&EPA
United las
Environ *- Protection
Agency
Office of Enforcement
and Compliance Assurance
Washington, DC 20460
EPA-300R-94-O09
December 1994
Environmental Management
System Benchmark Report:
A Review of Federal Agencies and
Selected Private Corporations
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TABLE OF CONTENTS
EXECUTIVE SUMMARY i
CHAPTER 1: INTRODUCTION 1
CHAPTER2: METHODOLOGY 4
CHAPTERS: DEFENSE RELATED AGENCIES 11
CHAPTER 4: CORPORATE PARTICIPANTS .. 42
CHAPTERS: CIVILIAN FEDERAL AGENCIES 74
CHAPTER 6: CONCLUSIONS 112
APPENDICES
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EXECUTIVE SUMMARY
Background
Executive Order 12088 requires the United States Environmental Protection Agency
(EPA) to provide technical assistance and guidance to Federal agencies to assist them in
complying with environmental regulations and statutes. In recognition of this responsibility,
EPA's Federal Facility Enforcement Office (FFEO) has begun to implement an outreach
program to facilitate the transfer of technical information and guidance to these agencies. One
component of that program involves identifying areas in which Federal agencies need
improvement to more successfully fulfill their environmental responsibilities. This
Environmental Benchmark Report is one part of that effort.
The purpose of this report is to evaluate how Defense Related Agencies (DRAs),
certain private corporations (Participating Corporations (PCs)), and Civilian Federal Agencies
(CFAs) perform against a benchmark developed to represent ideal organizational, managerial,
and operational performance in the execution of environmental responsibilities. Data for this
evaluation came from a questionnaire completed by 17 CFAs in 1993, and a separate
questionnaire completed by three private corporations and by four Defense Related Agencies
(the Departments of the Army, Navy, Air Force, and Energy) in 1994.
Methodology
Traditional benchmark analyses identify one "Best in Class" organization and compare
others to that model. In order to ensure that the benchmark developed for this project was
equally applicable to public and private sector organizations with widely disparate missions,
the benchmark used in this report was arrived at through the review of numerous draft and
final documents published by Federal agencies, and by national and international standard
setting agencies. The benchmark elements are composed of those standards that are common
to most or all of the reviewed publications.
The benchmark used to evaluate DRAs, PCs, and CFAs is composed of six major topic
areas (Benchmark Elements). A list of each Benchmark Element and a description of "Best in
Class" performance under each element is described in Exhibit ES-1.
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Exhibit ES-1
Benchmark Elements
Organizational Structure
Best in Class organizations have an organizational structure that gives authority,
input, and voice to environmental performance
Management Commitment
Best in Class organizations possess and demonstrate a commitment to environmental
excellence at each and every stage of the management hierarchy, and insist on
integration of environmental awareness and concerns into all relevant business
operations
Implementation
Best in Class organizations carry out their daily business operations in ways that
integrate environmental protection into their business conduct
Information Collection/Communication/Management/Follow-up
Best in Class organizations continually monitor environmental performance through
the use of formal tracking and reporting mechanisms. Information acquired through
these mechanisms is evaluated, disseminated, and used to continually improve
environmental performance
Internal and External
Best in Class organizations foster and use formal and informal channels to
communicate environmental commitment and performance information. Employee
communication is encouraged to develop cooperation and commitment, including
bringing together employees from different disciplines
Personnel
Best in Class organizations ensure that employees are capable of developing and
implementing environmental initiatives. Employees are hired, trained, and deployed
in ways that ensure that staff understand their environmental responsibilities and
receive the training and support necessary to achieve environmental excellence
In order to evaluate questionnaire responses against these six Benchmark Elements, key
indicators were developed that illustrate organizational attributes or activities whose presence
indicates behavior consistent with the Benchmark Element. To the greatest extent practicable,
questions on both questionnaires were "best fit" into the closest and most relevant key
indicator.
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This evaluation does not rank the participating respondent groups. This report is not
designed to publicly evaluate the performance of any individual organization; thus, information
about the range and patterns of responses within each respondent group is presented, rather
than identifying questionnaire responses by organization. In addition, this report does not
attempt to evaluate overall environmental compliance performance, either present or historical,
of a particular organization. Instead, the intention is to determine if certain organizational
enabling systems have been established to allow the repsondent group to fully implement a
sound environmental management program. Whether or not a particular organizational group
as discussed in this report has taken full advantage of these enabling systems and translated this
into an equally good compliance record was not evaluated during this assessment and is not the
subject of this report.
Conclusions drawn from this analyses of questionnaire responses should be evaluated in
light of the data limitations inherent in this project. Since the questionnaires were developed
and distributed prior to the development of the Benchmark Elements and key indicators, the
scope of the questions does not always correlate closely with the benchmark components. This
is especially true for the questionnaire sent to Civilian Federal Agencies which was primarily
focused on environmental compliance activities. In addition, the CFA questionnaire was
distributed in January of 1993 and the questionnaire to Defense Related Agencies and
Corporate Participants was distributed in the Spring of 1994. Changes in organizational
practices occurring since that time are not reflected in this report.
Findings and Conclusions
An analysis of questionnaire responses reveals meaningful data concerning the
comparative behaviors of the respondent groups and highlights each group's areas of relative
strength and weakness. In general, Defense Related Agencies and Corporate Participants
exhibit significantly more attributes and behaviors consistent with key indicators than do the
Civilian Federal Agencies. Within each Benchmark Element, fifty percent or more of the
Defense Related Agencies report indicative behaviors in all key indicators for which questions
were asked. In most instances all four Defense Related Agencies report indicative behaviors.
Corporate Participants also consistently report indicative behaviors in each of the Benchmark
Elements, but a majority of these respondents do not report indicative behaviors'for one key
indicator under the elements of Management Commitment, Implementation, and Information
Collection/Management/Follow-up.
Under the Benchmark Element entitled Organizational Structure, all seven DRA and
Corporate Participants report the presence of an organizational mission statement that sets forth
environmental objectives, organizational charts that describe clear lines of authority,
responsibility, and accountability for environmental functions, and the tracking of
environmental statutory and regulatory developments. In addition, they each state that
environmental functions are represented at the highest level of the organization. In contrast,
only four of 17 CFAs report that they have formal systems to track regulatory and statutory
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activities and a slim majority (9 of 17) state that senior managers meet to consider
environmental issues on a periodic basis. The other two key indicators were not addressed in
the CFA questionnaire.
In response to questions related to the Benchmark Element entitled Management
Commitment, a majority of all three respondent groups indicate that environmental
considerations are integrated into organizational business planning processes. All Defense
Related Agencies and two of three Corporate Participants indicate that management's
commitment goes beyond compliance with environmental requirements. In contrast, only five
of 17 CFAs report that management's stated environmental commitment leads to action in
terms of resource allocation, training, and environmental program support. All Defense
Related Agencies and Corporate Participants report that budget allocations are carried out in
ways that allow environmental projects to compete on an equal footing for scarce resources.
In contrast, while 12 of 17 CFA's report engaging in the Office of Management and Budget
(OMB) A-106 capital budgeting process, only six respondents indicate that environmental staff
is actively involved. The one area in which both Defense Related Agencies and Corporate
Participants could improve is in the reported use of formal risk management programs. Only
two of four Defense Related Agencies and one of three Corporate Participants report using
these systems. CFA's were not asked to address this issue.
For the Implementation Benchmark Element, respondents are evaluated against three
key indicators; the establishment of environmental performance goals that go beyond
compliance, the existence of a comprehensive, multi-media environmental programs, and the
development and distribution of formal environmental guidance materials throughout the
organization. Each response from Defense Related Agencies reveal indicative behaviors on all
three of these indicators. Similarly, a majority of CFAs respond positively regarding multi-
media programs and guidance materials, the two questions they were asked under this element.
All three Private Corporations report the existence of a comprehensive, multi-media
environmental program. However, only two of these respondents report that their
organizations establish environmental performance goals that go beyond compliance, and only
one of three respondents report the development and use of organization-wide guidance
materials.
For the Information Collection/Management/Follow-up Benchmark Element, CFAs
were asked questions that relate to only two of the six key indicators. A large majority of
CFAs report the use of environmental information management systems, although no CFAs
report the use of centralized, Agency-wide information repositories. Six of 17 CFAs use
systems to report regional compliance data to headquarters personnel. A majority of Defense
Related Agencies and Corporate Participants report that they use information management
systems to track environmental performance, that they document environmental performance
results, and that they take corrective actions to address identified problems. Only one of three
Corporate Participants and two of four Defense Related Agencies report using trends analyses
to uncover root causes of environmental problems.
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For the Internal/External Communication Benchmark Element, CFAs were again asked
questions that relate to only two of the six key indicators. Only three of 17 CFAs report that
their organizations have well publicized channels for employees to raise environmental
concerns. With regard to their organization soliciting environmental input from outside
parties, 10 of 17 CFAs report that they either compare their environmental programs to those
of other organizations, or that they engage in a program to secure third party environmental
assessments of their activities. AU respondents from the other two groups report the existence
of well publicized channels for employee environmental concerns, state that they actively
solicit employee suggestions and utilize a variety of communication mechanisms to
communicate their environmental commitment to employees. In response to questions
concerning the solicitation of environmental input from external parties, all four Defense
Related Agencies and two of three Corporate Participants report that they utilize formal
community outreach programs that serve this purpose.
Finally, every respondent group was asked questions relating to each of the four key
indicators under the Personnel Benchmark Element. All of the Defense Related Agencies
report that they engage in environmental awards programs to recognize the environmental
achievements of employees, use forecasting tools to project future environmental personnel
needs, and require environmental training for all employees. Three of four Defense Related
Agencies report mat they make all staff with environmental responsibilities accountable for
their environmental performance through performance reviews or through other measures.
Corporate Participants report similar data in these areas. All three of these respondents report
data that satisfies each key indicator. CFA performance is less strong. Only five of 17 CFAs
report utilizing formal training programs for compliance staff. 12 CFAs report that their
organizations consider environmental performance the responsibility of every employee, but
only five CFA respondents include environmental compliance in employee performance
evaluations. Finally, only four of 17 CFAs report the use of environmental award systems to
recognize employee environmental excellence.
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CHAPTER 1: INTRODUCTION
1.1 Background
Executive Order 12088 (§ 1-301) requires the United States Environmental Protection
Agency (EPA) to provide technical assistance and guidance to Federal agencies in then: effort to
comply with environmental regulations and statutes. In recognition of this responsibility EPA's
Federal Facility Enforcement Office (FFEO) has begun to implement an outreach program to
facilitate the transfer of technical information and guidance to these agencies. As part of this
effort, FFEO is in the process of developing a strategy to assist the smaller non-military (civilian)
Federal agencies in improving their performance of environmental compliance tasks.
In order to help identify areas where technical assistance resources should be directed to
assist Civilian Federal Agencies (CFAs) with their compliance responsibilities, FFEO sent out
questionnaires to 28 CFAs in January 1993. Among other things, this questionnaire asked
respondents to indicate how then* Federal agency is structured, managed, and operated so as to
fulfill environmental compliance responsibilities. Seventeen CFAs responded to this portion of
the questionnaire.
In the Spring of 1994, FFEO developed and distributed a separate questionnaire to the
Departments of Energy, Army, Navy, and Air Force (hereafter "Defense Related Agencies", or
"DRAs") and to five private companies. All of the Defense Related Agencies and three of the
private companies completed and returned this questionnaire. These completed questionnaires
provide data on a wide range of environmental management activities and provide a basis to draw
comparisons between the CFAs and these organizations.
FFEO has decided to use a benchmark approach to evaluate the environmental
organizational and operational performance of CFAs along with that of Defense Related Agencies
and Corporate Participants. Unlike traditional benchmark analyses that identify a "Best in Class"
organization that exemplifies an ideal model against which other organizations are measured, this
analyses identifies "Best in Class" organizational and operational benchmark elements through an
examination of various national and international standards documents. Questionnaire responses
were used to compare the performance of the three types of organizations (CFAs, Defense Related
Agencies, and Corporate Participants) against these benchmark elements.
The purpose of this report is to evaluate how each group of organizations perform against
a benchmark developed to indicate ideal organizational, managerial, and operational performance
in the execution of environmental responsibilities. This report is not designed to publicly evaluate
the performance of any individual organization; thus, information about the range and patterns of
responses within each respondent group is presented, rather than identifying questionnaire
responses by organization.
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1.2 Document Organization
This document is organized into six chapters. Chapter 2 describes the methodology used
in developing the benchmark and in evaluating reported organizational practices against
benchmark elements. Chapters 3,4, and 5 discuss and evaluate the questionnaire responses of the
Defense Related Agencies, Corporate Participants and of the participating CFAs, respectively.
Chapter 6 summarizes the results of the benchmark analyses and compares the patterns of
responses between the responding organizational groups.
1.3 Acknowledgements
FFEO gratefully acknowledges the participation of all of the responding Federal agencies
and Corporate Participants whose responses to the questionnaires formed the data for this report.
Exhibit 1-1 lists all of the organizations that provided data for this analysis.
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Exhibit 1-1
Respondent Organizations
Civilian Federal Agencies
Department of the Treasury
United States Postal Service
Federal Aviation Administration
Department of Commerce
National Oceanic and Atmospheric Administration (NOAA)
National Security Administration
Department of Agriculture
Department of Agriculture/Agricultural Research Service
Department of Agriculture/Gram Inspection Service
Department of Agriculture/ Animal and Plant Health Inspection Service
Department of Agriculture/Soil Conservation Service
Department of Justice
Department of Commerce
Environmental Protection Agency/Office of Administration and Resources
Management
Three anonymous Civilian Federal Agency responses
Defense Related Agencies
Department of Energy
Department of the Army
Department of the Navy
Department of the Air Force
Private Sector Corporations
Chevron Corporation
Xerox Corporation
3M Corporation
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CHAPTER!: METHODOLOGY
2.1 Benchmarking Overview
In recent years, benchmarking has proven to be a valuable tool for organizations committed
to continual improvement, particularly in the area of environmental performance. Through
benchmarking, managers can compare the attributes of their organization against the those of a
highly successful ("Best in Class") organization that has been identified as an exemplary
performer. Benchmarking can be an extremely useful tool to help organizations recognize areas
in which improvement is needed, and to provide a model toward which improvements can be
directed.
2.2 Benchmarking Methodology
The goal of the benchmarking process developed for this report is to identify those areas
in which the structural, managerial, and operating characteristics and practices of CFAs require
improvement in order to rise to the level of "Best in Class" performance. However, the
methodology used to establish the "Best in Class" benchmark for this study varies significantly
from traditional benchmarking procedures.
Rather than identifying one organization that could serve as a model toward which CFAs,
Defense Related Agencies, and private companies could all strive to emulate, the project team
identified, gathered, and reviewed various documents that present an ideal set of characteristics
for the performance of organizational environmental responsibilities. These documents were
developed by national and international standard setting organizations, as well as Federal agencies.
Some of these documents are in final form, others are in draft. A list of the documents that were
reviewed is found in Exhibit 2-1.
In addition, this report does not attempt to evaluate overall environmental compliance
performance, either present or historical, of a particular organization. Instead the intention is to
determine if certain organizational enabling systems have been established to allow the respondent
group to fully implement a sound environmental management program. Whether or not a
particular organizational group as discussed in this report has taken full advantage of these
enabling systems and translated this into an equally good compliance record was not evaluated
during this assessment and is not the subject of this report.
The project team reviewed these documents to identify organizational characteristics,
management attributes, and operational features that appeared in most or all of the standard setting
documents and were equally applicable to both public and private organizations. Six areas
meeting the above criteria were identified. These became "benchmark elements" for the purposes
of this analysis. Exhibit 2-2 lists and describes each of these elements.
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Exhibit 2-1
Documents Reviewed on Benchmark Development Process
Guideline for a Voluntary Environmental Management System, Revision 8.1. Canadian
Standards Association, March 1, 1994
Request for Environmental Leadership Program Pilot Project Proposals, United States
Environmental Protection Agency, Federal Register Notice 58FR4802, January 15, 1993
Proposed American National Standard, NSF International Standard for Environmental
Management Systems - Guidelines for Environmental Auditing - Principles and General
Practices. NSF 100-1994. Draft 3.5, February 1994
Proposed American National Standard, NSF International Standard for Environmental
Management Systems - Guiding Principles and Generic Requirements for Environmental
Management Systems. NSF 110-1994. Draft 5.1, May 1994
Protocols for Conducting Environmental Management Assessments of DOE Organizations,
United States Department of Energy, DOE/EH-0326, June 1993
A Guideline for a Voluntary Management System, NSF International. Revision 5.0, April
12, 1993
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Exhibit 2-2
Benchmark Elements
Organizational Structure
Best in Class organizations have an organizational structure that gives authority,
input, and voice to environmental performance
Management Commitment
Best hi Class organizations possess and demonstrate a commitment to environmental
excellence at each and every stage of the management hierarchy, and insist that the
organization integrate environmental awareness and concerns into all relevant
business operations
Implementation
Best hi Class organizations carry out then* day to day business operations in ways
that integrate environmental protection into then- business conduct
Information Collection/Management/Follow-up
Best hi Class organizations continually monitor environmental performance through
the use of formal tracking and reporting mechanisms. Information acquired through
these mechanisms is evaluated, disseminated, and used to continually improve
environmental performance
Internal and External Communication
Best hi Class organizations foster and use formal and informal channels to
communicate environmental commitment and performance information. Employee
communication is encouraged to develop cooperation and commitment, including
bringing together employees from different disciplines
Personnel
Best hi Class organizations ensure that employees are capable of developing and
implementing environmental initiatives. Employees are hired, trained, and deployed
hi ways that ensure that staff understand then- environmental responsibilities and
receive the training and support necessary to achieve environmental excellence
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Once the benchmark elements were identified, the project team developed a list of
indicative behaviors that exemplify organizational performance consistent with each benchmark
element. The presence or absence of these "key indicators" within the questionnaire responses
was the determining factor in analyzing whether or not reporting organizations were achieving
benchmark performance. Organizations reporting significant numbers of key indicators within
a benchmark element were determined to be demonstrating "Best in Class" performance within
that element; organizations reporting few or no indicative behaviors were determined to be
deficient hi that benchmark area.
Key indicators were identified through both an objective review of the standard setting
documents listed above, and through a subjective process where reported data was evaluated
against the definitions for each benchmark element. The list of key indicators associated with each
benchmark element is listed hi Exhibit 2-3.
Exhibit 2-3
Key Indicators of Best in Class Performance
Organizational Structure
Organizational mission statement exists that sets forth environmental business focus,
going beyond environmental compliance
Clear lines of authority, responsibility, and accountability are established for
environmental functions
Formal systems for statutory and regulatory tracking/monitoring exist and access to
legal resources is readily available
Environmental management functions are represented at the high(est) levels of the
organizations
Management Commitment
Organizations make resources available to identify, develop, initiate, and transfer
between facilities environmental improvement technologies and strategies
Environmental concerns are integrated into organizational business planning
Environmental considerations play a role hi all key organizational decisions
Management demonstrates a commitment to environmental protection that goes
beyond environmental compliance
A formal environmental risk management program has been instituted and is used to
assess potential risks from all proposed and existing operations
Capital budgeting evaluation criteria are used to allow environmental projects to
compete fairly for investment resources
Headquarters level policies exist that establish an environmental sense of direction
for facility level operations
Environmental criteria are used for the selection and management of
contractors/vendors
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Exhibit 2-3
Key Indicators of Best in Class Performance (continued)
Implementation
Short- and medium-range environmental performance goals are established for
individual business operations and for the organization as a whole
A wide range of potential environmental impacts are address through comprehensive
multi-media environmental programs. These programs include:
- pollution prevention
- recycling
-reuse
- control
- compliance
- affirmative procurement
- energy conservation
- emergency preparedness and response
Formal guidance is developed and disseminated to help ensure organizational
environmental excellence
Information Collection/Management/Follow-up
Information baselines have been established to identify, track, and measure inputs
(i.e., energy, water, materials) and wastes and emissions outputs
Information management systems are used to track and evaluate environmental
performance. These systems measure and verify data, evaluate collected data, and
identify improvement opportunities
Monitoring results are documented and distributed hi a timely manner to appropriate
management representatives
Business operations are modified in response to data findings to correct performance
and meet environmental goals. Corrective actions are tracked and verified to ensure
successful completion
"Lessons learned" programs have been implemented to identify improvement
opportunities
Trends analyses are performed to identify root causes of environmental performance
concerns
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Exhibit 2-3
Key Indicators of Best in Class Performance (continued)
Internal and External Communication
Channels exist for employees to anonymously communicate environmental
performance concerns without retribution
Employee suggestions are actively solicit. Concerns raised are addressed and
responses documented
Successful environmental programs and strategies are communicated throughout the
organization
Environmental awareness and performance information is communicated through the
use of employee newsletters, bulletin boards, electronic mail, etc.
