Who can I contact to obtain more information?
If your facility is interested in participating in an
EMR, or would like to obtain more information on
the program, please contact your Regional Federal
Facility Coordinator.
EPA Regional EMR Contacts
I Anne Fenn (617) 565-3927
II John Gorman (212) 637-4008
III Eric Ashton (215) 566-2713
IV Dave Holroyd (404) 562-9625
V Lee Regner (312) 353-6478
VI Joyce Stubblefield (214) 665-6430
VII Jamie Bernard-Drakey (913) 551-7400
VIII DianneThiel (303) 312-6389
IX Sara Segal (415) 744-1569
X Kathy Veil (206) 553-1983
EPA Headquarters
Federal Facilities Enforcement Office
Andrew Cherry (202) 564-5011
Related Guidance
The following reference materials provide more
detailed information on the EMR program and its
implementation and can be obtained from EPA's
Federal Facilities Enforcement Office.
Interim Final Policy on Environmental
Management Reviews at Federal Facilities, May
31, 1996.
Interim Technical Guidance for Conducting EMRs
at Federal Facilities, May 31, 1996.
Generic Protocol for Conducting Environmental
Audits of Federal Facilities, Volumes I & II (EPA
300-B-96-012A & B).
Code of Environmental Management Principles
(CEMP)for Federal Agencies (61 FR 54062,
October 16, 1996)
Guide for Implementing the CEMP — Available
Winter, 1997.
These documents can be obtained from Enviro$en$e,
EPA's free, public, integrated information system.
Enviro$en$e may be accessed via modem at (703)
908-2092 or on the World Wide Web at http//
es.inel.gov.
EPA300/F-97-005
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United States
Environmental Protection
Agency
Region 10
1200 Sixth Avenue
Seattle WA 98101-1128
Environmental
Management
Reviews
At Federal Facilities
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What are Environmental Management
Reviews?
An Environmental Management Review (EMR) is
an evaluation of an individual Federal facility's
program and management systems to determine how
well the facility has developed and implemented
specific environmental protection programs to ensure
compliance.
Two EPA Regions (I and VI) have been
conducting EMRs over the past few years.
Encouraged by the success of their efforts, EPA
Headquarters recently issued (May 31, 1996) an
interim final policy and technical guidance on
conducting EMRs at Federal facilities. The interim
policy stipulates that EMRs will be conducted as part
of a pilot program. Upon completion of the pilot at
the end of FY 1997, EPA intends to identify any
lessons learned, modify the policy as appropriate, and
implement a final EMR policy.
How do EMRs compare with other on-site
assessments?
EMRs are consultative technical assistance visits
intended to identify root causes of environmental
performance problems. EMRs are not compliance-
oriented assessments, audits, or inspections, nor
are they pollution prevention opportunity
assessments. They are voluntary and are often
initiated by the recipient agency or facility.
How can my facility benefit from an EMR?
EMRs help Federal facilities improve long-term
environmental compliance by developing a sound
foundation for an environmental management
program. They assist Federal facility personnel in
moving beyond immediate symptoms of
noncompliance and address underlying problems or
root causes. In addition, they may provide an early
warning of potential compliance problems. EMRs
foster improved working relationships with EPA and
encourage an open dialogue on environmental
concerns. EMRs also provide informal assessments
that are less costly than management assessments
conducted by a facility's contractor, and they provide
an independent perspective on prior self-assessment
activities.
How is the scope of an EMR determined?
EMRs are collaborative efforts between EPA and a
Federal facility in which the facility works with EPA
to determine the scope of the review. There are
seven potential areas of inquiry for an EMR:
• organizational structure;
• management commitment;
• resources;
• formality of program;
• communications;
• evaluation and reporting; and
• planning and risk management.
A typical EMR may address any of these areas,
and will take from one to three days to conduct.
Once EPA evaluates the results of the EMR, the
facility receives a written report.
Who actually conducts the EMR?
EMRs are conducted by a team of EPA Regional
staff with the assistance of qualified contractors,
when appropriate. Throughout the EMR process, the
team will coordinate closely with Federal facility
personnel.
How does the EMR process work?
The EMR process typically begins either with an
expression of interest by a Federal facility or an EPA
inquiry. If, after preliminary discussions, the facility
elects to proceed, the EMR planning stage begins.
During the planning stage, EPA staff and Federal
facility management will discuss the purpose and
scope of the EMR, the ground rules and operating
principles for conducting the review, and they may
sign a ground rules letter.
EPA and Federal facility personnel may continue
regular telephone discussions and correspondence
(e.g., pre-site visit questionnaire) to further refine the
scope and content of the EMR. During these
communications, EPA and the Federal facility will
identify technical points of contact. In addition, EPA
may work with facility staff to develop a list of
information needs (e.g., documents) and persons to
be interviewed as part of the site visit, as well as a
schedule for the on-site portion of the EMR. The
schedule will be customized to address the size and
complexity of the facility.
Prior to the site visit, EPA staff will review and
evaluate the environmental management program
documents identified during the planning stage (e.g.,
environmental policies, directives, protocols, and
standard operating procedures). Careful review prior
to the site visit will ensure that EMR staff are
sufficiently familiar with facility operations to
conduct effective on-site interviews and evaluations.
Although compliance assessment is not the intent,
occasionally during the course of an EMR, the team
may discover a potential violation. To address this
issue, EPA has developed an Incidental Violations
Response Policy (IVRP). In situations that may
cause an imminent and substantial endangerment to
public health or the environment, or serious actual
harm, the facility must address the situation
immediately. In other cases, EPA allows the facility a
60-day correction period and a waiver of certain
potential penalties, subject to formal disclosure of the
violation by the facility and the initiation of
appropriate corrective action. The IVRP is included
within EPA's Interim Technical Guidance on EMRs
and should be reviewed to obtain more details.
At the conclusion of the site visit, the EMR team
may provide an exit briefing in which preliminary
findings are presented to facility management.
Within 60 days after the site visit, the EPA
Regional Office will provide the facility with a
written report or letter discussing the conclusions of
the EMR and making recommendations for follow-up
activities. The facility must prepare a written
response to the EMR report within 60 days
explaining how it intends to address any issues raised
by the report. In addition, six months after this
response, EPA will ask the facility to provide a brief
progress report on the status of any follow-up
activities.
How will EMR reports be used?
The final EMR report is a public document, and as
such may be obtained by any member of the public
who follows proper procedures. However, it is not
EPA's intent to actively distribute or otherwise make
a report available to the general public or State/local
officials. In addition, the EMR can serve as a
foundation for on-going technical and compliance
assistance activities between EPA and the Federal
agency or facility.
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