United States
Environmental Protection
Agency
Enforcement and
Compliance Assurance
EPA315-B-97-001
March 1997
(2261 A)
»EPA
Implementation Guide
For The Code of
Environmental Management
Principles for Federal Agencies
(CEMP)
-------
This document was prepared by the
Federal Facilities Enforcement Office
(2261-A) in the Office of Enforcement
and Compliance Assurance. Consulting
assistance and document design/layout
services were provided under IAG
number DW89936515.
For additional copies of this document,
please contact:
Priscilla Harrington
U.S. EPA (2261-A)
1200 Pennsylvania Avenue, N.W.
Washington, B.C. 20460
Tel: (202)564-2461
Fax: (202) 501-0069
-------
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
HowDoesthe CEMPTielnto 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, A UTHORITYAND ACCOUNTABILITY 33
4.2 PERFORMANCE STANDARDS 34
7. MEASUREMENT AND IMPROVEMENT (PRINCIPLE 5) 35
5.7 EVALUATE PERFORMANCE 35
5.7.7 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
-------
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
-------
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 THE PRINCIPLES
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.
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.
Code of Environmental Management Principles
Implementation Guide
-------
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
"plan-do-check-act" cycle and the
emphasis on continuous improvement
Environmental Processes in a
Management System
4) Measure } ( 3) Implement
Organization and Resources
Code of Environmental Management Principles
Figure 1
Implementation Guide
-------
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.
Is the CEMP an EMS Standard?
BASIC EMS ELEMENTS
1.
2.
3.
4.
5.
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).
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,
CEMP BACKGROUND SOURCES
1. ISO 14001 EMS Standard (draft)
2. NSF-110 EMS Standard (draft)
3. CMA 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. GEMITQEM materials
10. Wever, "Utilizing a Self Assessment Matrix
for Implementing TQEM"
Code of Environmental Management Principles
Implementation Guide
-------
although EPA has participated strongly in the 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
PLUGGING THE GAPS
A gap analysis is designed to answer the following
questions:
I
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?
Code of Environmental Management Principles
Implementation Guide
-------
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 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 //the
ultimate performance exceeds that
achievable with full compliance.
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
improved 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
Code of Environmental Management Principles
Implementation Guide
-------
MANUAL ELEMENTS REQUIRED FORA
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.
In addition, EPA's National Enforcement Investigation 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]
What You Will Find in This Document
Code of Environmental Management Principles 6 Implementation Guide
-------
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, 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
EMS MANUAL ELEMENTS (cont.)
4. Environmental Requirements
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.
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.
Code of Environmental Management Principles 7 Implementation Guide
-------
Similarly, activities described in the context of one of the principles are often carried throughout other
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
a. Describes a program for ongoing community education and involvement in the environmental
aspects of the organization's operations and general environmental awareness.
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
Code of Environmental Management Principles 8 Implementation Guide
-------
"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 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.
Code of Environmental Management Principles 9 Implementation Guide
-------
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, in 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 on
an agency-wide basis have been received from the 16 agencies that participated in the development of
Code of Environmental Management Principles 10 Implementation Guide
-------
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 in 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 in job descriptions,
and that evaluation criteria for the major job components be prepared in employee's annual work plans.
Thus, persons with environmental responsibilities are evaluated on the performance of those
responsibilities and outstanding performance by installations and individuals is recognized via an awards
Code of Environmental Management Principles 11 Implementation Guide
-------
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 their agency's management system will meet the CEMP. DoE, Dol, and NASA indicated
that their agency's are evaluating the use of ISO 14001 as a management system to meet the CEMP. The
responses from the Department of Health and Human Services (HHS), Department of Transportation
Code of Environmental Management Principles 12 Implementation Guide
-------
(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.
Code of Environmental Management Principles 13 Implementation Guide
-------
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
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
Code of Environmental Management Principles
Implementation Guide
-------
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 in 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
well as develop criteria for evaluating
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
Code of Environmental Management Principles
Implementation Guide
-------
how well overall goals are met. The environmental policy will be the statement that establishes
commitments, goals, priorities, and altitudes.
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.