Full and open cooperation exists with external oversight organizations
Input regarding environmental performance and opportunity identification is actively
solicited from external parties (e.g., customers, neighbors, regulators, general
public)
Personnel
Sufficient qualified staff are hired, deployed, and trained to ensure that all aspects of
the business operation are executed hi accordance with the organization's
environmental commitment
All employees receive initial and ongoing training to ensure that they 1) understand
the environmental requirements of their job, and 2) have the skills necessary to
execute their job responsibilities hi an environmentally sound manner
Environmental excellence is the explicit responsibility of every employee throughout
the organization, as demonstrated by the presence of environmental criteria hi each
employees job description/performance evaluation, or by other means
Exemplary environmental efforts are recognized and/or rewarded
2.3 Data Limitations
The evaluation of questionnaire responses reveals a great deal of information concerning
the ways in which Defense Related Agencies, Civilian Federal Agencies, and three private
corporations structure themselves and operate in order to fulfill then* environmental agenda. A
comparison of the responses between groups identifies areas in which each group excels, and areas
hi which improvement is needed.
Conclusions drawn from the questionnaire responses must be evaluated with a clear
understanding of the limitations inherent hi this data. These limitations are discussed below.
The primary data limitation involving the CFA questionnaire concerns the specific
language and scope of the questions posed to respondents. Both questionnaires were distributed
prior to the development of benchmark elements and key indicators. The questionnaire distributed
to CFA's focused predominantly on issues relating to environmental compliance. Therefore,
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questions posed to CFAs had to be "best fit" into a key indicator associated with one of the six
benchmark elements. In a number of instances, no questions neatly fit into certain key indicators.
These instances are clearly delineated in the report. In addition, this questionnaire elicited a large
number of responses consisting of one or two word positive or negative responses. Finally, the
CFA questionnaire was sent to respondents in January of 1993. Organizational changes occurring
since that date will not be reflected in the data.
While the questionnaire sent to Corporate Participants and Defense Related Agencies also
was distributed prior to the development of the Benchmark Elements and key indicators, its scope
more clearly fits into the developed benchmark. Hence, there are significantly fewer data gaps.
There are instances in which multiple questions provide data for the same key indicator. In these
instances, a positive response to any of the questions is considered to represent behavior consistent
with the key indicator. In addition, it should be noted that only three companies participated in
this effort. Therefore, responses should not be interpreted as indicative of overall private sector
activities in these areas. Rather, they reflect the reported activities of the three responding
corporations.
Comparisons and conclusions drawn from questionnaire responses can only be as good as
the data upon which they are based. By design, questionnaires ask respondents to report upon
their own behaviors or those of the organization to which the respondent belongs, based upon the
perceptions of the individual completing the questionnaire. Therefore, questionnaire responses
may be affected by the responding individual's position within the organization, then* knowledge
of organizational activities and characteristics in other parts of the organization, and the
willingness of the individual to answer fully and candidly.
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CHAPTER 3: Defense Related Agencies
3.1 Data Sources
This chapter summarizes the responses received from four Federal agencies (i.e., military
agencies and Department of Energy; hereafter "Defense Related Agencies" or "DRAs") to a 94-
question survey. In general, the survey focused on eight topic areas: organizational structure;
environmental commitment; environmental protection program; formality of environmental
program; internal and external communication; staff resources, training, and development;
evaluation, reporting, and corrective action; and environmental planning and risk management.
A copy of the questionnaire is included in Appendix A, Exhibit A-2, of this document.
Responses to the questionnaire were received from the following Defense Related Agencies:
United States Department of the Air Force
United States Department of the Navy
United States Department of the Army
United States Department of Energy
3.2 Performance Measured Against Benchmark Elements
3.2.1 Element 1: Organizational Structure
"Best in Class" organizations have an organizational structure that gives authority,
input, and voice to environmental performance.
Overall Findings:
In general, all of the Defense Related Agencies responding to the survey report that they
have developed organizational structures that enable them to effectively provide direction and
authority to their environmental programs.
Four key indicators have been identified for "Best in Class" organizations in regard to
organizational structure.
1. Organizational mission statement exists that sets forth environmental business
focus, going beyond environmental compliance.
2. Clear lines of authority, responsibility, and accountability are established for
environmental functions.
3. Formal systems for statutory and regulatory tracking/monitoring exist and access
to legal resources is readily available.
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4. Environmental management functions are represented at the high(est) levels of the
organization.
As an introductory overview, Exhibit 3-1 presents the total number of respondents reporting
multiple key indicative behaviors.
Exhibit 3-1
Element 1: Organizational Structure Key Indicators
Reported by Defense Related Agencies
All 4 Respondents (100%)
The following discussion compares specific survey findings against each of the four key
indicators representing "Best in Class" activities with regard to organizational structure.
Findings:
All of the Defense Related Agencies surveyed report that they have an environmental policy
statement presented in their organization's mission statement (either at the headquarters level or the
subordinate command level). For example, one respondent expressed their environmental mission
commitment as, "Environmental compliance is an integral part of our mission and will be included in
our daily operations and our strategic plans." Three of the four Defense Related Agencies surveyed
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report that their major program offices with environmental responsibilities include an environmental
component in their vision and mission statements that complement the overall departmental mission.
,' and
^. ^« ','!//
, -
All of the Defense Related Agencies surveyed report that they have organizational charts that
illustrate clear lines of authority for their environmental management structure. Typically, the
management structure is headed by an Assistant Secretary, under who serves a director of
environmental operations leading numerous environmental technical support divisions.
In general, the Defense Related Agencies as a group appear to consciously and clearly define
environmental responsibilities and communicate them to their employees. Three of the four agencies
report that environmental responsibilities are defined and communicated to all of their employees
whose activities may impact environmental performance. The respondents list a variety of methods
used for documenting environmental responsibilities of their employees, including: regulations,
guidance documents, specialty training standards, lesson plans, career development courses, position
descriptions, policy directives, manpower standards, instructions, and pamphlets. In addition,
responsibilities are communicated to employees through a number of other methods, including
performance standards, mission statements, training courses, publications, and communication with
supervisors.
' ' ' . ' ' i ' ' " ' " ' ' ' ' ' ' i '
f f 't ff .? f ' S * f rr f . ""- ' f
'
exist
Findings:
Statutory and regulatory tracking/monitoring is performed by all of the Defense Related
Agencies surveyed according to the questionnaire responses. The methods used to track regulatory
developments varied among the survey respondents and included: subscriptions to periodicals (BNA
Environmental Reporter, Federal Register, and media-specific technical journals and newsletters),
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training courses on emerging compliance requirements, and on-line data retrieval through the Defense
Environmental Network and Information Exchange (DENIX) bulletin board. Several of the agencies
have also established centers or institutes to monitor changing Federal environmental regulations,
policies, and laws. One agency has an Office of Environmental Guidance that develops a bimonthly
environmental regulatory update table for distribution Department-wide. In addition, two of the four
agencies appear to be organized to have ready access to legal resources for interpreting new
environmental regulations. These two respondents indicate that attorneys in their Office of General
Counsel are available to assist in interpreting environmental regulations, and one respondent indicated
that their agency has a Legal Services Environmental Law Division to assist with this function.
Findings:
All of the Defense Related Agencies surveyed report having environmental management
functions represented at high levels of their organization. The positions of high-level authority with
direct environmental management responsibilities vary among the survey responses and include:
Director, Environmental Protection, Safety and Occupational Health; Assistant Secretary of the Navy
(Installations and Environment); Assistant Secretary for Environmental Management; Assistant
Secretary for Environment, Safety, and Health; Assistant Secretary of the Air Force for Manpower,
Reserve Affairs, Installations, and Environment (presidential appointee reporting directly to the
Secretary of the Air Force); Assistant Secretary of the Environment for Installations, Logistics, and
Environment; Deputy for Environment, Safety and Occupational Health; and Director of
Environmental Programs (a brigadier general). Most respondents report that environmental policy
and standards are established at the Assistant Secretary level and that technical support and
environmental oversight of line organizations is performed by a Director of Environmental Programs
or a Civil Engineer Support Agency. When asked what specific high-level positions have authority
to ensure compliance with Federal and state environmental laws and regulations, the other Federal
agency respondents report a variety of positions, including: installation Commanding officers, Deputy
Chief of Staff and Environmental Counselor (reporting directly to the Secretary); Chief, Compliance
Division, Directorate of Environmental Quality; and Director of Environmental Programs.
Benchmark Element Summary:
This section summarizes the collective behavior of the four responding Defense Related
Agencies as evaluated against the key indicators for this Benchmark Element. Exhibit 3-2 presents
the total number of respondents reporting each key indicative behavior.
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Exhibit 3-2
Number of Defense Related Agencies Reporting Each
Organizational Structure Key Indicator
I
«2 #3
Organizational Structure Key Indicators
#1 = Mission Statement Exists
#2 = Clear Lines of Authority
#3 = Statutory/Regulatory Tracking
#4 = High-level Representation
In general, all of the Defense Related Agencies responding to the survey report that they have
developed organizational structures that enable them to effectively provide direction and authority
to their environmental programs. All of the key indicators for "Best in Class" performance with
respect to environmental organizational structure are reflected in the responses of each of the Defense
Related Agencies surveyednone of the key indicators appeared with more frequency than the others.
3.2.2 Element 2: Management Commitment
"Best in Class" organizations possess and demonstrate a commitment to
environmental excellence at each and every stage of the management hierarchy, and
insist that the organization integrate environmental awareness and concerns into all
relevant business operations.
15
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Overall Findings:
In general, most of the Defense Related Agencies responding to the survey report a strong
management commitment to environmental excellence. Performance in a few areas (i.e. resource
availability, organizational decision making, and contractor/vendor selection) is unclear since the
questionnaire did not solicit this information. Eight key indicators have been identified for "Best in
Class" organizations in regard to management commitment.
1. Organizations make resources available to identify, develop, initiate, and transfer
environmental improvement technologies and strategies between facilities.
2. Environmental concerns are integrated into organizational business planning.
3. Environmental considerations play a role in all key organizational decisions.
4. Management demonstrates a commitment to environmental protection that goes
beyond environmental compliance.
5. A formal environmental risk management program has been instituted and is used to
assess potential risks from all proposed and existing operations.
6. Capital budgeting evaluation criteria are used to allow environmental projects to
compete fairly for investment resources.
7. Headquarters level policies exist that establish an environmental sense of direction for
facility level operations.
8. Environmental criteria are used for the selection and management of
contractors/vendors.
As an introductory overview, Exhibit 3-3 presents the total number of respondents reporting multiple
key indicative behaviors.
The following discussion compares specific survey findings against each of the eight key
indicators for "Best in Class" organizations with regard to management commitment.
16
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Exhibit 3-3
Element 2: Managment Commitment Key Indicators
Reported by Defense Related Agencies
1 Respondent (25%)
2 Respondents (50%)
1 Respondent (25%)
Findings:
The survey did not ask any questions regarding the availability of resources for identifying,
developing, initiating, and transferring environmental improvement technologies and strategies
between facilities; hence, this key indicator for management commitment was not reported by any of
the respondents.
2. ' Environmental concerns are integrated into organizational business
* ..*. ' ' * . .. *. ^
17
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Findings:
All of the Defense Related Agencies surveyed integrate environmental concerns into their
organizational business planning. Two of these respondents indicate that environmental planning is
integrally entwined with their overall business planning process. The other two respondents state that
environmental plans actually drive their long-term management plans. The survey respondents differ
in their responses regarding the frequency of their planning activities. One states that environmental
planning is a continuous improvement process, while the other three respondents state that
environmental planning is conducted on an annual basis.
'$. - -' BavJ^teBta! c^isiamtioas play *;ms it*-all
Findings:
The survey did not ask any questions regarding the role of environmental considerations in
making key organizational decisions; hence, this key indicator for management commitment was not
reported by any of the respondents. However, the Defense Related Agencies surveyed do integrate
environmental concerns into their organizational business planning, as discussed above.
4, ' MamgementdemoiBtmtes a commitment to envimnm
Findings:
Top management commitment to environmental programs was reported by all of the Defense
Related Agencies responding to the survey. Methods used by these agencies to show support for
environmental programs include publishing annual environmental reports (including an Annual
Environmental Report to Congress), holding semi-annual environmental briefings, presenting internal
and external speeches, conducting conferences, and distributing environmental policy statements.
One of these agencies reports that their Chief of Staff gives an address and presents environmental
awards at an annual Earth Week celebration. In addition, senior management meetings are used by
18
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all of the respondents as a forum for discussing environmental management issues. The reported
frequency of these management meetings ranged from weekly to annually.
5:. , A formal envkonraenM risk management program has bee^
is usei to' assess '
Only two of the Defense Related Agencies responding to the survey report that they use a
formal risk management program that addresses environmental concerns; however, one agency did
not respond to the survey questions on risk management and another indicated that they are currently
developing a risk based management process. Two survey respondents indicate that operations are
reviewed routinely by staff to minimize possible risk. One of these respondents describes their risk
management program as using a team approach which includes representatives from safety,
environmental, medical, police, fire department, and other functional areas to identify whether
systems, equipment, and procedures are in place or are required to prevent or lessen a hazardous
material release. In addition, all of the survey respondents answering the questions on risk
management unanimously state that all new projects are reviewed for environmental impact issues.
Findings:
The organization's budgeting process is affected by the results of the environmental planning
process according to all four Defense Related Agencies surveyed. Three of these respondents report
that environmental planning is integrally related to their budgeting process; the fourth respondent
states that environmental planning hi the form of compliance with the NEPA process reveals costs
which are included in budget submittals for proposed actions. Additionally, one respondent states
that their agency publishes an agency Instruction on Environmental Budgeting to provide information
required at installations to properly budget for pollution prevention requirements.
19
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Findings:
In addition to having corporate environmental policy statements, all of the Defense Related
Agencies surveyed report having environmental goals and corporate policy statements to support
their environmental programs. One respondent comments further that environmental policy
statements at their agency are signed jointly by the Secretary and Chief of Staff, and that policies are
formally supported by a policy directive entitled "Environmental Quality" and by agency instructions.
Findings:
Three of the Defense Related Agency respondents indicate that contractors are briefed on
corporate environmental standards and policies; the fourth respondent states that it is dependent on
the nature of the contract as to whether environmental policies are delineated to contractors. Those
agencies giving positive responses reported using environmental documentation, contract
requirements, and briefings during pre-startup meetings to inform contractors of their environmental
policies and performance requirements. Furthermore, one respondent states that it is their agency's
policy that "management and operating contractors will conduct their operations in an
environmentally sound manner that limits the risks to the environment and protects public health."
Thus, the survey responses show that the Defense Related Agencies manage their contractors with
environmental considerations in mind; however, the survey responses did not indicate whether
environmental criteria are used for the selection of contractors/vendors.
Benchmark Element Summary:
This section summarizes the collective behavior of the four responding Defense Related
Agencies as evaluated against the key indicators for this Benchmark Element. Exhibit 3-4 below
presents the total number of respondents reporting each key indicative behavior.
20
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Exhibit 3-4
Number of Defense Related Agencies Reporting Each
Management Commitment Key Indicator
i
5
f2 *3 f4 US *6 *7
Management Commitment Key Indicators
«8
(Indicators #1 and #3 were not addressed in the questionnaire.)
#1 = Resources Made Available #5 = Formal Risk Management Program
#2 = Business Planning Integration #6 = Budgeting Criteria Used
#3 = Role in all Organization Decisions #7 = Headquarters Level Policies
#4 - Management Commitment beyond #8 = Selection/Management of Contractors/
Compliance Vendors
In general, most of the Defense Related Agencies responding to the survey report strong
management commitment to environmental excellence. Performance in a few areas is unclear,
however, since the questionnaire did not solicit certain information. In particular, the questionnaire
did not address resource availability for identifying, developing, initiating, and transferring
environmental improvement technologies and strategies between facilities. The questionnaire also
did not ask whether environmental considerations play a role in all key organizational decisions.
Furthermore, it was not clear from the survey responses whether environmental criteria are used for
the selection of contractors and vendors. However, four of the management commitment key
indicators for "Best in Class" organizations were reflected in the responses of all the Defense Related
Agencies.
21
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3.2.3 Element 3: Implementation
"Best in Class" organizations carry out their day to day business operations in ways
that integrate environmental protection into their business conduct.
Overall Findings:
In general, all of the Defense Related Agencies responding to the survey have established
progressive goals and multi-media environmental programs to integrate environmental protection into
their daily business conduct.
Three key indicators have been identified for "Best in Class" organizations in regard to
environmental program implementation.
1. Short- and medium-range environmental performance goals are established for
individual business operations and for the organization as a whole.
2. A wide range of potential environmental impacts are addressed through
comprehensive multi-media environmental programs. These programs include:
pollution prevention - compliance
recycling - affirmative procurement
reuse - energy conservation
control - emergency preparedness and response.
3. Formal guidance is developed and disseminated to help ensure organizational
environmental excellence.
As an introductory overview, Exhibit 3-5 presents the total number of respondents reporting multiple
key indicative behaviors.
22
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Exhibit 3-5
Element 3: Implementation Key Indicators
Reported by Defense Related Agencies
All 4 Respondents (100%)
The following discussion compares specific survey findings against each of the three key
indicators for "Best in Class" organizations with regard to environmental program implementation
«goals are.
Findings:
All of the Defense Related Agency respondents indicate that they have established aggressive
waste and emission reduction goals beyond what is needed for compliance with existing regulations.
In addition, all of the respondents report that they have established facility-specific pollution reduction
goals. One of these respondents indicate that their strategic goal is to "prevent future pollution by
reducing hazardous material use and releases of pollutants into the environment to as near zero as
23
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feasible." Another respondent summarizes their goals as prioritizing risks, attaining public trust, and
leading Federal agencies in environmental technology development.
2,
A
Findings:
.. All of the Defense Related Agencies surveyed have comprehensive multi-media environmental
protection programs in place to implement their agency-wide environmental goals. In summary, all
of the agencies report establishing and using the following types of implementation programs:
emergency response plans; pollution prevention programs; recycling programs; waste minimization
programs; surface water protection programs; groundwater monitoring programs; toxic chemical
control programs (e.g. pesticides, PCBs, petroleum, and asbestos management); solid and hazardous
waste management programs (e.g. waste source identification, characterization, minimization, and
training); radioactive materials management programs, underground storage tank removal programs;
and NEP A compliance programs. In addition to the above programs, three agencies indicate that they
also have programs addressing air emissions control, and one agency reports that they have an energy
conservation program in place.
ftfttorr
3- FoiiMi^guidaaee: $
developed and disseminated to help ensure
-
24
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Findings:
All of the Defense Related Agencies surveyed provide formal guidance in meeting
environmental goals to all departments within their organization. These respondents indicated that
guidance is provided through strategic plans, policy directives, instructions, regulations, and other
directives.
Benchmark Element Summary:
This section summarizes the collective behavior of the four responding Defense Related
Agencies as evaluated against the key indicators for this Benchmark Element. Exhibit 3-6 below
presents the total number of respondents reporting each key indicative behavior.
Exhibit 3-6
Number of Defense Related Agencies Reporting Each
Implementation Key Indicator
5
#1 *2 f3
Implementation Key Indicators
#1 = Environmental Performance Goals Established
#2 = Comprehensive Multi-media Environmental Programs Exist
#3 = Formal Guidance Developed and Disseminated
25
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In general, all of the Defense Related Agencies responding to the survey have established
progressive goals and multi-media environmental programs to integrate environmental protection into
their daily business conduct. All three of the implementation key indicators for "Best in Class"
organizations were reflected in the responses of all the Defense Related Agencies.
3.2.4 Element 4: Information ColIection/Management/Follow-up
"Best in Class" organizations continually monitor environmental performance
through the use of formal tracking and reporting mechanisms. Information acquired
through these mechanisms is evaluated, disseminated, and used to continually
improve environmental performance.
Overall Findings:
In general, all of the Defense Related Agencies responding to the survey appear to have strong
programs for information collection, management, and follow-up. Performance in a few areas (i.e.
establishing information baselines and "lessons learned" programs) is unclear since the survey did not
request this information.
Six key indicators have been identified for "Best in Class" organizations in regard to
environmental information collection/management/follow-up.
1. Information baselines have been established to identify, track and measure inputs (i.e.,
energy, water, materials) and wastes and emissions outputs.
2. Information management systems are used to track and evaluate environmental
performance. These systems measure and verify data, evaluate the collected data, and
identify improvement opportunities.
3. Monitoring results are documented and distributed in a timely manner to appropriate
management representatives.
4. Business operations are modified in response to data findings to correct performance
and meet environmental goals. Corrective actions are tracked and verified to ensure
successful completion.
5. "Lessons learned" programs have been implemented to identify improvement
opportunities.
6. trends analyses are performed to identify root causes of environmental performance
concerns.
