.
3.2.g Inform personnel to be interviewed
of the EMR process as soon as
possible
Since the EMR team is usually on-site for only
a day or two, time management is a key
ingredient of a successful review. The ultimate
scenario is for the team members to interview
personnel who 1) comprehend the EMR
process and understand why the review is
being conducted, and 2) have copies of
tangible evidence (e.g., pages from a training
database and associated procedures to keep the
database updated) of a formal EMS that they
can provide to the EPA team members. This
scenario permits the team members to ask
questions instead of answer them.
3.2.h Neutral on-site escorts can facilitate
candid discussions
A facility usually has one or two people (e.g.,
environmental managers) who are in charge of
the site's environmental programs. Facility
personnel recognize this and sometimes tout the
environmental manager's accomplishments
during an interview if the manager is in the
same room as the person being interviewed.
Personnel being interviewed tend to be more
candid and forthcoming with information and
anecdotes about the environmental program
when a neutral person acts as the team's escort.
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jMR Pilot Program Methodology Assessment and Lessons Learned
3.2.1 Combine management and technical
expertise in an EMR team for best
results
Although an EMR is focused on the ways in
which a facility manages activities to achieve
and maintain environmental compliance,
technical environmental questions often arise
during the course of an EMR site visit. It
benefits both the team and the facility if, prior
to the on-site visit, the facility identified its
environmental permits/compliance
requirements. The team leader could then
ensure one of the EMR team members is
knowledgeable of the facility's processes or of
its permits/compliance requirements (or both).
3.2.J Produce report in a timely manner
It is beneficial to complete the EMR report in
a timely manner and submit it to the facility for
their review and response. Facility personnel
often have numerous duties, so it is important
to report as quickly as possible on the strengths
of a facility's EMS as well as its areas for
improvement. Facilities are more apt to
implement EPA's recommendations if the on-
site review experience is still familiar to
facility personnel.
3.2.k Note that an EMR is a snapshot in
time
The beginning of an EMR confirmation letter
should stress that a review is a snapshot in
time and will discover items of concern that in
the future may not be problems at all. A few
facilities requested that EPA delete certain
negative report findings because the facility
was either "planning on working on the
problem," or "working on the problem."
Instead of deleting these items, EPA generally
noted at the beginning of the report that an
EMR was an assessment of a dynamic
organization and that EPA is reporting on the
state of the facility's EMS at a given point in
time based on interviews with select personnel
and document reviews.
3.3 Federal Facility Comments/
Feedback on the Pilot Program
The following are general comments from
personnel whose facilities participated in the
EMR Pilot Program:
Federal Facility EMR Feedback
It gave the environmental staff a forum to
advance EMS ideas within a structured
framework.
It is easier to "sell" an EMS [to upper
management] that is looked on favorably
by EPA.
The EMR team was very well regarded
Communication was highly rated.
The EMR was helpful and better than
expected.
The EMR was a great tool for federal
facilities to build relations with the
regional EPA federal programs.
The EMR is also a good program to
receive a friendly environmental
management audit, which ultimately will
help the facility's environmental
programs succeed.
Some of the evaluation results were
difficult to assess.
The site would have benefitted from more
information on the EMR protocol.
Better planning and coordination would
have given the EMR team a better
snapshot picture of the site.
We encourage all EMR members to sign
the confirmation letter.
The facility should provide a neutral
escort for the EMR team interviews.
The process needs to be explained in a
laymen's format. Higher managers that
are not environmentally trained don't
understand the concept of EMS.
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jMR Pilot Program Methodology Assessment and Lessons Learned
Upper management likes to focus on the
areas for improvement, not on the
strengths of the EMS. EPA should find
some way to highlight the positives (e.g.,
a proclamation or certificate signed by
the EPA Region Director).
Get buy-in from top management as soon
as possible.
3.4 How Lessons Learned Resulted in
Changes in the EMR Policy
Once the EMR pilot program was completed,
EPA Regional Federal Facility Coordinators
and other regional staff, and OECA HQ
personnel submitted comments regarding
changes that should be made to the interim
EMR policy. Numerous changes were made to
the interim policy and guidance, many of which
were editorial revisions for clarification, or
were the result of merging the originally
separate EMR Policy and the EMR guidance.
However, there were six significant revisions:
Changing the number of days the
facility has to disclose incidentally
discovered violations
The interim EMR policy required
facilities to disclose violations
incidentally discovered during the
review within 30 days. The final EMR
policy and guidance changed that
requirement to 10 days to ensure
greater consistency with the EPA audit
and self-disclosure policy.
Adding that inspections may be
waived for six months after an EMR
Facilities were concerned that
voluntarily allowing EPA on-site could
potentially subject the facility to a
subsequent inspection. To allay
concerns, EPA added a provision to
the final EMR policy which states that
EPA generally will not conduct
inspections at the facility receiving the
review for six months, while the
facility prepares its plan in response to
EPA's EMR report. The policy also
describes certain exceptions to this
six-month window (e.g., statutory or
regulatory mandates, tips or
complaints).
Changing the number of facility
reports
The interim EMR policy required the
facility to submit two reports to EPA
after the review; a recommendation
implementation plan within 60 days,
and an implementation status report six
months later. The final EMR policy
reduced the number of reports to one.
The facility must submit an
implementation status report six months
after receiving the final management
review recommendations.
Changing the number of required
signatures on the confirmation letter
During the pilot program, EPA
required a signature from both the
facility and from EPA on the ground
rules letter. In the final EMR policy,
the letter is now being referred to as
the "confirmation letter," and only one
(EPA's) signature is required, although
a facility representative may sign it as
well.
Clarifying that EPA has various
enforcement options under the EMR
Program
Facilities were concerned by the
wording of the IVRP in the interim
policy which implied that formal
enforcement actions are taken for all
types of violations. Considering that
not all violations are the same, EPA
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'MR Pilot Program Methodology Assessment and Lessons Learned
clarified in the final EMR policy that
there are various enforcement actions,
both formal and informal, that EPA can
take in response to violations
discovered during a review.
Adding the relationship between the
EMR protocols, ISO 14001, and the
Code of Environmental Management
Principles (CEMP)
During the pilot program, many facility
personnel asked the EPA teams how
EMRs related to the CEMP or ISO
14001. The existence of different EMS
standards and guidelines show that
there are many ways to analyze an
EMS. The final EMR policy contains a
discussion on the correlation between
the EMR protocols, ISO 14001, and
the CEMP.
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s,
ummary Of Federal Facility Findings
SECTION 4
SUMMARY OF FEDERAL FACILITY EMR FINDINGS
This section summarizes the common findings of the majority of the pilot program EMRs
in terms of the strengths and weaknesses of the facilities reviewed.
4.0 Overview of findings and
recommendations in EMR reports
The facility EMSs reviewed during the course
of the EMR pilot program differed markedly in
thoroughness, formality, and complexity. The
systems ranged from a set of disparate
environmental programs in need of a formal
program, to comprehensive, well documented,
and formal systems. The following information
discusses some common strengths and
weaknesses encountered during the 29 pilot
program EMRs.
4.0.a Strengths of facility EMSs
Personnel acknowledge their
environmental responsibilities and
are committed to protecting the
environment
Facility staff acknowledge their environmental
responsibilities and care about their site's
and/or their job's environmental impacts. If
given access to appropriate resources and
training, interview results indicate that federal
facility personnel are generally committed to
protecting the environment.
Field staff routinely review facility
environmental performance
Some agencies require audits or formal
reviews of environmental performance on a
three- or five-year schedule. Interview results
from some of the EMRs indicate that facility
managers and/or key staff conduct informal
reviews more frequently. However,
implementation of recommendations from these
reviews is inconsistent because of limited
access to funds and technical assistance.
Strengths of Facilities' EMSs
Personnel acknowledge their
environmental responsibilities and
are committed to protecting the
environment
Field staff routinely review facility
environmental performance
Agencies participate in cooperative
environmental programs with other
organizations
Environmental considerations are
incorporated into most planning
processes
Agencies participate in cooperative
environmental programs with other
organizations
Many federal facilities support a variety of
environmental tracking and outreach efforts in
cooperation with other federal organizations.
For example, federal facility staff monitor air
26
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s,
ummary Of Federal Facility Findings
quality, track migratory birds, and provide
educational programs for local schools.
Environmental considerations are
incorporated into most planning
processes
Federal facilities often undertake new proj ects;
some are insignificant to the environment,
while others have potentially significant
environmental impacts. A mature EMS
incorporates the environmental manager into
the project planning process. The earlier the
environmental manager is able to review
project plans, the less time is wasted on
project revisions and stop-work issues. Many
of the facilities participating in the pilot
program EMRs incorporated environmental
considerations into the project planning
process. However, facilities did this
coordination mainly to satisfy NEPA
requirements, not because it was part of a
larger process of integrating environmental
considerations into everyday activities.