POSTAL SERVICE GUIDING PRINCIPLES
1. Meet or exceed all applicable environmental laws
and regulations in a cost-effective manner;
2. Incorporate environmental 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.
Appropriate steps to address program integration could include:
Code of Environmental Management Principles
Implementation Guide
-------
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
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
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
Code of Environmental Management Principles
Implementation Guide
-------
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;
! ensure that they utilize their authorities in a
way that facilitates the Ecosystem Approach;
! administer their programs in a manner that is
sensitive to the needs and rights of
landowners, local communities, and the
public;
! 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.
Appropriate steps in creating a culture of
environmental stewardship could include:
Code of Environmental Management Principles
Implementation Guide
-------
ECOSYSTEM CASE STUDIES
The Interagency Ecosystem Management Task
Force has conducted case studies in seven areas
facing extreme environmental stress:
I
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.
Anacostia River watershed;
Coastal Louisiana;
Great Lakes basin;
Pacific Northwest forests;
Prince William Sound;
South Florida; and
Southern Appalachians.
Code of Environmental Management Principles
Implementation Guide
-------
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 the effects of dioxins on living
tissue.
The lack of an underlying regulatory structure can be seen in the
legacy of contamination at CERCL A 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
Implementation Guide
-------
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;
Code of Environmental Management Principles
Implementation Guide
-------
Hold information sessions to explain the purpose and function of the compliance group;
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 in 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).
Code of Environmental Management Principles 22 Implementation Guide
-------
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 for "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
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 the 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.
Code of Environmental Management Principles
23
Implementation Guide
-------
citizen. 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:
I
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
Pollution Prevention Act
Environmental Management Hierarchy
Figure 2
Code of Environmental Management Principles
24
Implementation Guide
-------
environmental requirements." Making this critical link between pollution prevention and compliance
assurance is the key to achieving and maintaining a "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
productive soil.
NPR RECOMMENDATIONS
Improve Implementation of Environmental
Management
1. Improve Federal Decisionmaking 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.
2. Develop Cross-Agency Ecosystem Planning
and Management - the "MOU to Foster the
Ecosystem Approach," described under
Principle 1, demonstrates progress in this area.
water quality, while maintaining greater amounts of
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, timing of
planting, removing land from production for
a period) methods can decrease reliance on
chemical pesticides.
NPR RECOMMENDATIONS (cont.)
Improve Environmental Performance at Federal
Buildings and Facilities
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. Another aPProach 1S 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
Prevention of livestock waste material is not
a realistic goal, but it can be appropriately
managed to lessen environmental impacts.
Code of Environmental Management Principles
25
Implementation Guide
-------
clearing of land. Resource conservation strategies should be consistent with the agency's approach to
environmental stewardship and sustainable development (see Principle 1).
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, 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.
Code of Environmental Management Principles 26 Implementation Guide
-------
CHAPTER 5: ENABLING SYSTEMS (PRINCIPLE 3)
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 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-time 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 in 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 OSF£A 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 in 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;
! Train the trainers, if necessary;
! Establish periodic refresher training (e.g., 8-hour vs. 40-hour OSF£A 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.
Code of Environmental Management Principles 27 Implementation Guide
-------
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. to ensure currency.
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
WEAVING THE WEB INTERNALLY...
Many organizations are using the World Wide Web
(WWW) to disseminate environmental and other
information to the people who carry 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
Enviro$en$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 locations.
Code of Environmental Management Principles
28
Implementation Guide
-------
information available through the Internet (particularly the World Wide Web), organization intranets
(internal networks that utilize Internet technologies), and other commercial group software packages.
NEPA
Superfund Sites
Federal Agency
Environmental Compliance
Management System
Site Summary
Compliance Summary
RCRA: 3 USTs tested
CWA: NPDES permits amended
TSCA: PCBs removed
Figure 3
Code of Environmental Management Principles
29
Implementation Guide
-------
Figure 3 offers a conceptual depiction of the multiple 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 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.
...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 Enviro$en$e 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 Enviro$en$e, the Federal Facilities Environmental
Leadership Exchange (FFLEX) provides pollution prevention
strategies and other information of interest to the public sector.
Similarly, although not environmentally-related, the Internal
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
Code of Environmental Management Principles
30
Implementation Guide
-------
aware of this "tiering" effect and take steps to address it in order to maintain smooth
operations to the extent possible.
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;
Code of Environmental Management Principles 31 Implementation Guide
-------
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 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).