As an introductory overview, Exhibit 3-7 presents the total number of respondents reporting multiple
key indicative behaviors.
26
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Exhibits-?
Element 4: Information Collection/Management/Follow-up
Key Indicators Reported by Defense Related Agencies
2 Respondents (50%)
iiii-iii-iiiiii-iii-j
iiiiiiiiiiiiiiiii!
iii-i-il-ai
2 Respondents
(50%)
The following discussion compares specific survey findings against each of the six key
indicators for "Best in Class" organizations with regard to environmental information
collection/management/follow-up.
*~~wp
*?s
> ff f J f ' .. f' f f / ^ fvf' f f ff
f * * S'f -.4 f -f*f
. Information baselines have been established to identify, track and
Findings:
The survey did not ask any questions regarding information baselines; hence, this key indicator
for information collection/management/follow-up was not reported by any of the respondents.
27
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Findings:
All four Defense Related Agencies surveyed report that they use information management
systems to monitor and control environmental information. One of these respondents report that their
agency uses a central database system (Work Information Management System-Environmental
Subsystem) for tracking and reporting information on all cleanup, compliance, EIAP, natural/cultural
resources, and pollution prevention information. The other three respondents report that each
facility/installation has developed and uses some type of environmental information management
system, even though no standard department-level system exists. Three Defense Related Agencies
report that they are currently developing automated chemical inventory and tracking systems needed
for TRI reporting. Only one respondent indicates that their environmental database is integrated into
a larger information management system using the Defense Environmental Corporate Information
Management (DECIM) System; one other respondent states that their agency is in the process of
integrating their environmental system using DECIM. Three respondents indicates that they have,
on a facility-by-facility basis, databases which track waste manifests and permitting records; the fourth
respondent indicates that their agency tracks permits but does not track manifests. Two respondents
report that they have a central inventory which tracks and profiles waste streams and/or emissions;
however, none have a main inventory which tracks regulated sites or materials.
3>
and distributed in a timely manner
Findings:
All of the Defense Related Agencies surveyed report that they perform environmental audits
and evaluations using a combination of internal staff and outside consultants. All of the Defense
Related Agencies perform formal "external" audits every three years, with informal "self-audits" being
conducted by facilities on an annual basis. In addition, one of these respondents reports a third tier
under which Inspector General environmental evaluations are conducted on an "as needed" basis, and
another reports using a prioritization scheme to aid in selecting particular facilities to audit. 'This
28
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selection process is based upon a series of criteria that include: nature of the operation; environmental
organization and management; audit history; strength of internal programs; environmental
performance indicators; potential targets/receptors; and special issues.
At all of the Defense Related Agencies surveyed, audit results are documented and distributed
in a timely manner to appropriate management representatives; however, audit reporting methods
varied among the agencies surveyed. One agency electronically transmits audit findings to Major
Commands and Headquarters. Another agency requires auditors to conduct a close-out meeting with
facility management at the end of an audit and to provide management with a draft findings report
for comment before its final publication and distribution to the Assistant Secretary for Environment,
Safety, and Health; the Program Secretarial Officer; and field managers. A third agency has auditors
prepare a report for distribution to installations and Major Commands; the overall audit results are
entered into a Headquarters-level database and documented in an annual report, as well as being
presented in periodic briefings. The fourth agency reported that audit results are distributed to the
Commanding Officer of the installation, the installation environmental staff, and the Chief of
Operations.
Findings:
All of the Defense Related Agencies surveyed state that environmental issues and deficiencies
identified in audit reports are tracked by the installations to ensure corrective actions are taken on a
timely basis. One of these respondents comments further that the development of installation
corrective action plans is required.
29
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Findings:
The survey did not ask any questions regarding "lessons learned" programs; hence, this key
indicator for information collection/management/follow-up was not reported by any of the other
Federal agency respondents.
Findings:
Only two of the Defense Related Agencies surveyed indicate that environmental audit report
results are analyzed to identify root causes of environmental performance concerns. One of these
respondents states that their environmental division produces an annual report of evaluation results
with corresponding analyses; the other respondent states that their agency's Major Commands
conduct varying degrees of analysis on the audit data.
Benchmark Element Summary:
This section summarizes the collective behavior of the four responding Defense Related
Agencies as evaluated against the key indicators for this Benchmark Element. Exhibit 3-8 presents
the total number of respondents reporting each key indicative behavior.
30
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Exhibit 3-8
Number of Defense Related Agencies Reporting Each
Information Collection/Management/Follow-up Key Indicator
*2 *3 «4 «S
Info. Collection/Mgmt. Key Indicators
(Indicators #1 and #5 were not addressed in the questionnaire.)
#1 = Information Baselines Established
#2 = Information Management Systems Used
#3 = Monitoring Results Documented
#4 = Performance Corrected to Meet Goals
#5 = "Lessons Learned" Programs Established
#6 = Trends Analyses Performed
In general, all of the Defense Related Agencies responding to the survey appear to have strong
programs for information collection, management, and follow-up, although there are a few areas
where it is unclear whether their programs include components that address specific key indicators.
Specifically, the survey did not ask whether formal environmental baselines that measure the material
inputs and environmental releases of all current operations have been developed. Similarly, no
questions were asked in the survey regarding "lessons learned" programs. Three of the information
coUection/management/follow-up key indicators for "Best in Class" organizations were reflected in
the responses of all the Defense Related Agencies.
31
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3.2.5 Element 5: Internal and External Communication
"Best in Class" organizations foster and use formal and informal channels to
communicate environmental commitment and performance information. Employee
communication is encouraged to develop cooperation and commitment, including
bringing together employees from different disciplines.
Overall Findings:
In general, all of the Defense Related Agencies responding to the survey have strong internal
and external communication channels for soliciting and disseminating environmental information.
However, performance in a few areas (i.e. communicating successful strategies and cooperation with
external oversight organizations) is unclear since the survey did not request this information. Six key
indicators have been identified for "Best in Class" organizations in regard to internal and external
communication.
1. Channels exist for employees to anonymously communicate environmental
performance concerns without retribution.
2. Employee suggestions are actively solicited and any concerns raised are addressed and
responses documented.
3. Successful environmental programs and strategies are communicated throughout the
organization.
4. Environmental awareness and performance information is communicated through the
use of employee newsletters, bulletin boards, electronic mail, etc.
5. Full and open cooperation with external oversight organizations exists.
6. Input regarding environmental performance and opportunity identification is actively
solicited from external parties (e.g., customers, neighbors, regulators, general public).
As an introductory overview, Exhibit 3-9 presents the total number of respondents reporting multiple
key indicative behaviors.
32
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Exhibit 3-9
Element 5: Internal and External Communication
Key Indicators Reported by Defense Related Agencies
All 4 Respondents (100%)
The following discussion compares specific survey findings against each of the six key
indicators for "Best in Class" organizations with regard to internal and external communication.
I. Chaiaiels oft* Itor
Findings:
All of the Defense Related Agencies surveyed have a program in place which allows
employees to raise environmental concerns anonymously. All of the agencies have programs
providing for anonymous written comments; furthermore, three of these agencies have established
hotlines for employee concerns. The same three agencies indicated above reports that employees also
have access to the Inspector General complaint system. One agency comments further that steps are
being taken to promote the whistleblower effort within the Department to stress "zero tolerance" to
reprisal. Another agency noted that all employee concerns are submitted to the appropriate
department for investigation within ten days of receipt, and an Employee Concerns Manager and an
33
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Employee Concerns Review Panel ensure that appropriate actions are taken in accordance with
established schedules.
Findings:
All of the Defense Related Agencies surveyed have a program in place which solicits and
responds to employee suggestions (see discussion immediately above).
',-;i'*',*,' >'< /-1'-*;**,
" -*
-------
Findings:
All of the Defense Related Agencies responding to the survey report using a wide variety of
methods to communicate environmental awareness and performance information internally to their
employees. The methods used include memos, letters, guidance documents, department-wide
responses to rulemakings, regulatory bulletins, information briefs, formal directives, training,
meetings, distributed data bases, electronic mail, telephones, telefaxes, conferences, and articles in
internal publications.
Findings:
The survey did not ask any questions regarding cooperation with external oversight
organizations; hence, this key indicator for internal and external communication was not reported by
any of the Defense Related Agency respondents.
6. Input regarding environmental performance and opportunity
f& "%? 4^ f Jv p* <* * v
identification is actively solicited from external parties
-------
Benchmark Element Summary:
This section summarizes the collective behavior of the four responding Defense Related
Agencies as evaluated against the key indicators for this Benchmark Element. Exhibit 3-10 presents
the total number of respondents reporting each key indicative behavior.
Exhibit 3-10
Number of Defense Related Agencies Reporting Each
Internal/External Communication Key Indicator
«2 *3 *4 «S
Internal/External Comm. Key Indicators
(Indicators #3 and #5 were not addressed in the questionnaire.)
#1 = Channels Exist for Reporting Environmental #4 = Environmental Awareness Communicated
Concerns #5 = Cooperation with External Oversight Organizations
#2 - Employee Suggestions Solicited #6 = Input Solicited from External Parties
#3 = Successful Programs/Strategies Communicated
In general, all of the Defense Related Agencies responding to the survey have strong internal
and external communication channels for soliciting and disseminating environmental information.
However, performance in a few areas (i.e. communicating successful strategies and cooperation with
external oversight organizations) is unclear since the survey did not request this information. Four
of the internal/external communication key indicators for "Best hi Class" organizations were reflected
in the responses of all Defense Related Agencies.
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3.2.6 Element 6: Personnel
"Best in Class" organizations ensure that personnel are capable of developing and
implementing environmental initiatives. Employees are hired, trained, and deployed
in -ways that ensure that staff understand their environmental responsibilities and
receive the training and support necessary to achieve environmental excellence.
Overall Findings:
In general, all of the Defense Related Agencies responding to the survey have strong
employee hiring, training, and incentive programs to ensure that sufficient environmental personnel
are available to develop and implement environmental initiatives.
Four key indicators have been identified for "Best in Class" organizations in regard to
personnel.
1. Sufficient qualified staff are hired, deployed, and trained to ensure that all aspects of
the business operation are executed in accordance with the organization's
environmental commitment.
2. All employees receive initial and ongoing training to ensure that they a) understand
the environmental requirements of their job, and b) have the skills necessary to
execute their job responsibilities in an environmentally sound manner.
3. Environmental excellence is the explicit responsibility of every employee throughout
the organization, as demonstrated by the presence of environmental criteria in each
employee's job description/performance evaluation, or by other means.
4. Exemplary environmental efforts are recognized and/or rewarded.
As an introductory overview, Exhibit 3-11 presents the total number of respondents reporting
multiple key indicative behaviors.
37
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Exhibit 3-11
Element 6: Personnel Key Indicators
Reported by Defense Related Agencies
3 Respondents (75%)
1 Respondent (25%)
The following discussion compares specific survey findings against each of the four key
indicators for "Best in Class" organizations with regard to personnel.
Findings:
The current number of environmental staff reported to be employed by the Defense Related
Agencies surveyed varies from 1,000 to 3,018 persons. Whether this level of staffing is sufficient is
not indicated by the survey responses. All of the Defense Related Agencies surveyed employ some
type of forecasting method to determine future environmental staffing needs, based upon
departmental priorities or manpower staffing studies. All of the agencies specify qualifications
38
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required for entry-level and senior-level environmental positions (typically undergraduate or graduate
degrees in science or engineering and appropriate management experience).
All of the Defense Related Agencies surveyed state that they provide environmental training
to all their employees. Two agencies state that they provide initial environmental training as part of
employee orientation, and all of the agencies provide ongoing environmental training on a mandatory
basis. One of these agencies comments further that they work cooperatively with EPA and other
outside entities to offer joint training opportunities and to make outside environmental training
available to employees. The methods for assessing training needs varied among the respondents.
Two agencies state that training requirements are evaluated using a needs survey; two other agencies
indicate that they have developed a Master Training Plan to identify who needs training and what type
of training they require. All of the respondents indicate that emergency response procedures are
communicated to employees through routine training sessions and drills.
Per&waet Kg? In&G&t&f: ,,
3, Environmental ^excellence Is the expiiGJt responsibilily of
.. esaployee throJighcRit the wganization, as demonstrated by te
v ''"*^_^i ^4 efivfeoameikal criteda In «ach employee*? in*t'"
or by oflier means. -,, ,/
Findings:
Three of the Defense Related Agencies responding to the survey indicate that staff who have
some environmental duties, even though not their primary duties, have environmental responsibilities
documented (usually in their job descriptions). In addition, three of the Defense Related Agencies
responding to the survey indicate that all employees who are responsible for environmental
management are held accountable for their performance. These agencies indicate that employees are
39
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held accountable for their performance through environmental criteria included in their performance
evaluations.
Perwtmet Key Indicator:
ary environmeniai ertorts are recognized ana/or
' , ' # **,**<**,*' ^ - < * *"/ v/tf^/x - A
i * ^5 -.-*.*. '.. -" % . -** . ^ ^ * j- j> ' ^ ff. t ' s
' *f ff ' ' ; ', ' ^ ^ A %/ ^ ^ ^^^-*
All of the Defense Related Agencies surveyed recognize and/or reward their employees for
exemplary environmental efforts. Each agency has some type of formal program that consists of a
variety of awards and incentives. Three of these agencies present awards for individual and team
environmental excellence in various areas, including environmental quality, environmental restoration,
environmental compliance, pollution prevention, environmental planning, and natural/cultural
resources management. The major form of recognition reported is public and peer recognition, rather
than monetary rewards (which is reported by only one respondent).
Benchmark Element Summary:
This section summarizes the collective behavior of the four responding Defense Related
Agencies as evaluated against the key indicators for this Benchmark Element. Exhibit 3-12 below
presents the total number of respondents reporting each key indicative behavior.
40
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Exhibit 3-12
Number of Defense Related Agencies Reporting Each
Personnel Key Indicator
Personnel Key Indicators
#1 = Sufficient Qualified Staff Hired, Deployed, and Trained
#2 = Initial and Ongoing Training for all Employees
#3 = Environmental Excellence is the Responsibility of Every Employee
#4 = Exemplary Efforts Recognized/Rewarded
In general, all of the Defense Related Agencies responding to the survey have strong
employee hiring, training, and incentive programs to ensure that sufficient environmental personnel
are available to develop and implement environmental initiatives. Three out of four of the personnel
key indicators for "Best in Class" performance were reflected in the responses of all the Defense
Related Agencies.
41
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CHAPTER 4: Corporate Participants
4.1 Data Sources
This chapter summarizes the responses received from three private corporations to a 94
question survey. In general, the survey focused on eight topic areas: organizational structure;
environmental commitment; environmental protection program; formality of environmental
program; internal and external communication; staff resources, training, and development;
evaluation, reporting, and corrective action; and environmental planning and risk management.
A copy of the questionnaire is included as Appendix A, Exhibit A-2, of this document.
Responses to the questionnaire were received from the following three private corporations:
Xerox Corporation
Chevron Corporation
3M
4.2 Performance Measured Against Benchmark Elements
4.2.1 Element 1: Organizational Structure
"Best in Class" organizations have an organizational structure that gives authority,
input, and voice to environmental performance.
Overall Findings:
In general, all of the private organizations responding to the survey have developed
organizational structures that enable them to effectively provide direction and authority to their
environmental programs, performing well against the "Best in Class" measurement.
Four key indicators have been identified for "Best in Class" organizations in regard to
organizational structure.
1. Organizational mission statement exists that sets forth environmental business
focus, going beyond environmental compliance.
2. Clear lines of authority, responsibility, and accountability are established for
environmental functions.
3. Formal systems for statutory and regulatory tracldng/monitoring exist and access
to legal resources is readily available.
42
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4. Environmental management functions are represented at the high(est) levels of the
organization.
As an introductory overview, Exhibit 4-1 below presents the total number of respondents reporting
multiple key indicative behaviors.
Exhibit 4-1
Element 1: Organizational Structure Key Indicators
Reported by Corporate Participants
All 3 Respondents (100%)
The following discussion compares specific survey findings against each of the four key
indicators representing "Best in Class" activities with regard to organizational structure.
'---, -V, * v', " 'vv ?'-,"- "*"» '"-'" -
.* - - ','t '»,n "... *.:f"/'\,, Vfe^iA l'^₯A?j*'h'/#'r%'«",''- w>^/ ,vsy ?-., ''-',\
1. Organizational mission statement exists that ^tsio^
43
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Findings:
All of the Corporate Participants surveyed have a corporate environmental policy statement
presented either in their organization's mission statement or in a formal policy letter. One of the
respondent corporations has a particularly aggressive environmental policy statement, "It is our policy
to conduct business in a socially responsible and ethical manner that protects safety, health and the
environment. The goal is to be a leader within industry by emphasizing innovation and encouraging
creative solutions, both of which will improve our competitive position."
-{- , -'-. , ; *',
-2, dear lines of «Mjbttfigr,,,' m^wM&ty, w&
-are
?, , . -, '
f /* f
Findings:
All of the Corporate Participants surveyed report that they have organizational charts that
illustrate clear lines of authority for the company's environmental management structure. Two of the
corporations have a centralized environmental organization as a department in the corporate
structure. One of these corporations shows an organizational chart for their centralized department
"Corporate Strategic Services, Environment, Health and Safety" which is headed by a director and
has thirteen environmental subdivisions under it. The corporate environmental group handles the
majority of environmental issues for all of the operating units and is responsible for ensuring that all
facilities and operations are in compliance with all environmental requirements.
In general, the Corporate Participants as a group appear to consciously and clearly define
environmental responsibilities and communicate them to their employees. All of the corporations use
employee job descriptions as a medium for documenting the environmental responsibilities of their
employees. In addition, responsibilities are communicated to employees through a number of other
methods, including formal presentations, training sessions, internal correspondence, and specifications
in operating procedures. One respondent emphasizes its structure of total corporate responsibility,
stating that it communicates often the message that "all employees have responsibility for the waste
that they are generating and the responsibility to take action to reduce that environmental waste."
44
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Findings:
Statutory and regulatory tracking/monitoring is performed by all of the Corporate Participants
surveyed according to the questionnaire responses. The methods used to track regulatory
developments vary among the survey respondents and include: subscriptions to periodicals (BNA
Environmental Reporter, Inside EPA, Federal Register), regulatory tracking services, and personal
contact with government regulators. In addition, all of the corporations appear to have ready access
to legal resources for interpreting new environmental regulations. The entire group of respondents
indicate that attorneys in their Office of General Counsel are available to assist in interpreting
environmental regulations; although one respondent indicate that primary responsibility for this
function belongs with the environmental engineers.
Findings:
All of the Corporate Participants surveyed report that they perform well against the key
indicator of having environmental management functions represented at high levels of their
organization. The highest level of authority with direct environmental management responsibilities
reported by two of the corporations surveyed is a corporate vice president (e.g., Corporate Vice
President of Environmental Affairs, Vice President of Environmental Engineering and Pollution
Control), who reports directly to the Chief Executive Officer and Chairman of the Board. Most
respondents indicate that environmental policy and standards are established by the vice president of
the organizations and technical support and environmental oversight of line organizations is
performed by managers. Compliance with Federal and state environmental laws and regulations is
under the authority of line managers and engineers.
45
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Benchmark Element Summary:
This section summarizes the collective behavior of the three responding Corporate
Participants as evaluated against the key indicators for this Benchmark Element. Exhibit 4-2 below
presents the total number of respondents reporting each key indicative behavior.
Exhibit 4-2
Number of Private Corporations Reporting Each
Organizational Structure Key Indicator
&
"5
92 93 94
Organizational Structure Key Indicators
#1 = Mission Statement Exists
#2 = Clear Lines of Authority
#3 = Statutory/Regulatory Tracking
#4 = High-level Representation
In general, all of the private organizations responding to the survey report that they have
developed organizational structures that enable them to effectively provide direction and authority
to their environmental programs. All of the key indicators for "Best in Class" performance with
respect to environmental organizational structure are reflected in the responses of each of the
Corporate Participants surveyed-none of the key indicators appeared with more frequency than the
others.
46
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4.2.2 Element 2: Management Commitment
Best in Class" organizations possess and demonstrate a commitment to
environmental excellence at each and every stage of the management hierarchy, and
insist that the organization integrate environmental awareness and concerns into all
relevant business operations.
Overall Findings:
In general, most of the private organizations responding to the survey report a strong
management commitment to environmental excellence. Performance in a few areas (i.e. resource
availability, organizational decision making, and contractor/vendor selection) is unclear since the
questionnaire did not solicit this information.
Eight key indicators have been identified for "Best in Class" organizations in regard to
management commitment.
1. Organizations make resources available to identify, develop, initiate, and transfer
environmental improvement technologies and strategies between facilities.
2. Environmental concerns are integrated into organizational business planning.
3. Environmental considerations play a role in all key organizational decisions.
4. Management demonstrates a commitment to environmental protection that goes
beyond environmental compliance.