4.0.b Main areas for improvement of the
facility EMSs
Agencies and facilities lack adequate
environmental staff and formal,
annual training plans and
mechanisms to track individual
training needs and accomplishments
Environmental staffing levels at the facility,
regional, and agency level are inadequate to
ensure compliance with environmental
regulations, let alone to provide technical
assistance in pollution prevention and
proactive environmental programs. In
addition, while individual training records
generally are maintained in personnel files,
federal facilities may enhance environmental
performance by reviewing environmental
training needs and developing and monitoring
annual training plans to ensure that staff attend
environmental training necessary or
appropriate to their work assignments.
Facilities lack formal environmental
management programs
The majority of facility personnel described
actions that they take to reduce their site's
environmental impacts. However, the
personnel often indicated that the procedures
described to the EMR team were informal, that
is, not actually written anywhere. While this
method of informal environmental management
may work as long as the personnel remain
constant, it is vulnerable to personnel turnover.
For instance, if a person were to stop working
at a facility, the experience and informal
procedures designed to reduce the employee's
environmental impact would leave with that
person. Anyone replacing that employee
would then have to start from the beginning and
develop new procedures. Facilities should
examine their processes and activities, identify
which have the potential to create significant
environmental impacts, and develop formal,
written procedures to minimize those impacts.
A continuous improvement element also should
be incorporated into the procedures to ensure
the facility periodically looks for ways to
further minimize the processes' impacts.
Facilities can use the Generic Protocol (Phase
3) for Conducting Environmental Audits at
Federal Facilities, the CEMP, or ISO 14001
to develop the procedures.
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s,
ummary Of Federal Facility Findings
Facilities lack facility-specific
environmental policies, goals,
objectives, or targets
Many agencies manage environmental issues
via a "top-down" approach. Environmental
policies are often developed at the
headquarters level and distributed through
organizational channels. However, the
general policies written at the headquarters
Areas for Improvement
for Facility EMSs
Agencies and facilities lack adequate
environmental staff and formal,
annual training plans and
mechanisms to track individual
training needs and accomplishments
Facilities lack formal environmental
management programs
Facilities lack facility-specific
environmental policies, goals,
objectives, or targets
Facilities lack commitment to going
beyond compliance; facilities seek
only to meet compliance
requirements
Work being done does not match job
descriptions and performance
evaluations
Lessons learned (positive and
negative) are not shared with other
federal facilities, let alone with
facilities within the same agency
Line and staff 'personnel are not
asked for their opinion during the
policy development process
Tenant organizations are not held
responsible for adhering to a site 's
EMS
Management is not aware of the
work being done to minimize the
site 's impact on the environment
level lack detailed guidance on implementation
procedures for field facilities as well as site-
specific oversight. Facilities should develop
facility- and process-specific short- and long-
term goals, objectives and targets, and
implementation plans to support and
complement the policies developed by agency
headquarters.
Facilities lack commitment to going
beyond compliance; facilities seek
only to meet compliance
requirements
Most of a federal facility's environmental
metrics are based on the number of violations
or findings of non-compliance issued to a
facility in a given year. Facilities thus take a
reactive, rather than a proactive, approach to
environmental management.
While an EMS is designed to assist a facility in
achieving and maintaining compliance, the
EMRs detected a lack of measurement
elements that can help the facility look beyond
its environmental compliance requirements and
focus on continuous improvement. By initiating
reductions in a site's environmental burdens
and liabilities, an environmental manager can
demonstrate cost savings. A facility can save
money by eliminating hidden costs and seeking
pollution prevention solutions. In addition,
focusing only on compliance can sometimes
cloud an environmental manager's vision as to
the source of a waste or emission problem. A
properly designed EMS employs root cause
analysis techniques to address immediate and
long-term environmental issues.
Work being done does not match job
descriptions and performance
evaluations
Facility personnel's environmental compliance
responsibilities should be incorporated into
basic job descriptions or shop responsibilities
so that performance evaluations are based on
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s,
ummary Of Federal Facility Findings
an accurate job description. Many of the
facility staff interviewed described
responsibilities that were not part of their
position description. Managers usually had
environmental responsibilities as part of their
position descriptions, but environmental
responsibilities were not included in the job
descriptions of other personnel. A complete
EMS effectively delegates environmental
responsibilities to appropriately trained
personnel.
Federal facilities should work with Office of
Personnel Management (OPM) (or supplement
OPM forms) by developing facility-specific
position descriptions and performance
evaluation forms to accurately portray the
responsibilities and expectations of facility
staff.
Lessons learned (positive and
negative) are not shared with other
federal facilities, let alone with
facilities within the same agency
Technology and information transfer was an
afterthought to many of the facilities visited
during the EMR pilot program. Numerous
facilities implemented pollution prevention
projects that both reduced the site's
environmental impacts and saved money.
Successful processes and activities at one site
can be disseminated in the form of case
studies, allowing staff at similar facilities
throughout the country to learn from the lessons
learned. Thus, it would make sense to share
the success stories with fellow federal
facilities both inside and outside individual
agencies. In addition, line and staff were not
familiar with basic environmental information
sources available electronically, such as
Enviro$en$e and the Joint Service P2
Technical Library. The sharing of lessons
learned can be done via electronic bulletin
boards, WWW sites, e-mail, and memoranda.
Line and staff personnel are not
asked for their opinion during the
policy development process
Successful environmental management
programs often have buy-in both at the top of
the organization and also at the line and staff
level. Worker's attitudes about implementing
a new policy change dramatically when the
line and staff worker has been given the
opportunity to help shape that policy. In
addition, line and staff personnel are often the
most knowledgeable about a process and are
best able to determine how a proposed policy
will affect operations and environmental
management issues. Facilities should create
policy development procedures that solicit
employee input through the use of committees
or open suggestion processes.
Tenant organizations are not held
responsible for adhering to a site's
EMS
Federal agencies often share building space
with other federal agencies or have tenant
organizations located within their installation's
boundaries. If the site's landlord has not fully
integrated all tenants into its EMS, the landlord
may not know when/if a tenant is in danger of
environmental noncompliance. All tenants,
contractors, and concessionaires should be
active members of the installation's
environmental committees and communications
distribution lists to ensure tenants receive the
same environmental information as other
installation personnel.
To facilitate oversight, tenants also should be
required to comply with consistent, facility-
wide reporting requirements.
Management is not aware of the
work being done to minimize the
site's impact on the environment
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ummary Of Federal Facility Findings
Top management's environmental commitment
is critical to a successful EMS. If top
management is not familiar with the work of
the facility or regional environmental manager,
commitment and support, both in policy and
funding, may be difficult to obtain. It is crucial
for the environmental manager to report
regularly to the site/facility manager. Top
management should meet with environmental
staff quarterly. Environmental managers
should submit regular reports or provide
briefings documenting progress in compliance
and prevention, as well as current cost savings
and short and long-term policy and funding
needs. A representative of management should
read and sign these reports to indicate
awareness of the environmental status of each
facility.
4.1 Recommendations implemented by
facilities
EPA Regional Federal Facility Coordinators
are just beginning to receive feedback from
facilities that participated in the EMR pilot
program. It is too early in the program to
measure its overall effectiveness and/or to
determine whether or not EPA's
recommendations have been implemented.
EPA plans to follow up with selected facilities
which had EMRs during the pilot program to
examine the impact of actions taken on their
environmental management systems and overall
performance.
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Section 5
CONCLUSION
After reviewing some of the environmental
impacts of processes and activities at federal
facilities, it has become obvious that
environmental regulations alone are not enough
to ensure against environmental degradation.
In addition to enforcing the environmental
regulations, EPA also is expanding its role as
compliance assistance provider - - helping
facilities prevent pollution so that clean-up is
not required at a later date. EMRs are one
element of that compliance assistance process.
The EMR pilot program was created to assist
federal facilities in their environmental
management activities and to implement EPA's
interim final EMR policy. Based on feedback
from the participating facilities, the program
appears to have been a success.
Based on this success, EPA plans to conduct
more EMRs at federal facilities, and will
continue to offer the reviews as an integral part
of EPA's overall compliance assistance
efforts. EPA's goal is to use the management
systemreviewsto further develop partnerships
with other federal agencies, increase EPA's
accessibility to federal facilities, and help
those facilities move beyond compliance in a
systematic manner. As the program matures
and more EMRs are conducted, facilities can
expect a more streamlined and efficient review
process that will offer recommendations
focused on the root causes of environmental
concerns.
EPA looks forward to the opportunity to
continue working cooperatively with federal
facilities through the use of EMRs and other
tools to further reduce their environmental
impacts through a proactive approach to
environmental management.
