United States
Environmental Protection
Agency
Office Of
Enforcement and
Compliance Assurance
(2261 A)
EPA 402-R-96-017
November 1996
Implementation Guide
For The Code of
Environmental Management
Principles for Federal Agencies
(CEMP)
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This document was,prepared
by the Federal Facilities
Enforcement Office (2261-A)
in the Office of Envirocement
and Compliance Assurance.
Consulting assistance and
document design/layout
services were provided under
IAG number DW89936515.
For additional copies of this
document, piease contact:
PriscHla Harrington
U.S. EPA (2261-A)
401 M Street, SW
Washington, O.C. 20460
Tel: (202) 564-2461
; Fax: (202K501-0069
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IMPLEMENTATION GUIDE FOR THE CODE OF ENVIRONMENTAL
MANAGEMENT PRINCIPLES FOR FEDERAL AGENCIES (CEMP)
CONTENTS
1. INTRODUCTION 1
What is the Code of Environmental Management Principles (CEMP)? 1
What is an Environmental Management System (EMS)? 2
Is the CEMP an EMS Standard? 3
How Does the CEMP Tie Into Other EPA Programs? 5
What You Will Find in This Document 6
2. FEDERAL AGENCY RESPONSES TO THE CEMP 10
CEMP Development Process .' 10
Responses From Federal Agencies and Departments 10
3. MANAGEMENT COMMITMENT (PRINCIPLE 1) 15
1.1 OBTAIN MANAGEMENT SUPPORT 15
1.1.1 Policy Development 15
1.1.2 System Integration 16
1.2 ENVIRONMENTAL STEWARDSHIP AND SUSTAINABLE DEVELOPMENT 17
4. COMPLIANCE ASSURANCE AND POLLUTION PREVENTION (PRINCIPLE 2) . 20
2.1 COMPLIANCE ASSURANCE 20
2.2 EMERGENCY PREPAREDNESS 22
2.3 POLLUTION PREVENTION AND RESOURCE CONSERVATION 23
5. ENABLING SYSTEMS (PRINCIPLE 3) 27
3.1 TRAINING 27
3.2 STRUCTURAL SUPPORTS 28
3.3 INFORMATION MANAGEMENT, COMMUNICATION, DOCUMENTATION .... 29
6. PERFORMANCE AND ACCOUNTABILITY (PRINCIPLE 4) 33
4.1 RESPONSIBILITY, AUTHORITY AND ACCOUNTABILITY 33
4.2 PERFORMANCE STANDARDS 34
7. MEASUREMENT AND IMPROVEMENT (PRINCIPLE 5) 35
5.1 EVALUATE PERFORMANCE 35
5.1.1 Gather and Analyze Data 35
5.1.2 Institute Benchmarking 37
5.2 CONTINUOUS IMPROVEMENT : 38
8. CEMP SELF-ASSESSMENT MATRIX 40
How the CEMP Matrix Works 40
Moving From Level to Level 41
APPENDIX 1. AGENCY RESPONSES
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TABLES AND FIGURES
Table 1 Summary of Agency Responses to the CEMP 14
Figure 1 Environmental Processes in a Management System 2
Figure 2 Pollution Prevention Act Environmental Management Hierarchy 24
Figure 3 Federal Agency Environmental Compliance Management System 29
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CHAPTER 1: INTRODUCTION
What is the Code of Environmental Management Principles (CEMP)?
The Code of Environmental Management Principles for Federal Agencies (CEMP), developed by the
Environmental Protection Agency (EPA) in response Executive Order 12856, is a collection of five
broad principles and underlying performance objectives that provide a basis for Federal agencies to
move toward responsible environmental management. Adherence to the five principles will help
ensure environmental performance that is
proactive, flexible, cost-effective, integrated, ^^^^^^^^^^^^^^^^^^^^^^^
and sustainable.
CEMP focuses federal agencies on the necessity
of state-of-the-art environmental management
for reaching the highest levels of environmental
performance. State-of-the-art should be defined
as those environmental management programs
or systems that ensure environmental
performance be considered as world-class or
best-in-class by peers and stakeholders. EPA
has patterned the CEMP on the common critical
elements of a comprehensive management
system tailored to the environmental activities
of an organization (an Environmental
Management System).
Executive Order 12856, "Federal Compliance
with Right-to-Know Laws and Pollution
Prevention Requirements," which was signed on
August 3, 1993, requires EPA to "establish a
'Federal Government Environmental Challenge
Program'," one component of which is to
"challenge Federal agencies...to agree to a code
of environmental principles to be developed by
EPA, in cooperation with other agencies, that
emphasizes pollution prevention, sustainable
development and state-of-the-art environmental
management programs..." EPA has been
working to develop the CEMP through the
Interagency Pollution Prevention Task Force,
which was created by the Executive Order,
early in calendar year 1995. Sixteen Federal
agencies participated in the development of the
CEMP.
THE PRINCIPLES
1. MANAGEMENT COMMITMENT:
The agency makes a written top-management
commitment to improved environmental
performance by establishing policies which
emphasize pollution prevention and the need to
ensure compliance with environmental
requirements.
2. COMPLIANCE ASSURANCE AND
POLLUTION PREVENTION:
The agency implements proactive programs that
aggressively identify and address potential
compliance problem areas and utilize pollution
prevention approaches to correct deficiencies and
improve environmental performance.
3. ENABLING SYSTEMS:
The agency develops and implements the necessary
measures to enable personnel to perform their
functions consistent with regulatory requirements,
agency environmental policies, and its overall
mission.
4. PERFORMANCE AND
ACCOUNTABILITY:
The agency develops measures to address
employee environmental performance, and ensure
full accountability of environmental functions.
5. MEASUREMENT AND IMPROVEMENT:
The agency develops and implements a program to
assess progress toward meeting its environmental
goals and uses the results to improve
environmental performance.
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The CEMP is not a regulation, it is a voluntary component of a program established to encourage
federal agencies to enhance their environmental performance through the creative use of management
tools. As such, the goal is to move agencies "beyond compliance" and the traditional short-term
focus on regulatory requirements to a broader, more inclusive view of the interrelated nature of their
environmental activities.
Unfortunately, federal agencies often lack the resources to develop a complete environmental
management program, especially when their primary missions are not directly related to
environmental protection or management. They are often forced to take a "finger in the dike"
approach that focuses on compliance, addressing situations as they occur, instead of planning their
activities to prevent such situations. They may even be successful, until they run out of fingers.
Thus, short-term success is no indicator of the long-term stability of the system and may even lead to
complacency. Agencies that are able to better understand their "dike" (how it was built, why it was
built the way it was, and how the demands on it are changing over time) will be in a better position
to identify weak points and predict the next "high tide," managing their resources for prevention, not
just response. Of course, regulatory compliance is still required, but the CEMP, properly
implemented, will provide agencies with a tool to improve overall performance while maintaining
compliance as a performance baseline.
What is an Environmental Management System (EMS)?
The International Organization for Standardization (ISO) defines environmental management systems
as "that part of the overall management system which includes organizational structure, planning
activities, responsibilities, practices, procedures, processes and resources for developing,
implementing, achieving, reviewing and maintaining the environmental policy." In other words, an
EMS focuses on environmental management practices, rather than the activities themselves, such as
air monitoring or drum handling. The EMS provides the structure by which the specific activities can
be carried out efficiently and in a manner consistent with key organizational goals, but does not
specify levels of performance (e.g., the EMS will ensure that proper procedures are in place and that
operator training exists but won't specify methods or frequency of sampling). The EMS allows an
organization the flexibility to adapt the system to its needs and priorities, rather than forcing a "one
size fits all" mentality.
The EMS approach has its genesis
in the same movement that created
the "quality management" systems
traditionally applied to
manufacturing, such as Total
Quality Management (TQM). The
Global Environmental Management
Initiative (GEMI) patterned its Total
Quality Environmental Management
(TQEM) philosophy on TQM,
employing many of the same
diagnostic tools for environmental
applications. The more general
EMS approach incorporates the
Environmental Processes in a
Management System
Figure 1
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"plan-do-check-act" cycle and the emphasis on continuous improvement found in TQM and other
quality management schemes. [See Figure 1] A number of organizations and countries (e.g., ISO,
Britain, Canada) have developed standards to encourage implementation of the EMS approach.
BASIC EMS ELEMENTS
Is the CEMP an EMS Standard?
The CEMP is a set of principles - not a standard - that will help an organization improve its
environmental performance and level of environmental protection. In developing the CEMP, EPA
examined a number of EMS standards to identify common elements and areas that needed to be
addressed. The CEMP reflects its EMS origins in its structure and format; however, it is not a
standard. A technical standard for a product describes characteristics related to its performance, such
as size, strength, durability, and materials of construction.
Similarly, a technical management standard describes the
characteristics desirable for a management approach to a
particular subject area, such as quality or the environment.
Just as conforming to a technical product standard allows a
manufacturer to advertise that its product meets agreed-upon
specifications for performance, an organization conforming
to a technical management specification standard (such as
ISO 14001) can claim that its management practices are
aligned with consensus "best practices." In addition to the
possibility of improving performance through improved
management, one of the primary motivations for adopting
such standards is the potential for commercial advantage
resulting from independent certification of conformance to
the standard (and potential for disadvantage from failure to
conform).
1.
2.
3.
4.
5.
Environmental Policy
Planning
Implementation and Operation
Checking and Corrective Action
Management Review
Although these terms refer
specifically to the ISO 14001 EMS
Standard, they are common elements
of other EMS Standards and
reflected in the CEMP.
Rather than focus on strict evaluations of
conformance, EPA would like to emphasize the
aspects of improved management (leading to
improved performance) and continuous
improvement. In addition to a statement of
expectation for each broad principle, the CEMP
stresses the important indicators supporting each
principle (the "Performance Objectives"), so that
agencies can understand their intrinsic and
systemic value and better judge agency progress.
This Guide expands upon that informative
discussion. The CEMP also differs from most
EMS standards in its emphasis on regulatory
compliance and the fact that it is targeted toward
Federal agencies (essentially removing the appeal
of commercial advantage). For these reasons,
EPA believes that it would be inappropriate for it
to "endorse" a particular EMS standard at this
time, although EPA has participated strongly in the
CEMP BACKGROUND SOURCES
1. ISO 14001 EMS Standard (draft)
2. NSF-110 EMS Standard (draft)
3. CM A Responsible Care Program
4. CSA-2750 EMS Standard (draft)
5. DOE Environmental Management
Assessment Protocols
6. U.S. Sentencing Commission
Guidelines
7. Canadian Code of Environmental
Stewardship
8. EPA Environmental Leadership
Program (proposed)
9. GEMI TQEM materials
10. Wever, "Utilizing a Self Assessment
Matrix for Implementing TQEM"
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ISO process and exchanges information with other countries that have developed such standards.
On September 3, 1996, Steve Herman, the EPA Assistant Administrator for Enforcement and
Compliance Assurance, signed a letter transmitting the CEMP to the Federal agency executives who
had signed the Charter for the Interagency Pollution Prevention Task Force in September 1995,
requesting written commitment to the Principles contained in the CEMP. In this letter, EPA also
asked each agency to provide a written statement declaring their support for the CEMP principles at
the agency level along with a description of their plans for implementation of the CEMP at the facility
level. The CEMP was published in a Federal Register notice on October 16, 1996 (61 FR 54063).
The information in this document is provided as a guide to assist agencies in formulating their
responses to EPA and their approaches to implementation of the CEMP.
Although this document presents specific actions that could be taken in implementing the principles,
they are offered only as suggested steps that have proven useful to other organizations in
implementing similar programs. Agencies are encouraged to consider other steps that might be more
appropriate for their circumstances, or to adopt an EMS standard as the vehicle for implementing the
CEMP. An agency that implements an EMS (such as ISO 14001) will have addressed the major
elements of the CEMP, so long as its system includes an explicit compliance assurance component.
The term "agency" is used throughout the CEMP to represent the participation of individual federal
government bodies. Many Cabinet-level "agencies" have multiple levels of organization and contain
independently operating bodies (known variously as bureaus, departments, administrations, services,
major commands, etc.) with distinct mission and function responsibilities. Therefore, while it is
expected that a "parent agency" would subscribe to the CEMP, each parent agency will have to
determine the most appropriate level(s) of explicit CEMP implementation for its situation. Regardless
of the level of implementation chosen for the organization, it is important that the parent agency or
department demonstrate a commitment to these principles.
Before an agency can fully implement the CEMP, it should conduct an initial review or "gap
analysis" to evaluate its current program and specific needs. Although the gap analysis is very
important, it can be counter-productive for an
agency to focus narrowly on what it is not
doing. It is also important to understand what it
is already doing, and evaluate ways to improve
and build on existing programs and activities.
Some agencies may find that they are already
performing many of the suggested activities.
This is good; there is no need to rebuild a
program from scratch. In fact, EPA believes
that many agencies do have programs that
address the principles of the CEMP, but those
programs may not be seen as connected parts of
a system and may be operated in isolation or by
multiple contractors. Looking outside the
environmental arena can provide inspiration.
Agencies may be tempted to say "Yes, we do
that, but it's not environmental, it's part of our
quality (or some other) system." If it already
PLUGGING THE GAPS
A gap analysis is designed to answer the
following questions:
How well are the organization and its
environmental programs performing?
What standards of environmental performance
does the organization hope to achieve?
What are the gaps between objectives and
performance?
What existing programs and activities can
serve as the best foundation for improved
environmental performance?
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helps manage important agency activities, it can probably help environmental management as well.
The full impact of the CEMP/EMS approach will be realized in tying these programs and activities
together to improve efficiency, which is also likely to improve performance and cost-effectiveness.
Building on existing programs becomes even more important when agencies are faced with
diminishing resources and being asked to "do more with less." Through careful analysis, agencies
will probably find ways to address the principles at little or no cost. For example, developing a
policy statement on environmental protection does not require large investments in personnel or
equipment, yet it can carry agency-wide visibility and impact. Ultimately, agencies that are able to
invest in the implementation of the principles are likely to realize a high return on that investment
through an improved "risk profile" at their facilities, resulting in a lowering of costs associated with
regulatory compliance, health and safety, incident response, and cleanup of contaminated sites. Non-
monetary benefits, such as improved public opinion and employee satisfaction, can also be achieved.
How Does the CEMP Tie Into Other EPA Programs?
EPA has several programs that are designed to encourage creative approaches to environmental
protection. Most notable among these are Project XL and the Environmental Leadership Program
(ELP), both of which encourage Federal agency participation (McClellan AFB in Sacramento and
Puget Sound Naval Shipyard in
Bremerton, Washington
participated in the pilot phase of
the ELP). The ELP has
established the full-scale
implementation of an EMS as
one of its criteria for
participation, and evaluated the
CEMP and ISO 14001 as
background material in
developing this criterion.
Project XL also has the use of
innovative regulatory
management programs as a
required element. One major
difference between the two
programs is that the ELP seeks
to identify more efficient
operations within the existing
regulatory structure, while
Project XL will allow some
relief from regulatory
requirements if the ultimate
performance exceeds that
achievable with full compliance.
In addition, EPA's National
Enforcement Investigation
WHY DOES THE CEMP EMPHASIZE COMPLIANCE?
A basic EMS describes the managerial framework within which
environmental activities are carried out, rather than the activities
themselves The philosophy behind the EMS approach is that the
way in which a site is managed (rather than a strict focus on
outcomes) does make a difference. Most existing environmental
regulations do not address this management implementation aspect.
While EPA agrees with this approach, it does not wish to lose sight
of the fact that compliance with regulations is of paramount
importance, as well as a primary mission of the Agency.
Implementation of regulatory requirements has driven most of the
unproved environmental performance over the past quarter-century,
and the regulatory structure continues to ensure the basic level of
protection for workers, the public, and the environment. A
properly implemented EMS can provide more consistent levels of
compliance and higher levels of environmental performance,
depending upon the objectives and targets selected. Organizations
should not take the view that a few regulatory lapses are of
secondary importance to implementing the EMS. Indeed, low or
inconsistent levels of compliance can be indicative that the EMS is
not working. EPA approves of EMS implementation as a means to
identify weaknesses in an organization's approach to compliance
and to examine its internal compliance assurance process. The
EMS should not become such a weakness itself.
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Center (NEIC) has begun to require EMS elements in consent decrees with several private companies.
This approach is intended to ensure that companies with prior instances of non-compliance address the
root causes of those situations. [See Related Boxes]
MANUAL ELEMENTS REQUIRED FOR A
COMPLIANCE-FOCUSED ENVIRONMENTAL MANAGEMENT SYSTEM
IN A SETTLEMENT AGREEMENT
1. Management Policies and Procedures
a. Organization's Environmental Policy - Must clearly communicate management commitment to
environmental performance, including compliance with applicable federal, state, and local
environmental statutes and regulations, including permits (i.e., "environmental requirements").
b. Site-specific Environmental Policies and Standards
Body of general policies, rules, and procedures for environmental principles and practices.
Includes process for developing, approving, and communicating standard operating
practices for activities having potentially adverse environmental or regulatory compliance
impacts.
Clearly identifies organizational responsibilities for maintaining regulatory compliance,
including required reporting to regulatory agencies.
Includes ongoing means of communicating environmental issues and information to all
organization personnel, on-site service providers, and contractors, and receiving and
addressing their concerns.
Describes and establishes processes to ensure sustained interaction with regulatory
agencies, and within the organization (e.g., between the various divisions, contractors, and
the Environmental Control Department) regarding environmental issues and regulatory
compliance.
2. Organization, Personnel, and Oversight of EMS
a. Describes, organizationally, how the EMS is implemented and maintained.
b. Includes organization charts that identify units and individuals having environmental
performance and regulatory compliance responsibilities.
c. Identifies duties, responsibilities, and authorities of key environmental program personnel in
implementing and sustaining the EMS (e.g., could include position descriptions and
performance standards for all environmental department personnel, and excerpts from others
having specific environmental program and regulatory compliance responsibilities).
3. Accountability and Responsibility
a. Specifies accountability and responsibilities of organization's management, on-site service
providers, and contractors for environmental protection practices, compliance, required
reporting to regulatory agencies, and corrective actions implemented in their area(s) of
responsibility. Also specifies potential consequences of departure from specified operating
procedures, including responsibilities (personal and organizational) for civil/administrative
penalties imposed as a result of noncompliance.
What You Will Find in This Document
Chapter 2 summarizes federal agency responses to the CEMP, as received by EPA. Each of Chapters
3-7 is dedicated to one of the principles. The principle and its supporting Performance Objectives,
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which provide more information on the tools and mechanisms by which the principle is fulfilled, are
described in detail and several possible actions that can help an agency meet the principle are
provided. These actions are provided as guidelines to assist agencies in understanding the scope of
the principles, and as a suggested basis for planning. Agencies are not required to pursue all of these
actions, nor are they limited to them. It should be understood that, as is implicit in the EMS
approach, implementation of the principles will not be as effective if they are administered as though
they are discrete pieces of a larger program. In fact, they are so tightly interconnected that the entire
program can succeed only if the elements are fully integrated. Although clear managerial
responsibility must be assigned for each component, the system as a whole depends ultimately on
communication among the various program elements.
EMS MANUAL ELEMENTS (cont.)
4. Environmental Requirements t
a. Describes process for identifying, understanding, and communicating environmental
requirements to affected organization personnel, on-site service providers, and contractors, and
ensuring that facility activities conform to those requirements. Specifies procedures for
identifying and obtaining information about changes and proposed changes in environmental
requirements, and incorporating those changes into the EMS.
5. Assessment, Prevention, and Control
a. Identifies an ongoing process for assessing operations, for the purposes of preventing and
controlling releases, environmental protection, and maintaining compliance with statutory- and
regulatory requirements. This shall include monitoring and measurements, as appropriate, to
ensure sustained compliance. It shall also include identifying operations and waste streams
where equipment malfunctions and deterioration, operator errors, and discharges or emissions
may be causing, or may lead to, releases of hazardous waste or hazardous constituents to the
environment, or a threat to human health or the environment. Finally, process shall include
performing root cause analysis of identified problems to prevent recurring issues.
b. Describes process for identifying activities that could cause adverse environmental impacts
and/or regulatory noncompliance, and where documented standard operating practices need to
be developed [see element l.(b)].
c. Describes a system for conducting and documenting routine, objective, self-inspections by
department supervision and trained staff, especially at locations identified by the process
described in (a) above.
d. Describes process for ensuring input of environmental concerns and requirements in planning;
design; and operation of ongoing; new; and/or changing buildings, processes, maintenance
activities, and products.