5. A formal environmental risk management program has been instituted and is used to
assess potential risks from all proposed and existing operations.
6. Capital budgeting evaluation criteria are used to allow environmental projects to
compete fairly for investment resources.
7. Headquarters level policies exist that establish an environmental sense of direction for
facility level operations.
8. Environmental criteria are used for the selection and management of
contractors/vendors.
As an introductory overview, Exhibit 4-3 presents the total number of respondents reporting multiple
key indicative behaviors.
47
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Exhibit 4-3
Element 2: Management Commitment Key Indicators
Reported by Corporate Participants
1 Respondent (33%)
1 Respondent (33%)
1 Respondent (33%)
The following discussion compares specific survey findings against each of the eight key
indicators for "Best in Class" organizations with regard to management commitment.
Findings:
The questionnaire distributed to Corporate Participants did not include any questions that
specifically address this key indicator.
48
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Findings:
All of the Corporate Participants surveyed integrate environmental concerns into their
organizational business planning. Two of the respondents indicate that environmental planning is
integrally entwined with their overall business planning process (e.g., "there are some instances in
which the management plan drives the environmental plan, while there are other situations in which
the environmental plan will be a driver for the management plan"). The third respondent states that
environmental planning is incorporated into their long-term business plan. The survey respondents
differ in their responses regarding the frequency of their planning activities. One states that
environmental planning is a continuous improvement process based on environmental management
plans which are reviewed and updated quarterly. The other two respondents state that environmental
planning is conducted on an annual basis; however, one of the corporations is changing to a three-
year planning period beginning in 1994.
Findings:
The questionnaire distributed to Corporate Participants did not include any questions that
specifically address this key indicator. However, the Corporate Participants surveyed do integrate
environmental concerns into their organizational business planning, as discussed above.
49
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Findings:
Two of the three respondents indicate that corporate management is committed to
environmental protection that goes beyond environmental compliance. These corporations have
established aggressive waste and emission reduction goals beyond what is needed for compliance with
existing regulations. One respondent indicates that senior management has established a goal for all
its facilities to be "waste-free" by 1997, which includes a target of "zero" emissions and "zero" solid
waste being sent to landfills. To support this commitment, guidance is provided by environmental
staff and management has established measurement criteria. The second respondent indicates that
corporate management is committed to achieving the following goals: a 35% reduction in generation
of waste by 1995, a 70% reduction in air emissions by 1995, a 50% reduction in generation of waste
by 2000, and a 90% reduction of all environmental releases by 2000.
Top management commitment to environmental programs is reported by all of the Corporate
Participants responding to the survey. Methods used by these corporations to show support for
environmental programs include publishing environmental reports, presenting internal and external
speeches, incorporating environmental issues into their corporate annual reports, and establishing
corporate environmental policy. One corporation even distributes video tapes to its employees that
present the Chief Executive Officer and his position on environmental issues. In addition, senior
management meetings are used by all of the respondents as a forum for discussing environmental
management issues. One respondent indicates that environmental issues are discussed "routinely at
monthly senior management meetings, and quarterly at Environmental Leadership Steering
Committee meetings with senior management representation from all functions worldwide."
enwo^
-," -,- and; is used to assess potential risks from all proposed w& existing
_.-'-\/ f "* ; f f f f ^^
''' " '' ' "--.-'
Findings:
Only one of the Corporate Participants responding to the survey reports that they use a formal
risk management program that addresses environmental concerns. A second survey respondent states
that formal risk management programs are being developed by the business as a policy requirement;
however, the current focus of the programs is on process safety. Two survey respondents indicate
that operations are reviewed routinely by staff to minimize possible risk as part of
safety/environmental assessments of operational plans, processes, and products. In addition, the
survey respondents unanimously state that all new projects are reviewed for environmental impact
50
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issues. These reviews are typically conducted by the designing engineers and provide opportunity
for critique and design improvement. One respondent corporation has a "design for the environment"
program for products and processes that is based on full life cycle assessments.
tSXMKitf* / '/>,"",* ' ' >>?fA'
, ' ' / .- / -X- , f ,,'','* f
' £v * > f e ff ff ftf'f Sf -x- /'if & f$ $$f ff&j V f f
^ ' f't ft. J f f __ ftf ff,'t
Findings:
The organization's budgeting process is affected by the results of the environmental planning
process according to all three of the Corporate Participants surveyed. One respondent states that the
high cost of environmental compliance (e.g. $600 million in 1993) is factored into the organization's
budgeting process. Another respondent indicate that their organization functions on a capital forecast
system rather than a total budgeting process. Under the capital forecast system, all environmental
compliance requirements are treated as an absolute mandatory expenditure and are funded regardless
of whether they were in budgeting procedures or not; however, any voluntary pollution prevention
initiatives must compete with all other expenditures in the capital forecast.
/7.
Findings:
According to the questionnaire responses, all of the Corporate Participants surveyed posses
environmental goals and policies at the department or operating unit level in addition to having
corporate environmental policy statements. With the corporate policy statement serving as the
foundation, individual manufacturing plants and operating units develop their own goals and may
include an environmental statement in their vision, mission, or objectives.
51
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and tHasagemeBt of
Findings:
All of the private corporation respondents indicate that contractors are briefed on corporate
environmental standards and policies. One corporation conducts contractor safety training in which
environmental procedures are discussed. Another corporation thoroughly briefs contractors
regarding company environmental standards and policies and requires them to adhere to the same
high standards of environmental performance as are expected of internal staff. Thus, the survey
responses show that the corporations manage their contractors with environmental considerations in
mind; however, the survey responses did not indicate whether environmental criteria are used for the
selection of contractors/vendors.
Benchmark Element Summary:
This section summarizes the collective behavior of the three responding Corporate
Participants as evaluated against the key indicators for this Benchmark Element. Exhibit 4-4 below
presents the total number of respondents reporting each key indicative behavior.
52
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Exhibit 4-4
Number of Private Corporations Reporting Each
Management Commitment Key Indicator
M «S « §7
Management Commitment Kay Indicators
(Indicators #1 and #3 were not addressed in the questionnaire.)
#1 = Resources Made Available #5 = Formal Risk Management Program
#2 = Business Planning Integration #6 = Budgeting Criteria Used
#3 = Role in all Organization Decisions #7 = Headquarters Level Policies
#4 = Management Commitment beyond #8 = Selection/Management of Contractors/
Compliance Vendors
In general, most of the Corporate Participants responding to the survey report strong
management commitment to environmental excellence. Performance in a few areas is unclear,
however, since the questionnaire did not solicit certain information. In particular, the questionnaire
did not address resource availability for identifying, developing, initiating, and transfering
environmental improvement technologies and strategies between facilities. The questionnaire also
did not ask whether environmental considerations play a role in all key organizational decisions.
Furthermore, h was not clear from the survey responses whether environmental criteria are used for
the selection of contractors and vendors. However, four of the management commitment key
indicators for "Best in Class" organizations were reflected in the responses of all the Corporate
Participants.
53
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4.2.3 Element 3: Implementation
"Best in Class" organizations cany out their day to day business operations in ways
that integrate environmental protection into their business conduct.
Overall Findings:
In general, most of the private organizations responding to the survey have established
progressive goals and multi-media environmental programs to integrate environmental protection into
their daily business conduct.
Three key indicators have been identified for "Best in Class" organizations in regard to
environmental program implementation.
1. Short- and medium-range environmental performance goals are established for
individual business operations and for the organization as a whole.
2. A wide range of potential environmental impacts are addressed through
comprehensive multi-media environmental programs. These programs include:
pollution prevention - compliance
recycling - affirmative procurement
reuse - energy conservation
control - emergency preparedness and response.
3. Formal guidance is developed and disseminated to help ensure organizational
environmental excellence.
As an introductory overview, Exhibit 4-5 below presents the total number of respondents reporting
multiple key indicative behaviors.
54
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Exhibit 4-5
Element 3: Implementation Key Indicators
Reported by Corporate Participants
1 Respondent (33%)
1 Respondent (33%)
1 Respondent (33%)
The following discussion compares specific survey findings against each of the three key
indicators for "Best in Class" organizations with regard to environmental program implementation.
I." ,
as a whole.
55
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Findings:
Two of the three respondents indicate that their corporations have established aggressive
waste and emission reduction goals beyond what is needed for compliance with existing regulations.
One respondent indicates that senior management has established a goal for all its facilities to be
"waste-free" by 1997, which includes a target of "zero" emissions and "zero" solid waste being sent
to landfills. To support this commitment, guidance is provided by environmental staff and
management has established measurement criteria. The second respondent indicates that several short
and medium range performance goals have been established: a 35% reduction hi generation of waste
by 1995, a 70% reduction in air emissions by 1995, a 50% reduction hi generation of waste by 2000,
and a 90% reduction of all environmental releases by 2000.
2,- , A wide range of poteutial environmental impacts ate addreised?;'
Findings:
All of the Corporate Participants surveyed report the presence of comprehensive multi-media
environmental protection programs in place to implement their corporate environmental goals. In
summary, all of the corporations have established the following types of implementation programs:
emergency response plans; pollution prevention programs; recycling programs; air emissions control;
surface water protection programs; groundwater monitoring programs; toxic chemical control
programs (e.g. pesticides, PCBs, petroleum, and asbestos management); solid and hazardous waste
management programs; underground storage tank removal programs; and NEPA compliance
programs. In addition, one corporation indicates that they also have programs addressing
radioactive materials management and energy conservation.
56
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Findings:
Only one of the Corporate Participants surveyed provides formal guidance in meeting
environmental goals to all departments within their organization. Other respondents indicate that
individual operating units and production facilities must find their own ways to meet specific
environmental goals, with some assistance given by corporate environmental staff.
Benchmark Element Summary:
This section summarizes the collective behavior of the three responding Corporate
Participants as evaluated against the key indicators for this Benchmark Element. Exhibit 4-6 below
presents the total number of respondents repotting each key indicative behavior.
Exhibit 4-6
Number of Private Corporations Reporting Each
Implementation Key Indicator
2 «
Implementation Key Indicators
#1 = Environmental Performance Goals Established
#2 = Comprehensive Multi-media Environmental Programs Exist
#3 = Formal Guidance Developed and Disseminated
57
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In general, most of the private organizations responding to the survey have established
progressive goals and multi-media environmental programs to integrate environmental protection into
their daily business conduct. Two of the implementation key indicators for "Best in Class"
organizations were reflected in the responses of all the Corporate Participants; however, one key
indicator (i.e., provision of formal guidance to all corporate departments) was reported by only one
of the private corporation respondents.
4.2.4 Element 4: Information CoIIection/Management/Follow-up
"Best in Class" organizations continually monitor environmental performance
through the use of formal tracking and reporting mechanisms. Information acquired
through these mechanisms is evaluated, disseminated, and used to continually
improve environmental performance.
Overall Findings:
In general, most of the private organizations responding to the survey appear to have strong
programs for information collection, management, and follow-up. Performance in a few areas (i.e.
establishing information baselines and "lessons learned" programs) is unclear since the survey did not
request this information.
Six key indicators have been identified for "Best in Class" organizations in regard to
environmental information collection/management/follow-up.
1. Information baselines have been established to identify, track, and measure inputs
(i.e., energy, water, materials) and wastes and emissions outputs.
2. Information management systems are used to track and evaluate environmental
performance. These systems measure and verify data, evaluate the collected data, and
identify improvement opportunities.
3. Monitoring results are documented and distributed in a timely manner to appropriate
management representatives.
4. Business operations are modified in response to data findings to correct performance
and meet environmental goals. Correction actions are tracked and verified to ensure
successful completion.
5. "Lesson learned" programs have been implemented to identify improvement
opportunities.
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6. Trends analyses are performed to identify root causes of environmental performance
concerns.
As an introductory overview, Exhibit 4-7 below presents the total number of respondents reporting
multiple key indicative behaviors.
Exhibit 4-7
Element 4: Information Collection/Management/Follow-up
Key Indicators Reported by Corporate Participants
1 Respondent (33%)
1 Respondent (33%)
1 Respondent (33%)
The following discussion compares specific survey findings against each of the six key
indicators for "Best in Class" organizations with regard to environmental information
collection/management/foUow-up.
1.
established to identify, track and
59
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Findings:
The questionnaire distributed to Corporate Participants did not include any questions
regarding information baselines.
-',; v%y/«-'
IMonaation managemeiit systems
are used to track and evaluate
Two of the three Corporate Participants surveyed report that they use information
management systems to monitor and control environmental information. These two respondents use
computerized database systems to track waste manifests and facility permits, and one has recently
changed software to include a chemical tracking system that will be used to develop TRI reports. In
addition, one of these two corporations notes that they use an especially good computer program
which includes a tickler system to let staffknow when renewals or reauthorizations for the permits
are due to environmental agencies. None of the corporations surveyed have a central inventory which
tracks and profiles regulated sites, materials, waste streams, or emissions; however, the same two
corporations indicated above have individual systems to track waste materials and emissions.
a timely manner
Findings:
All of the corporations surveyed report that they perform environmental audits and
evaluations using either internal staff (reported by two respondents) or outside consultants (reported
by one respondent). One of the corporations has had an extensive auditing program in place since
1981 which audits against regulatory requirements and the corporation's own policies, standards, and
directives (which are reported to be substantially more stringent than the environmental compliance
60
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requirements). All of the corporations perform formal audits on an annual or bi-annual basis, with
informal "self-audits" being conducted by facilities on a more frequent basis (e.g. daily, weekly,
monthly).
At all of the Corporate Participants surveyed, audit results are documented and distributed
in a timely manner to appropriate management representatives; however, audit reporting methods
vary among the corporations surveyed. One corporation provides written audit reports to the
President of Operations and the Vice President of Environmental Affairs; another corporation submits
audit reports on a confidential basis to the facility manager and the general manager of the operating
division; a third corporation submits audit results to management personnel for evaluation and then
posts results for employees.
Findings:
All of the Corporate Participants surveyed state that environmental issues and deficiencies
identified in audit reports are tracked to ensure corrective actions are taken on a timely basis.
Two of the three corporations surveyed indicate that they have set specific time limits for the
correction of all issues raised by environmental audits to ensure their successful completion. Of these
two corporations, one respondent states that audit results are tracked on a monthly basis and results
are posted for employees to review their accomplishments. In addition, management personnel at this
corporation analyze the data with staff to ensure that corrected operations are on plan with
established environmental goals.
61
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Findings:
The questionnaire distributed to Corporate Particpants did not include any questions regarding
"lessons learned" programs.
causes of environmental
f f
Findings:
Only one private corporation surveyed indicates that environmental audit report results are
analyzed to identity root causes of environmental performance concerns. This corporation is
currently developing a database to aid in analyzing trends across various reports.
Benchmark Element Summary:
This section summarizes the collective behavior of the three responding Corporate
Participants as evaluated against the key indicators for this Benchmark Element. Exhibit 4-8 below
presents the total number of respondents reporting each key indicative behavior.
62
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Exhibit 4-8
Number of Private Corporations Reporting Each
Information Collection/Management/Follow-up Key Indicator
Info. Collection/Mgmt Key Indicators
(Indicators #1 and #5 were not addressed in the questionnaire.)
#1 = Information Baselines Established
#2 = Information Management Systems Used
#3 = Monitoring Results Documented
#4 - Performance Corrected to Meet Goals
#5 = "Lessons Learned" Programs Established
#6 = Trends Analyses Performed
In general, most of the private organizations responding to the survey have strong programs
for information collection, management, and follow-up, although there are a few areas where it is
unclear whether their programs include components that address specific key indicators. Specifically,
the survey did not ask whether formal environmental baselines have been developed that measure the
material inputs and environmental releases of all current operations. Similarly, no questions were
asked in the survey regarding "lessons learned" programs. Two of the information
collection/management/follow-up key indicators for "Best in Class" organizations were reflected in
the responses of all the Corporate Participants.
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4.2.5 Element 5: Internal and External Communication
"Best in Class" organizations foster and use formal and informal channels to
communicate environmental commitment and performance information. Employee
communication is encouraged to develop cooperation and commitment, including
bringing together employees from different disciplines.
Overall Findings:
In general, all of the private organizations responding to the survey have strong internal and
external communication channels for soliciting and disseminating environmental information.
However, performance in a few areas (i.e. communicating successful strategies and cooperation with
external oversight organizations) is unclear since the survey did not request this information.
Six key indicators have been identified that would indicate "Best in Class" performance in
regard to internal and external communication.
1. Channels exist for employees to anonymously communicate environmental
performance concerns without retribution.
2. Employee suggestions are actively solicited and any concerns raised are addressed and
responses documented.
3. Successful environmental programs and strategies are communicated throughout the
organization.
4. Environmental awareness and performance information is communicated through the
use of employee newsletters, bulletin boards, electronic mail, etc.
5. Full and open cooperation with external oversight organizations exists.
6. Input regarding environmental performance and opportunity identification is actively
solicited from external parties (e.g., customers, neighbors, regulators, general public).
As an introductory overview, Exhibit 4-9 below presents the total number of respondents reporting
multiple key indicative behaviors.
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Exhibit 4-9
Element 5: Internal and External Communication
Key Indicators Reported by Corporate Participants
2 Respondents (67%)
1 Respondent (33%)
The following discussion compares specific survey findings against each of the six key
indicators for "Best in Class" organizations with regard to internal and external communication.
' 1,', ' Channels exist for
Findings:
All of the Corporate Participants surveyed have a program in place which allows employees
to raise environmental concerns anonymously. One corporation has established a hotline for
employee concerns; the other two corporations have programs providing for anonymous written
comments. One respondent provides a detailed description of their "comment program" which they
report to be very successful. Comments from employees are submitted anonymously by mail under
65
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the program. The comments are required to be answered candidly, within a fixed time by the
appropriate expert and signed by a vice president or equivalent. The Director of Environment! Health
and Safety signs all environmental replies. If actions are not underway when the employee raises the
concern, a positive response, as appropriate, is usually the case. In addition, employees are
encouraged to call the Director of Environment, Health and Safety, which they often do. An
Employee Satisfaction Measurement System annually surveys satisfaction level and concerns.
Corrective action plans are mandatory under the comment program.
Findings:
All of the Corporate Participants surveyed have a program in place which solicits and
responds to employee suggestions (see discussion immediately above).
Findings:
The questionnaire distributed to Corporate Participants did not include any questions that
specifically address this key indicator.
; awareness*' and jperfojjaanqe, intaiatiofl is
i^iiaiealed:|hmujgfi the sse of einplqyfie ^wsletteb,
66
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Findings:
All of the Corporate Participants responding to the survey report using a wide variety of
methods to communicate environmental awareness and performance information internally to their
employees. The methods used include memos, meetings, bulletin boards, management letters,
electronic mail, video tapes, and articles in internal magazines and newsletters. These methods of
communication are also used to distribute information to field offices within each of the corporations
surveyed.
Findings:
The questionnaire distributed to Corporate Participants did not include any questions that
specifically addressed this key indicator.
«KMa&t fatties- g.«
Findings:
Two of the respondents indicate that their corporations have formal community outreach
programs to share environmental information with the community, neighbors, media, and customers.
Communication methods include speeches, benchmarking, technical papers, conference presentations,
and publishing periodic reports to the public. One of these corporations has had their community
outreach program in place for over 15 years, and the other corporation's program has been established
for three years. The third respondent does not have a formal external publicity program; rather, it
places responsibility with the plant manager that lives in the community to respond to any issues that
are raised in the media or by the community.
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Benchmark Element Summary:
This section summarizes the collective behavior of the three responding Corporate
Participants as evaluated against the key indicators for this Benchmark Element. Exhibit 4-10 below
presents the total number of respondents reporting each key indicative behavior.
Exhibit 4-10
Number of Private Corporations Reporting Each
Internal/External Communication Key Indicator
K « M tS
Internal/External Comm. Kay Indicators
(Indicators #3 and #5 were not addressed in the questionnaire.)
#1 » Channels Exist for Reporting Environmental #4 = Environmental Awareness Communicated
Concerns #5 = Cooperation with External Oversight
Organizations
#2 a Employee Suggestions Solicited #6 a input Solicited from External Parties
#3 a Successful Programs/Strategies Communicated
In general, all of the private organizations responding to the survey have strong internal and
external communication channels for soliciting and disseminating environmental information.
However, performance in a few areas (i.e. communicating successful strategies and cooperation with
external oversight organizations) is unclear since the survey did not request this information. Three
of the internal/external communication key indicators for "Best in Class" organizations were reflected
in the responses of all the Corporate Participants.
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4.2.6 Element 6: Personnel
"Best in Class" organizations ensure that personnel are capable of developing and
implementing environmental initiatives. Employees are hired, trained, and deployed
in ways that ensure that staff understand their environmental responsibilities and
receive the training and support necessary to achieve environmental excellence.