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A
ppendices
Appendices
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APPENDIX A
EMR CASE STUDIES
This Appendix contains synopses of four EMRs conducted at federal facilities during the
pilot program. The information is provided to help the reader better understand the benefits of
participating in the EMR program and the types of findings and recommendations that can be
expected from the EMR process. Although the actual EMR reports are a matter of public record,
i.e., they can be accessed under FOIA, we chose to highlight only the EMRs findings and
recommendations in a generic manner.
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Site/Facility A
A. Facility overview
The mission of the 35,000 acre site is to conserve
and provide for the enjoyment of the scenery, the
natural and historic objects and the wildlife on
certain federal lands and to leave them unimpaired
for the enjoyment of future generations.
B. EMR Logistics and Scope
During the two-day EMR, the two person team
consisting of the EPA Regional Federal Facility
Coordinator and an EPA contractor analyzed the
site's EMS in conjunction with the site's Chief of
Maintenance, a Maintenance Management
Technician, and the Fire Management
Coordinator/Spill Coordinator.
The protocol used for this EMR was a combination
protocol containing elements of the Code of
Environmental Management Principles (CEMP)
and EPA's Generic Protocol for Conducting
Environmental Audits at Federal Facilities, Phase
3. All five of the protocol's disciplines were
included in this EMR. Those disciplines are: 1)
Management Commitment, 2) Compliance
Assurance and Pollution Prevention, 3) Enabling
Systems, 4) Performance and Accountability, and
5) Measurement and Improvement.
C. EMR Findings and Recommendations
Strengths of the EMS
If funds are available in a department's
operating budget, Maintenance can simply
purchase equipment or initiate new
environmental projects. If funds are not
available in the operations budget, the
Superintendent must pursue funding through
the region and headquarters.
Site staff work very closely with the public in
a continuous effort to enhance the public's
experience at the site. Conservation easements
represent an ongoing local tax issue. The
organization has land use and zoning
information available in GIS format. Recently,
the site completed a visitor experience and
resource protection study focusing on
measurable indicators of and standards for
visitor use that can be used to develop
management strategies. This analysis of visitor
perception of crowding on the carriage road
system utilized computer simulations to analyze
visitor perceptions of resource use. The study
suggested that enforcement of appropriate trail
behavior and visitor education could resolve
concerns. The site produced a video on trail
behavior that is available through local bicycle
shops and on local access television.
The site has clearly defined,
mechanisms to share information.
routine
Each employee creates an annual performance
plan and goals, against which performance is
measured. The system is flexible enough to
allow a Supervisor to incorporate
environmental tasks into the review criteria.
For example, the Chief of Maintenance added
responsibility for identifying less toxic product
substitutes to the performance review criteria
for the Maintenance Foreman.
Areas where the EMS needs improvement
The site's HQ's Office of Environmental
Affairs published pollution prevention fact
sheets on a variety of topics including
automotive service stations. According to site
staff participating in the EMR, they do not
utilize HQ as an information resource and are
not familiar with the HQ's Commitment or fact
sheets. The site does not have a Solid Waste
Management Plan.
The site does not have a full-time staff position
responsible for coordination of environmental
compliance. The site's Administrative Officer,
whose duties include personnel, procurement
and budget, receives written policy updates and
places the information into three ring binders.
It is his responsibility to notify Maintenance
and other Divisions of changes that may affect
their operations. Neither the headquarters or
regional office appears to provide
implementation follow-up to ensure that site
staff has received policy and program updates
and has access to the expertise to identify
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responsibilities and implement them.
The site has not implemented a facility-wide,
formal environmental training plan.
Recommendations
1. Hire a minimum of one FTE to manage the
overall environmental compliance program,
provide on-site technical assistance and
promote pollution prevention at the site.
2. Establish more formal procedures for
environmental management planning and
budget development.
3. Establish formal procedures for annual
environmental compliance audits.
4. Establish a formal, annual training plan
and track individual environmental training
needs and accomplishments to ensure that
all training requirements for staff
performing duties with environmental
impacts are met. Provide additional
funding and opportunities for personnel
environmental training development.
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Site/Facility B
A. Facility overview
The site provides environmental oversight to 36
facilities. The site's primary mission is flood
control for more than 4,600 acres. It maintains
only about 300 total acres; the State Department of
Environmental Management (DEM), Division of
Fish and Wildlife leases 4,000 acres and OEM's
Division of Forests and Parks leases another 200
acres. There are some privately owned properties
within the flood control area, but there are no
habitable structures on these easement lands. DEM
is responsible for public recreation areas and
fisheries on the leased lands; the site provides
oversight but lessees are not required to comply
with the site's regulations.
B. EMR Logistics and Scope
During the two-day EMR, the two person team
consisting of the EPA Regional Federal Facility
Coordinator and an EPA contractor analyzed the
site's EMS in conjunction with the site's
Environmental Compliance Coordinator; the River
Basin Manager; a Project Manager; and a Park
Ranger.
The protocol used for this EMR was a combination
protocol containing elements of the Code of
Environmental Management Principles (CEMP)
and EPA's Generic Protocol for Conducting
Environmental Audits at Federal Facilities, Phase
3. All five of the protocol's disciplines were
included in this EMR. Those disciplines are: 1)
Management Commitment, 2) Compliance
Assurance and Pollution Prevention, 3) Enabling
Systems, 4) Performance and Accountability, and
5) Measurement and Improvement.
C. EMR Findings and Recommendations
Strengths of the EMS
The site's environmental policies and
procedures are codified in the Environmental
Review Guide for Operations (ERGO).
ERGO is a manual containing a series of
checklists that guide staff through the relevant
environmental laws and regulations. The site
published a sub-manual specific to
environmental issues relevant to Civil
Engineering activities.
The site has a career training plan based on job
title requirements.
The staff has initiated a number of community
outreach efforts focusing on the environment.
For example, staff operate a booth at the local
Environmental Expo each year. Staff provide
environmental programs and facility tours for
local schools. The Junior Project Manager
program brings students to the site for a day of
role-playing. During Earth Day, staff traveled
to a nearby town where they supported tree
plantings and water quality education activities.
Project staff conducts an annual internal
review and develops a Corrective Action Plan.
Project staff submits the Plan to a Manager
who reviews it and sends it on to the District
Environmental Coordinator. Staff updates the
Corrective Action Plan every six months, in
October and April. This requirement is spelled
out in the site's Facilities Environmental
Compliance Guidance Letter, "Environmental
Compliance Assessments." During audits,
performance is measured against established
Environmental-Natural Resources and/or
Environmental Compliance Performance
Measures. ERGO checklists guide the
assessment process.
Areas where the EMS needs improvement
Facility employees do not appear to have a
formal method for providing input to
environmental decision making. They are not
represented on the Environmental Steering
Committee.
While an official suggestion program allows
employees to complete a form and send it to
the District, such suggestions may not be
reviewed by staff with authority to proceed
toward implementation of suggestions.
The District Environmental Compliance
Coordinator tries to pass along regulatory
information via e-mail to the four Managers in
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his District and to the local facilities. He issues
memoranda asking whether local offices have
certain listed regulatory information. If they
respond that they do not have the information,
he will provide it. Given his other duties and
limited staff, however, there is not always time
for a comprehensive review of information
needs to ensure that each facility has access to
the appropriate federal, state and local
compliance information as well as the site's
policy memos and updates.
There is no required environmental training for
field personnel. Staff complete annual
Individual Development Plans that may
identify general training interests. However,
there is no specific determination of
environmental training needs. Park Rangers are
regarded as generalists and receive training for
broad responsibilities. The training for this title
is not focused on environmental awareness,
although the individual Ranger may have
responsibility for hazardous waste management
and may sign manifests.
Recommendations
1. Develop a formal environmental policy
and program priority statement for the
project.
2. Improve communications and access to
regulatory information.
3. Seek additional environmental staff
positions at the District and River Basin
levels.
4. Provide additional environmental
training.
5. Pursue additional funding for
environmental programs.
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Site/Facility C
A. Facility overview
The main laboratory complex examined during the
EMR occupies one building which houses offices
and laboratories. The site also maintains a boat
storage pad, fuel storage area, and a hazardous
waste storage area in the back parking lot. The site
conducts field sampling investigations and
laboratory analysis. The planning of the field
investigations and the laboratory analyses take place
at the site. The facility is approximately one year
old.
The site employs 138 people, about half of whom
work in one of the 60 laboratories at the facility.
The remainder of the facility is occupied by offices
for the laboratory and non-laboratory personnel.
To comply with the Solid Waste Disposal Act
(SWDA), non-hazardous solid wastes from all site-
occupied facilities are collected by a contracted
disposal service and disposed of at the local landfill.