6. Environmental Incident and Noncompliance Investigations
a. Describes standard procedures and requirements for incident and noncompliance reporting,
investigation; and development, tracking, and effectiveness verification of corrective and
preventive actions. The procedures shall specify testing of such procedures, where practicable.
Similarly, activities described in the context of one of the principles are often carried throughout other
principles. For example, benchmarking should be done not only in connection with daily operations,
but also in terms of information management, pollution prevention initiatives, safety and emergency
response, training, and so on. Audits will target not only what is commonly thought of as
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"environmental compliance," but also safety, emergency response, and documentation procedures.
Training and information management are integral to the successful operation of any organization.
The last chapter in this document contains a "Self-Assessment Matrix," which describes stages that an
organization may go through in implementing the principles. The Matrix shows five levels for each
of the Performance Objectives that support the principles, with a brief description of a typical
organization's accomplishments at that level. Agencies can use the Matrix and the accompanying text
EMS MANUAL ELEMENTS (cont.)
7. Environmental Training, Awareness, and Competence
a. Identifies specific education and training required for organization personnel, as well as
process for documenting training provided.
b. Describes program to ensure that organization employees are aware of its environmental
policies and procedures, environmental requirements, and their roles and responsibilities within
the environmental management system.
c. Describes program for ensuring that personnel responsible for meeting and sustaining
compliance with environmental requirements are competent on the basis of appropriate
education, training, and/or experience.
8. Planning for Environmental Matters
a. Describes how environmental planning will be integrated into other plans developed by
organizational subunits, as appropriate (e.g., capital improvements, training, maintenance).
b. Requires establishing written goals, objectives, and action plans by at least each operating
organizational subunit, as appropriate, including those for contractor operations conducted at
the facility, and how specified actions will be tracked and progress reported.
9. Maintenance of Records and Documentation
a. Identifies the types of records developed in support of the EMS (including audits and reviews),
who maintains them and where, and protocols for responding to inquiries and requests for
release of information. Specifies the data management systems for any internal waste tracking,
environmental data, and hazardous waste determinations.
10. Pollution Prevention Program
a. Describes an internal program for reducing, recycling, reusing, and minimizing waste and
emissions, including procedures to encourage material substitutions. Also includes
mechanisms for identifying candidate materials to be addressed by program and tracking
progress.
11. Continuing Program Evaluation
a. Describes program for periodic, at least annually, evaluation of the EMS, including
incorporating the results of the assessment into program improvements, revisions to the
manual, and communicating findings and action plans to affected employees, on-site service
providers, and contractors.
12. Public Involvement/Community Outreach
Describes a program for ongoing community education and involvement in the environmental
aspects of the organization's operations and general environmental awareness.
a.
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in the chapter to relate the suggested activities to the levels in the Matrix. There is no real
significance to the numbering of the levels. No scoring system is implied, although agencies are free
to track their own progress in such a manner, if they so desire. Agencies are also free to modify the
Matrix to make it a more useful tool.
EPA does not expect the CEMP to be implemented "overnight." EPA fully realizes that some
agencies, bureaus, and departments may require years to implement the CEMP. Awareness and
understanding are the necessary first steps. The CEMP, like EMS standards, includes ongoing review
and a commitment to continuous improvement, so in one sense implementation will never be
"finished."
EPA's Federal Facilities Enforcement Office (FFEO) is available to provide technical assistance to
agencies implementing the CEMP. EPA is also collaborating with the Department of Energy in
preparing a primer on environmental management systems for federal facilities. The Primer addresses
specific aspects of environmental management (e.g., pollution prevention and audits) and discusses
ways to integrate and make them more powerful within the context of an EMS. FFEO is leading
EPA's efforts on the Primer.
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CHAPTER 2: FEDERAL AGENCY RESPONSES TO THE CEMP
CEMP Development Process
On August 3, 1993, President Clinton signed Executive Order No. 12856, which pledges the federal
government to implement pollution prevention measures, and publicly report and reduce the
generation of toxic and hazardous chemicals and associated emissions. Section 4-405 of Executive
Order 12856 requires the Administrator of the Environmental Protection Agency (EPA), in
cooperation with federal agencies, to establish a Federal Government Environmental Challenge
Program. As required under the Executive Order, the Challenge program consists of three
components to challenge Federal agencies to: 1) agree to a code of environmental principles
emphasizing pollution prevention, sustainable development, and "state of the art" environmental
management programs; 2) submit applications to EPA for individual Federal facilities for recognition
as "Model Installations"; and 3) encourage individual Federal employees to demonstrate outstanding
leadership in pollution prevention.
On September 12, 1995, senior agency representatives signed the Charter for the Interagency
Pollution Prevention Task Force committing the federal government to achieve, among other items,
environmental excellence through various activities including: a) active agency and facility
participation in the Federal Government Environmental Challenge Program and, b) participation in the
establishment of an agency Code of Environmental Management Principles (CEMP). In June 1995, a
subcommittee of federal agency representatives was formed by the Task Force to work directly with
EPA in the development of the CEMP. Through this process, several drafts of the CEMP were
forwarded to federal agencies by the subcommittee for formal review and comment. The version of
the CEMP published on October 16, 1996 (61 FR 54062) represents the final version as approved by
the subcommittee and incorporates comments from members of the Interagency Task Force.
As stated in Chapter 1, EPA formally transmitted the CEMP to the federal agency executives who
had signed the Charter for the Interagency Executive Order 12856 Pollution Prevention Task Force on
September 3, 1996. In the letter accompanying the CEMP, Steve Herman, the EPA Assistant
Administrator for Enforcement and Compliance Assurance, requested written agency commitment to
the Principles contained in the CEMP and a description of their plans for implementation of the
CEMP at the facility level. EPA sought endorsement of the CEMP Principles on an agency wide
basis, with flexibility as to how the Principles themselves are implemented at the facility level. For
example, agencies could choose to directly implement the CEMP Principles at the facility level or use
another alternative environmental management system (e.g., ISO 14001). This flexible approach was
in recognition that of the fact that individual federal facilities and installations may already have
environmental management systems in place or are considering adoption of the ISO 14001
Environmental Management Standard.
Responses From Federal Agencies and Departments
As previously stated, hi September 1996 EPA requested federal agencies to provide a brief written
statement declaring the agency's support for the CEMP Principles along with a concise explanation of
how the agency plans to implement the CEMP at the facility level. Responses endorsing the CEMP
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on an agency-wide basis have been received from the 16 agencies that participated in the development
of the CEMP. A table summarizing the responses is provided in Table 1 and the copies of each
agency response are contained in Appendix 1.
Three of the responses were detailed in nature. The Postal Service, the Department of Defense
(DoD), and the Central Intelligence Agency (CIA) addressed each of the five CEMP principles as
well as the objectives of the principles, explained how the agency planned to implement the CEMP at
the facility level, and described how the agency's management system will meet the CEMP.
The Postal Service's head of Environmental Management Policy endorsed the CEMP, described its
management commitment, submitted a copy of its Policy for Environmental Protection which contains
seven guiding principles, and stated that the Postal Service is also evaluating the use of ISO 14001 as
a management system to meet the CEMP. The Postal Service described its compliance program,
discussed its Environmental Strategic Plan, and submitted its most recent annual status report which
tracks the status of the current 105 Tactical Action Plans intended to achieve compliance and
leadership. The Postal Service described its enabling systems and submitted a copy of its
environmental target areas (e.g., leadership targets and compliance targets) which provide focus and
direction for developing and implementing plans at the Area, District and Plant Levels. The Postal
Service described its performance and accountability program, and how it continuously monitors
progress and updates the Tactical Actions in its Environmental Strategic Plan to reflect many new
ideas, target areas and programs. Since Postal Service employees are accountable for environmental
objectives through the Policy for Environmental Protection, the Policy was integrated into personnel
evaluations to reinforce personnel accountability. The Postal Service also discussed its measurement
and improvement strategy, and its utilization of a concept known as Environment Information
Services and Support to gather, analyze and distribute data and information through the Postal Routed
Network to Postal environmental professionals and personnel throughout the U.S.
DoD endorsed the CEMP at the Deputy Under Secretary level, and provided the only response which
addressed all of the objectives of each CEMP principle. DoD discussed its management commitment,
and described its Environmental Security Directive which establishes environmental protection goals
and develops supporting strategies that fully complement accomplishment of DoD's overall mission.
DoD also stated that the Department is using ISO 14001 in the development of its current strategic
plan and is evaluating adoption of ISO 14001 as a management system for the entire Environmental
Security program. DoD described its compliance program hi the context of its Environmental
Security Directive and supporting instructions, and described its requirement that each installation
conduct a self audit for environmental performance at least annually. DoD described its enabling
systems in the context of the Environmental Security Directive which establishes environmental goals,
supporting strategies, budget priorities and measures of merit that support overall organizational
objectives. DoD also described its extensive environmental training program which includes military
recruit training, technical training programs, professional (officers) military education programs as
well as insertion of environmental requirements into the education programs for non environmental
professionals whose actions could affect the environment. DoD described its performance and
accountability program, and how the Environmental Security Directive establishes goals for
compliance, pollution prevention and conservation, and requires periodic reporting on progress
towards meeting these goals through measures of merit. DoD personnel regulations require that ,
major job components be identified hi job descriptions, and that evaluation criteria for the major job
components be prepared hi employee's annual work plans. Thus, persons with environmental
responsibilities are evaluated on the performance of those responsibilities and outstanding performance
Code of Environmental Management Principles 11 Implementation Guide
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by installations and individuals is recognized via an awards program. DoD also discussed its
measurement and improvement strategy which includes implementation of an automated data
management system, annual assessments of progress towards achieving the goals established by the
Environmental Security Directive, and evaluation/benchmarking of environmental operations in other
government and non-government organization which have environmental challenges similar to DoD
and CEMP. DoD efforts to improve environmental performance include establishment of hazardous
materials pharmacies at installations and ships to provide central control of purchasing, storing,
distributing and disposing of hazardous materials, resulting in reduced purchases, disposals, and
potential for violations.
The CIA's chief of Environmental Safety endorsed the CEMP, and described its management
commitment in the context of establishment of a formal environmental program in FY 1992. The
program is designed to gain compliance with environmental regulations and initiate remediation of
potential cleanup sites, and has been funded on a multiyear basis and administered by the newly
formed Environmental Safety Group. Most recently, the CIA issued an Agency Notice establishing
the CIA Pollution Prevention Policy and Goals, with a target of fifty percent reduction in the use of
toxic chemicals and a reduction in the use of extremely hazardous substances. The CIA described its
proactive compliance program which consists of annual compliance inspections of all CIA sites,
compliance audits at some sites, and provision of expert consultation and assistance to field sites to
address specific issues. The CIA described its enabling personnel including funding for
environmental compliance training programs for specialists, site managers, and selected component
personnel, and regular briefings of senior managers on the progress of the program. The CIA has
also established a Lotus Notes electronic bulletin board database which provides means to disseminate
regulatory updates to field personnel, functions as an inquiry and response forum, and serves as a
general discussion media for promoting environmental issues and policies. The CIA described its
performance and accountability program, and how all major field sites are staffed with a full-time
Environmental Safety Officer (ESO) who implements the environmental program under the direction
of the site manager. The ESOs are responsible for coordinating the environmental program among
the various tenants located at a site, and have their performance evaluations prepared annually by the
site manager and forwarded to the CIA environmental program office for review, accountability. The
CIA also discussed its measurement and improvement strategy, including annual programmatic
appraisals to assess the status of the CIA environmental program, periodic review by the CIA IG to
ensure programmatic compliance with environmental laws and regulations, and prioritization of
centrally funded resources to address deficiencies identified by the reviews/appraisals. Annual
environmental conferences are also held to assemble field ESOs to review the status of site and CIA
programs, and to discuss goals and Opportunities for improvement in areas such as pollution
prevention, affirmative procurement, waste reduction and recycling.
The remaining 13 responses endorsed the CEMP but were more general in nature. EPA is in the
process of following up with these agencies to obtain more specific information about how the
agencies plan to implement the CEMP at the facility level. The responses from the Department of
Commerce (DoC), Department of Energy (DoE), Department of Interior (Dol), Department of Justice
(DoJ), Environmental Protection Agency (EPA), and the National Aeronautics and Space
Administration (NASA) addressed the five CEMP principles in varying levels of detail. DoE, DoJ,
EPA and NASA explained in general terms how they plan to implement the CEMP at the facility
level. DoC, DoE, DoJ and EPA generally described how then- agency's management system will
meet the CEMP. DoE, Dol, and NASA indicated that their agency's are evaluating the usexrf ISO
14001 as a management system to meet the CEMP. The responses from the Department of Health
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and Human Services (HHS), Department of Transportation (DoTransp.), Department of Treasury
(DoTreas.), General Services Administration (GSA), Department of Agriculture (USDA), Veterans
Administration (VA), and Tennessee Valley Authority (TVA) addressed the CEMP principles and
how the agency's plan to implement the CEMP at the facility level in a very general way. GSA and
TVA briefly describe how their agency's management system will meet the CEMP, and DoTreas.,
indicated that it is evaluating the use of ISO 14001 as a management system to meet the CEMP.
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Table 1.
Summary of Agency Responses to Code of Environmental Management Principles (CEMP)
Agency
CIA
USDA
DoC
DoD
DoE
Dol
DoJ
DoTransp.
DoTreas.
EPA
GSA
HHS
NASA
Postal Service
TVA
VA
CEMP
endorsed on
agency wide
basis
Yes
Yes
Yes 7
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Explains plan
to implement
CEMP at
facility level
Yes
Partial
Yes
Partial
Partial
Partial
Partial
Partial
Partial
Partial
Yes
Partial
Describes how
alternative
system (e.g.,
ISO 14001)
will meet
CEMP
Yes
Partial
Yes and
evaluating ISO
14001
Partial and
evaluating ISO
14001
Evaluating
ISO 14001
Partial
Evaluating
ISO 14001
Partial
Partial
Evaluating
ISO 14001
Yes and
evaluating ISO
14001
Partial
Addresses
each CEMP
principle
Yes
Partial
Yes
Partial
Partial
Partial
Partial
Partial
Partial
Partial
Yes
Addresses the
objectives of
each CEMP
principle
Partial
Yes
Partial
Partial
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CHAPTER 3: MANAGEMENT COMMITMENT (PRINCIPLE 1)
The agency makes a written top-management commitment to improved environmental
performance by establishing policies which emphasize pollution prevention and the need to
ensure compliance with environmental requirements.
The first Principle stresses the importance of upper-level management in setting the agenda for the
agency's commitment to environmental management. Although it is possible for organizations to
adopt ideas that originate at the grassroots level, it is more likely that such ideas will be dismissed
unless they have a champion with sufficient organizational clout to advance them. Agencies can
advance the cause of environmental management by setting policies, ensuring that the environmental
system is integrated throughout the agency, and setting a clear example of long-term commitment by
articulating support for strategies that enhance environmental stewardship and sustainable
development.
PERFORMANCE OBJECTIVES:
1.1 OBTAIN MANAGEMENT SUPPORT
The agency ensures support for the environmental program by management at all levels and
assigns responsibility for carrying out the activities of the program.
Management sets the priorities, assigns key personnel, and allocates funding for agency activities.
In order to obtain management approval and support, the environmental management program
must be seen as vital to the functioning of the organization and as a positive benefit, whether it be
hi financial terms or in measures such as regulatory compliance status, production efficiency, or
worker protection. If management commitment is seen as lacking, environmental concerns will
not receive the priority they deserve.
Organizations that consistently demonstrate management support for pollution prevention and
environmental compliance generally perform at the highest levels and will be looked upon as
leaders that can mentor other organizations wishing to upgrade their environmental performance.
1.1.1 Policy Development
The agency establishes an environmental
policy followed by an environmental
program that complements its overall
mission strategy.
Management must take the lead in
developing organizational goals and
instilling the attitude that all
organization members are responsible
for implementing and improving
environmental management measures, as
POSTAL SERVICE POLICY
"The United States Postal Service is committed to
provide employees and customers with a safe and
healthy environment. Environmental protection is
the responsible thing to do and makes for sound
business practices,
"In performing its mission...the Postal Service
will conduct its activities in a manner protecting
human health and the environment,"
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POSTAL SERVICE GUIDING PRINCIPLES
well as develop criteria for evaluating how well overall goals are met. The environmental
policy will be the statement that establishes
commitments, goals, priorities, and
attitudes. It incorporates the organization's
mission (purpose), vision (what it plans to
become), and core values (principles by
which it operates). The environmental
policy also addresses the requirements and
concerns of stakeholders and how the
environmental policy relates to other
organizational policies.
1. Meet or exceed all applicable environmental laws
and regulations in a cost-effective manner;
2. Incorporate environmewal considerations into
business planning processes;
3. Foster the sustainable use of natural resources by
promoting pollution prevention, reducing waste,
recycling, and reusing materials;
4. Expect every employee to take ownership and
responsibility for environmental objectives;
5. Work with customers to address mutual
environmental concerns;
6. Measure progress in protecting the environment;
7. Encourage suppliers, vendors, and contractors to
comply with similar environmental protection
policies.
Appropriate steps to address policy
development could include:
Develop overall organizational goals and
priorities;
Prepare Mission and Vision statements
emphasizing commitment;
Communicate with stakeholders,
including regulatory agencies, to
identify needs, expectations, and
concerns.
1.1.2 System Integration
The agency integrates the environmental management system throughout its operations,
including its funding and staffing requirements, and reaches out to other organizations.
Management should institutionalize the environmental program within organizational units at
all levels and should take steps to measure the organization's performance by incorporating
specific environmental performance criteria into managerial and employee performance
evaluations, as appropriate.
Organizations that fulfill this principle demonstrate consistent high-level management
commitment, integrate an environmental viewpoint into planning and decision-making
activities, and ensure the availability of adequate personnel and fiscal resources to meet
organizational goals. This involves incorporating environmental performance into decision-
making processes along with factors such as cost, efficiency, and productivity.
As one of the main determiners of success or failure, management cannot afford to be isolated
from the strategies and activities associated with an organization-wide environmental
management program. All levels of management must be responsive to the demands of the
program, encourage initiatives to expand its effectiveness, and take proactive steps to integrate
program requirements into existing activities across the organization. Management should
also seek a leadership role for the organization in order to serve as an example to others
wishing to emulate its success. Management backing should also provide organization
members with an indication of the organization's place in the global community.
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Appropriate steps to address program integration could include:
Identify environmental liabilities and risks;
Conduct an organizational review to assist in integrating the environmental program into
all planning, organizing, implementing, and measuring processes;
Assign specific management responsibilities;
Encourage teaming across all divisions within the agency to improve communication and
teamwork;
Include environmental performance in the evaluation criteria for organizational units,
managers, and employees, as appropriate;
Coordinate and review budget requirements to ensure adequate funding to achieve goals;
Review responsibilities to ensure adequate staffing at all levels;
Assume a leadership role through involvement in outreach activities, such as professional
organizations, conferences, information exchanges, local government, and public
information sessions;
Provide awareness training to all levels of management and workers.
1.2 ENVIRONMENTAL STEWARDSHIP AND SUSTAINABLE DEVELOPMENT
The agency strives to facilitate a culture of
environmental stewardship and sustainable
development.
"Environmental Stewardship" refers to the
concept that society should recognize the
impacts of its activities on environmental
conditions and should adopt practices that
eliminate or reduce negative environmental
impacts. Every aspect of an organization's
operations, including strategic planning,
procurement, waste reduction, waste
management, water and energy usage, responses
to existing environmental problems, and land
management, must be conducted in such a way
as to limit or eliminate adverse impacts on the
environment. Government agencies, whose
national policies affect a range of complex
management decisions and who have been
entrusted with the management of the nation's
immense and diverse land and water resources,
must provide an example to others in
implementing programs of environmental
stewardship.