Overall Findings:
In general, all of the private organizations responding to the survey have strong employee
hiring, training, and incentive programs to ensure that sufficient environmental personnel are available
to develop and implement environmental initiatives.
Four key indicators have been identified for "Best hi Class" organizations hi regard to
personnel.
1. Sufficient qualified staff are hired, deployed, and trained to ensure that all aspects of
the business operation are executed hi accordance with the organization's
environmental commitment.
2. All employees receive initial and ongoing training to ensure that they a) understand
the environmental requirements of their job, and b) have the skills necessary to
execute their job responsibilities hi an environmentally sound manner.
3. Environmental excellence, is the explicit responsibility of every employee throughout
the organization, as demonstrated by the presence of environmental criteria hi each
employee's job description/performance evaluation, or by other means.
4. Exemplary environmental efforts are recognized and/or rewarded.
As an introductory overview, Exhibit 4-11 below presents the total number of respondents reporting
multiple key indicative behaviors.
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Exhibit 4-11
Element 6: Personnel Key Indicators
Reported by Corporate Participants
All 3 Respondents (100%)
The following discussion compares specific survey findings against each of the four key
indicators for "Best in Class" organizations with regard to personnel.
^ flgnefeilioBVcRyta^ I, '-. '
f '** * > tff f f ft * * * "/ i', * * * $,
",,',.'« ' ' - ' ' - - <', ' - ' '
Findings:
The current number of environmental staff reported to be employed by the corporations
surveyed varied from 38 to 150 persons. Whether this level of staffing is sufficient is not indicated
by the survey responses. All of the corporations surveyed employ some type of forecasting method
to determine future environmental staffing needs, taking into consideration business volume
70
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projections, new regulations, and environmental trends. All of the corporations specify qualifications
required for entry-level and senior-level environmental positions (typically undergraduate or graduate
degrees in science or engineering and appropriate management experience).
**,'->-*-.r, :/>- r v MW <,::', **%?w>
f .v «* f . . * e f ff , f ' f"~ f
Findings:
All of the Corporate Participants state that they provide environmental training to their
employees. Two corporations provide initial environmental training as part of employee orientation,
and all of the corporations provide ongoing environmental training on a mandatory basis. The
amount of training required for employees varies among the respondents. One corporation states that
a requirement of 8 hours training is specified in each employee's performance appraisal. Others
indicate that training is primarily based on the personal needs of the employees in conjunction with
discussions with their management. All of the respondents indicate that emergency response
procedures are communicated to employees through routine training sessions which are held at least
annually.
Findings:
All of the survey respondents indicate that staff who have some environmental duties, even
though not their primary duties, have environmental responsibilities documented (usually hi then* job
descriptions). One respondent indicates that plant managers and budget center managers have
71
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environmental performance measurements in their annual performance reviews; however, engineers
are appraised on environmental measurements only on a case by case basis.
In addition, all of the Corporate Participants responding to the survey indicate that all
employees who are responsible for environmental management are held accountable for their
performance and the performance of those they manage. The survey respondents differ in their
methods for documenting accountability for environmental criteria. One corporation indicates that
employees are held accountable for their performance through annual objectives to which pay and
advancement are directly correlated. Others indicate that environmental responsibilities are delineated
within business plans, job descriptions, or within the mission, vision, or objectives of a given
organization within the corporation.
Findings:
All of the corporations surveyed recognize and/or reward their employees for exemplary
environmental efforts. Each corporation has some type of formal program that consists of a variety
of awards and incentives. One corporation presents a Presidents award, an Earth award, and awards
for individual and team excellence, as well as gifts of merchandise and "dinner for two". Another
corporation presents the Pollution Prevention Pays Award to individual employees and team members
for developing and implementing pollution prevention projects, and bestows a Chairman's
Environmental Award to employees whose top projects or activities best exemplify the corporation's
commitment to the environment. The major form of recognition reported is public and peer
recognition, rather than monetary rewards.
Benchmark Element Summary:
This section summarizes the collective behavior of the three responding Corporate
Participants as evaluated against the key indicators for this Benchmark Element. Exhibit 4-12 below
presents the total number of respondents reporting each key indicative behavior.
-------
Exhibit 4-12
Number of Private Corporations Reporting Each
Personnel Key Indicator
*1
Hi
Personnel Key Indicators
#1 = Sufficient Qualified Staff Hired, Deployed, and Trained
#2 = Initial and Ongoing Training for all Employees
#3 = Environmental Excellence is the Responsibility of Every Employee
#4 = Exemplary Efforts Recognized/Rewarded
In general, all of the private organizations responding to the survey have strong employee
hiring, training, and incentive programs to ensure that sufficient environmental personnel are available
to develop and implement environmental initiatives. All of the personnel key indicators for "Best in
Class" performance were reflected in the responses of all the Corporate Participants.
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CHAPTER 5: CIVILIAN FEDERAL AGENCIES
5.1 Data Sources
This chapter summarizes the responses received from 17 Civilian Federal Agencies (CFAs)
to a 34-question survey. In general, the questionnaire included questions intended to solicit
responses regarding agency environmental compliance issues, as described by the following six
subcategories: environmental compliance policy and guidance manuals; training availability and
effectiveness; data management and access; internal agency compliance monitoring and auditing
procedures; management support and agency outreach; and budgetary procedures and concerns.
As a result, the questionnaire did not address many of the key indicators within the six Benchmark
Elements. A copy of the questionnaire is included in Appendix A, Exhibit A-l, of this document.
Responses to the questionnaire were received from the following 17 CFAs:
Treasury Department
Postal Service
Federal Aviation Administration
Department of Commerce, Office of Federal Assistance and Management Support
Department of Commerce, Economic Development Administration
National Oceanic and Atmospheric Administration
United States Department of Agriculture (USDA), Agricultural Research Service
USD A Federal Grain Inspection Service
USDA Animal and Plant Health Inspection Service
USDA Soil Conservation Service
USDA (branch not specified)
Department of Justice
EPA, Office of Administration and Resources Management
National Security Agency, Environmental Management Services Division
Three unidentified agencies
5.2 Performance Measured Against Benchmark Elements
5.2.1 Element 1: Organizational Structure
"Best in Class" organizations have established an organizational structure that
gives authority, input, and voice to environmental performance.
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Overall Findings:
Four key indicators nave been identified as "Best in Class" performance regarding
organizational structure.
1. Organizational mission statement exists that sets forth environmental business
focus, going beyond environmental compliance.
2. Clear lines of authority, responsibility, and accountability are established for
environmental functions.
3. Formal systems for statutory and regulatory tracking/monitoring exist and access
to legal resources is readily available.
4. Environmental management functions are represented at the high(est) levels of the
organization.
A total of three questions included in the questionnaire solicited information that could be
evaluated against two of these four key indicators (i.e., numbers 3 and 4). The three relevant
questions asked respondents to provide information pertaining to the following items: the use of
formal agency monitoring systems to track statutory and compliance issues; the occurrence of
senior executive meetings regarding environmental issues; and the existence of high level positions
that ensure statutorily compliant behavior. Exhibit 5-1 presents the total number of respondents
reporting multiple key indicative behaviors.
Exhibit 5-1
Element 1: Organizational Structure Key Indicators
Reported by 17 Civilian Federal Agencies
7 Respondents (41%)
7 Respondents
(41%)
3 Respondents
(18%)
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The following discussion compares specific survey findings to each of the two key
indicators addressed by the survey.
yiti3^p4&^'ttrfrt$4^ *&fl^& ebi&a
g&ing^yond tatiroiuJient^l complianee.; -
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Findings:
The CFA questionnaire did not include any questions that specifically addressed this key
indicator.
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Findings:
The CFA questionnaire did not include a question that specifically addressed this key
indicator.
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Findings:
One question from the questionnaire addressed this key indicator (i.e., "Does your agency
have a formal system for monitroing proposed regulatory changes and for developing guidance
on compliance with changing regulations?11) Twelve of 17 agencies report the existence of either
formal or informal systems that are used to monitor statutory and regulatory issues. Four
responses can be interpreted to mean formal agency monitoring systems are used. The most
frequently reported formal monitoring systems consist of the use of published documents and
attendance at interagency discussions. Eight respondents report the use of informal monitoring
systems of varying degrees of complexity. Although these latter responses do not demonstrate key
indicative behavior, they are discussed hi this section for informational value.
Of the four agencies that report the existence of a formal agency regulatory monitoring
system or program, two state attendance at EPA Roundtable meetings as the means to this end.
One response states that "government relations on Capitol Hill, Environmental Council, review
of Federal Register, and EPA activities updates" are the formal means of monitoring statutory
issues.
The systems hi place for respondents that report informal monitoring systems vary
significantly from one respondent to another. Several agencies report informal systems involving
the review of the Federal Register or the BNA Environmental Reporter, or both, on a regular
(sometimes daily) basis and the issuance of subsequent guidance from headquarters to affected
individuals at operating units or in the field. Several respondents also report that they attend EPA
Roundtable meetings. One agency reports that employees maintain a database of endangered
species that is consulted when appropriate hi the evaluation of a given program or proposed
program.
Four of the five negative responses are one word responses of "no." The fifth negative
is qualified, indicating that individual operating units are aware of the regulations that affect their
operations.
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Findings:
Two questions solicited responses regarding this key indicative behavior.
"Do senior executives, deputy administrators, deputy secretaries, etc. meet to
discuss environmental issues on a periodic basis?"
"Which specific high level persons, not reporting to departmental or facility
managers have authority to ensure compliance with Federal and state environmental
laws, and agency environmental policies and directives?"
In reply to the first question, nine of the 17 respondents report that senior personnel meet to
discuss environmental issues on a "periodic basis." Where provided, committee names are
mentioned below. One agency has an Environmental Quality Council that addresses
environmental issues hi a timely manner and resolves conflicts among agency offices that may
affect agency compliance. Another agency report that the Director meets with biotechnology and
environmental protection deputies regarding environmental issues at least once each week. This
agency also has a staff position entitled Deputy for Environmental Analysis and Documentation,
exemplifying a specific high level job title relating to environmental performance. One response
states that meetings are held largely on a case-specific basis. Another indicate that high level
meetings were held in fiscal year 1992, but that the Senior Executive Environmental Steering
Committee has been disbanded since then as the result of reorganization. Five agencies responded
with an unqualified "yes." Negative responses range form one-word "no" answers to "do not
know" to "very infrequently."
Additionally, the questionnaire inquired as to specific job titles for which personnel are
directly responsible for regulatory compliance as well as adherence to agency environmental
policies. For those ten agencies that respond positively to this question, or responses provide titles
of individuals. For example, one agency reports that Area Directors, Center Directors, Research
Leaders, and Location Coordinators all have the authority to ensure compliance with
environmental requirements. Other responses state that Division Directors, all Agency managers,
Deputy Chief for Administration, the Attorney General, and "designated agency personnel" are
responsible for compliance. While this question does not specificaly address indicative behavior,
the job titles provided as responses suggest the existence of high-level individuals that are
responsible for regulatory compliance as well as adherence to agency environmental policy.
Attributing such responsibilities to a high-level employee is indicative of an environmental
management function existing at a high level in an organization.
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Benchmark Element Summary:
This section summarizes the collective behavior of the 17 respondent agencies as evaluated
against the key indicators for the Organizational Structure Benchmark Element. Exhibit 5-2 below
presents the total number of respondents reporting each key indicative behavior.
Exhibit 5-2
Number of Civilian Federal Agencies Reporting Each
Organizational Structure Key Indicator
92 «3
Organizational Structure Key Indicators
4
(Indicators #1 and 02 were not addressed in the questionnaire.)
#1 = Mission Statement Exists
#2 = Clear Lines of Authority
#3 = Statutory/Regulatory Tracking
#4 = High-level Representation
As stated, the CFA survey did not solicit information regarding the first two key indicators
of this Benchmark Element. Regarding the third key indicator, the use of formal statutory
monitoring systems, the aspect of formality is lacking in most agency programs reported.
Although an awareness of monitoring is reported, informal systems, especially when instituted
only at the facility or operating unit level, have not been interpreted to demonstrate the key
indicative behavior at issue. Regarding the fourth key indicator, the majority of the respondents
report mat senior executives meet to discuss environmental issues on a periodic basis. However,
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the fact that senior level executives meet to discuss environmental issues represents only one
function of environmental management at a high organizational level. Positive responses to this
question do not necessarily indicate that multiple "environmental management functions are
represented at the highest levels of the organization."
5.2.2 Element 2: Management Commitment
"Best in Class" organizations possess and demonstrate a commitment to
environmental excellence at each and every stage of the management hierarchy,
and insist that the organization integrate environmental awareness and concerns
into all relevant business operations.
Overall Findings:
Eight key indicators have been identified for "Best hi Class" performance in regard to
management commitment.
1. Organizations make resources available to identify, develop, initiate, and transfer
environmental improvement technologies and strategies between facilities.
2. Environmental concerns are integrated into organizational business planning.
3. Environmental considerations play a role hi all key organizational decisions.
4. Management demonstrates a commitment to environmental protection that goes
beyond environmental compliance.
5. A formal environmental risk management program has been instituted and is used
to assess potential risks from all proposed and existing operations.
6. Capital budgeting evaluation criteria area used to allow environmental protjects to
compete fairly for investment resources.
7. Headquarters level policies exist that establish an environmental sense of direction
for facility level operations.
8. Environmental criteria are used for the selection and management of
contractors/vendors.
Five of the eight key indicators are addressed to some extent hi the CFAs questionnaire (i.e.,
numbers 2, 3, 4, 6, and 8). Six questions hi the CFA questionnaire solicited information that
could be evaluated against this Benchmark Element and its key indicators. The six relevant
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questions asked respondents to provide information pertaining to the following items: analysis of
potential environmental impacts on agency mission; communication with environmental program
offices regarding modified mission activities or planned demolition/construction activities; top
management support for environmental compliance programs; participation in the Office of
Management and Budget (OMB) A-106 process; briefing of contractors/vendors on environmental
policies prior to contract performance; and the existence of standard contract clauses.
As an introductory overview, Exhibit 5-3 presents the total number of respondents
reporting multiple indicative behaviors. Exhibit 5-3 illustrates that most agencies exhibit more
than one key indicative behavior. Three of 17 agencies reported exhibiting four or more
indicators, exemplifying "Best in Class" behavior.
Exhibit 5-3
Element 2: Management Commitment Key Indicators
Reported by 17 Civilian Federal Agencies
7 Respondents (41%)
4 Respondents (24%)
2 Respondents (12%)
1 Respondent
(6%)
1 Respondent
(6%)
2 Respondents
(12%)
The following discussion compares specific survey findings against each of the eight key
indicators for "Best in Class" performance with regard to management commitment.
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1. Organizations make resources available to
, develop, initiate,
Findings:
The CFA questionnaire did not include any questions that specifically addressed this key
indicator.
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Findings:
Most of the respondents report ntegrating environmental concerns, primarily regulatory
compliance, into organizational business planning. This indicator was evaluated based on the
responses to a question asking whether the agency had analyzed the potential impact of
environmental issues on the future mission of the agency. Twelve of 17 agencies report some kind
of analysis on the impacts to their future mission. Five agencies either respond negatively or
failed to respond. If an agency reported any land of analysis on the impacts to their future
mission it was interpreted as constituting key indicative behavior.
This question elicited a wide range of responses. Only three responding agencies report
that they had looked at the impacts to their agency's future mission. Most agencies state that their
analysis was ongoing or only minimally or partially conducted. While some agencies simply state
that only a partial analysis had been done, others describe what analyses they had conducted. For
example, one agency has analyzed compliance with the Clean Air Act and another agency has
considered the impact of changes in environmental regulations and pesticide laws on program
operations. In addition, one respondent states that this kind of analysis was conducted because
permitting requires it; another agency reports that this type of analysis was conducted at the
bureau level only. Four agencies reports they had not analyzed the impact on their agency s
future mission, and one agency failed to respond to the question.
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mmideratioas play a role -In s|i key orptbizaioiial*
' * ,'**, ,,,,, »r *" ,.
Finings:
This key indicator for management commitment was addressed in the CFA questionnaire
with a question asking about communicating regarding mission activities or construction planning
(i.e., "Do the process operation and construction engineering departments or offices communicate
with the environmental program offices when new or modified mission activities or demolition
or construction is planned?"). Six agencies responded that this type of communication does occur.
The remaining eleven agencies state either that this kind of communication only occurrs "in part
of their organization", "some of the time", "not at all", or that the question is not applicable. The
limited focus of this question makes it difficult to evaluate whether environmental considerations
play a role in all key organizational decisions. The six agencies that answered "yes" were
considered as exhibiting key indicative behavior.
Six of 17 agencies report a simple "yes" response to this question. Three other agencies
does not respond positively to this question, but provide qualified responses instead. One of these
respondents states that only the process engineering department communicates with the
environmental program office, and added that environmental functions at the agency are
fragmented. Another states that such communication takes place both at the headquarters and field
levels with varying relationships, and a third respondent states that communications between
contracting and engineering offices may occur through administrative channels or directly with
the environmental unit. Some responses are hard to interpret in the context of "Best hi Class"
behavior. For example, three agencies report that this land of communication occurs only some
of the tune and one of these agencies adds that a coordinating council was established between
office and environmental staff. Two agencies report "no" to this question. Two respondents state
that the question is not applicable, and one qualifies their answer by stating that the GSA provides
these services.
4.' /'
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Findings:
CFAs were surveyed regarding how top management supports the environmental
compliance programs (i.e., "How is top management support for the environmental compliance
program demonstrated?"). Extrapolation from this question to whether management at these
agencies demonstrate a commitment beyond environmental compliance is difficult. Five of 17
agencies respond that management support goes beyond verbal support and includes providing
resources, training, and program development. These five agencies were considered to be
exhibiting the desired indicative behavior.
A wide variety of responses were given to this question and it is difficult to evaluate
whether these agencies were following "Best in Class" behavior based on the responses. Five
agencies provide answers indicating that some type of management commitment has been made.
For example, some report that management has added staff dedicated to regional environmental
compliance, or approved staffing increases and training (including workshops and conferences).
One respondent states that in addition to written directives, guidance, and concern for how the
agency's accomplishments and services are perceived, "management support is seen through
"hands-on" interest in environmental issues." Two of these five respondents indicate that
management demonstrates its support through program development, either support of the safety
and occupational health program or through the development of one agency's Environmental
Management Services Division.
Other responses are not considered representative of "Best in Class" behavior. For
instance, two agencies respond that verbal support only was provided, and other responses indicate
minimal support, lack of budgetary resources, and inadequate management commitment. One
agency failed to respond to the question, and two agencies state that support was not
demonstrated.
; " A formal eir^^
v' ' and Is used to assess potential risks from at! proposed and existing
4, » * * * Jj^
Findings:
The CFA questionnaire did not include any questions that specifically addressed this key
indicator.
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-------
statements or directives. Other agencies respond that directives are communicated via hard copy,
electronic bulletin board, or memos. Some agencies report using a variety of communication
methods including guidance documents, technical guidelines, manuals, management instructions
or handbooks, administrative guides, safety, health and environmental program circulars, and
training.
Findings:
Two questions addressed whether environmental criteria are used for the selection and
management of contractors/vendors.
"Are contractors and vendors briefed on environmental policies prior to the
performance of a contract?"
"Do contracts contain an environmental and occupational health and safety clause
as part of the standard terms and conditions?"
The primary focus of these two questions is management of contractors and not selection. Six of
17 respondents state that they brief contractors and vendors on environmental policy prior to
performance on a contract. Eleven agencies state that their contracts contain an environmental and
health and safety clause as part of their standard contracts. Four of these eleven agencies respond
positively to both questions and, therefore, are only counted once in totaling the number of CFAs
displaying indicative behavior for this key indicator.
In answer to the first question, six of 17 respondents state that they brief contractors and
vendors on environmental policy prior to performance on a contract. Five of these agencies
respond that they do so in a limited fashion "when necessary", "not routinely", or "hi special
circumstances only". Two agencies state that environmental responsibilities are included in job
specifications or contract requirements. Two respondents state that the question is not applicable
and one provides no response.
Responses to the second question reveal that agencies include environmental and health and
safety clauses in their standard contracts. Eleven of 17 agencies give affirmative responses;
however, one of these agencies qualifies their response by saying the clause is "weak". One of
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the eleven agencies state that "all government contracts" contain such clauses and another
references the language in the contracts as "coming from the FARs".
Other types of responses are not considered as exemplifying key indicative behavior. For
instance, one respondent states that their contracts contain only cursory clauses, such as protection
of streams from sedimentation, while another state that inclusion of these clauses is done where
applicable. Four agencies respond that such clauses are not included in the contracts.
Benchmark Element Summary:
This section summarizes the collective behavior of the 17 respondent agencies as evaluated
against the key indicators for this Benchmark Element. Exhibit 5-4 presents the total number of
respondents reporting each key indicative behavior.