The site's main laboratory complex established a
recycling program for mixed-grade waste paper and
for beverage cans. For the paper, each office is
provided with a collection bin while centralized
collection containers are located in Branch offices
and hallways throughout the site. Janitorial staff
collect paper from the centralized bins for pickup
by the local recycling program.
The site has a program to properly dispose of
biomedical wastes, in particular, sharps (e.g.,
needles, syringes with needles, scalpel blades).
B. EMR Logistics and Scope
During the two-day EMR, the two person team
consisting of the EPA Regional Federal Facility
Coordinator, an Army representative, and two EPA
contractors analyzed the site's EMS in conjunction
with the site's full-time Safety, Health, and
Environmental Management Program (SHEMP)
Coordinator, the Maintenance contractor, and
numerous laboratory personnel.
The protocol used for this EMR was a combination
protocol containing elements of the Code of
Environmental Management Principles (CEMP)
and EPA's Generic Protocol for Conducting
Environmental Audits at Federal Facilities, Phase
3. All five of the protocol's disciplines were
included in this EMR. Those disciplines are: 1)
Management Commitment, 2) Compliance
Assurance and Pollution Prevention, 3) Enabling
Systems, 4) Performance and Accountability, and
5) Measurement and Improvement.
C. EMR Findings and Recommendations
Strengths of the EMS
The site has a full-time Safety, Health, and
Environmental Management Program
(SHEMP) Coordinator who works with an
Occupational Safety and Health Committee
(OHSC) comprised of safety, health, and
environmental management representatives
from each of the three branches and three
program offices within the Division. These
representatives set policy for and resolve any
management problems regarding safety, health,
and environmental management. New
environmental initiatives can be implemented
by the OHSC with the approval of senior
management. In addition, there are two people
on staff who act as the Pollution Prevention
Committee. All of these representatives
conduct these duties in addition to the duties
listed in their respective job descriptions.
The site implemented an excellent system used
to track hazardous components of samples to
ensure their proper disposal. This system
provides a foundation for the entire EMS.
Management sets the priorities to ensure that
the EMS is vital to the organization as a whole.
Areas where the EMS needs improvement
The site has established goals and a baseline
for the pollution prevention program, but there
is some question whether other programs, such
as the solvent recycling, are being accurately
measured and benchmarked.
The majority of the environmental
responsibility at the site falls essentially to one
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employee (the SHEMP Coordinator). It may
benefit the site to either delegate those
responsibilities among several employees or
document and formalize all of the
environmental responsibilities to ensure
continuity.
Many procedures are established and acted on
by verbal agreement; sometimes the verbal
procedures confuse employees with minimal
amounts of environmental compliance training.
Recommendations
1. Formalize the verbal agreements and
document these systems so they may be
reviewed and revised, as necessary.
2. Determine whether it is feasible to create a
formal chemical adoption plan. Develop
procedures for working with local labs to
use the site's excess chemicals and materials
if liability and RCRA issues can be
overcome.
3. Create a procedure to have the
Maintenance contractor coordinate with the
SHEMP Coordinator on facility
work/routine maintenance that has an
environmental impact.
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Site/Facility D
A. Facility overview
There are over 20 different organizations using the
site's facilities. These tenants, referred to as
"Resident Agencies," are taking advantage of the
many resources found at the site. The
Environmental Office is in charge of both
overseeing environmental compliance activities and
addressing environmental issues for the site.
The site is also host to a variety of temporary users,
with short-term agreements, using specified
facilities for specified periods of time. These range
from a few days to a few months. The main point
to remember is that the site has a wealth of
capabilities to be used and management is flexible
about the terms of use.
As a shared federal facility, operation costs are
shared by the site and all Resident Agencies on a
pro-rated reimbursable basis. As the airfield
manager, the site is ready, willing and able to
provide additional services to Resident Agencies as
requested.
There are numerous operations and activities at the
site which could create environmental impacts. For
instance, the site is a fully functional federal airport
with all the necessary facilities needed for aircraft
operations. It also maintains a wide variety of
facilities available for military personnel and their
families. Of the site's major activities, the four
which have the greatest potential environmental
impact include: 1) Facility Modifications and Site
Maintenance; 2) Wind Tunnel Testing; 3) Life
Sciences; and 4) Space Sciences.
On September 5, 1995, the site's HQ issued an
Agency-wide environmental policy. In response to
that directive, the site's Environmental Office
worked together with other organization offices in
developing issue-specific environmental policies for
a number of areas.
B. EMR Logistics and Scope
During the two-day EMR, the three person team
consisting of two EPA Regional Federal Facility
personnel and an EPA contractor analyzed the
site's EMS together with staff from the site's
Environmental Office.
The protocol used for this EMR was EPA's
Generic Protocol for Conducting Environmental
Audits at Federal Facilities, Phase 3. The
protocol consists of seven disciplines: 1)
Organizational structure; 2) Environmental
commitment; 3) Formality of environmental
programs; 4) Internal and external communication;
5) Staff, resources, training, and development; 6)
Program evaluation, reporting, and corrective
action; and 7) Environmental planning and risk
management. The goal of the EMR was to
determine how well the site's EMS compared to the
following two disciplines: 1) environmental
commitment, and 2) environmental planning and
risk management.
C. EMR Findings and Recommendations
Strengths of the EMS
The site indicates its pursuit of environmental
excellence through the development of issue-
specific policies, through top management
support, and by delegating environmental
responsibilities to the line and staff level.
Environmental considerations are generally
incorporated into the site's planning processes.
Facility projects and research and development
projects go through an Environmental Division
review prior to commencement.
Areas where the EMS needs improvement
Since the line and staff personnel are in charge
of addressing environmental issues, the site
must ensure that their EMS contains a formal
system to track environmental deficiencies
through closure. Currently, the Environmental
Office is wary of environmental deficiencies,
but it does not formally track those deficiencies
nor how the deficiencies were addressed.
One way the site could improve its
environmental risk management program is to
conduct root cause analysis on environmental
deficiencies to help ensure similar problems do
not arise in the future.
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Recommendations
1. Develop procedures to routinely distribute
environmental information to all site
personnel.
2. Identify what regulations apply to each
activity and ensure the courses provided to
the staff performing task associated with
that activity receive the right type of
training.
3. Create a procedure to update
environmental courses as regulations
change.
4. Develop procedures to ensure
environmental issues have been properly
addressed by line and staff personnel and
contractors once projects are complete.
5. Modify existing hazardous material
procedures to ensure all materials are taken
back during the appropriate time frame.
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APPENDIX B
Final EMR Policy
Environmental Management Review Policy and Guidance for Federal Facilities
In accordance with Executive Order 12088, our national and regional federal facility program has the
responsibility to provide technical advice and assistance to federal facilities to ensure their cost effective and
timely compliance with applicable requirements. In addition, the President called on the federal government to be
the leader in achieving and maintaining a clean environment. The provision of an Environmental Management
Review (EMR) is one increasingly important means of providing this technical assistance for federal sector
leadership.
An Interim EMR Policy was issued in May 1996, and a pilot program was undertaken to test out the
Interim Policy. Numerous EMRs were conducted as part of the pilot program, and this EMR Policy constitutes
the final policy and is based upon revisions determined to be necessary after the pilots. The EMR Policy lays out
the definition of an EMR, the operating principles under which EMRs are to be conducted by the EPA Federal
Facility Program, and the context in which EMRs will be conducted by EPA. The EMR Guidance is a technical
accompaniment to the EMR Policy, and is intended to assist EPA personnel in conducting EMRs.
A. EMR Policy
I. Definition and Benefits of an Environmental Management Review
An Environmental Management Review is a review of an individual facility's program and management
systems to determine the extent to which a facility has developed and implemented specific environmental
protection programs and plans which, if properly managed, should ensure compliance and progress towards
environmental excellence. Because of the programmatic nature of an Environmental Management Review (EMR),
the focus of this review is on the quality and/or implementation of the program, not on actual compliance
requirements. EMRs provide the federal facility information pertaining to:
o Strengths and areas for improvement of environmental management systems and programs at federal facilities;
o Identification of underlying causal factors which may contribute to the occurrence of compliance
deficiencies, and development of long-term environmental compliance by helping to build an environmental
management program foundation;
o Review of each of the individual components of an environmental management system (such as those listed
below); and
o Assistance on the effectiveness of their systems, bench marking their performance, and identification of
opportunities for improvement.
EMRs are not enforcement inspections. The EMRs are technical assistance site visits. They differ from a
compliance inspection or audit, which aim to capture a facility's compliance picture at a given point in time.