Code of Environmental Management Principles 32 Implementation Guide
-------
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
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 relatively
easy way for CFAs to begin to improve their
performance..."
EPA EMS Benchmark Report, December 1994
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);
! Issue, as necessary, statements defining
the authority for carrying out assigned
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.
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.
Code of Environmental Management Principles 33 Implementation Guide
-------
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 that 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:
I
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.
Code of Environmental Management Principles
34
Implementation Guide
-------
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
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.
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.
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 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.
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.
Code of Environmental Management Principles 35 Implementation Guide
-------
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 the agency's plan (e.g., in 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.
Appropriate steps to address performance
measurement could include:
I
Develop procedures to convey system measurements
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;
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 in FY 1999;
! prepare annual reports comparing performance to goals beginning in 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.
Code of Environmental Management Principles
36
Implementation Guide
-------
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, requires its winners to
share their strategies with other
organizations seeking improvements.
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
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
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.
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.
Code of Environmental Management Principles
37
Implementation Guide
-------
During 1993-94, EPA surveyed 21federal 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
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.
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.
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;
Code of Environmental Management Principles 38 Implementation Guide
-------
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
-------
CHAPTER 8: 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 in 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).
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
Code of Environmental Management Principles 40 Implementation Guide
-------
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.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
Corporate Priority
Integrated Management
Process of Improvement
Employee Education
Prior Assessment
Products and Services
Customer Advice
Facilities and Operations
Research
Precautionary Approach
Contractors and Suppliers
Emergency Preparedness
Transfer of Technology
Contributing to the Common Effort
Openness to Concerns
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 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
Code of Environmental Management Principles
41
Implementation Guide
-------
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.
Code of Environmental Management Principles 42 Implementation Guide
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 1: MANAGEMENT COMMITMENT
LEVEL
1.1 OBTAIN MANAGEMENT SUPPORT
Policy Development
System Integration
1.2
ENVIRONMENTAL
STEWARDSHIP
FINISH
• • •
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 hearings 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 and
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
-------
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
• • •
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
Agency develops proactive and
cooperative relations with
regulators; non-compliance
situations reduced significantly
! Employee reporting
encouraged
! Regular contact with
regulators
Procedures to elevate issues to
upper management
Pollution prevention is
primary management
approach
I
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
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 3: ENABLING SYSTEMS
LEVEL
3.1
TRAINING
3.2
STRUCTURAL SUPPORTS
3.3
INFORMATION
MANAGEMENT,
COMMUNICATION,
DOCUMENTATION
FINISH
• • •
5
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
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 4: PERFORMANCE AND ACCOUNTABILITY
LEVEL
4.1
RESPONSIBILITY, AUTHORITY AND
ACCOUNTABILITY
4.2
EMPLOYEE PERFORMANCE
STANDARDS
FINISH
Assignment of environmental responsibilities is
reviewed periodically in light of performance
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
• •
4
Personnel are provided avenues to provide input
and employees are held accountable for
environmental performance
! Develop employee input/concerns program
Personnel are evaluated based on environmental
aspects of their performance standards
! Develop procedures for evaluating performance
• •
3
All employees assigned environmental
responsibilities are given appropriate authority
and training
! Issue clear statements of environmental
responsibility
! Prepare process to address authority conflict
! Develop policy on accountability
Affected employees have environmental
responsibilities clearly stated in performance
standards
• •
2
Managers assigned environmental responsibilities
are given training and authority to meet those
responsibilities
! Issue statements defining authority
Managers have environmental responsibilities clearly
stated in performance standards
! Develop employee evaluation standards
! Publicize standards and solicit input from agency
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 5: MEASUREMENT AND IMPROVEMENT
LEVEL
5.1 EVALUATE PERFORMANCE
Gather/Analyze Data
Institute Benchmarking
5.2
CONTINUOUS
IMPROVEMENT
FINISH
• • •
5
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
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
I
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 5: MEASUREMENT AND IMPROVEMENT
Data-gathering 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
Agency develops procedures for
gathering appropriate data and
communicates them 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
them to management
! Develop procedures to identify
root causes
! Develop program of comparison
to other organizations
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:
-------
START
Agency identifies personnel with responsibility for
environmental performance
! Assign authority to ensure environmental
compliance
Agency identifies personnel with responsibility for
environmental performance
! Identify organizational performance goals
Notes:
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 3: ENABLING SYSTEMS
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 gathering,
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
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 the 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 envtl. IM procedures
Identify key records/documents
Develop in-house communication
Enable working relationships
Report completion procedures
Maintain MSDS, etc.