Exhibit 5-4
Number of Civilian Federal Agencies Reporting Each
Management Commitment Key Indicator
#2 #3 #4 #5 #6 #7
Management Commitment Key Indicators
(Indicators #1, #5, and #7 were not addressed in the questionnaire.)
#1 = Resources Made Available #5 = Formal Risk Management Program
#2 = Business Planning Integration #6 = Budgeting Criteria Used
#3 = Role In All Organizational Decisions #7 = Headquarters Level Policies
#4 = Management Committment Beyond Compliance #8 - Selection/Management of
Contractors/Vendors
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Few of the questions posed to CFAs regarding management commitment allow for
responses that can be analyzed for "Best in Class" behavior regarding this element. Two of the
indicators, however, appear to be more popular with CFAs than other indicators. The second
indicator listed in this element, relating to environmental concerns being integrated into
organizational business planning, has a large number of respondents. Most of the agencies report
analyzing to some degree the potential impacts that environmental issues have on their future
mission. The eighth indicator has a large number of respondents, hi part because there were two
questions asked and therefore two possibilities of responding positively. Some agencies are
already briefing contractors on environmental policy and many are including health and safety
clauses hi their contracts. Six respondents also report exhibiting indicator behavior for indicators
three and six. These agencies report that environmental considerations play a role hi key
organizational decisions and that capital budgeting evaluation criteria are used for funding
environmental projects.
5.2.3 Element 3: Implementation
"Best in Class" organizations carry out their day to day business operations in
ways that integrate environmental protection into their business conduct.
Overall Findings:
Three key indicators have been identified for "Best hi Class" performance as it relates to
implementation of environmental goals and programs.
1. Short- and medium-range environmental performance goals are established for
individual business operations and for the organization as a whole.
2. A wide range of potential environmental impacts are addressed through
comprehensive multi-media environmental programs. These programs include:
pollution prevention - compliance
recycling - affirmative procurement
reuse - energy conservation
control
emergency preparedness and response
investigation and remediation of past practices.
3. Formal guidance is developed and disseminated to help ensure organizational
environmental excellence.
A total of three questions included in the CFA questionnaire solicit information that could be
evaluated against two of these three key indicators (i.e., numbers 2 and 3). The relevant questions
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ask respondents to provide information regarding the following items: development and
communication of emergency response procedures through formal guidance documents;
headquarters guidance concerning the identification, characterization and control of suspect waste
streams; and identification of environmental impacts resulting from past agency operations.
Exhibit 5-5 presents the total number of respondents reporting multiple key indicative behaviors.
Exhibit 5-5
Element 3: Implementation Key Indicators Reported by
Civilian Federal Agencies
10 Respondents (59%)
2 Respondents
(12%)
5 Respondents
(29%)
The following discussion compares specific survey findings to each of the two key
indicators addressed by the survey. In general, a majority of CFAs report having some
implementation programs hi place, including programs for soil remediation and underground
storage tank removal. However, only two agencies report providing formal written guidance to
their employees.
.'*,? ' ' IJ* ,''"'/'
ffff. f f f-, t 0. f
-------
Findings:
The CFA questionnaire did not include any questions that specifically addressed this key
indicator.
^ -,,
impacts are addressed
Findings:
One question in the CFA survey solicited responses that can be used to evaluate agency
behaviors against this key indicator (i.e., "Have you identified and quantified environmental
liabilities from past oeprations, mission activities, discontinued offices, bureaus or departments?
Has the agency developed a plan for minimizing those liabilities?"). In response to this question,
ten agencies report having at least begun the process of identifying environmental liabilities
incurred as a result of past operations. In general, plans to continue investigation and to remediate
sites are underway for these ten agencies. Positive and negative responses are discussed hi further
detail below.
Of the ten agencies that respond positively to this question, one indicates that all sites have
been cleaned up. The other nine respondents report that identification and remediation activities
are underway at varying stages. One agency states that RCRA Section 3016 inventories have been
completed at several facilities. In addition, Preliminary Assessments, site inspections, the
identification of underground storage tanks (USTs) and removal actions have also been completed.
Several responses simply state that investigations have started or are ongoing. One agency reports
that decontamination of pesticides and disposal activities are conducted on an ad-hoc basis.
Negative responses range from an unqualified "no" to qualified responses such as "no, however
with pending closures [these activities] may be important in [the] future" and "no, a partial
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strategy [has been] developed, but seems inadequate for nationwide environmental needs." Two
agencies state that the question is not applicable to them.
Findings:
Two questions in the CFA survey solicited responses that can be evaluated against this key
indicator.
Have emergency response procedures been developed and communicated to all
affected employees through formal guidance documents?
What guidance does the agency offer to its regional units for the characterization
and control of all suspect waste streams and emissions in order to obtain
compliance?
In response to the first question, ten agencies report that formal emergency response procedures
are developed and disseminated to agency personnel.
The second question asks respondents to describe any guidance offered by the agency to
its regional units regarding the characterization and control of suspect waste streams. Only two
of the ten positive responses indicate that a formal guidance program is in place. Other positive
responses indicate that only informal guidance is provided to regional units by the agency.
In response to the first question, one agency reports that a formal Comprehensive
Emergency Response program is well publicized within the agency. A second agency reports that
emergency response procedures are included in its formal agency hazardous waste management
and underground storage tank (UST) programs. Two other agencies indicate that Safety and
Health divisions issue directives and develop formal channels of communication throughout the
agency. In addition, two agencies state that emergency response procedures have been developed;
however, they are informal and are developed at facility level as appropriate to specific functions.
The five negative responses consist of four unqualified, "no" answers and one answer of "in some
cases."
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The second question elicited only two responses that indicate formal agency guidance is
provided regarding the characterization and control of suspect waste streams. One agency reports
that formal recycling, waste reduction, hazardous waste, storm water, clean air, asbestos, and
UST programs are in place. The second agency states that guidance documents regarding
hazardous waste determination and the selection of a treatment, storage, disposal facility were
circulated in 1989 and 1990. Eight respondents indicate that informal guidance programs are in
place, including environmental audit programs, Health and Safety division training, technical
assistance through on-site Agency inspections, and broad policy documents emphasizing
compliance.
Benchmark Element Summary:
This section summarizes the collective behavior of the 17 respondent agencies as evaluated
against the key indicators for this Benchmark Element. Exhibit 5-6 presents the total number of
respondents reporting each key indicative behavior.
Exhibit 5-6
Number of Civilian Federal Agencies Reporting
Each Implementation Key Indicator
#1 *2
Implementation Key Indicators
(Indicator #1 was not addressed in the questionnaire.)
#1 = Environmental Performance Goals Estabished
#2 = Comprehensive Multi-media Environmental Programs Exist
#3 = Formal Guidance Developed and Disseminated
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As stated above, the CFA survey did not solicit information pertaining to the first key
indicator of this Benchmark Element. As a group, a majority of these CFAs have addressed the
identification of environmental impacts of past operations. Many of the agencies report addressing
remediation of contaminated sites. Regarding the third key indicator, it appears that the
respondents lack the formality required for "Best in Class" behavior. Although guidance is
provided at agency level according to ten of the respondents, management commitment
demonstrated by formal, written guidance is only evident hi two agencies.
5.2.4 Element 4: Information Collection/Management/Follow-up
"Best in Class" organizations continually monitor environmental performance
through the use of formal tracking and reporting mechanisms. Information
acquired through these mechanisms is evaluated, disseminated, and used to
continually improve environmental performance.
Overall Findings:
Six key indicators have been identified for "Best in Class" performance in regard to
environmental information collection/management/follow-up.
1. Information baselines have been established to identify, track and measure inputs
(i.e., energy, water, materials) and wastes and emissions outputs.
2. Information management systems are used to track and evaluate environmental
performance. These systems measure and verify data, evaluate the collected data,
and identify improvement opportunities.
3. Business operations are modified hi response to data findings to correct
perforamnce and meet environmental goals. Corrective actions are tracked and
verified to ensure successful completion.
4. Environmental performance results are documented and distributed hi a timely
manner to appropriate management representatives.
5. "Lessons learned" programs have been implemented to identify improvement
opportunties.
6. Trends analyses are performed to identify root causes of environmental
performance concerns.
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Only two of six indicators were addressed in the questionnaires sent to the CFAs (i e #2 and #4)
Four questions in the CFA questionnaire solicited information that could be evaluated against this
Benchmark Element and its key indicators. The four relevant questions asked respondents to
provide information pertaining to the following areas: agency-wide environmental databases for
tracking compliance; environmental auditing, assessment, and monitoring; central inventories for
tracking agency-regulated sites, materials, waste streams or emissions; and regional reporting of
regulatory data to agency executives at headquarters. As an introductory overview, Exhibit 5-7
presents the total number of indicators each respondent reported following.
Exhibit 5-7
Element 4: Information Collection/Management/Follow-up
Key Indicators Reported by Civilian Federal Agencies
9 Respondents (53%)
4 Respondents (24%)
4 Respondents (24%)
The following discussion compares specific survey findings against each of the two key
indicators for "Best hi Class" performance with regard to environmental information
collection/management/follow-up. In general, most reporting agencies show at least one
indicative behavior and four agencies indicate behavior hi accordance with both the indicators
surveyed.
1. Information
,- measure inputs
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Findings:
The CFA questionnaire did not include any questions that specifically addressed this key
indicator.
Findings:
Three questions addressed whether information management systems are used to track and
evaluate environmental performance.
"Is there an agency-wide environmental database established to ensure that proper
records (e.g., waste manifests, biennial reports, permits, etc.) are maintained and
updated?"
"Is there a central inventory, either computer-based or written, that tracks and
profiles all regulated agency sites, materials, waste streams or emissions?"
"Is there an environmental auditing, assessment or other system in place to oversee
and monitor the agency's compliance activities?"
Many of the agencies report having information management systems to track different types of
environmental activities. It should be noted, however, that the questionnaire did not ask whether
these systems are used to evaluate environmental performance or improvement opportunities.
None of the agencies respond mat they had a working agency-wide environmental database
to track compliance records; however, a variety of responses are given relating to the type of
databases or systems in place. Five agencies provide responses regarding the types of tracking
systems being used and are considered as having reported positively for this indicative behavior.
Thirteen of 17 CFAs state that some type of environmental auditing, assessment or other system
was in place or being developed to oversee and monitor the agency's compliance activities,
interpreted as indicative behavior. Only six CFAs respond that they have a central inventory and
are thus classified as exhibiting indicative behavior. Agencies reporting at least one type of
95
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information management tracking system are considered to be following this key indicative
behavior. 3 U*<-UYB
Only one respondent indicates having an agency-wide environmental database to track
compliance related records; however, the respondent commented that the database was inadequate
Five of the respondents report having some type of information management tracking system in
place. Most of these systems are separate, individual databases (for example, databases for USTs
pesticides, or solid and hazardous waste). One respondent states that they have a manual system.'
Three of the respondents indicate they are in the process of developing agency-wide tracking
systems. The remaining reporting agencies indicate they have no system or the question is not
applicable.
Thirteen of 17 CFAs state that they currently have or are developing an environmental
auditing or assessment system to monitor the agency's compliance activities. Five of the 17
respond affirmatively to the question and provided no qualifying information. One agency
comments that they are developing an auditing program for solid and hazardous waste. Another
respondent states that they plan to start annual inspections to target the overall quality of their
safety, health and environmental management programs. A third agency states that this type of
activity is developed at the bureau level. Three agencies report that they do not have
environmental auditing systems hi place and do not mention whether they are hi the process of
developing one.
The majority of respondents do not have a central inventory for tracking agency-regulated
sites, materials, waste streams or emissions. Only six CFAs responded that they have a central
inventory. One of these respondents states that their central inventory tracks agency sites and
materials and that this information is used to justify resource expenditures. Another agency
comments that their inventory database is used for tracking projects. Two other agencies indicate
that their inventory systems are used for monitoring field activities and waste streams.
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Findings:
The CFA questionnaire did not include any questions that specifically addressed this key
indicator.
Findings:
One survey question addressed this key indicator (i.e., "How does the system ensure the
reporting of regulatory data by regional comopliance staff to agency executives at
Headquarters?"). Eleven of 17 reporting agencies respond negatively, commenting that they
"didn't have such a system", that they "didn't know the answer to the question", that the question
"wasn't applicable" or providing no response at all. Those agencies that report some distribution
of environmental performance information are considered as exemplifying indicative behavior.
Only four agencies report how information is communicated from the field or regional
offices. One of these agencies states that reports are communicated from lab directors to
headquarters staff and another agency respond that field reports are handled by a single office at
headquarters but not in an automated fashion. One respondent states that notices of violation and
facility compliance agreements were generally executed in the field and sent to headquarters.
Another agency states that information on environmental incidents flows through administrative
channels to headquarters.
Seven of 17 respondents either provide no response or state that the question is not
applicable. One of these agencies explains that the question is not applicable since they do not
have regional offices and such matters are handled at the national headquarters office. Three
agencies respond that they do not have any systems in place, and one respondent replies that
he/she does not know the answer to the question.
97
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to identify
Findings:
The CFA questionnaire did not include any questions that specifically addressed this key
indicator.
Findings:
The CFA questionnaire did not include any questions that specifically addressed this key
indicator.
Benchmark Element Summary:
This section summarizes the collective behavior of the 17 respondent agencies as evaluated
against the key indicators for this Benchmark Element. Exhibit 5-8 presents the total number of
respondents reporting each key indicative behavior.
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Exhibit 5-8
Number of Civilian Federal Agencies Reporting Each
Information Collection/Management/Follow-up Key Indicator
#1 #2 #3 #4 #5 #6
Information Collection/Management/Follow-up Key Indicators
(Indicators #1, #3, #5, and #6 were not addressed in the questionnaire.)
#1 = Information Baselines Established #4
#2 = Information Management Systems Used #5
#3 = Monitorin g Results Documented #6
Performance Corrected to Meet Goals
Performance Corrected to Meet Goals
Trends Analysis Performed
The key indicator addressing information management tracking systems was highly
supported, in part because there were three questions asked on the subject and therefore three
possibilities of responding positively. The most popular information management system reported
related to environmental auditing and assessment. It is interesting to note that even though
auditing systems are in place, there are no mechanisms reported to be in place to ensure reporting
of regulatory data.
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5.2.5 Element 5: Internal and External Communication
"Best in Class" organizations foster and use formal and informal channels to
communicate environmental commitment and performance information. Employee
communication is encouraged to develop cooperation and commitment, including
bringing together employees from different disciplines.
Overall Findings:
Six key indicators have been identified for "Best in Class" performance in regard to
internal and external communication.
1. Channels exist for employees to anonymously communicate environmental
performance concerns without retribution.
2. Employee suggestions are actively solicited and any concerns raised are addressed
and responses documented.
3. Successful environmental programs and strategies are communicated throughout
the organization.
4. Environmental awareness and perormance information is communicated through
the use of employee newsletters, bulletin boards, electronic mail, etc.
5. Full and open cooperation with external oversight organizations exists.
6. Input regarding environmental performance and opportunity identification is
actively solicited from external parties (e.g., customers, neighbors, regulators,
general public).
Only two of the six indicators were addressed in some fashion by the questionnaire (i.e., numbers
1 and 6). Three questions in the CFA questionnaire solicited information that could be evaluated
against this Benchmark Element and its key indicators. The three relevant questions asked
respondents to provide information pertaining to the following areas: systems that encourage
employees to report environmental concerns; environmental program benchmarking activities; and
third party assessments of environmental programs. As an introductory overview, Exhibit 5-9
illustrates the total number of indicators each respondent reported they follow.
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Exhibit 5-9
Element 5: Internal and External Communication
Key Indicators Reported by 17 Civilian Federal Agencies
8 Respondents (47%)
5 Respondents (29%)
4 Respondents
(24%)
The following discussion compares specific survey findings against each of the six key
indicators for "Best in Class" performance with regard to internal and external communication.
In general, most reporting agencies show at least one indicative behavior and four agencies
indicate that they follow both the indicators surveyed.
?1v "', Cfeaimels exist far employees to anoilpnousiy communicate
's 'f
Findings:
A wide range of responses are reported regarding whether channels exist for employees
to anonymously communicate environmental performance concerns without retribution. One
question specifically asked whether a well-publicized systems existed at the agency to encourage
employees to report problems (i.e., "Are agency employees and contractors provided with a well-
publicized system that encourages the reporting of environmental problems, violations, or criminal
101
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conduct within the agency without fear of retaliation?"). Only three respondents state that they
have such a system in place. Four other respondents state that no formal system is in place but
that channels do exist. Either of these two responses are interpreted as key indicative behavior.
As stated above, only three agencies report the existence of well-publicized systems to
encourage employees to report problems. Seven respondents answer this question negatively. Of
the four agencies that do not report having a formal system, two state that employees were
encouraged to report problems. One of these respondents stated, however, that resolution of
problems is problematic. One agency comments that the system is not well publicized, while
another states that employees "know where to call anonymously". Two of 17 agencies did not
respond to the question at all.
Findings:
The CFA questionnaire did not include any questions that specifically addressed this key
indicator.
Findings:
The CFA questionnaire did not include any questions that specifically addressed this key
indicator.
102
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' ' ,"' :" ,V~ '/''!','< '--''"',' ' --
&y li$fcmt&& ''"- ' &.£,"*> - ""< '*' *
Finding,?:
The CFA questionnaire did not include any questions that specifically addressed this key
indicator.
c,',' 't '''''-, "'^-."'i y|T/'
-*"Z'M ''-''"', «v- '">"»'*>/
V *V^ f fy f ff V "V'' f fy f V f ff 'fff fff f f
'/_»"';"_"' *»< ',;-'* -
Findings:
The CFA questionnaire did not include any questions that specifically addressed this key
indicator.
103
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Findings:
There is a wide range of responses regarding the solicitation of input from external parties.
Two questions were asked regarding this key indicator.
"Has the agency formally compared its environmental programs (including
regulatory compliance, risk reduction and best management practices) with other
Federal agency programs? Has the agency compared its programs with those in
the private sector (Fortune 500 companies)?"
"Has an objective, third-parry assessment of the effectiveness of your agency's
environmental program been conducted?"
Nine of 17 CFAs report that then: agencies have not formally compared their environmental
programs to other Federal agency programs or the private sector. Eight of the respondents
indicate that an objective, third party assessment of the effectiveness of their environmental
program has not been conducted and a ninth failed to respond. It is interesting to note that even
though more respondents answer negatively to each of these questions, overall ten of 17
respondents indicate a positive response to at least one of these questions. Therefore, a majority
of respondents were given credit for exhibiting this indicative behavior.
Nine of the 17 reporting agencies respond negatively to the first question. Only one
agency responds that they have done benchmarking with other Federal and private organizations.
Most of the remaining organizations have surveyed or compared themselves to other Federal
agencies. Two agencies report comparing some programs to the private sector, one comments that
risk has not fully been evaluated.
With regard to the second question, most of the respondents indicate that an objective,
third party assessment of the effectiveness of their environmental program has not been conducted.
The question posed to respondents did not address whether the assessment was solicited by the
agency or required of them. Eight respondents state that no third party assessment has been
made. Two respondents states that consultants were brought in. Three agencies do not state who
performed the third party assessment but indicated that it was conducted. Two respondents state
that there has been an IG audit. If the respondent state that the third party audit was conducted
by IG, it was still interpreted as positive indicative behavior.
Benchmark Element Summary:
This section summarizes the collective behavior of the 17 respondent agencies as evaluated
against the key indicators for this Benchmark Element. Exhibit 5-10 presents the total number of
respondents reporting each key indicative behavior.
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Exhibit 5-10
Number of Civilian Federal Agencies Reporting Each
Internal/External Communication Key Indicator
#1 #2 #3 #4 #5 #6
Internal/External Communication Key Indicators
(Indicators #2, #3, #4, and #5 were n ot addressed in the questionnaire.)
#1 = Channels Exist for Reporting Environmental Concerns
#2 = Employee Suggestions Solicited
#3 - Successful Programs/Strategies Communicated
#4 = Environmental Awareness Communicated
#5 = Cooperation with External Oversight Organization
#6 = Input Solicited from External Parties
Very few of the indicators in this Benchmark Element were addressed by the questionnaire.
There is little difference in popularity between the two indicators discussed above. The sixth
indicator had a larger number of respondents, probably because there were two questions asked
and therefore two possibilities of responding positively.
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5.2.6 Element 6: Personnel
"Best in Class" organizations ensure that personnel are capable of developing and
implementing environmental initiatives. Employees are hired, trained, and
deployed in ways that ensure that staff understand their environmental
responsibilities are receive the training and support necessary to achieve
environmental excellence.
Overall Findings:
Four key indicators have been identified as "Best in Class" performance relates to
personnel.