EMRs attempt to facilitate an understanding of the underlying causes of current or potential compliance problems
and to develop suggestions for actions to correct them. They attempt to facilitate an understanding of the
environmental management system (EMS) process and identify some of the more obvious weaknesses and
strengths of the facility's existing EMS. EMRs assist federal facilities in developing long-term environmental
compliance by helping to build an environmental management program foundation. EMRs are intended to help
facility personnel understand how real environmental improvements can be achieved, by probing beyond the
immediate symptoms of non-compliance and attempting to identify and address underlying causes such as
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management system deficiencies. Further, they are not intended nor should they replace a facility's own efforts to
self-audit. Finally, an EMR is not a
Pollution Prevention Opportunity Assessment, although a review of a facility's pollution prevention program as it
relates to their environmental management system (EMS) may be conducted during an EMR.
EPA has conducted technical assistance visits at federal facilities as part of its pollution prevention
opportunity assessments program. Now, by conducting Environmental Management Reviews, EPA hopes to
cooperatively provide facilities with advice about effective environmental management. The facility has the choice
as to whether and how to use the advice, but EPA believes that engaging in an EMR visit will foster a good working
relationship between the Agency and the federal facility, encourage a continued dialogue on environmental issues,
and help improve environmental performance.
n. Scope of an Environmental Management Review
The scope of an EMR includes disciplines that are based on key characteristics and elements of effective
environmental management systems. There are a number of common elements for most EMS models. For
example, the Code of Environmental Management Principles for Federal Agencies (CEMP), developed by EPA in
response to Executive Order 12856 and in conjunction with representatives from 16 federal departments and
agencies, includes management commitment, compliance assurance and pollution prevention, enabling systems,
performance and accountability, and measurement and development. The ISO 14001 EMS standard includes
environmental policy, planning, implementation and operation, checking and corrective action, and management
review. The seven EMR disciplines listed below (along with the corresponding CEMP Principles and ISO 14001
Sections) are from Phase 3 of the Generic Protocol for Conducting Environmental Audits of Federal Facilities.
They are:
o Organizational Structure (CEMP Principle 1 and ISO 14001 Section 4.4)
o Environmental Commitment (CEMP Principle 1 and ISO 14001 Section 4.2)
o Environmental Planning and Risk Management (CEMP Principles 2 & 3 and ISO 14001 Sections 4.3 & 4.4)
o Staff Resources, Training, and Development (CEMP Principles 3 & 4 and ISO 14001 Section 4.4)
o Formality of Environmental Programs (e.g. p2, auditing, compliance) (CEMP Principles 2 & 3 and ISO 14001
Sections 4.2, 4.4 & 4.5)
o Internal and External Communication (CEMP Principle 3 and ISO 14001 Section 4.4)
o Program Evaluation, Reporting, and Corrective Action (CEMP Principles 3 & 5 and ISO 14001 Sections 4.5
&4.6)
While the wording of the EMR disciplines and the elements of CEMP and ISO 14001 are not identical,
the overlap, correlation and similarity are great. An EMR is a tool that can help facility personnel attain the CEMP
and move toward conformance with ISO 14001. This is because an EMR will provide a review of the individual
components of the facility's EMS, as well as provide the facility with information regarding areas for improvement
of the EMS, feedback on the effectiveness of their systems, and bench marking their performance.
An EMR is not a full-fledged Environmental Management Systems Audit. A management systems audit
would provide a thorough, systematic evaluation of all elements of a facility's implementation of an environmental
management system. EPA currently does not have the resources to conduct an in-depth environmental
management systems audit, which most often requires a week or several weeks stay at a given facility, and
significant resources depending on the size and type of facility. EPA envisions that an EMR may cover anywhere
from one to seven areas depending on EPA and the needs of the facility. The determination of this need can be
accomplished through consultations between EPA and the federal facility.
This document (EPA Document No. 300-B-96-012 A&B) can be obtained by contacting U.S. EPA
Federal Facilities Enforcement Office at 202-564-2461.
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An EMR is based on a combination of staff interviews, pre-site visit document reviews and a site visit at
the facility. Interviews are especially important in conducting an environmental management review. They provide
the primary means of understanding the organizational relationships, roles and responsibilities, policies, and
systems that form the framework for the management of environmental matters. More importantly, they often
reveal differences in the actual versus the documented practices. Document review is important to verify the
formality of the system and confirm interview information. A site visit is necessary to verify an EMS'
implementation and effectiveness.
Depending on the characteristics of the federal facility such as the degree of sophistication of the
environmental management program, the EMR could take place over the course of a day's visit or up to a week.
Those participating may include representatives from the EPA Regional Federal Facility program, Headquarters
and Regional technical assistance offices, other federal Agencies, contractors, and/or State Environmental
Agencies. As appropriate, EPA regional offices can conduct joint EMRs with their states, and should contact the
appropriate state technical assistance program as part of the development process for an EMR.
Where EMRs Are Likely to Be Conducted
Federal facility participation in an EMR under all circumstances is voluntary. In general, EPA would
prefer to conduct EMRs at facilities where there is a potential for environmental impact (e.g., facility is a permit
holder or notifier under one or more environmental statutes), and/or at facilities that have limited resources for
hiring a private consultant or where their Agency does not already have an internal environmental management
system audit program. This is more likely to be the case at smaller agencies such as civilian federal agencies
(CFAs). This is consistent with the nature of the overall findings of the Strategy for Improving Environmental
Management Programs at CFAs, which recommended training, technical support, and compliance assistance for
CFAs. However, EPA may conduct an EMR at larger facilities if invited by the facility or where an EMR will be
useful to follow-up on an enforcement action to identify root causes.
There may be some factors that could prohibit EPA from conducting an EMR at a facility. If a facility is
subject to an open criminal investigation, it should not be selected for an EMR. However, if a facility is a recent
recipient of an enforcement action, this would not prohibit EPA from conducting an EMR at that facility. In fact,
an EMR may be helpful in determining the root cause(s) of the violation(s). In cases of a state enforcement
action, EPA should contact the state as part of the development process for the EMR.
m. Operating Principles
The following are intended to provide EPA staff with general guidelines or operating principles for
conducting EMRs at federal facilities:
a. An EMR visit is not an inspection.
b. Participation in an EMR by a federal facility is voluntary, and facilities are invited to request an EMR. A
federal facility may also be contacted at least one to two months in advance of a visit to solicit interest,
and to ask for appropriate written documentation of their environmental management system.
c. While the primary focus and intent of the EMR program is at the facility level, EMRs may also
be appropriate at the regional and/or agency headquarters level. Agency headquarters are
encouraged to contact EPA about having an EMR conducted at the headquarters and/or regional
level. It would be helpful if agency headquarters would encourage individual facilities to
participate in an EMR.
d. The date for the EMR is mutually arranged between the federal facility and EPA. Information regarding
the topics that will be covered in the review will be discussed prior to the visit.
e. The facility will receive a confirmation letter prior to the EMR visit which will generally lay out the
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ground rules for the EMR. The confirmation letter will be signed by the appropriate EPA Regional
manager, and may be co-signed by the facility manager as well (See Attachment One for examples of
suggested components of a confirmation letter.) The confirmation letter will also ensure that EMR staff
have access to the appropriate personnel and documents at the facility, as well as summarize the
conditions of the Incidental Violations Response Policy (See Section IV).
f. Each EMR visit will include an in-briefing and an exit-briefing or close-out session in which preliminary
EMR results are shared with the host facility. Provisions for additional technical assistance such as a
future pollution prevention assessment can be discussed at this time.
g. Within 60 days after the visit, the EPA regional office will provide the facility with a written report
regarding the facility's environmental management system and provides recommendations for further
activities. EPA and the facility can make arrangements for the sharing of draft findings prior to issuance
of the final report. This EMR report will not contain information on incidental violations. All
communication with the federal facility with respect to incidental violations will be conducted separate
from the EMR report.
h. To better inform the federal facility's headquarters office about the potential resource needs that may
result from the EMR report, EPA may share a copy of the final report with headquarters, unless the
federal facility requests EPA to do otherwise.
i. The facility will, no later than six months after receipt of the EPA EMR report, produce a response plan
that lays out how they plan to address the EMR findings and reports on progress made to that point.
During this six-month period, EPA generally will not conduct inspections at the facility receiving the
EMR unless such inspection is required by statute, regulation, or EPA policy involving compliance with
environmental statutes, or unless good cause exists including belief of misrepresentation or falsification
of any report required by law, to determine whether the facility may present an imminent and substantial
danger to public health or the environment, or to investigate a tip, complaint or other information
concerning potential civil or criminal violations at the facility.
j. Within approximately twelve months of the EPA EMR report, the EPA regional office will
informally contact the facility to get an update on, for example, the areas of change that resulted
from the EMR, any staffing or resources changes, and any other appropriate information
regarding the facility's response to the recommendations made in the EPA EMR report.