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 3: ENABLING SYSTEMS
START
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
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
PRINCIPLE 2: COMPLIANCE ASSURANCE AND POLLUTION PREVENTION
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 recordkeeping
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
1 Toxic materials reductions
! Water conservation program
! "Repair or Replace" program
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
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 1: MANAGEMENT COMMITMENT
Agency evaluates environmental
concerns of key stakeholders
! Develop goals and priorities
! Communicate with
stakeholders
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
Agency evaluates its mission in
environmental terms
! Prepare Mission/Vision
statements
START
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:
-------
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 (Do J)
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)
US Department of Defense
Veterans Administration (VA)
-------
Centra! Intelligence Agency
9 October 1996
Mr. Steven A. Herman
Assistant Administrator
Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Herman:
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 ICEMP). The
following is a brief description of the comprehensive CIA program and the
implementation of the CEMP fundamental elements.
1- MggMg°8nt JEojBalfcfflejlt • In FY92, the Sxecutive Director,
in coordination with the Deputy Director for Administration CDDA},
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 (BEG) 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 DBA, who
serves as the Agency Environmental Executive, issued a policy
statement which makes individual Agency components accountable for
any fines or penalties issued fay federal or state regulators. In
March 1995, the Da& also issued an Agency Notice establishing the
CIA Pollution Prevention Policy and Soals. 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
environmental specialists. In addition, compliance audits have
been performed at some Agency sites by environmental consultants,
0.3. Army and U.S. Navy environmental audit teams, and other
governmental agencies such as the National Security Agency. ESG
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 cheMicals and to reduca 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 ESG 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 Parsopnal• 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 iuquiry and response forum, and serves as a
general discussion media for promoting environmental issues and
policies.
4- Performance and Accountability• 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 SSG 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, toy
deficiencies that are identified by these inspections are targeted
f oawarreetion . Deficiencies requiring an outlay of resources are
centrally funded by ESG 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 yon 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
-------
UNITED STATES DEPARTMENT OF COMMERCE
Office of the Secretary
Washington, D.C. 20230
for the
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 .», ij>s>b, -he U
Department of Commerce is pleased to express its support for t
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 (IPPTF5 in our efforts to ensure that the CEMP is
fully realized in the Department of Commerce and throughout the
Federal government.
Sincerely,
effrey Hunker
Deputy Assistant Secretary
-------
Department of Energy
Washington, DC 20SSS
ttr. Steven A. Htnoan
Assistant fcsinistrator
Office of Enforcment ind Coiapnaiice Assurance
U.S. Ehviroraaental Protection Agency
401 H Street, S.V.
Washington, D.C- 20450
Dear Mr, Hermit;
you for your letter of Septenfcer 3, 1995, revesting Ui&
Department's support for the Coda of EnviromeJital Jtenagaient
Principles JCEMP). Protecting tirf restoring the environment 1s a
central nissiotv for thi Departaent of Energy (ME). The five
principles of this Code are consistent with BUT continuing efforts to
Hqjrowe the quality. cost-effectiveness, and integration of our
awiroj»efrt;a1 operates- Me therefore KJdorse the CW on an igencv
basis. s J
laplaiaitini the COff across WE will require a range of strategies
DOE operates nuwrous facilities that vary widely in terns of
sissies, size, and environments I condition. For this reason no
single salfftion can be effective in inptaieiitifis the &W
Dep»rt»eot-iiride. Ve plan to incorporate. principles of the CEK? into
the inplaaentitiou of sit Integrated Safety Managewft Systea it DOE
facilities. This approach to inttgming ths protectian of workers
the puttie, and the emfiroifflient has been decelooed in response to a'
recaaaendation by t*e Beftnse Nuclear ftcilitiss Safety foard and i*
in the first phase of iaplanentation, IB tfte near tera, ve plan to
provide guidancb to oar sitas for preparation of their updated
pollution prevention plans; SB ail! attach the EB®» and encoursce its
use in all site euvirwwBrtal aanagiaent planning. The eleneats of
tte CEHP are also feeing incorporated into caapreheBsiv* plans nhieh
the Department is current ly iavsl oping to guide land and facility use
decisieas. These decisions will be based on the principles of
ecosystea asrmgeBent and sustainable
Implementing the CEMP via the Integrated Safety Hanagarent Svstm
coaprehensive plans, and pollution prevention plans is also '
consisteftt sdth use of the ISO 14001 Standard,
,
Kwa&aeRt Systaa Specfffcatfos. Several sites are currently asinq
or- adopting envlrosiaaital aanigMBnt systeas consistent witft the ISQ
Standard. This approach is b«ir,s voluntarily Hspleaented at several
sites, is radar consids^tioTi at others, and was included as a
-------
perforaance incentive in the recent Wanford contract. Ve look
forward tn netting tht challenge of inplaniHting the Cadi of
EBVirewerital RaBageBBui Prineiplss is an isportant requirement of
Executive Order 1Z85S.