The President's Council on Sustainable
Development was established on June 29, 1993
by Executive Order 12852. The Council has
ECOSYSTEM MANAGEMENT
Ecosystem management is a relatively recent
development that has been adopted by several
federal agencies. The concept of ecosystem
management is a response to the recognition
of the inadequacy of the traditional resource-
management approach, which focused on
individual resources, such as water, land,
forest, wildlife, etc. It has become clear in
recent years that these seemingly separate
components are in fact highly integrated and
interdependent. Therefore, the federal
government is attempting to tailor its
management responsibilities to entire
ecosystems, many of which range across
legislatively or administratively defined
boundaries. It is believed that encouraging
consideration of these complex and dynamic
systems as complete entities will provide a
more coherent framework for resource
management and protection, reduce
administrative conflict, and better address
declining ecological conditions. This
approach will require significant interaction
and coordination with state and local
authorities and private landowners.
Code of Environmental Management Principles
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adopted the definition of sustainable development as: "meeting the needs of the present without
compromising the ability of future generations to meet their own needs." The concept was
developed to provide insight into the way in which natural resources and systems (rainforests,
atmospheric conditions, natural water bodies, etc.) are integrated within the environment and how
that relationship is affected by the use of the resources. It is hoped that this understanding will
lead to a new level of consciousness in which use of natural resources is limited to identifiable
needs, original conditions are restored as much as possible, and waste material is managed in an
environmentally friendly manner, all of which will
help to ensure the presence of these resources for
future generations.
INTERAGENCY COOPERATION IN
ECOSYSTEM MANAGEMENT
Fourteen federal agencies came together to sign
the "Memorandum of Understanding to Foster
the Ecosystem Approach" (December 15,
1995). The MOU defines the Ecosystem
Approach as:
a method for sustaining or restoring
ecological systems;
goal driven;
based on a vision of desired future
conditions that integrates ecological,
economic, and social factors;
applied within a geographic framework
defined primarily by ecological boundaries.
The goal of the Ecosystem Approach is to
"restore and sustain the health, productivity,
and biological diversity of ecosystems and the
overall quality of life through a natural
resource management approach that is fully
integrated with social and economic goals."
The signatories agree that federal agencies
should
* provide leadership in and cooperate with
activities that foster the Ecosystem
Approach;- ; -.i?r.-..V :; ,. ., v::-.;-:V :'.;.:
ensure that they utilize their authorities in a
way that facilitates the Ecosystem
'
.
administer their programs in a manBer that
is sensitive to the neete ami rights of
landowners, local communities, and the
. . ,
work with landowners, local communities,
and the public to achieve common goals.
Responsible environmental management should be
one of the main pillars of the organization, not an
ancillary concern or afterthought. Personnel at all
levels need to be "on the same page" when it
comes to environmental issues. In order to
generate this level of awareness, personnel need
to have some understanding of environmental
issues, how they are related to the organization's
activities, and the consequences of inaction or
negative action. Where possible, the organization
should attempt to supplement information on
specific regulatory, compliance, or management
concerns by providing a global perspective in its
presentation of environmental issues that
encompasses concepts such as sustainable
development and ecosystem management. The
organization's culture should be extended to draw
in the surrounding community, in which personnel
are likely to reside.
An organization's commitment to environmental
stewardship and sustainable development would be
demonstrated through implementation of several
of the CEMP Principles and their respective
Performance Objectives. For example, by
implementing pollution prevention and resource
conservation measures (see Principle 2,
Performance Objective 2.3), the agency can
reduce its negative environmental impacts
resulting directly from its facilities. In addition,
by including the concepts of environmental
protection and sustainability in its policies, the
agency can help develop the culture of
environmental stewardship and sustainable
development not only within the agency but also
to those parts of society that are affected by the
agency's activities.
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Appropriate steps in creating a culture of environmental stewardship could include:
ECOSYSTEM CASE STUDIES
The mteragency Ecosystem Management Task
Force has conducted case studies in seven areas
facing extreme environmental stress:
Anacostia River watershed;
Coastal Louisiana;
Great Lakes basin;
Pacific Northwest forests;
Prince William Sound;
South Florida; and
^Southern Appalachians.
Provide orientation describing the
program for all personnel;
Encourage each organizational group to
prepare an environmental action plan,
which will describe the steps the group
will implement to improve
environmental performance and what
will be achieved;
Introduce the concepts of life-cycle
analysis and design for the environment
to the agency, focusing on groups with
responsibilities in potentially affected
areas (e.g., procurement or
engineering);
Provide outside speakers describing
issues of environmental concern and how they relate to the agency;
Provide in-house "brown bag" speakers from various aspects of the agency describing their
responsibilities;
Create newsletters and other promotional items describing the progress of the program and
how it benefits the agency;
Encourage organizational sponsorship of outside activities with environmental content, such as
"Clean up days" or school visits;
Promote "Open House" days for the local community;
Participate in local government hearings and other activities;
Implement a program that demonstrates commitment to sustainable development and
renewable resources by planting trees or other such activity;
Incorporate evaluations of environmental implications of proposed activities into decision-
making processes.
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CHAPTER 4: COMPLIANCE ASSURANCE AND POLLUTION
PREVENTION (PRINCIPLE 2)
The agency implements proactive programs that aggressively identify and address potential
compliance problem areas and utilize pollution prevention approaches to correct deficiencies and
improve environmental performance.
The second Principle addresses what might be considered the core of environmental management.
Whatever an agency's approach to environmental management, it must always meet the obligation of
compliance with regulations. The CEMP is intended to help agencies more easily meet this obligation
and expand their vision "beyond compliance." Aggressive pollution prevention strategies will also be
central to maintaining compliance, improving environmental performance, reducing risks, and cutting
costs. Preparation for emergency situations can also help avoid breakdowns in compliance and
pollution control.
PERFORMANCE OBJECTIVES:
2.1 COMPLIANCE
ASSURANCE
The agency institutes support
programs to ensure compliance
with environmental regulations
and encourages setting goals
beyond compliance.
Implementation of an
environmental management
program should be a clear signal
that non-compliance with
regulations and established
procedures is unacceptable and
injurious to the operation and
reputation of the organization.
Satisfaction of this performance
objective requires a clear and
distinct compliance management
system as a component of the
agency's overall environmental
management system.
All personnel, beginning with
management, must understand
that the objective of a
compliance program is not to set
up obstacles that prevent
COMPLIANCE ASSURANCE...
Environmental compliance can be a sensitive subject, and not
one that many organizations eagerly address. Environmental
regulations have been characterized by some as unnecessary,
burdensome, overly costly, stifling of creativity, and
ineffective. Federal facilities, which were not a primary focus
of many of the environmental statutes but have come under
their jurisdiction, may consider these descriptions particularly
appropriate.
However, EPA and other regulatory agencies weigh the
societal benefits of regulation against the societal burden of
compliance, taking into account the best available scientific
information. Admittedly, it can be difficult to assign a dollar
figure to improved air or water quality, and many issues are
not easily resolved by science, such as die effects of dioxins
on living tissue.
The lack of an underlying regulatory structure can be seen in
die legacy of contamination at CERCLA sites and many
Federal facilities. Compliance with regulations must be a core
value of any organization. Federal agencies, which are
endowed with the public trust, should give no more thought to
violating environmental rules than they would to distributing
sensitive information or disregarding contracting, procurement,
and other financial requirements.
Code of Environmental Management Principles
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meaningful work from being accomplished, but
...AND "BEYOND COMPLIANCE"
Supporters of Environmental Management
Systems and other "quality" approaches to
environmental management often speak of the
need to go "beyond compliance." What does
this mean? Are there different levels of
compliance, rather than just "in" or "out of"
compliance? What can be found "beyond
compliance"?
"Beyond compliance" is recognition that much
of the activity that falls under environmental
programs is driven by regulations. Permits are
requested, forms are filled out, reports are
filed, to comply with regulation. But accepting
compliance as a core value doesn't preclude
looking for ways to make it easier, less costly,
and less pervasive.
Although an EMS is a management system, not
a compliance system, the benefit of an EMS is
that it forces a look at all activities that can
have an environmental impact and provides an
integrating structure for supporting activities
that are not strictly environmental in nature,
such as training and documentation. This
"holistic" approach provides a context in which
the core of compliance can incorporate the
organization mission and vision. It encourages
participation at all levels to improve and
coordinate management, rather than a "do this
because it's required" directive.
A 1993 survey of six major corporations found
that facilities spent more on compliance than on
pollution prevention, but would rather have the
ratio heavily weighted toward pollution
prevention (Source: Business Roundtable). A
"beyond compliance" approach can help to
reallocate resources to priority areas without
sacrificing compliance. "Beyond compliance"
also includes working with regulators to form
mutually beneficial partnerships, rather than
approaching them as adversaries.
to guide the organization through complex and
often uncertain terrain to the successful
completion of tasks. Early incorporation of a
compliance perspective will prevent unpleasant
and costly surprises later in a project's schedule.
The environmental management program must
also encourage forward-thinking to go beyond
simple compliance, as the organization will be
constantly playing catch-up to meet stricter
standards. For example, the agency should stress
the importance of the environmental compliance
performance of its outside contractors and
suppliers, perhaps by encouraging (and eventually
requiring) their adherence to a specified set of
environmental management principles.
An agency that fully incorporates the tenets of this
principle demonstrates maintainable regulatory
compliance and addresses occasions of non-
compliance swiftly and efficiently. It also has
established a proactive approach to compliance
through tracking and early identification of
regulatory trends and initiatives and maintains
effective communications with both regulatory
authorities and internally to coordinate responses
to those initiatives. It also requires that
contractors demonstrate their commitment to
responsible environmental management and
provides guidance to meet specified standards.
Appropriate steps to ensure compliance could
include:
Develop an independent compliance group,
with clear assignment of responsibility and
appropriate authority;
Review organizational activities in the context
of Federal, state, and local regulations;
Assess compliance status to establish a
baseline (performing compliance audits can
help with this step);
Establish a compliance management system
that is integrated with the overall
environmental management system;
Track regulatory initiatives to identify future
compliance issues;
Hold information sessions to explain the
purpose and function of the compliance group;
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Develop guidance for operations to maintain compliance;
Inform and coordinate with regulatory authorities as necessary;
Evaluate the environmental and safety performance of outside contractors;
Develop a program that encourages employees to report knowledge of environmental
violations, departures from procedure, or criminal conduct, and that maintains employee
confidentiality;
Take immediate action to address conditions identified as giving rise to incidents resulting in
non-compliance;
Plan, track, schedule, and report on corrective actions;
Develop procedures to elevate compliance issues to upper management, when necessary.
Appropriate steps to move beyond compliance could include:
Make pollution prevention the primary approach for addressing environmental issues;
Implement an effective system to keep environmental recordkeeping up-to-date;
Utilize quality management tools and procedures to identify potential problems and prevent
incidents resulting in non-compliance;
Develop regular contacts with regulatory authorities to proactively identify and prepare for
future compliance issues;
Ensure that information on applicable regulations and permit limitations is communicated and
understood;
Set performance goals that improve upon compliance standards;
Introduce risk assessment considerations into compliance situations, where appropriate.
2.2 EMERGENCY PREPAREDNESS
The agency develops and implements a program to address contingency planning and emergency
response situations.
Emergency preparedness is not only required by law, it is good business. Properly maintained
facilities and trained personnel will help to limit property damage, lost-time injuries, and process
down time. Personnel should understand the use of fire extinguishers and other such equipment
and know whom to call, where to go, what to do, and (most importantly) what not to do.
Simulated spill-response and other such exercises are invaluable hi limiting damage due to "upset
conditions." In addressing the environmental consequences of spills and other incidents,
procedures should incorporate an understanding of concepts such as ecosystem management that
can be applied to limit damage.
The emergency response program will also be the most likely mechanism for integrating the
environmental program with the organization's operational health and safety procedures. Sound
worker safety practices will help to limit situations that could result in environmental damage as
well as worker injuries.
Commitment to this principle is demonstrated by the institution of formal emergency-response
procedures (including appropriate training) and the appropriate links between health and safety
programs (e.g., medical monitoring for federal employees performing hazardous site work).
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Appropriate steps in development of an emergency preparedness program could include:
Develop procedures to address accidents, fires, spills, meteorological, seismological,
radiological incidents, etc.;
Develop a disaster preparedness plan that details procedures to be followed at all of the
agency's facilities;
Identify hazards associated with the activities of the agency and its facilities (e.g., chemicals,
equipment, transportation);
Devise appropriate measures to address and mitigate identified hazards (risk management),
and coordinate these measures with generic procedures;
Implement a preventive maintenance program for all equipment;
Identify an Emergency Management Team (EMT), with clear managerial responsibility;
Provide appropriate training for the EMT and other personnel;
Conduct exercises on a regular basis;
Develop an in-house program that provides medical monitoring ror "high-risk" employees and
emergency treatment services as appropriate;
Coordinate with local fire, law enforcement, and medical authorities;
Develop a communication plan that outlines the coordination with local fire, law enforcement,
and medical authorities;
Identify available resources during emergency situations including lines of authority (e.g.,
emergency procurement
authority) for responding
to and mitigating
emergency situations.
2.3 POLLUTION
PREVENTION AND
RESOURCE
CONSERVATION
The agency develops a
program to address pollution
prevention and resource
conservation issues.
An organization with a
fully-developed pollution
prevention program
ultimately can save time and
money, and reduce its
liability. Use of
environmentally-friendly
materials is also friendly to
the organization's reputation
and reinforces the idea that
the organization is a
responsible citizen.
POLLUTION PREVENTION TOOLS
As interest in pollution prevention grows, and organizations look to
move beyond the "low-hanging fruit," it becomes increasingly
important to find ways to evaluate the potential benefits of
competing approaches. Two such tools are Life Cycle Analysis
(LCA) and Total Cost Assessment (TCA).
Life Cycle Analysis generally focuses on the environmental
aspects of a specific product (although it could be applied to
processes or services) over its lifetime. LCA looks at each stage
from raw material through production, use, and disposal. Inputs to
the analysis include energy use, waste generation, emissions, and
releases from each stage.
Total Cost Assessment focuses on the economics of a given
situation, including costs related to environmental variables. For
example, TCA might compare the cost of retrofitting to address
increased emissions with die cost of additional waste treatment and
disposal for two alternatives.
A number of publications give further detail on LCA and TCA. A
starting point for Federal agencies could be Federal Facility
Pollution Prevention Project Analysis: A Primer for Applying Life
Cycle and Total Cost Assessment Concepts, EPA 300-B-95-008,
July 1995.
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Reducing exposure to toxics through material substitution or process modifications and
improvements also benefits employee health and can improve morale. Although source reduction
should be the primary focus of pollution prevention, recycling and reuse programs should also be
aggressively pursued and promoted.
NATIONAL PERFORMANCE REVIEW
In 1993, the National Performance Review
examined the Federal role in environmental
protection and degradation. Specifically, the
NPR looked at ways to improve the Federal
ability to:
promote sustainable economic development;
prevent environmental degradation;
reduce costs; and
maintain the long-term health of the nation's
ecological systems.
The NPR made four specific recommendations in
two broad areas (see related boxes).
In order to be fully effective, pollution
prevention programs must be integrated
throughout the organization's activities. All
personnel should be encouraged to identify
additional opportunities for pollution prevention
initiatives. Energy conservation efforts can
often be paired effectively with pollution
prevention concerns, as can parallel programs to
identify conservation opportunities for water and
other resources. The pollution
prevention/resource conservation program can
be employed as a strong indicator of the
organization's commitment to sustainable
development. Incorporation of concepts such as
life-cycle analysis and total cost assessment can
help to identify preservation or conservation
opportunities.
An organization committed to pollution prevention has a formal program describing procedures,
strategies, and goals. In connection with the formal program, the most advanced organizations
have implemented policy that encourages employees to actively identify and pursue pollution
prevention and resource conservation measures, and instituted procedures to incorporate such
measures into the formal program. Resource conservation practices would address the use by the
agency of energy, water, and transportation resources, among others. Greater efficiency in using
natural resources will also help to cut pollution (e.g., lowered emissions from power generation
and vehicles, lessened need for wastewater treatment) and related costs. Pollution prevention
policies and practices should follow the environmental management hierarchy prescribed in the
Pollution Prevention Act of 1990
[Figure 2]: 1) source reduction; 2)
recycling; 3) treatment; and 4) disposal.
Section 3-301(b) of Executive Order
12856 requires the head of each federal
agency to make a commitment to
utilizing pollution prevention through
source reduction, where practicable, as
"the primary means of achieving and
maintaining compliance with all
applicable federal, state and local
environmental requirements." Making
this critical link between pollution
prevention and compliance assurance is
the key to achieving and maintaining a
Pollution Prevention Act
Environmental Management Hierarchy
Figure!
Code of Environmental Management Principles
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"beyond compliance" state. An integrated environmental management system can help agencies
make this link.
It is equally important to understand the link
between pollution prevention and resource
conservation, and the cyclical nature of this
relationship. For example, agriculture has
been identified as a principal source of
non-point source water pollution, mainly
through run-off that increases sedimentation
in waterways and deposits large amounts of
pesticides, nitrates, phosphates, and other
compounds. The soil's productive capability
is diminished and water quality degraded,
with the result that greater amounts of
pesticides and fertilizers are needed to
maintain crop yields, and water supplies
may eventually be unsuitable for irrigation
(e.g., through increased salinity). However,
more strategic approaches to irrigation that
reduce run-off can both reduce water usage
and preserve water quality, while maintaining
NPR RECOMMENDATIONS
Improve Implementation of Environmental
Management
1.
2.
Improve Federal Deasionmaking Through
Environmental Cost Accounting - use of tools
such as Life Cycle Analysis and Total Cost
Assessment, discussed earlier, is increasing
among Federal agencies. A number of
software packages have also been developed
to address this issue.
Develop Cross-Agency Ecosystem Planning
and Management - the "MOU to Foster the
Ecosystem Approach," described under
Principle 1, demonstrates progress in this
area.
greater amounts of productive soil.
Similarly, new techniques are being employed to reduce the impacts of pesticide usage and
livestock management. Integrated pest management approaches that utilize both biological
(breeding pest-resistant strains, selective
introduction of pest predators) and strategic
planting (crop rotation, tuning of planting,
removing land from production for a period)
methods can decrease reliance on chemical
pesticides. Prevention of livestock waste
material is not a realistic goal, but it can be
appropriately managed to lessen
environmental impacts. Another approach
is to encourage the growth of natural
vegetation along waterways to act as a
natural filter for run-off, to act as a barrier
that prevents livestock from directly
contaminating the water, and to help absorb
greenhouse gases produced by livestock and
through clearing of land. Resource
conservation strategies should be consistent
with the agency's approach to environmental
stewardship and sustainable development
(see Principle 1).
NPR RECOMMENDATIONS (cont.)
Improve Environmental Performance at Federal
Buildings and Facilities
3. Increase Energy and Water Efficiency - Executive
Order 12902 calls for Federal buildings to use
30% less energy, become 20% more energy
efficient, increase use of renewable energy
sources, incorporate water conservation goals,
and undertake energy and water audits.
Increase Environmentally and Economically
Beneficial Landscaping - the President issued a
"Memorandum on Environmentally Beneficial
Landscaping" (April 26, 1996) directing Federal
agencies to use regionally native plants, minimize
adverse effects on native habitat, use integrated
pest management practices, and use water-
efficient landscaping practices.
4.
A number of initiatives over the past several years have boosted federal agency participation in
pollution prevention and resource conservation activities. Many originate from agency missions,
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such as EPA's 33/50, Energy Star, and Green Lights programs, the Department of Energy's
Federal Relighting Initiative, and the New Technology Demonstration Program, which is
sponsored by DOE and the Department of Defense through the Strategic Environmental Research
and Development Program (SERDP). Others arise from statute or directive, such as Executive
Order 12856, which requires federal agencies to develop facility-wide pollution prevention plans
and report releases and transfers of toxic chemicals to the Toxic Release Inventory (TRI), and
Executive Order 12902, which sets targets for reducing energy use and increasing energy
efficiency in federal buildings, encourages use of renewable energy sources, and requires Federal
agencies to evaluate opportunities for water conservation and develop plans for comprehensive
energy and water audits at their facilities.