IV. Incidental Violations Response Policy (IVRP)
The purpose of an EMR is not to assess the compliance status of a federal facility. There may, however,
be circumstances when an EMR incidentally uncovers violations either through document review or while on site.
EPA's Office of Enforcement and Compliance Assurance (OECA) has developed enforcement response policies
for several programs with industry such as the Environmental Leadership Program, the Common Sense Initiative,
and Project XL that detail how violations will be treated if they are discovered as part of these programs. The
Incidental Violations Response Policy (IVRP) described below details how violations will be treated that are
incidentally uncovered at a federal facility that is participating in the EMR program. As previously stated, EMRs
are not enforcement inspections. In fact, situations presenting enforcement issues have occurred very infrequently
in the EMRs conducted at federal facilities to date.
Imminent and Substantial Endangernient
In cases where the EMR team finds situations that may cause an imminent and substantial endangerment to
public health or the environment or serious actual harm, EPA expects the facility to address the situation
immediately and retains the right to respond as necessary.
Other Violations
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OECA's Federal Facilities Enforcement Office (FFEO) is responsible for ensuring that federal facilities
take all necessary actions to prevent, control and abate environmental pollution. FFEO uses a comprehensive
approach encompassing compliance assistance, compliance oversight and enforcement, and systematic reviews of
federal agency environmental plans and programs to ensure that federal agencies are in compliance and taking
steps toward pollution prevention. Generally, EPA bases its initial response to a violation on the type of violation
and the potential risk posed by the violation. Although the pertinent statute/regulation and media-specific or
program-specific guidance governs the type of initial EPA response, they can vary from a Notice of Violation
(NOV)/Notice of Noncompliance (NON), to an Order or Compliance Agreement without penalties, to a Complaint
or Order assessing penalties.
Consistent with EPA's Audit Policy (Incentives for Self-Policing, 60 FR 66706, December 22, 1995),
and in the context of the EMR program and the IVRP, following the identification of a violation(s) as a result of an
EMR, the federal facility will be required to disclose the violation(s) in writing to EPA within 10 days of its
identification. In addition, the federal facility must correct the violation(s) within 60 days of its disclosure to
EPA, certifying in writing that the violation(s) has been corrected, and take appropriate measures as determined by
EPA to remedy any environmental or human harm due to the violation(s).
If more than 60 days will be needed to correct the violation(s), the federal facility must notify EPA in
writing before the 60-day period has passed. The facility must then enter into a written compliance agreement
that:
o establishes a specified period for correcting all outstanding violations; and
o incorporates interim milestones that demonstrate reasonable progress toward compliance and sets forth the
additional correction period and any additional steps to be undertaken by the facility to achieve compliance.
The total period of time for correction is not to exceed one-year, except in cases where pollution
prevention is used as the means of correction, in which case the facility could have a total of 18 months for
correction. The correction period may be limited based on statutory/regulatory requirements, as well as media-
specific policy and guidance regarding significant non-compliers.
Consistent with EPA's Audit Policy, this IVRP does not apply to criminal violations, repeat violations,
Identification of a potential violation can either occur during the EMR visit or after the EPA staff on
the EMR team consults with other appropriate regional staff. EPA will generally take no longer than 10 days
after the EMR visit to contact the federal facility with information about any additional violations that result
from this consultation.
In special cases an EPA region may grant a facility more than a year to correct violations due to the
particular budget constraints at the facility. A region must first make the Federal Facilities Enforcement
Office aware of the situation prior to granting additional time to the facility. A region should also make a
facility aware that such facility may be inspected to verify that the facility has corrected violations pursuant
to this IVRP.
See also the Audit Policy Interpretive Guidance for additional definitions and information
concerning the EPA Audit Policy.
The specific violation (or closely related violation) can not have occurred previously within the past
three years, or is not part of a pattern of federal, state or local violations by the facility's parent Agency,
which have occurred within the past five years. A violation is: (a) any violation of federal, state or local
environmental law identified in a judicial or administrative order, consent agreement or order, complaint, or
notice of violation, conviction or plea agreement; (b) any act or omission for which the regulated entity has
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violations that resulted in serious actual harm (or may have presented an imminent and substantial endangerment
to) human health or the environment, violations of the specific terms of any judicial or administrative order or
consent agreement, or actions to address recurrences of violations.
In those instances where the media-specific or program-specific guidance calls for the assessment of a
penalty, EPA will completely waive the gravity-portion of such penalty for federal facilities that disclose and
correct violations detected during the EMR as described above. EPA reserves the right to collect any economic
benefit that may have been realized as a result of noncompliance. Economic benefit may be waived, however,
where EPA determines that it is insignificant.
Where EPA and or the state is concerned about appropriate response from the facility, EPA reserves its
rights to respond as it deems appropriate to instances of non-compliance. Except where explicitly noted, nothing
in this policy should be construed to limit any legal authority EPA may have.
previously received penalty mitigation from EPA or a state or local agency.
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B. EMR Guidance
I. Purpose:
This guidance is intended as a technical accompaniment to the EPA Environmental Management Review
Policy for Federal Facilities. Its purpose is to assist EPA Headquarters and EPA Regional personnel in conducting
Environmental Management Reviews (EMRs). This document will outline key areas of performance that should be
considered when EPA staff and contractors are conducting EMRs. The guidance refers the users of this guidance
to the Generic Protocol for Conducting Environmental Audits of Federal Facilities (EPA Document No. 300-B-
96-012 A&B) for reference to expected performance criteria during the conduct of an EMR (performance
objectives, key evaluative concerns, and criteria) and are therefore not restated within this guidance. The
definition of an EMR as well as the scope of these reviews are discussed in Section II of the EMR Policy. This
technical guidance will not define a specific technical approach to be followed in all circumstances. Instead, the
guidance emphasizes the planning (Section II) and communications (Section III) aspects of the EMR process, and
also provides discussion on the use of protocols and checklists during the EMR process (Section IV). These
sections were developed to help ensure consistency in the quality of the work to be performed, and to ensure that
the expectations between the EPA regions and the participating federal facilities on the outcome of the EMR
process are one and the same.
To a great extent, the success of the EMR program will depend on the quality of the products and service
provided to federal facility participants. For this reason, FFEO strongly recommends that EPA staff and EPA
contractors participating in the EMRs are trained in environmental audit procedures, and especially in the
techniques of auditing environmental management systems. To help ensure an appropriate degree of expertise,
Section VI of this guidance outlines training considerations (e.g., skills) needed by EPA staff and contractors.
n. Planning:
EPA regional staff responsible for organizing and conducting the EMR should spend a significant amount
of time planning for the site visit. Careful planning is crucial to ensuring that the limited time typically available
for the site visit is used most effectively. Careful planning also minimizes the time necessary for follow-up
activities after the site visit, and reduces the burden on facility management by efficiently utilizing the time and
talents of their staff during the EMR process. The factors to consider in planning an EMR: (1) the goals and scope
of the EMR; (2) the size and complexity of the facility operations; (3) the regional staffs familiarity with the site;
(4) resources available for conducting the EMR; and (5) the desired form and content of the final EMR report.
If a contractor will be accompanying the EPA regional staff while conducting the EMR, regional staff
should develop a scope of work that clearly establishes roles and protocols for each phase of the EMR (i.e., pre-
visit, on-site, post-visit). If in-house regional staff are conducting the EMRs, the Federal Facility Coordinator or
other regional member in charge of the EMR should select team members and assign roles and responsibilities.
Regardless of who performs the EMRs, as part of the planning phase, EPA regional staff should ensure that the
members of the EMR team:
1. clearly understand the goals and scope of the EMR;
2. upon reviewing preliminary information, are familiar with the facility's operations, environmental
management policies, compliance history, waste streams and other environmental releases;
3. have the correct checklists and protocols and understands how to use them;
4. agree to follow the detailed EMR agenda formulated specifically for that facility;
5. are aware of potential health and safety issues and are prepared to handle them on-site; and
6. understand how information collected on-site will be presented in the EMR final report.
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m. Communications With Facility Management:
Once contact is initiated by either EPA, the facility management, or federal agency headquarters staff
who have expressed an interest in having an EMR conducted at a particular site, EPA staff and federal facility
management should discuss, in detail, the purpose and scope of the EMR, especially the ground rules for engaging
in the process. Additionally, facility management should be briefed on the Operating Principles contained in
Section III of the EMR Policy, including the outcome of the process (i.e., development of a written report) and the
time frame under which that occurs. Following these discussions, a confirmation letter/ground rules letter will be
sent to the facility prior to conducting the EMR planning process and site visit (see Section III (e) and Attachment
One of the EMR Policy) to ensure that all parties understand the conditions under which the EMR will be
conducted. This letter will also ensure that EMR staff have access to the appropriate personnel and documents at
the facility, and also document that all participants are aware of terms and conditions of the Incidental Violations
Response Policy (IVRP) discussed in Section IV of the EMR Policy. Examples of suggested components of a
sample confirmation letter are included as Attachment One of the EMR Policy document.