'Richard J. airaond
Assistant Surgeon tetertl, USPHS
Principal Deputy Assistant Secretary
for Environmental Management
Environmental Executive
-------
United States Department of the Interior
OFFICE OF THE SECRETARY
Washington, D,C. 20240
Mr. Jim Edward SEP 3 0 t)96
Director
FPEO Planning, Prevention and Compliance
AM "«E"^ironaental Protection Agency
401 M Street, S.W. (2261A)
Washington D,c. 20460
Dear Mr. as>«rdlj
I'll 1C "J tt "T
£..,. J.1 _. ucl ''J ¥as developed concerning compliance with
and local waste management
.
preferred'pSucts g'P?nfnC qUMSltl°n °f e"vironraentally-
manager fof Se Ilk SnSft,??' f Snt Giezent^ner, a refuge
Closing the SrcS Lard £ Sjf8^1"' W3S 3 reciP«nt of the
pollution preventractities at thrrr0miien1:al.pr0tection and
Refuge in Austwell Texas Aransas National Wildlife
-------
Again, DOI supports the intent of the CEMP and would appreciate
IPA'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.
'Willie
Director
Office of Environmental Policy
and Compliance
-------
U.S. Department of Justice
2030
3B96
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 20044
Dear Mr. Herman:
Lois J. Schiffer, Assistant Attorney General, Environment and
Natural Resources Division, referred your recent letter to her
concarning the Code of Environmental Management Principles (CEHPJ
to my office for action. As the Assistant Attorney General for
Adfflinistration, 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 CM? for Federal agencies. As your letter recognizes, some
of our components have already implemented internal systems and
approaches to address their environmental responsibilities.
Thefefore< we aPPreciate fc«e 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 Cenaral 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
program managers on recycled vSicSar SL5J ^f^^tal
cop^r paper with postlonsmerSntent* £ ? "^ *** Use
"
ar
paper with postlonsmerntent* £ ? "^ *** Use of
supported the efforts of several ofour"^,! h*Vf successfully
laboratories that havl outmoded ewLomL^ 6 f^ional
Emigration and Naturalization Ser^S^ t .f?steas- Tbe
S21-5 mili^n dollar, nitSSLf^ojLfL 'JiSSV J^W,
underground fuel storage tanks n^^ replace leaking
Department are addrelsiL SSronSJS i COaponents ™ the
lead hazards in- iSool ?LSg r°Ses a/f ^^ associated with
Paint in residential housing ' e11 as' lead-based
Next spring we win start a seven-vear si^n -i, -
renovation of the Main T»J--i a -H? ' *150 million dollar
strong support^ S^anS Svir^f8?3 has >»•»
comprehensive environmental ecvcl?^"n P alf° lnsfc^uted a
institution" ?hf extract pro^s^ofnr/K^31 Co^tional
water using solar energy L thl rSwablf »« W? doaesti= hot
long-range energy saviSgs pdtentiS rgY S°Urce and ^
ri -"ect a^reness of
environnental chalienoe nroi-^ * ^ our suPP°rt of the
fiscal year, the DepStmeS^ui co^*9 th6 remain<1^ « this
leadership, direction aSd support ?f JSVi? eff°rts to Provi^
Our thrust win be to establish a «L components' programs.
insuring compliance and 2™? K-?^e systejnati= basis for
briefing by Don *Z^^^££*' »• »««tly hosted a
information management system Sic^ i« S-^i 5 PDPL^-PC
representatives froa all Sr r-ISi? ? atte««»ed by
evaluating their reporting res^K t^' • Co^°^^ are nov
will detenaine if thef im ^fth- blllties under FK.PLAH-PC and
nonreportable enviroSeSaJ *
^rie asked
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. WUen issued, it will serve as
basic program guidance for all Departmental components and
incorporate the essential elements of the CHIP, AS 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 202-514-04S8.