Appropriate steps in developing a pollution prevention/resource conservation program could
include:
Implement a program to identify and evaluate pollution prevention opportunities that
emphasizes source reduction as the policy and practice of first choice;
Implement a program to identify and evaluate energy conservation opportunities;
Implement a program to identify and evaluate opportunities to conserve other resources, such
as water;
Implement an affirmative procurement program to address use of recycled-content materials;
Identify and implement opportunities to reduce the use of toxic materials;
Perform life-cycle analyses to assess overall environmental impacts;
Incorporate design for the environment principles into activities, as appropriate;
Implement a system of product stewardship;
Implement a "Repair or Replace" program to track the condition of capital equipment;
Institute recycling programs for glass, plastic, aluminum, cardboard, paper, and other waste
streams;
Encourage reuse of paper and other materials.
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CHAPTER 5: ENABLING SYSTEMS (PRINCIPLE 3)
The agency develops and implements the necessary measures to enable personnel to perform
then* functions consistent with regulatory requirements, agency environmental policies, and its
overall mission.
The third Principle concerns the underlying or supporting functions for an environmental management
system. These functions are generic in the sense that they support any type of management system,
but are critical to the system's effectiveness and success. Functions falling under this Principle
include training, operating procedures, technical standards, goal-setting, communication, information
management, and documentation.
PERFORMANCE OBJECTIVES:
3.1 TRAINING
The agency ensures that personnel are fully trained to carry out the environmental responsibilities
of their positions.
Comprehensive training is crucial to the success of any enterprise. People need to know what
they are expected to do and how they are expected to do it. Organizations that attempt to save
time or money by limiting training often exceed those savings through non-compliance, rework,
remediation of contaminated sites, or lost-tune injuries. Trained personnel are better able to
understand the processes for which they are responsible and are therefore more likely to offer
suggestions to improve those processes.
Training for those expected to oversee the environmental management program must receive equal
priority with training for those whose functions are central to the organization's primary mission.
However, training hi environmental subjects should not be limited to those directly involved with
the program, but should be extended to all employees as appropriate. For example, an
environmental training program may take a three-phase approach: 1) awareness training to
introduce all employees to the environmental program; 2) mandatory training for personnel
directly involved with the program (e.g., RCRA 262, 264, 265 and/or OSHA 40-hour training);
and 3) skills training for personnel operating equipment or for other specific tasks. Refresher
training offered on a regular basis is also an important component of any training program.
An organization will be operating at the highest level when it has an established training program
that provides instruction to all employees sufficient to perform the environmental aspects of their
jobs, tracks training status and requirements, and offers refresher training on a periodic basis.
Appropriate steps hi development of a training program could include:
Develop a "Core Curriculum" that is required of all personnel;
Identify additional job-specific training requirements;
Determine availability of outside training vs. desirability of "in-house" training;
* Establish an in-house training group to be responsible for tracking the program;
Code of Environmental Management Principles 27 Implementation Guide
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Train the trainers, if necessary;
Establish periodic refresher training (e.g., 8-hour vs. 40-hour OSHA training);
Develop methods to obtain feedback from employees and assess the effectiveness of the
training;
Investigate alternative training methods, such as computer-based or video conference training;
Encourage continuing education for employees, such as seminars, trade shows, and college
courses.
3.2 STRUCTURAL SUPPORTS
The agency develops and implements procedures, standards, systems, programs, and objectives
that enhance environmental performance and support positive achievement of organizational
environmental and mission goals.
Clear procedures, standards, systems, programs, and short- and long-term objectives must be in
place for the organization to fulfill its vision of environmental responsibility. The commitment to
responsible environmental management should be prominent within the organization's Mission and
Vision statements. The interrelationship and interdependence of environmental concerns with all
other activities needs to be spelled out in such a way as to infuse the organization with
environmental consciousness. It must also
be clear how the organization's method of
operation will help to support the concept of
environmental stewardship.
A streamlined set of procedures, standards,
systems, programs, and goals that describe
and support the organization's commitment
to responsible environmental management
and further the organization's mission
demonstrate conformance with this
principle.
Appropriate steps in developing clear
organizational documentation could include:
Review organizational documentation
for clarity, conciseness, conflict, and
redundancy;
Eliminate or revise procedures,
standards, systems, programs, and goals
determined to be barriers to
organizational goals;
Encourage constructive input from all
personnel;
Pursue integration of the environmental
program throughout the agency;
Conduct periodic review of procedures, etc.
WEAVING THE WEB INTERNALLY...
Many organizations are using the World Wide
Web (WWW) to disseminate environmental and
other information to the people who cany out
their missions. Most federal agencies have a
presence on the Web, many with very
sophisticated links to information of interest.
EPA, for example, uses its EnviroSen$e pages to
describe EPA programs and policies, provide
points of contact, and point to environmental
information provided by other agencies and the
private sector. EPA's Enviro$en$e is available
on the Web at www.epa.gov/envirosense.
Agencies use their Web pages to post bulletins,
notices on meetings, reports on internal task
forces, etc. Some post electronic versions of
internal directives, technical standards, and
procedures (e.g., audit protocols). In this way,
personnel across the agency can be sure that they
have the most current version of a document, and
that it is the same version used by other agency
to ensure currency.
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3.3 INFORMATION MANAGEMENT, COMMUNICATION, DOCUMENTATION
The agency develops and implements systems that encourage efficient management of
environmentally-related information, communication, and documentation.
Information management, communication, and documentation are necessary elements of an
effective environmental management program. The need for advanced information management
capabilities has grown significantly to keep pace with the volume of available information to be
sifted, analyzed, and integrated. The ability to swiftly and efficiently digest data and respond to
rapidly changing conditions can be key to the continued success of an organization. For example,
an integrated information management system may be used to track process requirements,
procedures, measurements, compliance standards, and compliance status. The effects of process
changes can be followed and incidents resulting in non-compliance quickly rectified. Generation
of reports is also greatly simplified, reducing demand on time, personnel, and financial resources.
Many private and public organizations have taken advantage of the explosion in networking
capabilities to make information available through the Internet (particularly the World Wide
Web), organization intranets (internal networks that utilize Internet technologies), and other
commercial group software packages. Figure 3 offers a conceptual depiction of the multiple
Federal Agency
Environmental Compliance
Management System
Superfund Sites
Audits and
Inspections
Site Summary
* Summary
Figure 3
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sources of environmental information that can be maintained, coordinated, and combined through
sophisticated information management using such technologies.
Information management capabilities include not only hardware and software concerns, but also
people who are able to understand the information, draw informed conclusions, and make
intelligent decisions and recommendations. Integrating information management capabilities
throughout the organization will help to ensure that no part of the organization is left behind. A
drawback to rapid technological advances, such as those exemplified by the use of the Internet, is
that they tend to create "tiers" within organizations. At the top of the organization are the
traditional decision-makers, who
obtain the bulk of their information
through briefings, status reports,
and assignments to staff that have
specific information-gathering
functions. These people will
...AND WITH STAKEHOLDERS
Agencies also find the Web helpful in communicating with
stakeholders. As an example, DOE has made available large
amounts of information related to its investigations of Human
Radiation Experimentation (HREX). Electronic public-access
information areas can save agencies the resources that would
be necessary to generate and distribute thousands of pages of
text that must be continually updated. Special care must be
taken, however, to ensure that sensitive information is
properly excised before making it available.
Agencies can also fulfill much of their public assistance
responsibilities electronically. For example, both the DOE
Pollution Prevention Information Clearinghouse (EPIC) and
EPA's EnviroSenSe pages provide the public with information
on pollution prevention, energy efficiency, and other
environmental assistance information through case studies,
reports, event calendars, notices of newly available documents,
etc. Under EPA's EnviroSenSe, the Federal Facilities
Environmental Leadership Exchange (FFLEX) provides
pollution prevention strategies and other information of interest
to die public sector. Similarly, although not environmentally-
related, the Internal Revenue Service offers downloadable tax
forms, electronic technical assistance, and electronic filing.
EPA's EnviroSenSe is available on the World Wide Web at
www.epa.gov/envirosense.
generally continue to receive
information through these
specialized channels.
The next tier is often the sectional
or line managers, who may be
responsible for reports or briefings
to top management, but are also
responsible for some level of daily
operations. These people often find
that rapid technological advances
can make their functions more
difficult, at least initially. They find
that the people they are managing
are using unfamiliar technologies in
ways they don't understand, while
their "tried and true" methods of
gathering and evaluating information
are being phased out or are
suddenly seen as inadequate. Their
survival may depend on how quickly
they can adapt to the new
technology.
The third tier consists of personnel who are at the "cutting edge" of technological advances,
whether they are responsible for development and implementation or simply use the technology in
their daily activities. The people at this level will ultimately determine how widely a technology
is adopted by demonstrating its value in meeting the needs of the organization. The lowest tier
generally consists of personnel who do not have access to the technology, such as people in
remote field offices or very old buildings. Their ability to function may be severely hampered.
Agencies need to be aware of this "tiering" effect and take steps to address it in order to maintain
smooth operations to the extent possible.
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Effective communication allows coordination among the various parts of the organization, ensures
that activities are more clearly focused, enhances consistency, and limits duplication of effort.
Complete documentation and recordkeeping improves regulatory compliance efforts, clarifies
responsibilities, and enhances tracking of processes.
Organizations adopting this principle have developed a sophisticated information gathering and
dissemination system that supports tracking of performance through measurement and reporting.
They also have an effective internal and external communication system that is used to keep the
organization informed regarding issues of environmental concern and to maintain open and
regular communication with regulatory authorities and the public. Those organizations operating
at the highest level ensure that employees have access to necessary information and implement
measures to encourage employees to voice concerns and suggestions.
Appropriate steps in developing information management, communication, and documentation
capabilities could include: "
Information Management:
Assign managerial responsibility for information management;
Create an in-house group to identify equipment needs, new developments, and trends in
information management;
Review current capabilities to determine whether they are sufficient to meet expected needs;
Streamline and integrate existing technology to ensure that all personnel have compatible
capabilities;
Develop procedures for evaluating new information management projects;
Assign a "shepherd" (project point of contact) for each new initiative;
Develop procedures for collection, management, and dissemination of information obtained
through the environmental program (routine reports and audits);
Establish a Resource Center that includes regulations, guidance documents, and other
publications relating to environmental management;
Implement the use of electronic networks including on-line databases and libraries (see Figure
3);
Identify key environmental records and documents to be managed and inventoried;
Develop procedures to assure validity of environmental data;
Develop secure procedures for handling, manipulating, and maintaining environmental data;
Develop methods to employ environmental management system data in strategic decision
making.
Communication:
Develop a clearly delineated organizational structure indicating desired lines of
communication;
Assign each organizational group a "shepherd" within the environmental program to act as the
group's point of contact on the environmental program;
Develop efficient in-house communication through the use of voice mail, electronic mail, and
inter-office mail;
Provide regular status updates on organizational activities through the use of newsletters,
electronic bulletin boards, etc.;
Provide a "shepherd" (project point of contact) for each major initiative;
Develop a formal system to allow personnel to anonymously communicate (without fear of
Code of Environmental Management Principles 31 Implementation Guide
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retribution) environmental concerns to upper levels of management for resolution;
Develop a communication network with other organizations (both public and private), as
appropriate; '
Develop a public outreach program that can encourage public participation, where
appropriate;
Develop channels to encourage cooperation, commitment, and solicit employee environmental
concerns;
Develop a communications network to report environmental performance to stakeholders and
that can address compliance and emergency response situations;
Ensure that effective working relationships exist between environmental staff of headquarters
and field units as well as between staff and line personnel whose responsibilities directly
impact environmental performance.
Documentation:
Develop a centralized filing system;
Develop an appropriate distribution network for documents;
Develop procedures for completion of all reports;
Develop quality assurance and security procedures for documentation;
Maintain documentation on the properties of materials used by the organization, such as
Material Safety Data Sheets (MSDS).
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CHAPTER 6: PERFORMANCE AND ACCOUNTABILITY (PRINCIPLE 4)
The agency develops measures to address employee environmental performance, and ensure full
accountability of environmental functions.
The fourth Principle concerns the need to lay out the organizational structure and lines of
responsibility for the environmental system. Without a clear structure showing who's in charge and
who's accountable for getting things done, the system components won't mesh as well as they should
and the benefits of the system will be reduced. Putting expectations into individual performance
standards is one way to ensure that people are aware of their responsibilities.
PERFORMANCE OBJECTIVES:
4.1 RESPONSIBILITY, AUTHORITY AND ACCOUNTABILITY
The agency ensures that personnel are assigned the necessary authority, accountability, and
responsibilities to address environmental performance, and that employee input is solicited.
At all levels, those personnel designated as responsible for completing tasks must also receive the
requisite authority to carry out those tasks, whether it be in requisitioning supplies or identifying
the need for additional personnel. Similarly, employees must be held accountable for their
environmental performance. Employee acceptance of accountability is improved when input is
solicited. Encouraging employees to identify barriers to effective performance and to offer
suggestions for improvement provides a feeling of teamwork and a sense that they control their
own destiny, rather than having it imposed from above.
Appropriate steps in addressing responsibility issues could include:
Assign specific individuals who are senior management or above at the agency the authority to
ensure compliance with established environmental standards and procedures;
Issue clear statements defining
responsibilities for personnel and groups
within the agency that are directly
involved in the environmental program
(these statements should tie into the
agency's mission and vision statements
that stress the importance of
environmentally responsible operation);
REWARDS...
"Four of 17 {Civilian Federal Agencies] reported
the use of award programs to recognize employee
environmental achievements. Expanding the use
of these programs is needed, and may be a
. ,_F. relatively easy way for CFAs to begin to improve
Issue, as necessary, statements defining performance. .
the authority for carrying out assigned
EPA EMS Benchmark Report, December 1994
responsibilities;
Prepare a process for addressing
conflicting spheres of authority;
Develop a policy detailing the agency's
approach to accountability;
Develop a program to solicit employee input and address concerns.
Code of Environmental Management Principles 33 Implementation Guide
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4.2 PERFORMANCE STANDARDS
The agency ensures that employee performance standards, efficiency ratings, or other
accountability measures, are clearly defined to include environmental issues as appropriate, and
that exceptional performance is recognized and rewarded.
A major barrier to efficient operation is a lack of specificity regarding employee expectations.
Therefore, performance criteria relating to environmental practices should be specifically
incorporated into employee evaluations, and employees should be rewarded for satisfying or
exceeding those criteria. Performance incentives give people the feeling that their contributions
are important. Employees who feel valued pay more attention to their work and perform at a
higher level. As noted above, providing employees with avenues for constructive input, and the
expectation that they will provide such input, spreads an attitude of ownership. In addition, the
agency's written policies defining standards and procedures to be followed by its employees must
be consistently enforced through appropriate disciplinary mechanisms.
....AND PITFALLS...
...to be avoided in developing performance
incentives or awards. Some management experts
believe that incentives simply cannot work in any
meaningful way. How can this be true? Some
objections are mat incentives:
do not motivate beyond short-term
compliance;
don't differ from punitive management;
can harm relationships;
don't address root causes;
impede management's ability to manage;
discourage creativity;
undermine intrinsic motivation.
Agencies developing incentive or awards
programs need to give careful thought to the
outcomes they want to encourage, not just
behaviors.
Organizations that identify specific
environmental performance measures (where
appropriate), evaluate employee performance
against those measures, take appropriate
disciplinary action when agency procedures are
violated, and publicly recognize and reward
employees for excellent environmental
performance through a formal program
demonstrate conformance with this principle.
Appropriate steps in developing performance
evaluations could include:
Identify appropriate organizational
performance goals;
Develop standards upon which employee
evaluations will be based;
Publicize and solicit input from the agency;
Develop procedures for evaluating
performance;
Prepare a program to reward or recognize
honorees;
Prepare disciplinary mechanisms to be
utilized when agency policy and procedures
are not followed.
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CHAPTER 7: MEASUREMENT AND IMPROVEMENT (PRINCIPLE 5)
The agency develops and implements a program to assess progress toward meeting its
environmental goals and uses the results to improve environmental performance.
The fifth Principle addresses the "feedback" aspect that is critical to any system and the importance of
collecting internal and external information on system performance. When the agency can judge how
well the system is working, it can also identify steps to improve the system. The measurement-
improvement cycle is continuous for the life of the system.
PERFORMANCE OBJECTIVES:
5.1 EVALUATE PERFORMANCE
i
The agency develops a program to assess environmental performance and analyze information
resulting from those evaluations to identify areas in which performance is or is likely to become
substandard.
Measurement of performance is necessary to understand how well the organization is meeting its
stated goals. Businesses often measure their performance by such indicators as net profit, sales
volume, or production. Two approaches to performance measurement are discussed below.
5.1.1 Gather and Analyze Data
The agency institutes a systematic program to periodically obtain information on
environmental operations and evaluate environmental performance against legal requirements
and stated objectives, and develops procedures to process the resulting information.
Managers should be expected to provide much of the necessary information on performance
through routine activity reports that
include environmental issues.
Performance of organizations and
individuals in comparison to accepted
standards can also be accomplished
through periodic environmental audits or
other assessment activities.
Assessments can be performed by
members of the organization or by an
outside group brought in for the specific
purpose of evaluating the organization.
In order to be fully effective,
measurable performance indicators
(activities to be performed or results to
be achieved) against which the organization's performance can be compared must be
identified. However, assessments that concentrate solely on numerical "accounting" issues
will tell only part of the story and may miss vital information. Assessments will need to
MEASURING PERFORMANCE
When choosing performance indicators, think
about whether they:
Address key organizational goals;
Can show performance trends;
Provide directly usable information;
Are controlled by the group being measured;
Show the way to improve performance.
Code of Environmental Management Principles
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evaluate the effectiveness of the overall management system, even if this aspect is not directly
quantifiable. Various audit protocols have been developed by Federal agencies and private
concerns. EPA is in the process of revising its
Generic Protocols for Conducting Environmental
Audits at Federal Facilities, which incorporates
information from other agencies.
COMPLIANCE VS. CONFORMANCE
Agencies should be aware that their EMS, as well
as their performance, needs to be evaluated.
While they will continue to audit their
environmental activities for compliance with
regulations, the EMS must be audited for
conformance with the system as designed. That
is, how well does the system match with die
agency's plan (e.g., hi terms of training,
documentation, policy development)? Whether an
EMS Standard like ISO 14001, or an EMS of the
agency's own design, this is a crucial step in
maintaining and improving a fully-functional
EMS.
The operation of a fully-functioning system of
regular evaluation of environmental
performance along with standard procedures to
analyze and use information gathered during
evaluations signal an organization's
conformance with this principle.
Appropriate steps to address performance
measurement could include:
Develop, collect data, and report on
measurable performance indicators for each
organizational activity;
Develop an internal environmental audit program;
Identify an independent outside (third party) environmental audit group;
Define the scope, type, and frequency of assessments;
Develop quality assurance objectives, including appropriate levels of review;
Develop procedures for management and use of information obtained from routine reports
and during audits, including analysis of results, reporting, trend analysis, and root-cause
analysis;
Develop procedures to convey system measurements into the review and improvement
process.
GOVERNMENT PERFORMANCE AND RESULTS ACT OF 1993 (GPRA)
GPRA requires Federal agencies to provide information on their goals and how well they achieve
them. Agencies will have to:
develop strategic plans prior to fiscal year 1998 that describe goals and objectives, plans to meet
them, necessary resources, and key external factors;
develop annual plans describing fiscal year performance goals beginning hi FY 1999;
prepare annual reports comparing performance to goals beginning hi March 2000.
Agencies can use the GPRA planning framework to include environmental goals and identify how they
will be met and the resources that will be needed.
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5.1.2 Institute Benchmarking
The agency institutes a formal program to compare its environmental operations with other
organizations and management standards, where appropriate.
"Benchmarking" is a term often used for the comparison of one organization against others,
particularly
those that are
considered to be
operating at the
highest level.
The purpose of
Benchmarking is
twofold: first,
the organization
is able to see
how it compares
with those whose
performance it
wishes to
emulate; second,
it allows the
organization to
benefit from the
experience of the
peak-performers,
whether it be in
process or
managerial
practices. The
higher-
performing organization also benefits by passing along innovations or efficiencies, which will
enhance its reputation among its peers. It may also obtain more tangible benefits, such as
innovative technological approaches.