EPA regional environmental staff should also use the confirmation letter to confirm the scope and dates
of the EMR site visit, and to establish points of technical contact (POC) for both parties. In addition, EPA staff
involved in the EMR will have an opportunity to propose an agenda for the site visit, and to send a pre-site visit
questionnaire which will be helpful in determining the specific focus of the EMR. All EPA regional staff
members involved in the EMR should be mindful of the fact that the facility to be visited is volunteering for this
effort and, therefore, developing and maintaining a positive relationship with the facility POC is vital to the
success of the EMR. Taking care to set the right tone when contacting facility personnel is critical. Important
points to communicate to facility management include:
1. The purpose of the EMR Both facility management and EPA regional staff assigned to conduct the EMR
should be fully aware of the EMR's goals and scope, and the EPA EMR Policy document. In addition, facility
management and staff should understand how the EMR results will be used both by their agency headquarters
personnel (if appropriate) and by EPA. Facility understanding of how the EMR results will be used and how it
may impact facility operations and relationship with EPA is particularly important.
2. Information needs and critical persons needed for interview: EPA regional staff conducting the EMR should
work with facility management to develop a list of information needs and persons to be interviewed as part of
a site visit, including management and line and staff personnel at all levels at the facility. To accomplish this
task, a pre-site visit questionnaire should be forwarded to facility management in advance of the site visit to
alert facility management of the documents that should be available for review (e.g., organizational charts,
job-descriptions and environmental planning documents), and the facility staff that the EMR team will want to
interview during the site visit. A timely and well crafted pre-site visit questionnaire will save EPA regional
staff considerable time by answering fundamental questions about the facility practices and policies, and
allowing the regional staff to focus the site visit on the critical issues and matters requiring a more in-depth
review. FFEO has provided an appendix to the EPA Phase III protocol, Selecting Documents to Review and
Individuals to Interview for Environmental Management Assessments, to assist personnel in this phase of
the EMR process. EPA Region 1 has also developed a pre-site visit questionnaire that may prove useful for
other Regions (See Attachment Two).
3. Time schedules: Regional environmental staff should work with the facility to develop an appropriate agenda
and schedule for the EMR. The time schedule will depend on the size and complexity of the facility and the
number of individuals that need to be interviewed.
IV. Protocols/Checklists:
Because the scope of the EMR site visit will likely involve a review and assessment of more than one of
the environmental organizational disciplines outlined in Section II of this technical guidance and Section II of the
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EMR Policy, FFEO recommends that Phase III of the EPA Generic Protocol For Conducting Environmental
Audits of Federal Facilities be consulted by EPA regional staff when developing the actual working documents
and specific tools for a given site. The Phase III Protocol will provide specific guidance to EMR team members in
evaluating the facility activities, and in documenting the procedural elements that are to be reviewed during the
EMR. The Protocol also identifies performance objectives, and key evaluative concerns and criteria related to
each of the organizational disciplines to be evaluated. Once the scope of the EMR is agreed upon by EPA regional
staff and facility management, the EMR team conducting the review should select the appropriate performance
objectives and criteria needed from the Phase III Protocol, and develop the appropriate protocols and checklists
for that site. EPA Region 1 has also developed an EMR protocol which incorporates many items from the Phase
III Protocol, and is organized around the Code of Environmental Management Principles for Federal Agencies
(CEMP) (See Attachment Three). Both of these documents may be helpful to EMR team members in other
Regions developing protocols and checklists for a specific site.
A checklist is an actual on-site tool developed specifically for the facility that is being reviewed. A
checklist is dynamic, and should reflect only the areas to be evaluated for a particular facility based upon
information gathered from the pre-site visit questionnaire, and pre-site visit communications with facility
management. FFEO recommends that EPA staff conducting EMRs either develop a unique checklist for each
facility undergoing a review, or annotate and modify existing checklists to reflect the specific scope agreed upon
for a particular facility visit. Points to consider in developing or using a checklist include:
o Is the checklist applicable to the type of facility being evaluated?
o Is it pertinent to the organizational disciplines being reviewed?
o Is it consistent with the goals and scope of the EMR for that particular facility ?
Protocols and checklists are essential tools for assuring that an EMR has adequately addressed all issues
that need to be examined during an EMR. However, they are not static (i.e., one size fits all), and should reflect the
unique considerations and differences attributable for each federal facility program and management system being
reviewed. Protocols and checklists also are not a substitute for critical and independent judgement or decision
making, and should only be used as a reference point to affirm that key criteria and evaluative areas have been
examined.
V. Training and Development of Expertise:
The success of the EMR program depends on the quality of the service being provided to facility
management. Since federal agencies and their facilities will be looking to EPA for guidance in improving their
overall environmental management systems, EPA staff and contractors conducting EMRs should be able to
demonstrate having both appropriate knowledge of the issues included in the scope of the EMR, and sufficient
training and proficiency prior to participating in EMRs.
The qualifications of the staff assigned to conduct EMRs should be commensurate with the objectives,
scope and complexities of that particular EMR assignment. Although EMRs will vary in scope, they all require
some degree of professional assessment of apparent problems as well as some verification and documentation of
the facility's systems for the full range of potential hazards - not just those related to compliance requirements.
While the balance between assessment and verification will vary, in general the EPA staff member's background
should include at a minimum:
o technical training and experience appropriate to the work called for by the particular EMR;
o an understanding of basic auditing theory and procedures, and the experience needed to apply it in
particular situations;
o a working knowledge of environmental regulations, evaluation criteria in the Phase 3 Protocol, and
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general EMS standards appropriate to the scope of the EMR; and
o general familiarity with the type of operations to be reviewed, and the issues likely to be encountered
within the scope of the EMR.
While the precise mix of experience and knowledge that is desirable can vary, the EMR team as a whole should
represent sufficient depth in these four areas of experience.
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Attachment One
Examples of Suggested Components of a Sample Confirmation Letter
The confirmation letter for an EMR could include the following elements:
a. specific objectives of the EMR~a brief discussion of which components of an environmental
management system the review will focus on;
b. a statement that an EMR is not an inspection.
c. brief discussion of EPA's expectations of the federal facility with respect to requests for access to
specific staff, parts of the facility, access to info, etc.
d. a brief explanation of the Incidental Violations Response Policy (IVRP) and any necessary definitions.
Emphasize that instances involving the IVRP are very infrequent.
e. a brief explanation of how the site visit will be conducted, what documents will be requested in advance,
what federal facility personnel will be interviewed, etc.
f a disclaimer that the facility is responsible for compliance with all applicable regulations regardless of
whether or not they have an EMR.
g. a statement that the facility will, no later than six months after receipt of the EPA EMR report, produce a
response plan that lays out how they plan to address the EMR findings and reports on progress made to
that point.
h. a statement that the EMR is available through FOIA.
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APPENDIX C
Process steps for a sample EMR
TASK#
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
TASK
U.S. EPA provides federal facility with a draft
Confirmation Letter for comment and a pre-site visit
questionnaire for completion
Federal facility provides U.S. EPA with Confirmation
Letter comments
Federal facility submits to U.S. EPA completed EMR
pre-site visit questionnaire
Federal facility submits to U.S. EPA samples and
copies of documents requested in the Confirmation
Letter
Confirmation Letter is signed by both U.S. EPA and
federal facility
Federal facility submits to U.S. EPA a list of
personnel available for on-site interviews
U.S. EPA submits EMR protocol to federal facility
for distribution to personnel who will be interviewed
U.S. EPA submits to federal facility EMR logistical
plan
U.S. EPA develops draft interview schedule and
submits to federal facility for comment
Federal facility submits to U.S. EPA interview
schedule comments
U.S. EPA submits to federal facility final interview
schedule
On-site portion of the EMR - document review and
interviews
U.S. EPA submits to federal facility EMR findings
and recommendations
Federal facility submits to U.S. EPA a plan to
implement certain EMR recommendations
Federal facility submits to U. S. EPA an implementation
progress report
DATE OF COMPLETION
May 18, 1998
June 1, 1998
June 1, 1998
June 8, 1998
June 15, 1998
July 10, 1998
July 13, 1998
July 20, 1998
July 27, 1998
July 30, 1998
August 7, 1998
Two days during the week of
August 17, 1998
60 days after on-site portion
of the EMR
60 days after receipt of the
U.S. EPA report
Six months after submitting
initial report
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APPENDIX D
EMR TOOLS AND RELATED COMPLIANCE ASSISTANCE RESOURCES
Regional Federal Facility Coordinator Contact Information
Anne H. Fenn
US EPA Region I (CT, MA, ME, NH, RI, VT)
One Congress St.-Suite 1100
Mail: SPP
Boston, MA 02114-2023
Tel: 617-981-1805
Fax:617-918-1810
fenn.anne@epa. gov
Bill Arguto
US EPA Region III (DE, DC, MD, PA, VA, WV)