1. Sufficient qualified staff are hired, deployed, and trained to ensure that all aspects
of the business operation are executed in accordance with th eorganization's
environmental commitment.
2. All employees receive initial and ongoing training to ensure that they a) understand
the environmental requirements of then- job, and b) have the skills necessary to
execute then: job responsibilities hi an environmentally sound manner.
3. Environmental excellence is the explicit responsibility of every employee
throughout the organization, as demonstrated by th presence of environmental
criteria hi each employee's job description/performance evaluation, or by other
means.
4. Exemplary environmental efforts are recognized and/or rewarded.
A total of seven questions included hi the CFA questionnaire solicited information that could be
evaluated against all four of the key indicators. In general, these questions asked respondents to
provide information regarding personnel issues such as agency provision of formal training for
employees charged with environmental compliance responsibilities; establishment of award
systems for environmental performance; me inclusion of environmental performance hi employee
job descriptions and performance evaluations; and the agency view that is a responsibility of every
employee. Exhibit 5-11 presents the total number of respondents reporting multiple key indicative
behaviors.
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Exhibit 5-11
Eiement 6: Personnel Key Indicators Reported
by 17 Civilian Federal Agencies
5 Respondents (29%)
4 Respondents
(24%)
3 Respondents (18%)
2 Respondents
(12%)
3 Respondents (18%)
The following discussion compares specific survey findings to each of the four key
indicators. As a group, these agencies report engaging in all four of the key indicative behaviors.
Only three of the respondents fail to exhibit at least one of the key indicative behaviors. Five of
the respondents exhibit more than half of the identified key indicative behaviors.
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Findings:
One question included in the CFA questionnaire solicited responses that can be evaluated
against this key indicator (i.e., "Has the agency established a formal training system for
employees charged with ensuring agency complianc ewith environmental compliance both at
Headquarters and at the Regional level?"). Three responses indicate formal training systems, two
additional responses indicate informal training systems.
Formal training systems reported consist of in-house courses including diverse curriculum,
attendance at environmental conferences, and annual training. Semi-formal or informal systems
consist of training programs for environmental monitors, NEPA training for environmental
employees, to the evaluation of individual personnel responsibilities and provision of appropriate
training. The twelve negative responses ranged from one-word answers to qualified answers
indicating that no system is in place but courses can be attended as applicable.
>
, * <.,
AfteMgfcg** receive^tiaJ ancf x?%$^calfaing to fiajsue^ flat tiey '*
; 1)TfiKferstand && environmental ^e^ieai^fe^^ek jeto^ai^ 2) have,.
»^^l!^^WWWi^fr»,«WI^ A~ '''"'
ff f
Findings:
Two questions included in the CFA questionnaire solicited responses that can be evaluated
against this key indicator.
"Are agency employees provided with formal guidance regarding the application
of Federal, state, and local environmental statutes and regulations to agency
operations, including facility maintenance?"
"Does the agency have a training program to foster the implementation of Pollution
Prevention strategies as part of the agency's mission?"
These two questions asked respondents to provide information regarding the following items:
agency provision of formal guidance to employees regarding environmental statutory requirements
at the agency and facility levels; and the existence of an agency pollution prevention training
program.
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Eight of the fourteen positive responses to the first question exemplify this key indicative
behavior. Formal guidance reported by respondents consist of written documentation directing
all officials to implement agency requirements regarding environmental compliance, the training
of all management employees regarding CERCLA and RCRA, the distribution of state law
requirements to employees in affected programs, seminars, and formal meetings. Six other
positive responses are not considered to represent key indicative behavior because only selected
employees receive the formal guidance.
The second question elicited five responses indicating that employees receive ongoing
training that allows them to execute their job responsibilities in an environmentally sound manner.
Responses range from agency provision of pollution prevention seminars to the distribution of
updated information to inclusion in-house course materials. All but two of the 12 negative
responses are unqualified.
3,'
" ; ''<.' '''< . <#
*& * : '/'i
f f' "<"/ '','&'* X't-tt't " *'-,, r ,
.' ,"'/,','s*,'*^ %,, -,'; \:, r ff.',
*i '* ' '".'" '**&'?-tfa,'"** '»"*'' i*
Findings:
Three questions included in the CFA survey solicited responses that are relevant to this key
indicative behavior.
"Do facility or site managers and regional directors who have operational and/opr
real property management responsibilities, also have compliance with
environmental requirements as part of then* overall performance standards and
evaluations?"
"Does your agency view environmental performance not just as a staff unction, but
as the responsibility of all employees? All bureaus, offices and departments?"
"How are environmetnal compliance responsibilities consistently enforced through
disciplinary mechanisms administered by the agency executives and/or the
personnel department?"
109
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Five positive responses to the first question indicate that facility managers have
environmental compliance as part of their performance evaluations. However, these responses
do not completely exemplify the key indicative behavior at issue, which relates to all employees
job descriptions and performance evaluations. All other responses are negative. One negative
response states that "... an attempt to integrate ... [environmental] performance with merit
evaluation was discouraged."
Regarding the second question, 12 of the 17 respondents report that environmental
performance is the responsibility of all employees. Several agencies report that agency policies
and directives are written to convey this concept. One agency indicates that the level of
commitment may vary with different components of environmental performance. All negative
responses are unqualified.
Regarding the third question, seven agencies report enforcement mechanisms for
environmental compliance responsibilities. None of these mechanisms are related to disciplinary
actions. The nature of enforcement mechanisms range from the application of health and safety
or environmental policies and directives, on site visits by monitoring unit personnel, and safety
reviews. Qualified negative responses indicate that these agencies have no internal enforcement
mechanisms or have mechanisms that are inconsistently enacted.
en^^
' '
Findings:
One question in the CFA survey solicited responses that can be evaluated against this key
indicator (i.e., "Has the agency established employee award systems for recognizing good
performance in environmental compliance areas?"). Four respondents reported key indicative
behavior.
Of the positive respondents, one agency indicates that in addition to recognition of
pollution prevention efforts, a program that fosters suggestions for improvement has been
implemented. All other positive responses consist of an unqualified "yes." Of the thirteen
negative responses, several indicate that although employees may be recognized for good
performance, there is not a separate program that acknowledges good environmental performance.
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Benchmark Element Summary:
This section summarizes the collective behavior of the 17 respondent agencies as evaluated
against the key indicators for this Benchmark Element. Exhibit 5-12 presents the total number of
respondents reporting each key indicative behavior.
Exhibit 5-12
Number of Civilian Federal Agencies Reporting Each
Personnel Key Indicator
« #3
Personnel Key Indicators
#1 = Sufficient Qualified Staff Hired, Deployed, and Trained
#2 = Initial and Ongoing Training for all Employees
#3 * Evnironmental Excellence in the Responsibility of Every Employee
#4 = Exemplary Efforts Recognized/Rewarded
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CHAPTER 6: CONCLUSIONS
6.1 General Conclusions
An analysis of the questionnaire responses from each respondent group, and a comparison
of responses between respondent groups, reveals response patterns that form the basis for general
conclusions regarding structural, managerial, and operational performance. General conclusions
are presented first, followed by a discussion of conclusions drawn that relate to performance
within each benchmark element.
When comparing responses between respondent groups, it is important to keep in mind that
the Civilian Federal Agency (CFA) questionnaire asked different questions than the survey
distributed to Defense Related Agencies (DRAs) and Corporate Participants. As a result, there
are few key indicators in which a true "apples to apples" comparison can be made. However,
because the patterns of responses are consistent throughout the six benchmark elements, general
performance comparisons can be drawn.
The most readily apparent conclusion that can be drawn from a review of the data is that
as a group, Defense Related Agencies and Corporate Participants report engaging in substantially
more key indicative behaviors than CFAs. This pattern is exhibited in responses to most of the
six benchmark elements. Corporate Participants and Defense Related Agencies report similar
levels- of key indicative behaviors on the whole, though there is some discrepancy between
benchmark elements in the number of indicative behaviors reported, and in the types of key
indicators favored by each respondent group.
Throughout all six benchmark elements, half of the Defense Related Agencies or greater
report indicative behavior for each key indicator covered in the questionnaire. In most instances,
all four respondents in this group report indicative behavior on each relevant question. All three
Corporate Participants also report indicative behavior on each questioned indicator, in a majority
of cases. However, within the Benchmark Elements of Management Commitment,
Implementation, and Information Collection/Management/Follow-up, only one of the three private
sector respondents report indicative behavior on one of the key indicators.
With the exception of the Implementation Benchmark, CFAs report fewer key indicative
behaviors than either of the two other respondent groups. Even within the key indicators in which
greater than 50% of CFA respondents report indicative behavior, rarely do more than 10 of the
17 respondents respond affirmatively.
6.2 Element 1: Organizational Structure
Exhibit 6-1 displays the overall responses for each of the respondent groups to the
Organizations Structure Benchmark Element. As the exhibit indicates, both the Defense Related
Agencies and the Corporate Participants report organizational behavior consistent with each of the
112
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four key indicators. In fact, each of the four DRA respondents and each of the three corporate
respondents report indicative behavior for every indicator. In contrast, while only four of 17
CFA respondents report the existence of formal tracking systems covering environmental statutes
and regulations, nine of 17 CFAs report periodic meetings of senior managers covering
environmental issues. Although the questionnaire distributed to CFA's targeted only two of the
four key indicators, it appears that in comparison to the other two respondent groups, the CFAs
do not demonstrate Best in Class performance against this benchmark element.
Exhibit 6-1
Overall Responses to Key Indicators for Benchmark
Element #1: Organizational Structure
Mission Statement Exists
Clear Lines of Authority
Statutory/Regulatory
Tracking
High-Level Representation
N/A
N/A
Defense Related
Agencies
Corporate
Participants
CFAs
Legend
/ = Positive responses from 50% of respondents or greater
- Positive responses from less than 50% of respondents
N/A = Questionnaire did not address indicator
6.3 Element 2: Management Commitment
Exhibit 6-2 displays the overall responses for each of the respondent groups to this
Benchmark Element. As the exhibit indicates, respondents were not asked questions that would
solicit information concerning whether responding organizations make resources available to
transfer environmental technologies and strategies between facilities. All of the Defense Related
Agencies and Corporate Participants report that environmental concerns are integrated into
business planning activities. 12 of 17 CFAs satisfy this key indicator by reporting that analyses
are conducted to determine the potential impact of environmental issues on the Agency's mission.
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Exhibit 6-2
Overall Responses to Key Indicators for Benchmark
Element #2: Management Commitment
Resources Made Available
Business Planning
Integration
Role in All Organization
Decisions
Management Commitment
Beyond Compliance
Formal Risk Management
Program
Budgeting Criteria Used
Headquarters Level
Policies
Selection/Management of
Contractors/Vendors
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Defense Related
Agencies
Corporate
Participants
CFAs
Legend
Positive responses from 50% of respondents or
greater
Positive responses from less than 50% of
respondents
Questionnaire did not address indicator
Considerable differences between the three groups are apparent hi responses to the key
indicator that asks whether management commitment to the environment goes beyond
environmental compliance. All four Defense Related Agencies report that their Agencies
demonstrate this commitment through policy statements, published environmental performance
reports, environmental awards, or other means. Two of the three Corporate Participants report
the presence of waste and emission reduction goals that exceed regulatory requirements. In
114
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contrast, only five of the 17 CFAs state that their Agency backs up their verbal support for the
environment by providing resources, training, and program development support.
One area in which questionnaire results indicate that both Defense Related Agencies and
Corporate Participants could improve is in the area of formal risk management programs. Only
one of the three Corporate Participants and only two of four Defense Related Agencies report the
presence of a formal risk management program. The CFA questionnaire did not address this
issue.
In response to questions addressing capital budgeting methodologies that create a level
playing field for potential environmental investments, all of the Defense Related Agencies and
Corporate Participants report procedures that ensure that environmental projects receive equal or
preferential treatment. In contrast, only six of 17 CFAs report that field or headquarters
environmental staff are involved in the Office of Management and Budget (OMB)A106 investment
review process.
Although both Defense Related Agencies and Participating Corporations could improve
in the area of instituting formal risk management programs, they generally report behaviors
consistent with this benchmark element. In contrast, although a majority of CFAs report
analyzing environmental implications to Agency mission requirements and include contract
language requiring environmental compliance on the part of contractors and vendors, the overall
reported performance of CFAs under this benchmark element demonstrates a need for
improvement.
6.4 Element 3: Implementation
Exhibit 6-3 displays the overall responses for each of the respondent groups to the
Implementation Benchmark Element. As the exhibit indicates, Defense Related Agencies report
behaviors consistent with each of the three key indicators, Private Corporations report 50% or
greater compliance with two of three indicators, and CFAs report 50% or greater compliance with
both of the key indicators addressed in then: questionnaire.
The response of the Defense Related Agencies to each question addressing key indicators
in this benchmark element was unanimously positive. In questions relating to each key indicator,
all four Defense Related Agencies report indicative behavior. CFAs report a comparatively large
proportion of positive responses, when compared to the two previous benchmark elements.
Specifically, 10 of 17 CFAs satisfy the key indicator relating to the existence of comprehensive
multi-media environmental programs through the reported presence of Agency programs to
identify and address actual and potential environmental liabilities arising from past Agency
practices. Similarly, 10 of 17 CFAs report the development of emergency response procedures
and have provided guidance to regional units regarding the characterization and control of problem
waste streams.
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In contrast, certain responses from Participating Corporations indicate that some efforts
toward improvement may be warranted. Specifically, only one of these respondents report the
presence of formal corporate guidance to all departments to help ensure the attainment of
corporate environmental goals. The two other respondents state that this responsibility is left to
individual facilities and operating units. Two of three respondents report environmental
performance goals that go beyond environmental compliance.
Exhibit 6-3
Overall Responses to Key Indicators for Benchmark
Element #3: Implementation
Environmental
Performance Goals
Established
Comprehensive Multi-
media Environmental
Program Exists
Formal Guidance
Developed and
Disseminated
N/A
Defense Related Corporate
Agencies Participants
CFAs
Legend
/ = Positive responses from 50% of respondents or greater
= Positive responses from less than 50% of respondents
N/A = Questionnaire did not address indicator
6.5 Element 4: Information CoIlection/Management/Follow-up
Exhibit 6-4 displays the overall responses for each of the respondent groups to this
Benchmark Element. As the exhibit indicates, both the Defense Related Agencies and the
Corporate Participants report indicative behavior for the preponderance of key indicators in which
questions were posed. CFAs report indicative behavior for one of the two key indicators in which
questions appeared on their questionnaire.
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All four Defense Related Agencies respond positively to questions addressing the key
indicators relating to the use of information systems, the documentation of monitoring results, and
the use of corrective action when problems are identified. In contrast, only two of four DRA
respondents report performing trends analyses to identify areas requiring environmental
improvement.
All Corporate Participants report that they document the results of environmental
performance monitoring and institute corrective actions to address identified problems. Two of
the three respondents utilize formal environmental information management systems. Like the
Defense Related Agencies, Corporate Participants do not consistently practice trends analysis.
Only one of three respondents in this group reports using this analytical tool.
Exhibit 6-4
Overall Responses to Key Indicators for Benchmark
Element #4: Information Collection/Management/Follow-up
Information Baselines
Established
Information Management
Systems Used
Monitoring Results
Documented
Performance Corrected to
Meet Goals
Performance Corrected to
Meet Goals
Trends Analysis Performed
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Defense Related
Agencies
Corporate
Participants
CFAs
Legend
/ = Positive responses from 50% of respondents or greater
= Positive responses from less than 50% of respondents
N/A = Questionnaire did not address indicator
The questionnaire distributed to CFAs addressed only two of the six key indicators under
this benchmark element. 13 of 17 CFA respondents report conducting environmental audits and
117
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documenting results. Six of 17 CFAs report the presence of a system to communicate compliance
data from regional units to headquarters.
6.6 Element 5: Internal/External Communication
Exhibit 6-5 displays the overall responses for each of the respondent groups to this
Benchmark Element. Although the questionnaire sent to CFAs only addressed two of the six key
indicators, the exhibit indicates that CFAs do not appear to perform as well as Defense Related
Agencies and Corporate Participants in the area of internal and external communication.
Exhibit 6-5
Overall Responses to Key Indicators for Benchmark
Element #5: Internal/External Communication
Channels Exist for
Reporting Environmental
Concerns
Employee Suggestions
Solicited
Successful Program/
Strategies Communicated
Environmental Awareness
Communicated
Cooperation with External
Oversight Organization
Input Solicited from
External Parties
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Defense Related
Agencies
Corporate
Participants
CFAs
Legend
/ = Positive responses from 50% of respondents or greater
= Positive responses from less than 50% of respondents
N/A = Questionnaire did not address indicator
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For each of the four key indicators covered in their questionnaire, every DRA respond
positively. This pattern is repeated for Corporate Participants, with the exception of the key
indicator concerning the solicitation of environmental input from external parties. In that case,
two of three DRA respondents report the existence of formal community outreach programs at a
corporate level, while one respondent indicates that this communication responsibility is left to
individual facility management.
Only three of 17 CFA respondents report the existence of well publicized channels for
employees to report environmental problems. Ten of 17 CFAs satisfy the key indicator relating
to the solicitation of input from external parties by reporting that they either conduct comparisons
of their environmental programs to those of other organizations or that they engage in a program
that allows environmental assessments to be performed by outside entities.
6.7 Element 6: Personnel
Exhibit 6-6 displays the overall responses for each of the respondent groups to this
Benchmark Element. As the exhibit clearly indicates, both Defense Related Agencies and
Corporate Participants satisfy each of the four key personnel indicators. However, CFAs only
report indicative behavior hi the area of communicating that environmental protection is the
responsibility of every employee.
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Exhibit 6-6
Overall Responses to Key Indicators for Benchmark
Element #6: Personnel
Sufficient Qualified Staff
Hired, Deployed, and
Trained
Initial and Ongoing
Training for all Employees
Environmental Excellence
is the Responsibility of
Every Employee
Exemplary Efforts
Recognized/Rewarded
Defense Related
Agencies
Corporate
Participants
CFAs
Legend
/ = Positive responses from 50% of respondents or greater
= Positive responses from less than 50% of respondents
N/A = Questionnaire did not address indicator
Both Defense Related Agencies and Participating Corporations report that they use
forecasting tools to project future environmental staffing needs and specify minimum qualifications
for all environmental employees. In response to their question on this key indicator, five of 17
CFAs report the presence of formal Agency training of all environmental compliance staff. All
of the Defense Related Agencies and Participating Corporations report that environmental training
is routinely provided to all employees. In response to questions concerning the environmental
training of all employees, each DRA and Corporate Participant report that they train all
employees. Six CFAs report that training is provided only to staff with environmental
responsibilities. FJght others responded that some level of training is provided to all employees.
A substantive majority of CFAs (12 of 17) report that their Agency considers
environmental performance the responsibility of every employee. Five of these 17 respondents
include compliance activities within the performance evaluation process. Three of the four DRA
responses and all of the responses from Corporate Participants indicate that systems are in place
to hold environmental staff accountable for their environmental performance. One corporate
120
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respondent indicates that environmental performance is an evaluations criteria used for all plant
managers and budget center managers.
Four of 17 CFAs, and all other respondents report the use of award programs to recognize
employee environmental achievements. Expanding the use of these programs within Civilian
Federal Agencies is needed, and may be a relatively easy way for CFAs to begin to improve their
performance as it relates to the Personnel Benchmark Element.
121
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APPENDIX A
Environmental Benchmarking Questionnaires
This appendix contains copies of the written questionnaires sent to participants in this
environmental benchmarking project. Exhibit A-l is the questionnaire sent to Civilian Federal
Agencies (CFAs). Responses were received from the following:
Treasury Department
Postal Service
Federal Aviation Administration
Department of Commerce, Office of Federal Assistance and Management Support
Department of Commerce, Economic Development Administration
National Oceanic and Atmospheric Administration
United States Department of Agriculture (USDA), Agricultural Research Service
USD A, Federal Grain Inspection Service
USDA Animal and Plant Health Inspection Service
USDA Soil Conservation Service
USDA (branch not specified)
Department of Justice
EPA, Office of Administration, Safety, Health & Environmental Management
Division
National Security Agency, Environmental Management Services Division
Three unidentified agencies
Exhibit A-2 is the questionnaire sent to Corporate Participants and to participants from Defense
Related Agencies (DRAs). Responses were received from the following:
Corporate Participants
Chevron Corporation
Xerox Corporation
3M Corporation
Defense Related Agencies
Department of Energy
Department of the Army
Department of the Navy
Department of the Air Force
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Exhibit A-1
Civilian Federal Agencies Questionnaire
CIVILIAN FEDERAL AGENCY EVALUATION QUESTIONNAIRE
OFFICE OF FEDERAL FACILITIES ENFORCEMENT
STRATEGIC PLANNING AND PREVENTION DIVISION
Attached is the Civilian Federal Agency Evaluation Questionnaire.