Benchmarking also serves an overall
good by fostering a spirit of
cooperation, rather than competition and
secrecy. The Malcolm Baldrige
National Quality Award, for example,
FEDERAL AGENCY BENCHMARK REPORT
EPA surveyed 17 civilian federal agencies (CFA), 4 defense related agencies
(DRA), and 3 corporations (Chevron, Xerox, and 3M) to evaluate their approaches
to six Benchmark Elements:
Organizational Structure;
Management Commitment;
Implementation;
Information Collection/Management/Follow-up;
Internal and External Communication;
Personnel.
EPA selected a total of 31 Key Indicators as representative of the six Elements.
While 50 percent or more of the DRAs responded positively to all Key Indicators,
CFAs did so for fewer than half the Indicators. Rarely did more than 10 of the 17
CFAs respond positively to an Indicator. Corporate responses fell much closer to
the DRAs.
Source: "Environmental Management System Benchmark Report: A Review of
Federal Agencies and Selected Private Corporations," EPA-300R-94-009,
December 1994
requires its winners to share their
strategies with other organizations
seeking improvements.
Benchmarking offers an attractive path
to improvement of performance through
adoption of practices already proven to
be effective. However, reliance on such
comparisons can be more harmful than
BENCHMARKING TIPS
1. Tie efforts to strategic objectives;
2. Keep teams of manageable size (e.g., 6 to 8);
3. Involve those most affected;
4. Avoid focusing on overly broad issues;
5. Set realistic timetables;
6. Pick benchmarking partners carefully;
7. Follow benchmarking protocol;
8. Focus the data collection process;
9. Focus on process, not on numbers;
10. Identify future recipient of information.
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beneficial in certain circumstances. Too often, organizations fail to focus their efforts
appropriately and attempt to adopt practices that simply do not fit. The practice of
Benchmarking, rather than the improper approach to it, is then blamed for the poor result and
abandoned.
During 1993-94, EPA surveyed 21 federal agencies and three private corporations to
determine whether they display behavior indicative of "best in class" environmental
management systems. The elements used for the "best in class" benchmark were taken from
a number of sources, including management standards. Benchmarking against established
management standards, such as the ISO 14000 series or the Responsible Care program
developed by the Chemical Manufacturers Association (CMA), may be useful for those
agencies with more mature environmental programs, particularly if the agencies' activities are
such that their counterparts in the private sector would be difficult to find. However, it
should be understood that the greater benefit is likely to result from direct comparison to an
organization that is a recognized environmental leader in its field.
Appropriate steps to address benchmarking could include:
Evaluate the agency to identify areas in which benchmarking would be most beneficial;
Begin to develop and implement a program of comparison with other organizations;
Develop methods to apply results of inter-organizational comparisons and further
encourage comparison with other organizations and networking through professional
organizations and conferences;
Explore the possibility of mentoring another public or private organization.
5.2 CONTINUOUS IMPROVEMENT
The agency implements an approach toward continuous environmental improvement that includes
preventive and corrective actions as well as searching out new opportunities for programmatic
improvements.
Continuous improvement is approached through the use of performance measurement to determine
which organizational aspects need to have more attention or resources focused upon them.
Environmental excellence should be viewed as a journey, not a destination. There are always
constructive steps to be taken. The
development of organizational goals should
incorporate the principle of continuous
improvement. The institution of a program
to solicit and respond to employee
suggestions is an important step in
generating confidence in the organization's
commitment to improvement. Public and
private organizations that are generally
considered by their peers and the public to
be performing at the highest levels can
provide incentive and insight toward
implementation of improvement measures.
MANAGEMENT REVIEW
An EMS needs periodic management review.
This is different from the conformance review
discussed earlier. Management needs to evaluate
the EMS to see if it needs to be changed to meet
an organization's evolving goals and needs. Of
course, the implemented EMS will have to be
evaluated to see if it conforms to the revised EMS
plan.
Code of Environmental Management Principles 38 Implementation Guide
-------
Continuous improvement may be demonstrated through the implementation of lessons learned and
employee involvement programs that provide the opportunity to learn from past performance and
incorporate constructive suggestions. In addition, the agency actively seeks comparison with and
guidance from other organizations considered to be performing at the highest level.
Appropriate steps to address continuous improvement could include:
Develop procedures to address the root cause of current deficiencies and prevent future
deficiencies;
Develop a "lessons learned" program to educate personnel;
Develop and implement a program of comparison with other organizations;
Develop a program to apply results of inter-organizational comparisons and continue to
conduct comparisons and/or develop partnerships with other organizations, particularly those
considered "best in class";
Encourage suggestions for improvement from all personnel;
Conduct periodic review of operating procedures;
Review contemporary management philosophies to identify viable approaches;
Provide a mechanism to incorporate identified improvements into the next planning cycle;
Periodically review and report on improvements.
Code of Environmental Management Principles 39 Implementation Guide
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CHAPTERS: CEMP SELF-ASSESSMENT MATRIX
The CEMP Self-Assessment Matrix is a tool to help agencies evaluate their progress in implementing
the CEMP and map their next steps. The Matrix was designed to support the gradual development of
an environmental program that addresses the CEMP principles, and to relate the suggested actions
presented in previous chapters to the stage in the program's evolution when they are most likely to be
implemented. The Matrix is also intended to support several points that are key to development of an
environmental management system, including:
there is a logical (but not strictly structured) progression of activities hi the growth of a
program;
advancing to the next "higher" level builds upon the foundation of more fundamental activities
at "lower" levels;
integration of the system by addressing all of the .principles, and maintaining that integration
throughout the life of the program, is fundamental to its success;
even after reaching the "highest" level, continual review and improvement is necessary to
maintain that level of performance.
It will be helpful for agencies to keep in mind that they may already have a foundation of system
elements that they can build upon. The results of an agency's "gap analysis" can provide a starting
point for implementation of each principle.
How the CEMP Matrix Works
The CEMP Matrix is laid out to show the implementation of each principle over five levels of
development. There is nothing magical about the use of five levels. The number was chosen as an
intermediate point that communicates the idea of progression without overwhelming the user.
Although the levels are numbered, no "scoring" scheme is implied, although agencies are free to
develop such schemes if they believe it would benefit them. Similar approaches that are intended to
be used as scoresheets have been developed by other organizations. For example, the Council of
Great Lakes Industries (CGLI) has developed a matrix that is intended to take an organization through
a "roadmap" to implement Total Quality Environmental Management. The CGLI uses the seven
Malcolm Baldrige Award criteria as its categories, and ranks progress over ten levels. Like the
Baldrige award itself, the seven categories are weighted to indicate their relative importance.
The Global Environmental Management Initiative has developed two slightly different approaches to
environmental self-assessment. The first is based on the 16 principles found in the International
Chamber of Commerce (ICC) Business Charter for Sustainable Development, which are generally
applicable to any organization. Using this "Environmental Self-Assessment Program," organizations
rate their performance for 71 "elements" identified under the 16 principles on a scale of 1 through 4
(or Not Applicable), with 1 corresponding to simple regulatory compliance. Each element is also
assigned a weighting factor, which represents its relative importance to the scoring organization
(unlike the CGLI matrix, where a category has the same weighting factor for all organizations).
Code of Environmental Management Principles 40 Implemenation Guide
-------
The second GEMI approach is for organizations that want to measure their environmental
management systems against the ISO 14001 EMS Standard. The "ISO 14001 Self-Assessment
Checklist" covers a total of 31 questions under the five ISO 14001 EMS elements. By scoring each
on a scale of 0 through 2, an organization should get an idea of how well its EMS conforms to the
ISO 14001 Standard. The Checklist can be used to support a gap analysis or as an indicator that ISO
conformance has been achieved. This exercise would be especially useful for companies that may
need to explore ISO certification (and third-party certification) for business purposes, although
Federal agencies may also benefit from comparison to a recognized international standard. Agencies
will also recognize that the questions in the
Checklist can help them implement the CEMP.
For the CEMP Matrix, each block gives an
indication of what the agency will have
accomplished under a particular principle.
Some of these are more concrete than others,
while some may be more subjective and will
require interpretation by the agency. For
example, Level 3 under "Policy Development"
states that the agency "develops draft policy and
circulates it for review and comment," which is
fairly straightforward. Level 3 under
"Environmental Stewardship" states that the
agency "identifies alternatives to high-impact
activities," which will require agencies to
determine which activities are high-impact and
develop criteria for identifying alternatives.
The Matrix is offered as a potentially useful tool
that gives one approach to implementing the
principles, not as a rigid "one size fits all"
blueprint. Agencies are encouraged to adapt the
Matrix to their own programs, and to make
whatever modifications they deem advisable.
ICC CHARTER
The International Chamber of Commerce
Business Charter for Sustainable Development
Principles for Environmental Management cover
the following areas:
1. Corporate Priority
2. Integrated Management
3. Process of Improvement
4. Employee Education
5. Prior Assessment
6. Products and Services
7. Customer Advice
8. Facilities and Operations
9. Research
10. Precautionary Approach
11. Contractors and Suppliers
12. Emergency Preparedness
13. Transfer of Technology
14. Contributing to the Common Effort
IS. Openness to Concerns
16. Compliance and Reporting
Moving From Level to Level
Previous chapters have presented possible steps that could be taken by agencies implementing the
CEMP. To enhance the usefulness of the Matrix, the steps are repeated here and related to the
Matrix level (1 through 5) at which they might be most appropriate. Again, the Matrix is intended as
a guide and therefore these actions are not required, nor is it required that they be performed in any
particular order. Not all levels have actions associated with them, and many of the activities will be
continuing or ongoing through the upper levels of the Matrix, rather than performed on a one time
only basis. However, it will be beneficial to agencies to understand that some activities are very
basic "first steps," while others are likely to require significant groundwork in terms of program
maturity if they are to be properly conducted. Some agencies may find that they are in a position to
conduct some "higher-level" activities before other "lower-level" activities can be completed, or can
Code of Environmental Management Principles
41
Implementation Guide
-------
skip some activities altogether. The important thing is for agencies to understand their own
circumstances and tailor their activities appropriately.
Similarly, it is not necessary for agencies to complete the same level for all principles before moving
to the next level. In fact, this would be counterproductive. An agency may well find that it has
reached Level 4 for one principle before Level 1 is completed for another. It is, however, important
that the various parts of the program maintain communication with each other, as is illustrated by the
number of candidate actions that cover similar ground. For example, several of the principles can be
partially fulfilled by implementing a system to obtain employee feedback. Even though this activity
cross-cuts the principles, it does not necessarily appear at the same Matrix level for each.
Finally, the Matrix does not represent a mythical state of perfection that will be impossible for
agencies to attain. Rather, it should be thought of as a means by which agencies can gauge their
progress in implementing the CEMP and, more broadly, in improving their approaches to
environmental management by incorporating those elements considered "state of the art."
Improvements in management should be reflected by improvements in the efficiency, cost-
effectiveness, and performance of environmental programs.
_. . , 42 Implementation Guide
Code of Environmental Management Principles
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CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 1: MANAGEMENT COMMITMENT
LEVEL
1.1 OBTAIN MANAGEMENT SUPPORT
Policy Development
System Integration
1.2
ENVIRONMENTAL
STEWARDSHIP
FINISH
ft
5
Agency communicates its policy externally, to regulatory
authorities, other agencies, and other stakeholders
Agency decisions consider environmental criteria when
appropriate; program thoroughly integrated
Assume leadership through outreach
All agency decisions include appropriate environmental
criteria to minimize impact
Consider environmental impacts
Participate in bearings and other activities
Agency develops final policy and communicates it
internally
Over 50% of agency decisions consider environmental
criteria; program integrated through 75% of agency
Encourage teaming across divisions
Agency develops procedures to evaluate environmental
impacts of future activities
Introduce LCA and design for environment concepts
Provide outside speakers
Sponsor outside activities
"Open House" for community
Demonstrate commitment
Agency develops draft policy and circulates it for review
Mid comment
Environmental criteria are incorporated into employee
performance standards as appropriate; program integrated
through 50% of agency; criteria for environmental
decision-making developed *
Review responsibilities
Agency identifies alternatives to high-impact activities
Encourage environmental action plans
Provide "brown bag" speakers
Create promotional items
f
2
Agency evaluates environmental concerns of key
stakeholders
Develop goals and priorities
Communicate with stekeholders
Environmental criteria are incorporated into affected
managerial performance standards; program integrated
through 25% of agency, starting with activities most
affected
Conduct organizational review
Assign management responsibilities
Include performance criteria
Coordinate and review budget
Agency implements awareness programs to inform
employees and stakeholders
Provide orientation
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 1: MANAGEMENT COMMITMENT
i
ft
START
Agency evaluates its mission in environmental terms
Prepare Mission/Vision statements
Environmental program is communicated throughout
agency; environmental groups established and their
missions defined and communicated
Identify liabilities and risks
Provide awareness training
Agency evaluates environmental impacts of its activities
Notes:
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 2: COMPLIANCE ASSURANCE AND POLLUTION PREVENTION
LEVEL
2.1
COMPLIANCE ASSURANCE
2.2
EMERGENCY PREPAREDNESS
2.3
POLLUTION PREVENTION AND
RESOURCE CONSERVATION
FINISH
t
5
Full agency compliance is sustainable; contractors are
included within the compliance program
Set "beyond compliance" performance goals
Evaluate contractor performance
Introduce risk assessment
All agency personnel are trained in emergency response
procedures; full-scale exercieses are conducted at least
annually
Program maintained throughout the agency; significant
reductions in waste generation achieved
t
4
Agency develops proactive and cooperative relations with
regulators; non-compliance situations reduced
significantly
Employee repotting encouraged
Regular contact with regulators
Procedures to elevate issues to upper management
Pollution prevention is primary management approach
Agency implements medical monitoring for environmental
program personnel as appropriate and inspects facilities
periodically
In-house medical monitoring, where appropriate
Agency encourages reduced use of resources and
identifies indificuals contributing to the success of the
program; process improvements implemented
Affirmative procurement program
Life-cycle analysis performed
Design for environment
Product stewardship
Agency fully implements compliance program, develops a
program to track relevant legislation and regulations, and
sees improved performance
Track regulatory initiatives
Address non-compliance conditions
Track corrective action progress
Environmental recordkeeptng system
Identify problems and prevent non-compliance
incidents
Establish compliance management system that is
integrated with EMS
Agency emergency response teams are trained and
periodic drills are conducted
Emergency Response Team
Training for Emergency Response Team and other
personnel
Conduct regular exercises
Identify emergency resources
Agency develops goals, implements employee suggestion
procedures, and identifies alternatives to major
generators
Toxic materials reductions
Water conservation program
"Repair or Replace" program
It
2
Agency communicates with regulatory authorities,
develops procedures to address compliance situations, and
distributes them throughout the agency
Introduce compliance group
Develop compliance guidance
Coordinate with regulators
Communicate information on regulations and permits
Agency develops procedures to address emergency
response, distributes them throughout the agency
Develop response procedures
Disaster preparedness plan
Hazard mitigation measures
Preventive maintenance program
Coordinate with authorities
Develop communication plan
Agency communicates pollution prevention commitment
to all personnel and begins recycling programs (paper.
aluminum, glass)
Energy conservation program
Recycling program in place
Encourage reuse of materials
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 2: COMPLIANCE ASSURANCE AND POLLUTION PREVENTION
i
t
START
Agency compliance group evaluates agency's activities
and compliance history
Develop compliance group
Review agency activities
Assess compliance, baseline
Agency emergency response group evaluates its activities
and vulnerability to natural disaster and accidents
Identify hazards from agency activities and facilities
Agency evaluates its waste generation profile and
identifies major points of generation
Pollution prevention program that emphasizes source
reduction
. Notes:
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 3: ENABLING SYSTEMS
LEVEL
3.1
TRAINING
3.2
STRUCTURAL SUPPORTS
3.3
INFORMATION MANAGEMENT,
COMMUNICATION, DOCUMENTATION
It
4
100% of agency fully trained, refresher training provided,
computer-based and distance learning employed when
appropriate; training program continually evaluated
Obtain feedback on training
Investigate alternative training methods
Procedures are fully implemented and reviewed
periodically
Conduct periodic review of procedures to ensure
currency
Agency maintains effective communications, applies
environmental information to decision-making, and
maintains thorough records
Use EMS data in decision-making
75% of agency fully trained; refresher training developed
and available, where appropriate; continuing education
encouraged
Establish refresher training
Encourage continuing education
Agency implements procedures and begins training of all
staff, as appropriate
Pursue integration of environmental program
throughout agency
Agency develops procedures for use of information,
provides avenues for employee input, and has a well-
maintained records center
Use electronic networks
Assure validity of envtl. data
Secure data-handling procedures
Employee reporting system
Encourage employee input
t
3
50% of agency fully trained; system to track fulfillment
of training requirements developed and implemented
Establish in-house group to track training program
Agency disseminates procedures throughout to raise
awareness of issues; implementing staff is trained
Encourage input from personnel
Agency communicates with regulators and stakeholders
and develops information garnering, manipulation, and
management procedures
Evaluate new IM projects
Assign POC for new projects
Establish Resource Center
Provide regular status updates
Communicate with other orgs.
Develop public outreach program
Communicate with stakeholders
Develop distribution network
QA and security procedures
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLES: ENABLING SYSTEMS
it
2
Agency training group identifies available outside training
and develops in-house training where necessary; 20% of
agency fully trained
Identify job-specific requirements
Evaluate outside vs. in-house training
Train die trainers as necessary
Agency develops or revises procedures to address
activities identified as having environmental aspects
Eliminate or revise procedures found to be barriers
Agency develops internal communications and
information management infrastructure, and document
control procedures
Ensure compatibility
Develop envd. IM procedures
Identify key records/documents
Develop in-house communication
Enable working relationships
Report completion procedures
Maintain MSDS, etc.
Agency training group identifies environmental training
needs and where training is available
Develop "Core Curriculum"
Agency identifies and evaluates existing procedures and
activities that have environmental aspects
Review agency documentation
ft
START
Agency identifies lines of communication, information
needs, documentation procedures
Assign managerial responsibility
Create in-house IM group
Review current capabilities
Define lines of communication
Assign environmental POCs
Develop centralized filing system
Notes:
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLED PERFORMANCE AND ACCOUNTABILITY
LEVEL
FINISH
I
5
t
4
t
3
1
2
1
1
4.1
RESPONSIBILITY. AUTHORITY AND ACCOUNTABILITY
Assignment of environmental responsibilities it reviewed periodically in light of
performance
Penonnel are provided avenues to provide input and employees ace held
accountable for environmental performance
All employees assigned environmental responsibilities are given appropriate
authority and training
Issue elear statements of environmental responsibility
Prepare process to address authority conflict
Managers assigned environmental responsibilities are given training and authority to
meet those responsibilities
Issue statements defining authority
Agency identifies personnel with responsibility for environmental performance
Assign authority to ensure environmental compliance
4.2
EMPLOYEE PERFORMANCE STANDARDS
Agency develops a program to recognize and reward personnel that carry out
environmental responsibilities exceptionally well; appropriate disciplinary
mechanisms also in place
Prepare program to reward or recognize honorees
Prepare disciplinary mechanisms to address non-conformance with agency
policy or procedures
Personnel are evaluated based on environmental aspects of their performance
standards
Develop procedures for evaluatioe performance
Affected employees have environmental responsibilities clearly stated in
performance standards
Managers have environmental responsibilities clearly stated in performance
standards
Develop employee evaluation standards
Agency identifies personnel with responsibility for environmental performance
Identify organizational performance goals
Notes:
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLES: MEASUREMENT AND IMPROVEMENT
LEVEL
5.1 EVALUATE PERFORMANCE
Gather/Analyze Data
Institute Benchmarking
5.2
CONTINUOUS IMPROVEMENT
Data-gathering is a continuous process; gaps in
performance are identified and analyses conducted to
identify their root cause(s)
Agency maintains ongoing "benchmarking cycles";
agency becomes a target for benchmarking by others
Explore possibility of mentoring other organizations
Agency shows significant improvement in addressing
substandard performance situations and aggressively
seeks to compare its performance to others
Review other management approaches for
applicability
t
4
Periodic evaluations of operations and data-gathering
procedures are conducted to assess performance
Include system measurement in review and
improvement process
Agency identifies and implements improvements based on
evaluation of other organization
Develop methods to apply results of benchmarking and
pursue further involvement
Agency fully implements periodic reviews of systems
and performance and seeks out additional opportunities
for improvement
Develop methods to apply results of benchmarking
and pursue further involvement
Conduct review of procedures
Review and report improvements
ft
3
Data-garnering and processing procedures are
implemented throughout the agency
Identify independent audit group
Develop procedures to manage and use information
from audits
Agency evaluates performance of target organization
through sharing of information (e.g., site visit) for
comparison with its own
Agency implements employee-involvement measures,
such as newsletters and lessons learned, to solicit input
on improving performance
Develop lessons learned program
Encourage employee suggestions
Work to include improvements in next planning cycle
t
2
Agency develops procedures for gathering appropriate
data and communicates mem to management
Define assessment parameters
Develop QA objectives
Agency identifies other organizations with similar
activities and/or exceptional performance and initiates
contact with them
Develop program of comparison to other organizations
Agency develops procedures to address preventive and
corrective action situations and communicates mem to
management
Develop procedures to identify root causes
Develop program of comparison to other
organizations
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLES: MEASUREMENT AND IMPROVEMENT
i
t
START
Agency identifies performance indicators, data needs, and
standards of comparison
Develop and report on performance indicators
Develop internal audit program
Agency evaluates its activities and sets goals for
environmental performance
Evaluate most useful benchmarking areas
Agency .evaluates performance to identify areas needing
improvement
Notes:
-------
Appendix 1: Agency Responses
Central Intelligence Agency (CIA)
Department of Agriculture (USDA)
Department of Commerce (DoC)
Department of Energy (DoE)
Department of Interior (Dol)
Department of Justice (DoJ)
Department of Transportation (DoTransp.)