841 Chestnut St.
Philadelphia, PA 19107
Tel: 215-814-3367
Fax:215-566-2783
arguto.wilriam@epa. gov
Lee Regner
US EPA Region V (IL, IN, MI, MN, OH, WI)
77 West Jackson Blvd.
Chicago, IL 60604
Tel: 312-353-6478
Fax:312-353-5374
regner.lee@epa. gov
Diana Jackson
US EPA Region VII (IA, KS, MO, NE)
901 N. 5th St.
Mail: RA/ECO
Kansas City, KS 66101
Tel: 913-551-7744
Fax:913-551-7941
iackson.diana@epa.gov
Sara Segal
US EPA Region DC (AZ, CA, HI, NV, AS, GU,
TTP)
75 Hawthorne St., CMD-2
San Francisco, CA 94105
Tel: 415-744-1569
Fax: 415-744-1598
se gal. sara@epa. gov
Jeanette Dadusc
US EPA Region II (NJ, NY, PR, VI)
290 Broadway-21th Fl.
New York, NY 10007
Tel: 212-637-3492
Fax: 212-637-4086
dadusc.ieanette@epa.gov
Stacy Howard
US EPA Region IV (AL, FL, GA, KY, MS, NC, SC,
TN)
61 Forsyth St., SW
Atlanta, GA 30303
Tel: 404-562-9633
Fax: 404-562-9598
howard.stacy@epa.gov
Joyce Stubblefield
US EPA Region VI (AR, LA, NM, OK, TX)
Mail: 6EN-XP
1445 Ross Ave.
Dallas, TX 75202
Tel: 214-665-6430
Fax: 214-665-7446
stubblefield.ioyce@epa. gov
Dianne Thiel
US EPA Region VIII (CO, MT, ND, SD, UT, WY)
999 18th St. -Ste. 500
Mail: 8P-P3T
Denver, CO 80202-2466
Tel: 303-312-6389
Fax: 303-312-6044
thiel.dianne@epa. gov
Michele Wright
US EPA Region X (ID, OR, WA, AK)
1200 6th Ave., OEC-157
Seattle, WA 98101
Tel: 206-553-1747
Fax: 206-553-7176
wright.michele@epa. gov
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ENVIRONMENTAL MANAGEMENT REVIEW (EMR)
Process Evaluation Team
Thank you for participating in this management system review. In an effort to continuously improve
our process, we are asking for your evaluation and suggestions. Your candid insights will be
extremely helpful to us.
How well prepared did you feel you were for the EMR?
Knowledge of objectives and process
Understanding of organization to be reviewed
Understanding of EMR criteria
How efficient was the process?
Preparation
On-site
Synthesis of data
How effective were communications?
Within the team
With organization being reviewed
Were your views and ideas heard and accommodated?
How useful were the tools we used?
How thorough was the process?
How useful was the outcome to the organization reviewed?
How challenging was the process?
How close was the actual experience to your expectations?
How useful to you was the process as a learning experience?
How could the process be improved? (Please be specific. Continue on reverse if necessary)
very
very
very
very
very
very
very
very
very
very
very
very
very
better
very
somewhat
somewhat
somewhat
somewhat
somewhat
somewhat
somewhat
somewhat
somewhat
somewhat
somewhat
somewhat
somewhat
close
somewhat
not at all
not at all
not at all
not at all
not at all
not at all
not at all
not at all
not at all
not at all
not at all
not at all
not at all
worse
not at all
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ENVIRONMENTAL MANAGEMENT REVIEW (EMR)
Process Evaluation Site
Thank you for participating in this management system review. In an effort to continuously improve
our process, we are asking for your evaluation and suggestions. Your candid insights will be
extremely helpful to us. (Feel free to skip questions that do not apply.)
How well prepared did you feel you were for the EMR?
Knowledge of objectives and process
Understanding of EMR criteria
somewhat not at all
somewhat not at all
How efficient was the process?
Preparation
On-site
How disruptive to the organization was the activity?
How effective were communications from the team?
Were your views and ideas heard and accommodated?
How useful were the tools we used?
How thorough was the process?
How accurate were the observations?
How useful were the recommendations?
How timely was the report?
How helpful was the overall experience?
How close was the actual experience to your expectations?
How professional were the team members?
How knowledgeable were the team members?
How objective were the team members?
How flexible were the team members?
How responsive were the team members?
How could the process be improved? (Please be specific. Continue on reverse if necessary)
somewhat not at all
very
very
very
very
very
very
very
very
very
very
better
very
very
very
very
very
somewhat
somewhat
somewhat
somewhat
somewhat
somewhat
somewhat
somewhat
somewhat
somewhat
close
somewhat
somewhat
somewhat
somewhat
somewhat
not at all
not at all
not at all
not at all
not at all
not at all
not at all
not at all
not at all
not at all
worse
not at all
not at all
not at all
not at all
not at all
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EPA ENVIRONMENTAL MANAGEMENT REVIEWS
FOR FEDERAL FACILITIES
FACILITYPRE-SITE QUESTIONNAIRE
FACILITY CONTACT INFORMATION
NAME OF FACILITY:
FACILITY
DIRECTOR/COMMANDER:
ADDRESS:
TELEPHONE:
FAX:
FACILITY ENVIRONMENTAL COORDINATOR:
ADDRESS:
TELEPHONE:
FAX:
PARENT ORGANIZATION:
PARENT ORGANIZATION
ENVIRONMENTAL MANAGER:
ADDRESS:
E-MAIL:
E-MAIL:
TELEPHONE:
FAX:
H. FACILITY ORGANIZATIONAL STRUCTURE
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1. Please describe your facility's mission/major activities:
2. How does your facility fit into the organizational structure of your parent agency?
3. Has your parent agency issued a formal, organization-wide environmental policy and
standards? When?
4. Does your parent agency provide environmental assistance and/or oversight? How does
your parent agency collect reporting data from and/or provide environmental information to
your facility? Who is your facility's point of contact with your parent agency?
5. How does your Environmental Program fit into your facility's organizational structure?
What is the facility's annual budget? What is the level of funding for the Environmental
Program?
6. Do any other facility staff or programs have environmental management responsibilities?
If yes, please explain.
7. How is your facility Environmental Management Program organized? How many staff at
your facility have full-time or part-time environmental responsibilities? Briefly describe
the general responsibilities of your Environmental Program.
8. What is the internal process for implementing new environmental initiatives? What is the
approval process and how are funds allocated for new environmental initiatives?
9. What methods are used to track and measure facility environmental performance? How
frequently is such measurement performed?
PLEASE PROVIDE COPIES OF THE FOLLOWING:
Parent agency organization chart
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Parent agency environmental policy and standards
Staffing and organization chart for your facility
Samples of supporting documentation for reporting and communication
networks such as meeting notices, meeting minutes, memoranda, etc.
Samples of written Environmental Program performance and status reports
Samples of facility-specific environmental policies and procedures
Please complete the following chart. The information will help the EMR team determine what
environmental issues should be planned for and taken into account by your facility. When
completing the chart, please indicate the policies, procedures, and personnel that are pertinent to
the various aspects of the media/program.
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m.
FACILITY BACKGROUND INFORMATION
MEDIA PROGRAM REVIEW
MEDIA/
PROGRAM
CAA
SDWA
UIC
FIFRA
PLANS/
PERMITS
SOURCES/
DISCHARGES
UNDERSTAND
REGS?
MGMT.
PROCEDURES
PERSONNEL
TRAINING
RECORDKEEPING/
REPORTING
OVERSIGHT/
EVALUATION
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MEDIA PROGRAM REVIEW
MEDIA/
PROGRAM
NPDES
WETLANDS
RCRA
Generator
Status:
PLANS/
PERMITS
SOURCES/
DISCHARGES
UNDERSTAND
REGS?
MGMT.
PROCEDURES
PERSONNEL
TRAINING
RECORDKEEPING/
REPORTING
OVERSIGHT/
EVALUATION
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MEDIA PROGRAM REVIEW
MEDIA/
PROGRAM
TSCA/PCBS
UST
PLANS/
PERMITS
SOURCES/
DISCHARGES
UNDERSTAND
REGS?
MGMT.
PROCEDURES
PERSONNEL
TRAINING
RECORDKEEPING/
REPORTING
OVERSIGHT/
EVALUATION
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vvEPA
United States
Environmental Protection Agency
(2261A)
Washington, DC 20460
Official Business
Penalty for Private Use
$300
Printed on recycled paper
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