The purpose of this Questionnaire is to assist EPA in identifying
and evaluating Federal agency resources which could provide
support for other Federal environmental programs. In addition,
EPA is seeking data which will provide the basis for a focused
approach to technical support and information sharing.
Please complete the Questionnaire and return it to:
Richard satterfield
U.S. Environmental Protection Agency
Office of Federal Facilities Enforcement
401 M. Street, 8.W. (OB-2261)
Washington D.c. 20460
If you have any questions or concerns regarding the
Questionnaire, do not hesitate to contact Richard Satterfield at
260-9759 or Davina Pujari at 260-5757. Thank you for your time
and consideration.
A-2
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Exhibit A-1 (continued)
Civilian Federal Agencies Questionnaire
SECTION I - AGENCY PROFILES
EPA would like to identify the basic components of your agency's
environmental compliance infrastucture. The following questions
address several key areas which contribute to an effective
environmental program. In identifying the degree to which
compliance infrastructure has been developed within different
Federal agencies, EPA will be better equipped to design a system
for information exchange and technical support.
Section I contains several subsections which cover Policy and
Guidance, Training, Data Management, Internal Agency Monitoring
and Auditing Procedures, Management Support and Budgetary
Concerns. In answering the questions, please provide any
additional information which may be helpful in EPA's analysis of
your program. The format has been kept open to encourage
detailed, informative responses and comments. Please feel free
to attach additional pages if necessary.
A-3
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Exhibit A-1 (continued)
Civilian Federal Agencies Questionnaire
Environmental Camn^tanee Policy and Guidance Manuals
1. By what procedure and in what form are your environmental
policy statements and directives communicated throughout the
agency?
2. Are agency employees provided with formal guidance regarding
the application of Federal, state, and local environmental
statutes and regulations to agency operations, including
facility maintenance?
3. Have emergency response procedures been developed and
communicated to all affected employees through formal
guidance documents?
4. What guidance does the agency offer to its regional units
for the characterization and control of all suspect waste
streams and emissions in order to obtain compliance?
5. Does your agency have a formal system for monitoring
proposed regulatory changes and for developing guidance on
compliance with changing regulations?
Training Availability and Effectiveness
6. Has Total Quality Management (TQM) been integrated into the
agency's environmental compliance programs?
7. Has the agency established a formal training system for
employees charged with ensuring agency compliance with
environmental compliance both at Headquarter and at the
Regional level?
8. Does the agency have a training program to foster the
implementation of Pollution Prevention strategies as part of
the agency's mission?
9. Are contractors and vendors briefed on environmental
policies prior to the performance of a contract?
Data Management and Access
10. Is there an agency-wide environmental database established
to ensure that proper records (e.g., waste manifests,
biennial reports, permits, etc.) are maintained and updated?
A-4
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Exhibit A-1 (continued)
Civilian Federal Agencies Questionnaire
11. Does the database or system control the contents, location
and updating of these records and restrict access to
appropriate personnel?
12. How does the system ensure the reporting of regulatory data
(e.g., notices of violation, facility compliance agreements)
by regional compliance staff to agency executives at
Headquarters?
13. Is there a central inventory, either computer-based or
written, that tracks and profiles all regulated agency
sites, materials, waste streams or emissions?
14. Has the agency formally compared its environmental programs
(including regulatory compliance, risk reduction and best
management practices) with other Federal agency programs?
Has the agency compared its programs with those in the
private sector (Fortune 500 companies)?
Internal Agency Compliance Monitoring and Auditing Procedures
15. is there an environmental auditing, assessment or other
system in place to oversee and monitor the agency's
compliance activities?
16. Are agency employees and contractors provided with a well-
publicized system that encourages the reporting of
environmental problems, violations, or criminal conduct
within the agency without fear of retaliation?
17. Do facility or site managers and regional directors who have
operational and/or real property management
responsibilities, also have compliance with environmental
requirements as part of their overall performance standards
and evaluations?
18. Does your agency routinely conduct environmental assessments
on potential acquisitions and/or transfers of real property?
19. Are risk evaluations performed on environmental cleanup and
waste disposal contractors prior to award?
20. Do contracts contain an environmental and occupational
health and safety clause as part of the standard terms and
conditions?
21. Do the process operation and construction engineering
departments or offices communicate with the environmental
program offices when new or modified mission activities or
demolition or construction is planned?
22. Have you identified and quantified environmental liabilities
4
A-5
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Exhibit A-1 (continued)
Civilian Federal Agencies Questionnaire
from past operations, mission activities, discontinued
offices, bureaus or departments? Has the agency developed a
plan for minimizing those liabilities?
23. Has the agency analyzed the potential impact of
environmental issues on the future mission of your agency?
24. Has an objective, third-party assessment of the
effectiveness of your agency's environmental program been
conducted?
Management Support and Agency Outreach
25. Does your agency view environmental performance not just as
a staff function, but as the responsibility of all
employees? All bureaus, offices and departments?
26. How often are environmental issues discussed in meetings of
the agency's Office of General Counsel and Inspector
Generals Office?
27. DO senior executives, deputy administrators, deputy
secretaries, etc. meet to discuss environmental issues on a
periodic basis?
28. HOW is top management support for the environmental
compliance program demonstrated?
29. Which specific high level persons, not reporting to
departmental or facility managers have authority to ensure
compliance with Federal and state environmental laws, and
agency environmental policies and directives?
30. How are environmental compliance responsibilities
consistently enforced through disciplinary mechanisms
administered by the agency executives and/or the personnel
department?
31. Has the agency established employee award systems for
recognizing good performance in environmental compliance
areas?
Budgetary Procedures and Concerns
32. Does your agency actively participate in the OMB A-106
process? What offices are involved (e.g., procurement,
budget)?
33. what is the approximate size of the agency's environmental
compliance staff, i.e., in terms of FTEs?
34. Has your agency ever reported or considered reporting
5
A-6
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Exhibit A-1 (continued)
Civilian Federal Agencies Questionnaire
insufficient resource levels within your environmental
compliance program as a material weakness under the Federal
Managers Financial Integrity Act (FMFIA)?
A-7
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Exhibit A-2
Private Corporations and Defense Related Agencies Questionnaire
BENCHMARK QUESTIONNAIRE
ENVIRONMENTAL COMPLIANCE PROGRAM
Organizational Structure
A- Goals and Objectives
1. Does your organization's goals and objectives statement include an
environmental policy statement? If yes, please enclose a copy of
the statement.
2. Among departments with environmental responsibilities (such as a
product manufacturing division which needs to dispose of
hazardous waste), do any departments address environmental
responsibilities in their goals and objectives statement?
B. Organization
3. Is there an organizational chart which illustrates the company's
environmental management structure?
4. Do departments with environmental responsibilities have
organizational charts that illustrate:
Your organization's environmental management structure?
Any environmental management responsibilities?
C. Environmental Responsibility and Authority
5. Are environmental responsibilities defined and communicated to all
or some (Please circle one) of the employees whose activities may
impact environmental performance?
If environmental responsibilities are defined and
communicated to some employees, what criteria is used to
determine which positions will have defined responsibilities?
How are environmental responsibilities communicated to
employees?
What documentation is used to define roles and
responsibilities (e.g., program manuals, job descriptions)?
1
A-8
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Exhibit A-2 (continued)
Private Corporations and Defense Related Agencies Questionnaire
6.
7.
8.
Are employees who are responsible for environmental management
held accountable for their performance and the performance of
those they manage?
How are they held accountable (e.g., rewards, reprimands for
failure to carry out environmental responsibilities)?
How is accountability documented (e.g., job descriptions,
performance standards, performance appraisals)?
In case of an environmental emergency, who has the authority to
"stop work" (what position within the organization)?
What is the highest level of authority within your organization with
direct environmental management responsibilities (e.g.. Vice
President)?
11.
9. What position within your organization (e.g.. Vice President):
Establishes organization-wide environmental policy and
standards?
Provides environmental oversight of line organizations?
Provides technical support for line organizations?
10. What specific high-level positions (i.e., those not reporting to
departmental or facility managers) have authority to ensure
compliance with Federal and state environmental laws, policies,
regulations, and directives?
11. From what organizational authority level (e.g.. Vice President of
Environmental Affairs) are environmental procedures and standards
issued?
Environmental Commitment
A. Top Management
1. Are the following methods used by top management to demonstrate
support for compliance programs? (Please circle all that apply.)
Corporate annual reports
A-9
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Exhibit A-2 (continued)
Private Corporations and Defense Related Agencies Questionnaire
Published environmental reports
General environmental policy
Internal Speeches
External Speeches
Other (Please describe.)
Do senior management meetings include discussions of
environmental management issues or programs?
If yes, are environmental issues or programs discussed
routinely or periodically? (Please circle the appropriate
response.)
Has senior management set goals and expectations regarding
environmental performance (e.g., environmental compliance as a
minimal expectation, goals that go beyond compliance, emission
reduction)?
What are these goals and expectations?
Are departments given guidance in reaching these goals?
How frequently does senior management communicate its
environmental goals and expectations to employees? (Please circle
all that apply.)
Weekly
Biweekly
Monthly
Quarterly
Other (Please describe.)
Is your organization's environmental status or performance
routinely and formally reported to management?
If not. what methods of communications are used?
A-10
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Exhibit A-2 (continued)
Private Corporations and Defense Related Agencies Questionnaire
III. Environmental Protection Program
A. General Program
1. Does your organization have formal written emergency response
plans?
2. How is you organization's emergency response procedures
communicated to employees?
3. Have staff received training in emergency response procedures?
4. Does your organization hold periodic drills or other readiness
exercises?
B. Pollution Prevention/Waste Minimization
5. Does your organization have a pollution prevention program in
place?
6. Does your pollution prevention program utilize the following
methods of source reduction:
Product changes (e.g., design products for less environmental
impact)?
Process changes (e.g., control for fugitive emissions)?
input material changes (e.g., substitution of less toxic
materials)?
Technology changes (e.g.. improved equipment)?
Improved operating practices (e.g.. waste segregation)?
7. Does your organization have a formal pollution prevention plan or
strategy? If yes, does this plan or strategy include the following
elements:
Corporate policy statement of support for pollution
prevention?
Requirements for facility-specific plans?
A-ll
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Exhibit A-2 (continued)
Private Corporations and Defense Related Agencies Questionnaire
8.
9.
Description of your pollution prevention planning team(s)
makeup, authority, and responsibility?
Organization-wide pollution reduction goals?
Facility-specific pollution reduction goals?
Description of the processes that produce, use. or release
hazardous or toxic materials?
List of treatment, disposal, and recycling facilities and
transporters currently used?
Description and evaluation of current and past pollution
prevention activities at your facilities?
Criteria for prioritizing candidate facilities, processes, and
streams for pollution prevention projects?
Plan for communicating the successes and failures of
pollution prevention programs within your organization
Other? (Please Describe.)
What isjhe most successful pollution prevention measure or project
that has been implemented by your organization?
Does your organization have a recycling program in place? Please
list the types of materials that are recycled.
10. What other waste minimization program(s) does your company
have in place? Please list these programs.
11. What benefits have your organization experienced from your
pollution prevention and waste minimization programs (e.g.,
recycling programs)?
C. Media-Specific Programs
12. Are environmental protection programs in place to identify, control
or monitor air emissions? (Please circle all that apply.)
13. Does your organization have a program in place to protect surface
waters?
A-12
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Exhibit A-2 (contmuea)
Private Corporations and Defense Related Ansneift« Questionnaire
Does this surface water protection program include:
Identification of discharge points and sources?
Applicable discharge permits, monitoring program, a
Spill Prevention. Control and Counter-measures Plan?
Reporting and recordkeeping system?
14. When necessary, has a groundwater monitoring program been
established to address the needs of specific sites?
15. Are programs in place for all stages of management and control of
toxic and chemical materials to prevent or minimize their release
into the environment?
Do these programs include:
Procurement handling, and storage of toxic and .
chemical materials?
Management and control of PCBs (polychlorioated
biphenyls)?
Management and control of pesticides?
Management and control of petroleum, petroleum
products, and chemicals in aboveground or
underground storage tanks?
Containment or removal of asbestos?
16. Does your organization have a program for the management of
solid, hazardous, or radioactive waste? (Please circle the
appropriate responses.)
Does this program include:
Waste source identification?
Waste characterization?
Waste acceptance criteria, where appropriate?
Treatment storage, and disposal practices?
Contingency plans?
Recordkeeping systems?
Training?
Waste Minimization?
17. Is there a program in place that monitors potential contamination
from radiation?
A-13
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Exhibit A-2 (continued)
Private Corporations and Defense Related Agencies Questionnaire
18. Does your organization have a program in place to identify,
remove, and/or routinely monitor underground storage tanks?
19. Does your organization have a program in place to ensure
compliance with the National Environmental Policy Act (NEPA)?
IV. Formality of Environmental Program
A. Regulatory Tracking and Interpretation
1. What methods does your organization use to follow new and
emerging environmental regulations and trends (e.g.. government
liaisons, subscriptions to tracking services, periodicals)?
2. Within your organization, what departments participate in the
interpretation of environmental regulations (e.g., government
affairs, environmental compliance, engineering)?
3. What procedures are used to incorporate new regulatory
requirements into existing programs?
B. Environmental Information Management
4. How is environmental program information distributed to field
offices (e.g., memos. internal publications. E-mail, meetings)?
5. Does your organization have an automated system to control
environmental information such as manifests or TR1 (Toxic Release
Inventory)?
Is this system integrated into a larger information
management system?
6. For general environmental information, what information sources
does your organization use (e.g., industry publications, regulatory
reference materials, on-line systems)?
C. Environmental Program Management
7. Does your organization have a formal program to address
environmental quality issues such as emissions control or waste
disposal?
A-14
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Exhibit A-2 (continued)
Private Corporations and Defense Related Agencies Questionnaire
8. What management techniques (e.g., TQM. MBO) does your
organization use to keep its environmental program operating as
efficiently as possible?
9. Does your organization have a database which tracks waste
manifests and permitting records?
Is this system computer-based?
10. Is there a central inventory which tracks and profiles regulated
sites, materials, waste streams, or emissions?
Is this system computer-based?
V. Internal and External Communication
A. Internal Communication
1. What methods are used to communicate environmental information
within your organization (e.g., memos. meetings, bulletin boards)?
2. Is there a program in place which allows employees to raise
environmental concerns anonymously?
How many times per year do employees use this program?
How are concerns expressed (e.g., survey, suggestion box)?
To what authority level are concerns reported?
What action is taken in response to employee concern?
B. External Communications
3. Does your organization have a program to publicize its
environmental effort and address the environmental concerns of the
larger community (e.g.. nearby residents)?
Why was this program developed?
How long have you had the program?
A-15
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Exhibit A-2 (continued)
Private Corporations and Defense Related Agencies Questionnaire
What methods of communication are utilized (e.g.,
environmental reports, residents' advisory boards.
newsletters, speakers' bureaus)?
VI. Staff Resources. Training, and Development
A. Staff Resources
1. How many people does your organization employ?
2. How many of your organization's employees:
Have primarily environmental responsibilities?
Are in your environmental division(s)?
3. How does your organization assess environmental staffing needs
(e.g., surveying environmental managers, personnel studies)?
4. What qualifications does your organization look for in:
Junior level environmental staff (i.e.. entry level positions)?
Senior level environmental staff (i.e.. environmental staff
with supervisory responsibilities)?
Staff members in other positions of environmental
responsibility (e.g., health & safety officers, plant managers)?
Contractors with environmental responsibilities?
B. Staff Accountability
5. Are environmental responsibilities included in job descriptions of
staff whose primary duties are not environmental but who have
some environmental duties (e.g., plant managers, health & safety
officers)?
6. When appropriate, are environmentally related factors included in
the performance evaluations of non-environmental staff (e.g.,
unplanned releases at a factory affecting plant managers'
performance reviews)?
A-16
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Exhibit A-2 (continued)
Private Corporations and Defense Related Agencies Questionnaire
7. What rewards or recognition is given by your organization for
environmental achievement (e.g., favorable staff performance
reports, awards, monetary rewards, public recognition)?
8. What disciplinary actions are taken for poor environmental
performance (e.g.. negative staff performance reports, standard
disciplinary procedures)?
C. Staff Training
9. Is training available for staff with environmental responsibilities?
Is this training required?
Is this training available to other personnel?
10. How does your organization determine staff environmental training
needs (e.g., surveys, industry requirements, employee interest)?
11. Is environmental protection training included in personnel
orientation?
12. Are contractors briefed on your organization's environmental
standards and policies?
D. Staff Development
13. What career opportunities are available for environmental staff
(personnel with primarily environmental responsibilities) within
your organization?
14. Within your organization, what is the highest level to which an
environmental staff member has been promoted?
V1L Evaluation. Reporting, and Corrective Action
A. Environmental Program Evaluation
1. Does your organization have any formal environmental evaluation
programs such as environmental audits or assessments?
What operations (e.g., waste transportation, recovery
systems, energy efficiency, recordkeeping) are assessed by
environmental evaluations?
10
A-17
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Exhibit A-2 (continued)
Private Corporations and Defense Related Agencies Questionnaire
2. How frequently do environmental evaluations take place (e.g.,
monthly, quarterly, annually, other)?
3. Arc environmental evaluations conducted by your organization's
staff or by an outside party such as a contractor?
Why did you choose this approach?
4. Has your organization ever conducted a benchmarking program to
assess your organization's environmental programs against those of
similar organizations?
B. Program Reporting
5. What methods are used to report environmental evaluation results?
Who receives evaluation results?
Are evaluation results tracked over time and analyzed?
(Please describe.)
6. Have previously undetected environmental problems ever been
found as a result of an environmental evaluation?
VIII. Environmental Planning and Risk Management
A. Environmental Planning
1. Does your organization conduct environmental planning?
(Environmental planning is the outlining of long-term goals which
an organization then strives to meet.)
How often does environmental planning take place (e.g.,
every year, once every five years)?
2. Is the method used for environmental planning similar to or
different from the planning methods used for other concerns such
as marketing or capital investment? (Please circle appropriate
response.)
If a different method is used, how does it differ, and why
was this method chosen?
11
A-18
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Exhibit A-2 (continued)
Private Corporations and Defense Related Agencies Questionnaire
3. How does environmental planning affect your organization's long-
term business plans?
4. How do the results of environmental planning affect your
organization's budgeting process?
B. Risk Management
5.
Does your organization have a formal risk management program?
(Risk management is a program of action designed to reduce the
possibility of an accident or similar unwanted event from occurring.
Risk management includes but is not limited to environmental
concerns.)
What are this program's objectives and approach?
6. Are your organization's operations reviewed or assessed for risk .
management concerns?
is this review separate from or a pan of a larger review (e.g.,
environmental, managerial, safety)?
7. Axe new projects reviewed for risk management or environmental
impact issues?
12
A-19
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APPENDIX B
Environmental Benchmarking Resources: Reports and Standards
Benchmarking for Public and Third-Sector Planning. Kleiner, Brian. Federal Facilities
Environmental Journal. Volume 5, Number 1. Spring 1994.
Environmental Benchmarking: AT&T and Intel's Project to Determine the Best-in-Class
Corporate Pollution Prevention Programs. Klafter, Brenda, et. al. Corporate
Quality/Environmental Management m. Leadership - Vision to Reality 1993.
Facility Level Pollution Prevention Benchmarking Study. The Business Roundtable
November 1993.
Guideline for a Voluntary Environmental Management System. Canadian Standards
Association. Revision 8.1. March 1, 1994.
International, North American, National Standards for Environmental Management Systems.
Bellen, Gordon and A. Jensen, and A. Knight. Presentation to the Global Environmental
Management Initiative Third Environmental Management Conference. March 25, 1993.
Proposed American National Standard/NSF International Standard for Environmental
Management Systems - Guidelines for Environmental Auditing - Principles and General
Practices. NSF International. NSF 100-1994, Draft 3.5. February 1994.
Proposed American National Standard/NSF International Standard for Environmental
Management Systems - Guiding Principles and Generic Requirements for Environmental
Management Systems. NSF International. NSF 110-1994, Draft 5.1. May 1994.
Protocol for Conducting Environmental Management Assessments of DOE Organizations.
United States Department of Energy. DOE/EH-0326. June 1993.
Request for Environmental Leadership Program Pilot Project Proposals. United States
Environmental Protection Agency. Federal Register Notice. May 1994.
Total Quality Environmental Management: The Search for Globally Useful Environmental
Standards. Bellen, Gordon, A. Jensen, and A. Knight. Corporate Environmental Strategy.
Volume 1, Number 2.
Utilizing a Matrix Framework and Assessment Tool for Total Quality Environmental
Management. Wever, Grace. Presentation to the Successfully Utilizing Environmental
Measurement, Benchmarking and Employee Empowerment Conference. September 1993.
B-l
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