Department of Treasury (DoTreas.)
Environmental Protection Agency (EPA)
General Services Administration (GSA) '.<
Health and Human Services (HHS)
National Aeronautics and Space Administration (NASA)
Postal Service
Tennessee Valley Authority (TVA)
Veterans Administration (VA)
-------
Central Intelligence Agency
\\,. \J \1
. _ """'' f-
Washington, D.C. 20505
9 October 1996
Mr. Steven A. Herman
Assistant Administrator
Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Herman:
t
In response to your letter dated, 3 September 1996, the Central
Intelligence Agency (CIA;) is pleased to demonstrate its participation with the
federal government Code of Environmental Management Principles (CEMP). The
following is a brief description of the comprehensive CIA program and the
implementation of the CEMP fundamental elements.
1. Management Commitment: In FY92, the Executive Director,
in coordination with the Deputy Director for Administration (DDA) ,
established a formal environmental program to gain compliance with
environmental regulations and initiate remediation of potential
cleanup sites. Funding for the multi-year program was identified
by the Comptroller commencing with the FY94 budget.
Administration of the program was assigned to the newly formed
Environmental Safety Group (ESG) within the Office of Medical
Services, Directorate of Administration. ESG is responsible for
centralized program management which includes planning, funding,
staffing, and program oversight. Individual Agency field sites
are staffed with an Environmental Specialist on assignment from
ESG. These Environmental Safety Officers (ESOs) are responsible
for implementation of the program and remediation of identified
deficiencies. Concurrently, the Agency established an
environmental compliance regulation requiring all components and
personnel to comply with environmental laws and regulations,
executive orders, and internal Agency requirements. The DDA, who
serves as the Agency Environmental Executive, issued a policy
statement which makes individual Agency components accountable for
any fines or penalties issued by federal or state regulators. In
March 1995, the DDA also issued an Agency Notice establishing the
CIA Pollution Prevention Policy and Goals. These goals are a
fifty percent reduction in the use of toxic chemicals and a
reduction in the use of extremely hazardous substances.
2. Compliance Assurance and Pollution Prevention: The CIA
has established a proactive program at all Agency sites to assure
compliance with environmental laws and regulations. This consists
of annual compliance inspections of all Agency sites by ESG
-------
Mr. Steven A. Herman
i i
environmental specialists. In addition, compliance audits have
been performed at some Agency sites by environmental consultants,
U.S. Army and U.S. Navy environmental audit teams, and other
governmental agencies such as the National Security Agency. ES6
specialists provide expert consultation and assistance to field
sites to address specific issues or to provide surge support
during periods of increased workload.
The CIA has also implemented a proactive pollution
prevention program. As previously stated, the goal of this
program is to achieve a fifty percent reduction in the use of
toxic chenicals and to reduce the use of extremely hazardous
substances. To date, the pollution prevention program reduced the
Agency's inventory of toxic chemicals by thirty-eight percent and
is well on the way to attaining the fifty percent five-year goal.
Source reduction is the primary strategy in this effort with
recycling as a secondary approach. Each site has submitted a
pollution prevention plan which describes the methods by which
they will meet the corporate pollution prevention goals. An
officer in ES6 has been designated as the Pollution Prevention
Program Manager. This individual visits each of our field sites
annually to provide assistance and guidance to site managers on
the program. Progress on this effort is tracked annually to
ensure that the December 1999 target date will be met.
3. Enabling Personnel: ESG provides funding for
environmental compliance training for program specialists, site
managers, and selected component personnel. A number of ESG
specialists are pursuing advanced degrees in Environmental
Engineering, Environmental Management, and Environmental Science
to further their expertise in these fields. Senior managers are
briefed on the progress of the program on a regular basis. A
Lotus Notes based electronic bulletin board database provides a
means to disseminate regulatory updates to field personnel,
functions as an inquiry and response forum, and serves as a
general discussion media for promoting environmental issues and
policies.
4. Performance and Account ability All major Agency field
sites are staffed with a full time ESO who implements the
environmental program under the direction of the site manager.
The ESO is responsible for coordinating the environmental program
among the various tenants located at the site. Performance
evaluations for the ESO are prepared annually by the site manager,
and forwarded to the Agency environmental program office for
review. The site manager and the chief of the environmental
program office are mutually accountable for the performance of the
-------
Mr. Steven A. Herman
ESO and the site program. However, as previously stated, the site
manager or offending component is held accountable for any fines
or penalties assessed against the site from an inspection by state
or federal regulators.
5. Measurement and Improvement: Programmatic appraisals
are conducted annually by ESG to assess the status of the Agency
environmental program. In addition, the Agency Inspector General
conducts periodic reviews of the program to ensure programmatic
compliance with environmental laws and regulations. Any
deficiencies that are identified by these inspections are targeted
for correction. Deficiencies requiring an outlay of resources are
centrally funded by SSG on a basis of priority. Annual
environmental conferences are held to assemble the field ESOs to
review the status 'of site programs as well as the Agency program.
Progress on pollution prevention, affirmative procurement, waste
reduction, and recycling goals are reviewed and discussed.
Additional pollution prevention opportunities are identified and
targeted.
Should you require any additional information on the CIA's
implementation of the CEMP, please contact Mr. Randy Hyde, Pollution
Prevention Program Manager on (703)482-6081.
Sincerely,
Lawrence J. McGinty
Chief, Environmental Safety Group
-------
USDA
United States
Department of
Agriculture
Office of the
Assistant Secretary
for Administration
Hazardous Waste
Management Group
1400 Independence
Avenue, SW
Washington, DC
20250-9100
January 28,1997
Mr. James R. Edward
Acting Associate Director
Federal Facilities Enforcement Office
U.S. Environmental Protection Agency
401MSt.,SW(2261A)
Washington, DC 20460
Dear Mr. Edwar'd:
In response to my staffs recent conversations with Andrew Cherry of your staff, I
am writing to inform you that USDA and its agencies generally support the overall
objectives of the Code of Environmental Management Principles '(CEMP). A number of
USDA agencies already embrace pollution prevention, and others have initiatives in
various stages of planning and implementation. However, we will be unable to complete
the specific plans for agency- and facility-specific CEMP implementation Assistant
Administrator Herman requested in time for inclusion in your guidance document. In
fact, in view of your plans for speedy publication of that guidance, we would prefer to
take full advantage of the expertise that went into its preparation by making it a primary
resource for our agencies. Accordingly, we request that your office provide us with as
many copies as possible for wide distribution within USDA.
Please feel free to contact George Sundstrom at (202) 260-6556 for additional
information on our efforts to implement the CEMP.
Sincerely,
Blake T. Velde
Director
cc: R. Tucker, DA
AN EQUAL OPPORTUNITY EMPLOYER
-------
UNITED STATES DEPARTMENT OF COMMERCE
Office of the Secretary
Washington. D.C. 20230
Mr. Steven A. Herman
Assistant Administrator
Office of Enforcement and
Compliance Assurance
Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Herman:
In response to your letter dated September j, ia^S, che U.S.
Department of Commerce is pleased to e'xpress its support for the
Code of Environmental Management Principles (CEMP) for Federal
Agencies. The Department is committed to improving its
environmental performance by developing and enhancing policies
and programs for pollution prevention and compliance with the
best environmental practices.
The Department has in place an effective policy and statement of
responsibilities for environmental compliance and has developed a
network of key environmental managers at the operating unit
level. These officials and their staff ensure that facilities
that store hazardous materials continue to make progress in
developing and implementing effective pollution prevention plans.
We look forward to continuing our work with the Environmental
Protection Agency (EPA) and the Interagency Pollution Prevention
Task Force (IPPTF) in our efforts to ensure that the CEMP is
fully realized in the Department of Commerce and throughout the
Federal government.
Sincerely,
Jeffrey Hunker
Deputy Assistant Secretary
-------
OFFICE OF THE UNDER SECRETARY OF DEFENSE
3000 DEFENSE PENTAGON
WASHINGTON DC 2O3O1-3OOO
ACQUISITION AND
TECHNOLOGY
Mr. Steven Herman
Assistant Administrator Og jv0y 1996
Office of Enforcement and Compliance Assurance
Environmental Protection Agency
Mail Code 2261A
401M Street SW
Washington, DC 20460
Dear Mr. Herman:
I endorse the draft Code of Environmental Management Principles (CEMP) on an agency
level as described in your letter dated September 3,1996.
The Department of Defense is fully committed to protecting the environment and
building excellence into the management of its programs. The Department is using ISO 14001 in
the development of its current strategic plan and is evaluating the adoption of ISO 14001 as an
Environmental Management System for the entire Environmental Security program. Our goal is
continuous improvement of our environmental performance through a cost-effective
implementation strategy. The enclosed implementation plan describes how the CEMP is
incorporated into the Department's existing environmental management system.
I would be happy to brief you on the Department's Environmental Security program. If
you have any questions, please do not hesitate to contact me at (703) 695-6639 or Mr. Peter
Walsh at (703) 604-1529.
Very trafy yours,
Sherri Goodman
Deputy Under Secretary of Defense
(Environmental Security)
Enclosure
Environmental Security -fZDefending Our Future
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IMPLEMENTATION OF THE CODE OF ENVIRONMENTAL
MANAGEMENT PRINCIPLES
Principle 1: Management Commitment
Performance Objectives:
1.1 Obtain Management Support
1.1.1 Policy Development
The Department of Defense (DoD) Environmental Security Directive and supporting
instructions signed by the Under Secretary of Defense (Acquisition and Technology) establish
environmental protection goals and developed supporting strategies that fully complement
accomplishment of the Department's overall mission. The instructions also establish budget
priorities and measures for evaluating how well established goals are being met. (see attachment
2)
1.1.2 System Integration
The DoD Acquisition Directive, recently published, directs that environmental performance
must be considered in the acquisition process along with other factors such as mission
performance and cost. In addition, the DoD Planning instruction requires the completion of an
environmental analysis in accordance with the National Environmental Policy Act to aid decision
making.
The Department annually provides budget development guidance direction to the
Services through both the Program Objective Memorandum (POM) Preparation Instruction and
Defense Planning Guidance. These documents specifically identify environmental performance
goals or accomplishments. Thereafter, the Deputy Under Secretary of Defense (Environmental
Security) reviews the Services' budget submissions to ensure they meet guidance.
1.2 Environmental Stewardship and Sustainable Development
The Department's policies, as described in the Environmental Security Directive and
supporting instructions, and annual budget planning guidance, promotes environmental
stewardship and sustainable development.
The DoD policies conserve natural and cultural resources, and promote biological
diversity and total ecosystem land management. The DoD instructions require completion of
inventories of special resources such as wetlands, endangered species habitat, archaeological
sites and historic properties. They further require preparation of integrated plans for their proper
management The Department's land management practices at training ranges balance the
military training needs with the ability of the land to sustain and recover, thereby protecting
valuable resources and ensuring future realistic training oppdrtunities.
The DoD instructions also promote the conservation of resources through the
establishment of goals and reporting requirements for the reducing solid waste, hazardous waste,
and toxic substances released from, an installations each year. The Department's instructions also
require a recycling program at every installation and establish goals and reporting requirements
for increasing the total volume of material recycled each year. The Department's instructions
1
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also requires, with some exceptions, the purchase of EPA-specified products made with recycled
content. The Department also encourages the purchase of environmentally preferred products by
maintaining and distributing a catalogue of products. In addition, it is the Department's policy,
as stated in instruction and budget planning guidance, to give preference to the use of pollution
prevention projects over "end of pipe" treatment or disposal to meet compliance requirements.
The Department is in process of implementing a program to educate or train personnel to
meet the environmental responsibilities of their jobs. The Department's Environmental Security
directives and supporting instructions establish goals for compliance, pollution prevention and
conservation and require periodic reporting on progress towards meeting those goals through
measures of merit.
DoD personnel regulations require that supervisors identify major job components in
employees' job descriptions and prepare evaluation criteria for those major job components in
employees' annual work plans. Supervisors therefore evaluate persons with environmental
responsibilities on the performance of those responsibilities, as appropriate. Similarly, military
personnel with environmental responsibilities would be evaluated on their performance of those
responsibilities. Installation commanders are evaluated on the total performance of the
installation. The installation's environmental performance is one of many considerations that
would contribute to the commander's performance appraisal.
The Department believes this is the appropriate interpretation of the phrase
"organizational units should take steps to measure the organization's performance by
incorporating specific environmental performance criteria into managerial and employee
performance evaluations."
Principle 2: Compliance Assurance and Pollution Prevention
Performance Objectives
2.1 Compliance Assurance
The DoD's directive and supporting instructions require compliance with federal, state
and local environmental laws.. Annual budget guidance requires the full funding of actions to
stay in compliance and to get into compliance if currently out, and a prudent investment in those
actions necessary to meet standards whose effective date is in the future. The Department's
instructions also require mat each installation conduct a self audit for environmental performance
at least annually, and that the Services report progress on specific compliance and pollution
prevention measures of merit annually to the Deputy Under Secretary of Defense (Environmental
Security). The reported progress is also reported in the Department's Annual Environmental
Quality Report to Congress. The Department's instructions establish Regional Environmental
Coordinators to work closely with federal, state and local environmental regulators in identifying
potential problems and seeking resolution. The Department requires that all contractors on
military installations meet appropriate environmental standards.
2.2 Emergency Preparedness
The DoD instructions require compliance with all applicable federal, state, and local
environmental laws. These laws include the requirement to prepare and exercise of emergency
-------
response plans. The checklist developed to aid the mandatory environmental self audit includes
this requirement.
2.3 Pollution Prevention and Resource Conservation
The DoD Pollution Prevention instruction establishes pollution prevention goals and
strategies. It requires all installations accomplish an opportunity assessment and develop a
pollution prevention plan. Further, the instruction requires installations to give preference to
pollution prevention projects over "end of pipe" treatment and disposal to meet compliance
requirements. The Department's annual budget guidance reinforces this preference for pollution
prevention solutions. The instruction also establish goals for reductions in solid waste and
hazardous waste released from an installation and requires periodic reporting by the Services on
their progress towards achieving these goals. ''
Principle 3: Enabling Systems
Performance Objectives
3.1 Training
The Department is developing an extensive training program so that all persons can meet
the environmental responsibilities of their jobs. The Department provides an environmental
awareness program during military recruit training. The Services have evaluated the
environmental requirements of military enlisted personnel jobs, such as jet engine maintenance
and fire fighting, and are currently in process of embedding appropriate environmental
instruction into the technical training programs.. The Department is also hi process of inserting
discussion of national and international environmental in professional (officers) military
education programs. The Services are developing an integrated professional continuing
education and training program for both civilians and officers. This program provides the legally
mandated training for those persons handling hazardous materials. It also provides education for
environmental professionals so they can meet the changing challenges of their jobs. The
Department is also inserting environmental instruction into the education programs for non
environmental professionals whose actions could affect the environment. For example, the
Department is currently revising the curricula at the Defense Acquisition University so that
persons managing acquisitions in the future would better understand environmental requirements
and the environmental cost implications of their decisions. The Services and the Department
conduct Environmental Leadership Courses to prepare installation commanders and senior
officials to understand and meet the environmental responsibilities of their jobs.
3.2 Structural Supports
The Department's Environmental Security Directive and supporting instructions
establish environmental goals, supporting strategies, budget priorities, and measures of merit
that support overall organizational objectives. The Department reports progress towards
achieving the goals hi its annually environmental quality and restoration reports to Congress.
3.3 Information Management, Communication, Documentation
The Department is currently developing a Defense Environmental Security Corporate
Information Management (DESCIM) system to provide for more effective and efficient
-------
management of the environmental program. The system, to be used by all Services, standardizes
data entries and information display. The system is being developed to meet management needs
at all organizational levels - installation, major command and headquarters.
Principle 4 Performance and Accountability
Performance Objectives
4.1 Responsibility, Authority and Accountability
The Department is in process of implementing a program to educate or train personnel to
meet the environmental responsibilities of their jobs. The Department's Environmental Security
directives and supporting instructions establish goals for compliance, pollution prevention and
conservation and require periodic reporting on progress towards meeting those goals through
measures of merit.
DoD personnel regulations require that supervisors identify major job components in
employees' job descriptions and prepare evaluation criteria for those major job components in
employees' annual work plans. Supervisors therefore evaluate persons with environmental
responsibilities on the performance of those responsibilities, as appropriate. Similarly, military
personnel with environmental responsibilities would be evaluated on their performance of those
responsibilities. Installation commanders are evaluated on the total performance of the
installation. The installation's environmental performance is one of many considerations that
would contribute to the commander's performance appraisal.
4.2 Performance Standards
The Department's instructions establish environmental compliance performance
measures. The instructions further require the Services report to the Deputy Under Secretary of
Defense (Environmental Security) semi-annually on their environmental compliance
performance using these established measures.
The Department's instructions establish an awards program to recognize outstanding
performances by installations and by individuals. The Services select winners in each of 17
categories from nominations from their respective installations. These Service winners, in rum,
compete for recognition as best in the DoD.
Principle 5: Measurement and Improvement
Performance Objectives
5.1 Evaluate Performance
5.1.1 Gather and Analyze Data
The Department is in process of implementing a automated data management system to
collect data to support management needs at installation, major command and headquarters
levels.
The Department's Environmental Security directive and supporting instructions establish
goals and require the Services to provide assessments, at least annually, to the Deputy Under
Secretary of Defense (Environmental Security) on progress towards achieving those goals.
5.1.2 Institute Benchmarking
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The Department is currently evaluating environmental operations in other government
and non-government organizations which have similar environmental challenges.. The effort is
scheduled for completion by January 1997.
5.2 Continuous Improvement
The Department is promoting numerous initiatives to improve environmental
performance. For example, the Department is establishing hazardous materials pharmacies at
most installations and on ships. Pharmacies provide central control of purchasing, storing,
distributing and disposing of these materials. Implementation of pharmacies results in reduced
purchases, disposals, and potential for violations. Another example is the "ENWEST"
initiative, jointly sponsored by EPA and the Department. Under this initiative, a regulator may
grant relief from requirements that provide little additional health protection or environmental
improvement. In return for such relief, the installation commander, in coordination with the
regulator, commits the money originally programmed to satisfy the "waived" requirements, to
fund high payback pollution prevention projects. A third example is the single process
initiative. Under this initiative, program managers for different weapon systems supported by a
single process agree to a single test and validation process for an environmentally sound
alternative to that process. If the test and validation process is successful, changes affecting all
weapons are made simultaneously, thereby improving the environment and reducing costs.