Sincerely,
Sti
A
for Administration
-ce: Lois J. Schiffer
-------
Hi Department of Mmltni Secretary «o Seventh Si.. S.w.
Transportation '«Administration Washington. D.C. 20590
October 30, 1996
Mr. Steven A. Hennas
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 wiU be a valuable internal benchmarking tool. We
inraid to support inese principles to me maximum extent feasible given our existing resources
and current budget consttamts*
If you have any questions regarding this comment please call Christina Barrett of my staff on
202-366-0038.
Sincerely,
Melissa J. Spillenkotfaen
-------
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:
Bank you for yoyrj«terregarding the Code of Environment MUfam ^naptesjor
: Department of tike Treasury ftdly suppom the L
; to continuing to work with the Interagency PolhtioQ
We have taken a number of initiatives, over the last feu-years, toward improving the
environment management program here at Treaswy, All bureaus a
CEMP provides s valuable plan for fitture activities. We arc also examining the potential for
Z±rt£° ° 34°01 ^1*M^Sh^-tWfiBaii^
forward wnh Aese programs to the maxta extent that our existing resource levels pSt
If you have any questions, please call me at (202) 622-0043,
Sincerely,
Bill McOovem
Environment and Energy
Programs Officer
-------
I* gg \ UNITED STATES ENVIRONMEN
* WASHINGTON,
tM* A ^M OFFICE C
NOT 8 1MB ADMINISTR*
AMD RE SOU
MAN AGE M:
MEMORANDUM
SUBJECT: Commitment to the Code of Environmental Management Principles
FROM:/.- Alvin M. Pesachowitz
•J^"^ Acting Assistant Administrator
TO: Steven A. Herman, Assistant Administrator
Office of Enforcement and Compliance
This memorandum responds to your request concerning the Agency's plans to impiemt
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 an-
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 environments
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 qu;
of environmental management systems and visible management commitment.
Although we have integrated several of these environmental management principles in!
the Agency's Safety, Health and Environmental Management (SHEM) Program, we think we
do better. We have updated many of our program documents and issued memorandums from
Deputy Administrator and myself to enhance the understanding of these responsibilities by sen
managers. We want to ensure the Agency" s business is conducted in a manner that protects tfc
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 cul
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.
Rscyctoo/Recycls
dwIlfc Scy/Canq
contain* it lean *e% i
-------
A *u U yOUf *!**hM the dm«. we would appreciate your Office'* review of both the quality
, tr5 f00**8 of our P^S"™, **«* would appreciate yo«r ideas for tasemitm cuitomer
satistmction.
I have asked JuHut C. Tiineno, Director, Safety, Health aod Environmental Manaeemei
Drviwon, to meet with Craig Hook» and disait* how we might "bench mark" the Agency's effi
and incorporate more aspect* of the environmental management principles into our SHEM
Program.
cc: John C. Chamberlin
Julius C. Jimeno
James H, Mat hews
-------
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.O. 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 SO percent by 1999;
Federal Recycling Program •_ 3ft Printed art 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 1 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
Foekwal Recycling Program It ^m Primed on Recyeted Paper
-------
DEPARTMENT OF HEALTH «L HUMAN SERVICES nK
OfficB of th« Sac
r». O.C
SEP 27 IS36
Steven A. Herman
Assistant Administrator
««: Env"±:ronmental Protection Agency
?of1£e«,°f Enforcement and Compliance
4Oi M Street, SW
Washington, D.C, 2046O
Dear Mr. Herman:
't1-0^ ?^f^^ntai pJotlctL^Lrfn^S:
initiating an "Sn^ironmental Protection
i^«««»t:ion, please
contact, Dick
Terrenes J. ^ychan, HHS
Executive
-------
National Aeronautics and
Space Administration
Headquarters
Washington, DC 20546-0001
SEP 3 0 !995
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 pan
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."