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Department of Energy
Washington, DC 2OS85
2 I
Hr. Steven A. Herman
Assistant ftdariiristrator
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
401 M Street, S.H.
Washington, D.C. 20460
Dear ttr. Herman:
Thank yan for your letter of September 3, 1996, requesting the
Department's support for the Code of Environmental Management
Principles (CEMP). Protecting and restoring the environment is a
central mission for the Department of Energy (DOE). The five
principles of this Code are consistent with our continuing efforts to
improve the quality, cost-effectiveness, and integration of our
environmental operations. He therefore endorse the CEHP on an agency
basis.
Implementing the CEHP across DOE vill require a range of strategies.
DOE operates nunerous facilities that vary widely in terms of
mission, size, and environmental condition. For this reason, no
single solution can be effective in implementing the CEHP
Department-wide. Me plan to incorporate principles of the CEHP into
the implementation of an Integrated Safety Management System at DOE
facilities. This approach to integrating the protection of workers,
the public, and the environment has been developed In response to a
recoaaeiwiation by the Defense Nad ear Facilities Safety Board and is
in the first phase of implementation. In the near term, we plan to
provide guidance to our sites for preparation of their updated
pollution prevention plans; «s will attach the CEMP and encourage its
use In all site environmental management planning. The elements of
the CEHP are also being incorporated into comprehensive plans which
the Department is currently developing to guide land and facility use
decisions. These decisions will be based on the principles of
ecosystem management and sustainable development.
Implementing the CEMP via the Integrated Safety Management System,
comprehensive plans, and pollution prevention plans is also
consistent with use of the ISO 14001 Standard, Environments}
jfeoageoeflt System Specification. Several sites are currently using
or adopting environmental management systems consistent with the ISO
Standard. This approach is being voluntarily implemented at several
sites, is under consideration at others, and was included as a
-------
performance incentive in the recent Hanfnrd contract. Ve look
forward to meeting the challenge of implementing the Code of
Environmental Management Principles as an important requirement of
Executive Order 12856.
'Richard J. Guimond
Assistant Surgeon General, USPHS
Principal Deputy Assistant Secretary
for Environmental Management
Environmental Executive
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United States Department of the Interior
OFFICE OF THE SECRETARY
Washington, D.C. 20240
SEP 30 TO
Mr. Jim Edward
Director
FFEO Planning, Prevention and Compliance
U.S. Environmental Protection Agency
401 M Street, S.W. (2261A)
Washington^DTC. 20460
Dear Mr.
This is ₯h response to your memorandum of September 3, 1996, and
addressed to Deputy Secretary of the Interior John R. Garamend!
concerning the Code of Environmental Management Principles (CEMP)
for Federal Agencies. The Department of the Interior (DOI) fully
supports the intent of CEMP and has already implemented
provisions consistent with both CEMP and Executive Order 12856.
The Office of Environmental Policy and Compliance (PEP) has
issued the "DOI General Guidance on Pollution Prevention, Right-
to-Know, Recycling, and Green Acquisition" and developed 26 "Fact
Sheets" on pollution prevention activities (e.g., vehicle
maintenance).
The PEP developed overall Departmental policy (518 DM 1) on
comprehensive waste management which prescribes responsibilities
and functions regarding management of wastes on Departmental
lands and facilities through improved awareness, program
management, and accountability. Also, another Departmental
policy (518 DM 2) was developed concerning compliance with
Federal, State, interstate, and local waste management
requirements.
The PEP issued a "Solid Waste and Hazardous Materials Management
Compliance Handbook" for use by Departmental bureaus and offices.
Also, PEP has established an annual and competitive Environmental
Achievement Award which recognizes Departmental bureaus and
offices, employees, and contractors for their exceptional
achievements or contributions in pollution prevention, waste
reduction, recycling, and acquisition of environmentally-
preferred products. Finally, Mr. Brent Giezentanner, a refuge
manager for the-Fish and Wildlife Service, was a recipient of the
Closing the Circle Award in 1995 for environmental protection and
pollution prevention activities at the Aransas National Wildlife
Refuge in Austwell, Texas.
We are presently working on the development of a Departmental
policy for environmental auditing which will incorporate elements
of both EPA's Generic Environmental Auditing Protocol and the ISO
14000 standard series.
-------
Again, DOI supports the intent of the CEMP and would appreciate
EPA's efforts to facilitate implementation of CEMP government-
wide, particularly at the field level. If you have any
questions, please contact Jim Ortiz, of my office, at
(202) 208-7553.
Sin
lylor s^)
Director *^
Office of Environmental Policy
and Compliance
-------
U.S. Department of Justice
20530
NOV 13
Mr. Steven A. Herman
Assistant Administrator for Enforcement
Compliance Assurance
Environmental Protection Agency
Room 3204, Ariel Rios Federal Building
1200 Pennsylvania Avenue, NW
Washington, DC 20O44
Dear Mr. Herman:
Lois J. Schiffer, Assistant Attorney General, Environment and
Natural Resources Division, referred your recent letter to her
concerning the code of Environmental Management Principles (CEMP)
to my office for action. As the Assistant Attorney General for
Administration, responsibility for the Department's internal
environmental management program falls under my general
responsibilities.
We, of course, endorse the concepts and objectives embodied in
the CEMP for Federal agencies. As your letter recognizes, some
of our components have already implemented internal systems and
approaches to address their environmental responsibilities.
Therefore, we appreciate the flexibility identified in your
letter and intend to encourage our components to move toward the
implementation of the CEMP principles in a manner which is most
appropriate for their needs.
Almost two years ago, I made a commitment to strengthen the
Department's environmental program by assigning additional staff
and resources. I also gave the program greater visibility by
elevating it organizationally to report directly to a Deputy
Assistant Attorney General for Administration. The newly
designated Department of Justice (DOJ) Environmental Executive
regularly participates in my executive staff meetings which
provide him the opportunity to bring environmental program
concerns to my immediate attention.
During the past year, we sponsored several briefings on
environmental and energy conservation topics for Departmental
program managers and administrative staff. These included
briefings by representatives from the Environmental Protection
-------
Mr. Steven A. Herman 2
Agency (EPA) on the Green Lights Program and the Energy Star
Program. At our request, Fran HcPoland, the Federal
Environmental Executive, arranged briefings for Departmental
program managers on recycled vehicular products and the use of
copier paper with post consumer content. We have successfully
supported the efforts of several of our bureaus to obtain funding
to address significant, long-standing environmental issues. The
Drug Enforcement Administration has embarked on a $21 million
dollar multi-year program to replace four of its regional
laboratories that have outmoded environmental systems. The
Immigration and Naturalization Service has initiated a five-year,
$21.5 million dollar, nationwide project to replace leaking
underground fuel storage tanks, other components in the
Department are addressing environmental concerns associated with
lead hazards in' indoor firing ranges, as veil as, lead-based
paint in residential housing. r ,
Next spring we will start a seven-year, $150 million dollar,
renovation of the Main Justice Building which will include the
installation of state-of-the-art energy efficient HVAC equipment,
insulated window glazing, and high efficiency electrical and
water system equipment. Our Bureau of Prisons (BOP) has been a
strong supporter of enhanced environmental, pollution reducing,
and energy conserving programs. BOP has instituted a program of
environmental self-audits and expects to have completed six such
audits by the end of this fiscal year. BOP also instituted a
comprehensive environmental recycling program for core items at
its institutions. This project was identified for recognition in
PY 96 and was submitted for consideration under the second annual
White House Closing the Circle Awards. Recently, BOP entered
into its first renewable energy savings contract for an
innovative project in its Phoenix, Arizona Federal Correctional
Institution. The contract provides for pre-heating domestic hot
water using solar energy as the renewable energy source and has
long-range energy savings potential.
These projects are cited as examples which reflect awareness of
our environmental responsibilities and our support of the
environmental challenge prpgram. During the remainder of this
fiscal year, the Department will continue its efforts to provide
leadership, direction and support to its components' programs.
Our thrust will be to establish a more systematic basis for
insuring compliance and accountability. We recently hosted a
briefing by Don Franklin of your office on EPA's FEDPLAN-PC
information management system which was attended by
representatives from all DOJ components. Components are now
evaluating their reporting responsibilities under FEDPLAN-PC and
will determine if they will use this system for tracking
nonreportable environmental projects. In following-up on this
briefing, we asked each component to identify active, planned, or
-------
Mr. Steven A. Herman 3
anticipated environmental projects, once this information is
reported, the Department will have a basis to provide oversight
and assistance for the environmental projects underway or planned
throughout the Department.
In addition, we have recently drafted our first proposed
Departmental policy guidance document on pollution prevention,
control and energy conservation. When issued, it will serve as
basic program guidance for all Departmental components and
incorporate the essential elements of the CEKP. AB we mentioned
earlier, our bureaus with significant environmental issues have
already implemented some type of environmental management system
to track compliance, accountability, and progress at their
facilities. In promulgating our guidance, we will share
information with all of our components about the environmental
management system standards described in the enclosure to your
letter and urge them to evaluate them and consider adopting one
if it appears to be beneficial.
If you have any questions regarding our response, your staff may
contact Warren Oser, Department of Justice Environmental
Executive, on 202-514-0458.
Sincerely,
for Administration
cc: Lois J. Schiffer
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115. Department of Assistant Secretary 400 Seventh St., S.W.
Ttanspertotian for Administration Washington, D.C. 20590
October 30, 1996
Mr. Steven A. Herman
Assistant Administrator
Federal Facilities Enforcement Office
Office of Enforcement and Compliance Assurance
United States Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Herman:
Thank you for your letter regarding the Code of Environmental Management Principles for
Federal Agencies (CEMP). The Department of Transportation is committed to quality
environmental program management and agrees with the spirit and intent of the CEMP.
We already have initiatives which address many of the CEMP principles and we are making
significant efforts toward the goal of improving our existing environmental management
systems. As we progress, the principles will be a valuable internal benchmarking tool. We
intend to support these principles to the maximum extent feasible given our existing resources
and current budget constraints.
If you have any questions regarding this comment please call Christina Barrett of my staff on
202-366-0038.
Sincerely,
Melissa J. Spillcnkothen
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DEPARTMENT OF THE TREASURY
WASHINGTON, D.C.
December 10,1996
Mr. Steven A. Herman
Assistant Administrator for
Enforcement and Compliance Assurance
Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
Dear Mr. Herman:
Thank you for your letter regarding the Code of Environmental Management Principles for
Federal Agencies (CEMP). The Department of the Treasury fully supports the goals of the
CEMP process, and we look forwarding to continuing to work with the Interagency Pollution
Prevention Task Force on its implementation.
We have taken a number of initiatives, over the last few years, toward improving the
environmental management program here at Treasury. All bureaus are required to conduct
environmental surveys to determine their compliance status. Pollution Prevention strategies and
plans have been developed for our facilities.
CEMP provides a valuable plan fof future activities. We arc also examining the potential for
implementation of the ISO 14001 Environmental Standard at our facilities. We are moving
forward with these programs to the maximum extent that our existing resource levels permit.
If you have any questions, please call me at (202) 622-0043.
Sincerely,
Bill McOovem
Environment and Energy
Programs Officer
Mad* from lUuyded U.S. Currency
-------
UNITED STATES ENVIRONMEN
WASHINGTON,
MTW
**"
OFFICE OF
ADMINISTRATION
ANDRESOURCES
MANAGEMENT
MEMORANDUM
SUBJECT: Commitment to the Code of Environmental Management Principles
FROM:/^AlvinM.Pesachowitz llla/lJOf (1 '/L _
J*S Acting Assistant Administrator MM* ^ ' V ^ --
TO: Steven A. Herman, Assistant Administrator
Office of Enforcement and Compliance
This memorandum responds to your request concerning the Agency's plans to implement
the Code of Environmental Management Principles for Federal Agencies^ announced in the
October 16, 1996 Federal Register. As EPA's Designated Official for Safety, Health and
Environmental Management, I can assure you that EPA is committed to adopting the Code and
incorporating its principles throughout the Agency. I have coordinated this response with
James S. Mathews, Office of Solid Waste and Emergency Response (5101), who serves as the
Agency's Environmental Executive, and will coordinate the implementation of these principles
with him.
By implementing these principles throughout EPA, the Agency's internal environmental
management practices will be significantly improved. We have documented, through our
extensive audits and program reviews, that the level of compliance is directly related to the quality
of environmental management systems and visible management commitment.
Although we have integrated several of these environmental management principles into
the Agency's Safety, Health and Environmental Management (SHEM) Program, we think we can
do better. We have updated many of our program documents and issued memorandums from the
Deputy Administrator and myself to enhance the understanding of these responsibilities by senior
managers. We want to ensure the Agency's business is conducted in a manner that protects the
environment and its employees from harm. We have developed Pollution Prevention Plans for
each of EPA's facilities and are trying to integrate waste reduction into the work ethic and culture
of EPA employees. We are using technology-based job tools to improve program delivery, to
help our environmental officials, and to reduce program operating costs. We measure the
Agency's environmental performance through internal technical audits and program reviews.
Fttcyctod/RaeyelablB
Prinnd«lth Sey/Canola Ink on wpvr mat
contain* al ban so* racycted life*
-------
If your stafFhu the time, we would appreciate your Office's review of both the quality
and the scope of our program, and would appreciate your ideas for assessing customer
satisfaction.
I have asked Julius C. Jimeno, Director, Safety, Health and Environmental Management
Division, to meet with Craig Hooks and discuss how we might "bench mark" the Agency's efforts
and incorporate more aspects of the environmental management principles into our SHEM
Program.
cc: John C. Chamberlin
Julius C. Jimeno
James H. Mathews
-------
Deputy Administrator
General Services Administration
Washington, DC 20405
December 2, 1996
Mr. Steven A. Herman
Assistant Administrator
Office of Enforcement and Compliance Assurance
Environmental Protection Agency
Washington, DC 20460
Dear Mr. Herman:
Thank you for your letter of September 3,1996, requesting a brief statement
declaring the General Services Administration's (GSA's) support for the Code of
Environmental Principles (CEMP). You also requested a concise explanation of
how GSA plans to implement the CEMP at the facility level.
GSA fully endorses the principles of the CEMP. Our agency currently has an
environmental management plan and will use it to implement the CEMP at the
facility level. GSA's current environmental management plan includes:
1) designation of a Senior Executive to serve as GSA's Environmental
Executive empowered to cut across organizational lines, facilitate the
development of agency-wide goals, and report directly to the Deputy
Administrator on environmental matters;
2) formation of an agency-wide Environmental Program Council (EPC)
composed of representatives from all GSA service and staff offices to
assist GSA Environmental Executive in the development of agency-wide
goals and review the status and achievement levels for all GSA
environmental programs;
3) the GSA Pollution Prevention Strategy of August 1994. The strategy
lays out GSA's pollution prevention goals, identifies the pollution
prevention activities in which GSA currently engages, and lists GSA's
pollution prevention innovative technologies that exceed the requirements
of E.0.12856;
4) development of sample guidelines for a facility pollution prevention
plan that provides detailed information on How a facility can help reduce
the use and storage of toxic chemicals 50 percent by 1999;
Federal Recycling Program W-Ji\ Printed on Recycled Paper
-------
-2-
5) designation of environmental and recycling program coordinators at
GSA regional office level to implement and monitor their respective
programs at all GSA regional offices, field offices, and all other GSA-
owned and -operated Federal buildings; and
6) preparation of quarterly and annual reports on the status and
accomplishments of all existing GSA environmental programs.
My staff and I look forward to working with you to make the Federal Government
a leader in pollution prevention. The CEMP is certainly a positive step toward
meeting this important goal.
Sincerely,
Thurman M. Davis, Sr.
Deputy Administrator
Federal Recycling Program Wvm Printed on Recycled Paper
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DEPARTMENT OF HEALTH Ct HUMAN SEAVICES Office of the Secretary
Washington. O.C. 20201
SEP 27 1995
Steven A. Herman.
Assistant Administrator
U.S. Environmental Protection Agency
Office of Enforcement and Compliance
401 M Street, SW
Washington, D.C. 20460
Dear Mr. Herman:
This letter responds to your September 3, 1996 request for a
brief statement from the Department of Health and Human Services
supporting the Code of Environmental Management Principles
(CEMP) .
The Department of Health and Human Services (HHS) strongly
supports and is committed to CEMP. To implement CEMP at our
facilities, HHS will include CEMP principles in the HHS General
Administration Manual on Environmental Protection and in the near
future, HHS plans on initiating an "Environmental Protection
Newsletter" to assist us in educating employees at our facilities
to develop a more proactive and integrated approach to
environmental protection/pollution prevention.
If you need additional, information, please contact Dick Green on
(202) 619-1994.
Terrence J. ychan, HHS
Environmental Executive
-------
National Aeronautics and
Space Administration
Headquarters
Washington, DC 20546-0001
SEP 30 I995
Reply to Ann of:
Mr. Steven A. Herman
Assistant Administrator
Office of Enforcement and Compliance Assurance
U. S. Environmental Protection Agency
Washington, DC 20460
Dear Mr. Herman:
The National Aeronautics and Space Administration (NASA) has already embraced the
principles put forth in the Code of Environmental Management Principles (CEMP) and fully
endorses them on an Agencywide basis. The NASA Strategic Plan recognizes our
responsibility to preserve the environment as one of the four strategic outcome activities
contributing significantly to the achievement of the Nation's science and technology goals and
priorities.
Additionally, the NASA Environmental Excellence for the Twenty-First Century states:
"Environmental Excellence is not a program, nor can it be achieved through a policy
statement. Environmental excellence is a way of life and must be ingrained as part
of our culture", and, "Our Agencywide impact on the global environment must be
able to withstand the scrutiny of the international community. No one person can do
this alone, but working together, the entire NASA community-civil service contractor
alike-can make the vision a reality."
One of the avenues NASA is investigating to fully implement CEMP principles at the facility
level is the ISO 14001 process. Currently, we are forming a working group that will analyze
ISO 14001 requirements and make recommendations on implementing the standard. Several
organizations have been identified that can provide the necessary training and education to
facilitate this process. A number of NASA Centers have already begun incorporating ISO
14001 standards into their policy documents.
-------
Please be assured that NASA fully endorses the CEMP principles and has already incorporated
them into our environmental policy and goals. Our focus now is to fully implement those
principles throughout the Agency. If you have any questions regarding this effort, please
contact Ms. Olga Dominguez at 202-358-0230.
Sincerely,
Benita A. Cooper
Associate Administrator for
Management Systems and Facilities
cc:
JE/Ms. Dominguez
ARC/223-l/Ms. Offlges
DFRC/D-44809B/Mr. Ambrose
GSFC/205.0/Mr. McNeil
JPL/301-420/Mr. Buril
JSC/JJ12/Mr.Hickens
KSC/DE-EMO/Mr. Wright
LaRC/429/Mr. Lee
LeRC/3065/Mr. McCaUum
MSFC/AEOl/Ms. McCaleb
MAF/SA39/Mr. Celino
SSC/GAOO/Mr. Magee
WSTF/RA/Mr.Amidei
WFF/205/Mr. Potterton
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ENGINEERING
UNITEDSTATES
POSTAL SERVICE
September 30,1996
Mr. Steven A. Herman
Assistant Administrator
Office of Enforcement and Compliance Assurance
U. S. Environmental Protection Agency
Washington, DC 20460
Dear Mr. Herman:
Your September 3 letter to Mr. Gerald McKieman was forwarded to my office for response. The
Postal Service supports the Code of Environmental Management Principles (CEMP). Attached is
our strategy for the implementation of the CEMP. We are continuing our investigation and
evaluation of IS014001 for its implication and applicability to our organization. Thank you for
keeping us informed on the progress of your environmental ventures.
Please contact Paul Fennewald at (202) 268-6239 or me at (202) 268-6188 if you have any
questions.
Sincerely,
Charles E. Bravo
Manager
Environmental Management Policy
Attachment
cc: Mr. Dowling
Mr. McKieman
Mr. Edward
475 L'ENFANT PIAZA SW
WASHINGTON DC 20260-2810
FAX: 202-268-6016
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UNITED STATES
POSTAL SERVICE
Strategy for Implementation of
Code of Environmental Management Principles (CEMP)
for Federal Agencies
I. Management Commitment: The agency makes a written top management
commitment to improved environmental performance by establishing policies
which emphasize pollution prevention and the need to ensure compliance
with environmental requirements.
- *
The United States Postal Service (USPS) has a Policy for Environmental
Protection which is signed by the Postmaster General. The policy commits
the Postal Service to provide employees and customers with a safe and
healthy environment and promotes seven "Guiding Principles" that promote
Environmental Protection as a responsible thing to do, and as a sound
business practice.
(See Attachment I - Policy for Environmental Protection)
The USPS environmental function was placed in the operations and facilities
portion of the organization and the environmental responsibility was placed
on line management with environmental personnel providing technical
guidance and assistance to the field in implementing environmental policies
and procedures.
II. Compliance Assurance and Pollution Prevention: The agency
implements proactive programs that aggressively identify and address
potential compliance problern areas and utilize pollution prevention
approaches to correct deficiencies and improve environmental performance.
An Environmental Strategic Plan was developed for the period 1993 - 2000.
The plan's strategies and actions were aligned with the Policy for
Environmental Protection and its Guiding Principles. The plan initially
contained 117 tactical actions towards the goals of achieving compliance and
leadership. The tactical action plan is flexible with the ability to integrate
additional tasks and target areas as needed.
(See Attachment II - Annual Status Report Memo, October 16,1995)
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III. Enabling Systems: The agency develops and implements the necessary
measures to enable personnel to perform their functions consistent with
regulatory requirements, agency environmental policies and its overall
mission.
The Postal Service also provides Environmental Target Areas to its Area and
District personnel to provide focus and direction for developing and
implementing plans at the Area, District and Plant levels. Two major
categories of environmental target areas have been identified:
1) Leadership targets which are intended to establish the USPS as a
leading organization in environmental initiatives, and
2) Compliance targets which are intended to reduce liability and ensure
USPS compliance with federal, state and local laws and regulations.
(See Attachment III - Environmental Target Areas)
IV. Performance and Accountability: The agency develops measures to
address employee environmental performance and ensure full accountability
of environmental functions.
In keeping with its guiding principle
"We will incorporate environmental considerations into our business planning
processes"
the Postal Service continuously monitors progress and updates the Tactical
Actions in its Environmental Strategic Plan to reflect many new ideas, target
areas and programs.
Since Postal Service employees are accountable for environmental
objectives through the Policy for Environmental Protection, it was integrated
into personnel evaluations to reinforce personnel accountability.
V. Measurement and Improvement: The agency develops and implements a
program to assess progress toward meeting its environmental goals and
uses the results to improve environmental performance.
The Postal Service implementation strategy for Measurement and
Improvement is based on the following Guiding Principle:
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"We will measure our progress in protecting the environment."
and is defined in the USPS Environmental Strategic Plan 1993-2000:
TRACK PROGRESS
Define performance criteria for key target areas of environmental concern.
Establish and maintain a national information system to monitor
environmental performance and compliance.
Establish procedures for allocating resources to and monitoring the costs
of national environmental initiatives.
The USPS utilizes a concept known as Environmental Information Services
and Support (EISS) to gather, analyze and distribute data and information
through the Postal Routed Network (PRN) to Postal environmental
professionals and personnel throughout the United States. EISS currently
consists of a bulletin board system (an environmental and safety information
source module on the Customer Service Bulletin Board System (CSBBS)).
The USPS is developing an electronic Environmental Management
Information System (EMIS) that will be linked to the Environmental
Management Policy worldwide web homepage. The homepage will give easy
access to stored information, currently not available on CSBBS, through
EMiS. EMIS will be capable of storing and disseminating large amounts of
environmental information focused on key target areas of environmental
concern and essential to daily Postal Service operations.
Through EMIS, resources may be allocated and costs of national
environmental initiatives may be monitored more effectively through shared
information resources.
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UNITED STATES
POSTAL SERVICE.
UNITED STATES POSTAL SERVICE
POLICY FOR
ENVIRONMENTAL PROTECTION
POLICY
The United States Postal Service is committed to provide
employees and customers with a safe and healthy environment.
Environmental protection is the responsible thing to do, and
makes for sound business practices.
GUIDING PRINCIPLES
m We will meet or exceed all applicable environmental laws and
regulations in a cost effective manner.
We will incorporate environmental considerations into our
business planning processes.
We will foster the sustainable use of natural resources by
promoting pollution prevention, reducing waste, recycling, and
reusing materials.
We will expect every employee to take ownership and
responsibility for our environmental objectives.
We will work with customers to address mutual
environmental concerns.
We will measure our progress in protecting the environment.
We will encourage suppliers, vendors, and contractors to
comply with similar environmental proto^n&n policies.
Marvin Runyon
Postmaster General
September 1995
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UNITED STATES
POSTAL SERVICE
October 16,1995
MEMORANDUM FOR LEADERSHIP TEAM
SUBJECT: Annual Status Report
Attached is a copy of the Annual Status Report of the Postal Service's Environmental
Strategic Plan.
During this past year, we have made substantial progress in the development of our
environmental program. In addition, we have also been recognized nationally, through
various environmental awards, as a leader in environmental excellence. We are
continuing to make superb progress in achieving our goal in making environmental
excellence an integral part of the way we do business.
We are pleased to provide you with this Annual Status Report of our environmental
efforts. If you have any questions, contributions, or suggestions, please feel tree to
act nae
Charles E.Bx
Manager
Environmental'Management Policy
cc: Area Environmental Compliance Coordinators
District Environmental Coordinators
475L'&**wPu«ASW
WAWWOTON DC 20260
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UNITED STATES POSTAL SERVICE
ENVIRONMENTAL STRATEGIC PLAN
STATUS REPORT
SEPTEMBER 30, 1995
Two years ago we developed a comprehensive Environmental Strategy Plan for the
1993-2000 period. The plan's strategies and actions were aligned with the Environmental
Guiding Principles issued by the Postmaster General in April of 1993 and reissued in
September 1995 (enclosed). To support this commitment to a strong and active
environmental program, the Postal Service identified 10 target areas -- categorized as
either leadership or compliance targets to provide focus and direction for developing
and implementing plans at the Area, District and plant/facility level. Those original 10
environmental target areas has now been expanded to include Energy and Water
Conservation (enclosed).
The plan initially contained 117 tactical actions put forth with a view towards achieving
two principle goals:
Compliance with federal, state, and local laws and regulations by postal facilities at
all levels.
Leadership objectives that establish us as a leading organization in environmental
issues.
Integrating the consideration of the environment into our everyday business decision-
making process continues to evolve as shown in this status report. The results of this
comprehensive program have exceeded our expectations and served as a catalyst for
many new ideas and programs. As stated earlier, the energy conservation function has
been integrated within Environmental Management Policy and will be expanded to
include water conservation. We expect a number of new tactical action items developed
over the coming months related to this new target area. What began as 117 separate
tactical actions and increased to 135, has now been pared down to 105. To date, 67
tactical actions have been completed, in which 46 have been embedded into continuing
programs, with 38 tactical actions ongoing and are continuing to progress (Chart 1). This
progress indicates that the managers are buying into the Environmental Strategic Plan.
Enclosed are listed some of our most significant environmental achievements during the
past two years. Although we have made significant progress carrying out our Strategic
Environmental Plan, we still have some important challenges ahead of us. Listed below
are some of the challenges we face in the coming year:
Set goals, develop strategies, and establish programs for the Energy and Water
Conservation target area.
Expand the application of the NEPA process to operational activities and improve the
integration of environmental consideration into our business planning process.
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Establish DECs in every district and ensure they are adequately trained to assume
their responsibilities.
Update, test, and field the Progress in Environmental Protection - Management
Information System (PEP-MIS) and the Customer Service and Sales Bulletin Board
System (CSBBS).
Expand our environmental awareness programs and continue reaching out to our
employees, and suppliers, venders, and contractors.
Intensify our efforts in pollution prevention, recycling, and waste reduction.
r ,
The progress we have made is attributed to the diligent work of the Work Groups and
their corporate sponsors (Chart 2). They were charged with developing the programs that
answered the "how to" to comply with the tactical actions. They, in turn, provided
headquarters, Environmental Management Policy, with updates on their progress.
Chart 3 represents the current distribution by lead office, of the ongoing tactical actions
that are at various stages of completion. This Annual Status Report comprises the details
of the work groups to date.
The attached tabular summary is organized as follows:
Column I Tactical Action Plan
Of the 135 tactical actions plans, 30 have been combined with like actions
(deleted).
The current tactical action plans are numbered 1 to 105.
Column n Contacts
The following is the key for the listings in the contacts column:
The first item is the Lead Office
The second item is the Point of Contact
The third item is the telephone number of the Point of Contact
The fourth item is the Corporate Sponsor
Column HI Concepts
The concept is the work groups "how to" to develop a solution to the
Tactical Action Plans.
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Column IV Status
This is the status of the tactical action as of September 30,1995.
Column V Next Step
This column identifies any future efforts necessary to complete the tactical
action.
Chart 1 Environmental Strategic Plan
Status of the 135 Tactical Action Plans as of September 30,1995.
Chart 2 Environmental Strategic Plan
Distribution of the current 105 Tactical Actions by Lead Office as of
September 30,1995.
ChartS Environmental Strategic Plan
Distribution of the current 38 Ongoing Tactical Actions by Lead Office as
of September 30,1995.
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ENVIRONMENTAL TARGET AREAS
Leadership Targets
Compliance Targets
Underground Storage
Tanks
- Establish monitoring procedures
& reduce number of USTS
\
Clean Air Act Amendment
- Reduce emissions
- Develop plan to use alternate fuels
Hazardous Chemicals'
- ID hazardous substances & use
environmentally safe alternatives
Paint Spray Operations
- Reduce total number
Main Transport Equipment
- Reduce wastestreams & increase
lifecycle of materials
Recycling & Pollution
Prevention
- Conduct P2 assessments, develop
recycling programs & reduce waste
Regulatory Outreach
- Work with regulators & local
officials
',-
Sensitivity to State & Local
Regulations
- Be active with associations & local
government activities
Awareness Training
(culture change)
- Train at all levels & increase
environmental awareness
Quality Assurance Reviews
- Conduct QARs & implement
corrective actions
Energy & Water
Conservation
- Set goals, develop strategies &
establish programs
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June 21.1996
ENVIRONMENTAL TARGET AREAS
Environmental Target Areas provide focus and direction for developing and implementing plans at
the Area and District and Plant levels. Two major categories of environmental target areas have
been identified: (1) leadership targets which are intended to establish the DSPS as a leading
organization in environmental initiatives; and (2) compliance targets which are intended to
reduce liability and ensure USPS compliance with federal, state and local laws and regulations.
LEADERSHIP TARGET AREAS
1. Underground Storage Tanks
Tanks used for underground storage of fuels and hydraulic fluid present the potential for
leakage and high cost for remittal, penalties, and fines.
Reduce number of underground storage tanks
Complete surveys and upgrade remaining tanks
Establish monitoring and inspection procedures
Establish monitoring and inspection requirements for above ground tanks required by
state and local laws
2. Clean Air Act Amendments
Increasingly stringent amendments of the CAA will impose compliance requirements for
reducing emission sources and using alternate fuel vehicles.
Identify applicable laws, regulations
Reduce emissions from stationary sources, e.g., underground storage tanks, paint spray
booths, diesel generators
Develop plans to use alternate fuels
Increase the utilization of alternate fuel vehicles
Obtain air credits and rebates, wherever possible
3. Hazardous Chemicals
Many postal facilities use chemicals which are identified as hazardous waste for cleaning,
repairing, printing and painting operations.
Identify hazardous substances
Determine potential for substituting environmentally safe alternatives
Work to reduce the generator status to conditionally exempt, wherever possible
4. Paint Spray Operations
Numerous environmental laws apply to paint spray operations including the Clean Air Act and
the hazardous waste laws. In addition, most postal systems are not the most efficient as noted
in the Buffalo Pollution Prevention Study performed by EPA.
Minimize liability and reduce costs by reducing total number of paint spray operations
Convert remaining operations to most efficient technologies including High Volume Low
Pressure Systems (HVLP) and low volatile organic paints
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5. Recycling/Pollution Prevention (P*)
Activities in support of recycling and pollution prevention generate revenue, save money and
reduce liability. Increasing our activities in these endeavors increases customer and employee
satisfaction and identifies the Postal Service as a good neighbor and leader in environmental
issues. Moreover, these initiatives support sustainable development for future generations.
Complete Pa plans at all plants, VMFs. and large AOs
Establish procedures for wastestream assessment at all facilities
Select methods for recycling, e.g., Southwest Area model
Reduce/eliminate disposal contracts
Generate revenue from recycling activities
6. Mail Transport Equipment
Much of the waste generated at a plant is cardboard, plastic, shrink-wrap, and pallets used in
handling mail.
Establish strategies to reduce wastestream and increase life cycle of materials including
use of long-life pallets,' reusable trays
Establish recycling programs of MTE items
Work with MTE centers on recycling
COMPLIANCE TARGET AREAS
1. Quality Assurance Reviews
A review system Is essential to (1) identify and ensure compliance with environmental
regulations in all facilities and (2) to identify and monitor implementation of corrective measures
and improvements.
Implement immediate corrective actions
Implement pollution prevention initiatives
Change applicable work practices
Initiate review and evaluation process in all "high-risk" facilities on a regular basis
Establish a follow-up program
Ensure VMFs and Plants conduct a self-review (brief checklist) annually (e.g., VMF model
review, section six)
2. Regulatory Outreach
Effective compliance with applicable laws and regulations requires consistent interaction with
regulators who monitor public and private organizations. Developing good working
relationships with regulators ensures awareness of regulatory changes and increases timely
compliance.
Participate in award programs sponsored by regulatory agencies
AECCs and DECCs should work with appropriate regulators to help affect federal, state
and local laws which are beneficial to the environment and the Postal Service
Participate in Regulatory Task Forces and industry groups
Attend conferences and workshops sponsored by regulatory agencies
Encourage facility managers to contact appropriate local environmental officials
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3. Sensitivity to State and Local Regulations
To enhance the Postal Service's position as a good neighbor and leader in environmental
initiatives, community outreach and environmental practices need to match local laws and
regulations. Postmasters, managers, environmental professionals and other employees need
to more actively participate in state and local activities.
Managers and environmental professionals should participate in associations and local
government activities
Encourage employees at all levels to participate in appropriate environmental activities,
e.g., local government recycling programs, local Earth Day events
Provide Postmasters Training and state specific Postmasters Guides
4. Awareness Training (Culture Change)
Successful implementation of environmental initiatives first requires an organization-wide
awareness and understanding of roles and responsibilities to increase compliance with
applicable laws and regulations.
Provide multi-media training at all levels on environmental issues and initiatives
Develop communications initiatives to increase employee awareness
Brief union and management association leaders to stimulate environmental awareness
Provide local training and/or have key environmental stakeholders attend environmental
training at the Technical Training Center
5. Energy Savings Program
Energy savings techniques and technologies will be implemented to meet the Energy Policy
Act (1992) requirement of a 20% reduction in energy use by the year 2000. In addition,
strategies will be implemented to achieve water conservation.
Designate Energy Coordinators
Implement high ROI projects
Focus on lighting opportunities with new technology
Use shared energy savings as appropriate
Implement demonstration projects
Evaluate renewable energy opportunities
Review energy rates to obtain best values
Promote environmental awareness
Conduct training on energy
Target high energy rate utilities/areas
Partner with other federal agencies when aggregating (GSA, DOE, DQD) and negotiating
with utility companies
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USPS ENVIRONMENTAL PROGRAM
SIGNIFICANT ACHIEVEMENTS
District Environmental Coordinators
In the final stages of establishing DECs in each District
Expanding Alternate Fuel Program
More than 4,185 vehicles converted to compressed natural gas with plans to
increase to 6,500 by the end of 1995.
Testing ethanol-fueled and electric powered vehicles.
Leading an international effort on studying alternative fuels with the Universal
Postal Union.
Recycling and Pollution Prevention
Developed a National Strategy.
VMFs are reducing the number of chemical line items which has resulted in cost
avoidance related to hazardous materials management and cost savings through
waste reduction of less frequently used chemicals.
Significantly expanded our recycling effort both in what we purchase and what
we discard, especially in UBBM.
Using recyclable material in many of our Mail Transport Equipment.
More than 400,000 tons of wastepaper, cardboard, plastics, cans, and other
material were recycled last year. These activities generated about $6.4 million in
revenues this year.
The Postal Service is a national leader in the use of re-refined oil. More than
100,000 postal vehicles currently use re-refined oil.
Underground Storage Tanks
Removed over 500 nationwide since 1992.
Issued a new MI establishing guidance that will minimize the installation of
additional tanks.
Paint Spray Operations
Sixty-nine painting operations have been deactivated, with the remainder either
discontinuing, consolidating, or upgrading their painting operations.
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Significant Achievements (continued)
Reduction of Hazardous Waste
Issued a new policy goal to virtually eliminate 17 targeted chemicals by 1998.
We are on target to achieve a 50% reduction by the end of this year.
Developing a new MI on integrated Pest Management.
Environmental Awareness and Training
Sixteen environmental courses are now offered at the TTC.
Environmental content is being embedded into 45 other courses.
Over 20,000 employees have received environmental training in 1995.
Environmental awareness is part of new employee orientation.
Updated and revised the Environmental Resources Handbook that outline
environmental roles and responsibilities.
Using PSTN, video-conferencing, articles in the postal bulletin, and special
events such as Earth Day to increase environmental awareness.
Quality Assurance Reviews (OARs)
Completed the development of a QAR manual and MI.
Conducted over 105 QARs in which 60 were conducted this year.
National Recognition for Environmental Leadership and Excellence
Recognized by government and industry for environmental leadership and
excellence.
Received several White House and industry awards for recycling and waste
reduction programs.
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QCT 3 11SS6
Mr. Steven A. Herman, Assistant Administrator
Office of Enforcement and Compliance Assurance
Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
Dear Mr. Herman:
7VA appreciates the opportunity to participate in the Interagency Pollution Prevention
Task Force that is developing the Federal Government Environmental Challenge
Program and the Code of Environmental Management Principles (CEMP).
TVA has developed and commenced implementation of a state-of-the-art
Environmental Management System (EMS) to ihlegrate environmental management
into business planning and operations ensuring that resources are committed to carry
out TVA's environmental goal. The TVA EMS was designed concurrently with the
development of the ISO 14001 Environmental Standard and the CEMP and has been
aligned to the extent practicable with both.
Presently, our operations management is reviewing.the CEMP as it relates to the TVA
EMS to determine the implications on the operation of their facilities. Once their review
is complete, we will provide you with more definitive information on TVA's position and
plans regarding the CEMP.
If you have questions relating to TVA's Environmental Management System and its
relationship to the CEMP, please contact Jon Loney at (423) 632-3012.
Sincerely,
William H. Kennoy. P.E.
LRB:SC '
cc: Craven Crowell, ET12A-K
Johnny H. Hayes, ET 12A-K
Alan Carmichael, ET 12A-K
Kathryn J. Jackson, WT11A-K
Jon M. Lonev. WT 8C-K
Ronald J. Williams, CTR 2C-M
Norman A. Zigrossi, ET 12A-K
Prepared by Lynn R. Brown; reviewed by Jon Loney and Ronald J. Williams; approved
by Kathryn J. Jackson.
GTS Number 080444
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DEPARTMENT OF VETERANS AFFAIRS
DEPUTY ASSISTANT SECRETARY FOR ACQUISITION AND MATERIEL MANAGEMENT
WASHINGTON DC 20420
DEC 24 1993
Mr. Steven A. Herman
Assistant Administrator
U.S. Environmental Protection Agency
Office of Enforcement and Compliance Assurance
401 M Street, SW
Washington, DC 20460
Dear Mr. Herman:
We are responding to your letter regarding the Code of Environmental
Management Principles (CEMP). The Department of Veterans Affairs (VA)
is committed to maintaining the highest level of environmental
compliance at its facilities and in enhancing the management of
environmental programs Department-wide.
We have reviewed the five principles that comprise the CEMP and
believe they provide a sound basis in which to enhance the management
of environmental programs at VA. We intend to develop a VA CEMP that
addresses these principles. My staff is working with other organizations
within VA to affect the foregoing programs. The initial draft will be
available by February 1, 1997.
If you have any questions, contact Mr. John Staudt, Chief,
Environmental Engineering Division (10NB), at (202) 273-5863.
Sincerely,
Gary J. Krump
Environmental Executive
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