3ne of the avenues NASA is investigating to fully implement CEMP principles at the facility
evel is the ISO 14001 process. Currently, we are forming a working group that wiH analyze
.SO 14001 requirements and make recommendations on implementing the standard. Several
jrgamzations have been identified that can provide the necessary training and education to
acilitate this process. A number of NASA Centers have already begun incorporating ISO
4001 standards into their policy documents.
-------
Please be assured that NASA fully endorses the CEMP principles and has already incorporat<
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,
.dL(^Qfr^~
^.r^su „„,--. <^fc- \ x /
Benita A. Cooper j
Associate Administrator for
Management Systems and Facilities
cc:
IE/Ms. Dominguez
ARC/223-l/Ms. OlHges
DFRC^D-^4809B/Mr. Ambrose
GSFC/205.0/Mr. McNeil
JPL/3Ql--420/Mr. BurU
JSC/JJ12/Mr. Hickens
KSC/DE-EMO/Mr. Wright
LaRC7429/Mr. Lee
LeRC/3065/Mr. McCallum
MSFC/AEOl/Ms. McCaleb
MAF/SA39/Mr. Celino
SSC/GAOO/Mr. Magee
WSTF/RA/Mr. Amidei
WFF/205/Mr. Potterton
-------
m
WSBtSERWd
September 30,199i
Mr, Steven A, Herman
Assistant Administrator
Of ce of Enforcement and Compliance Assurance
U. S, Environmental Protean 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 s
our strategy to the implementation of the CEMP, We are continuing oyr investigate and
evaluation of IS014001 for its implication and applicability to our organization. Thank you for
keeping us informed on the progress of vour environmental ventures.
Please contact Paul Femewati at (202) 268-6239 or me at (202) 268-6188 if you have any
.Bravo
Manager
Attachment
cc: Mr. Dowlng
Mr. McKieman
-------
UNITED STATES
POSTAL SERVICE
Strategy for Implementation of
Code of Environmental Management Principles (CEMP)
for Federal Agencies
. 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 Postaf 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.
"• compliance Assurance and Pollution Prev?riti>ty 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.
An Environmental Strategic Plan was developed for the period 1993 - 2OOO.
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)
-------
'"• 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- MeasMrement 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
Improvement is based on the following Guiding Principle:
-------
"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.
-------
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 heafthy environment
Environmental protection is the responsible thing to do and
makes for sound business practices.
GU/D/NG 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 protection policies.
Marvin Runyon
Postmaster General
September 1995
-------
UNITED STATE*
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 free to
atact me.
Charles E. B
Manager
Bnvironmenta
cc: Area Environmental Compliance Coordinators
District Environmental Coordinators
4T5 L'EfftMT Pt»z* SW
WMMMZTON DC 2O26O
-------
UNITED STATES POSTAL
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 I). 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 corning 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.
-------
* 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.
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 th
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 detail
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 action
(deleted).
The current tactical action plans are numbered 1 to 105.
Column II 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.
-------
Column TV Status
This is the status of the tactical action as of September 30, 1995.
Column V Mext Step
This column identifies any future efforts necessary to complete the tactical
action.
Chait 1 Environmental S
Status of the 135 Tactical Action Plans as of September 30, 1995.
01)3112 Environmental Strate^r PI?»
105 Tactical Actions by L-d Offi~ -
Chait3 Environmental Strategic Plan
-------
ENVIRONMENTAL TARGET AREAS
Leadership Targets
Compliance Targets
Underground Storage
Tanks
- Establish monitoring procedure:
& 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
-------
June 21, 1996
ENVIRONMENTAL TARGET AREAS
LEADERSHIP TAff?«=T APEA?
1. Underground Storage Tanks
Reduce number of underground storage tanks
Complete surveys and upgrade remaining tanks
Establish monitoring and inspection procedures
ESS? and inSpeCti°n re<>uirem*nts for above ground tanks required by
2. Clean Air Act Amendments
• Identify applicable laws, regulations
* 2^d'ES5SJI^lrtl0na'y S°UrCeS' ••»- ""*•*««* storage tanks, paint spray
• Develop plans to use attemate fuels
Increase the utilization of alternate fuel vehicles
• Obtain air credits and rebates, wherever possible
3. Hazardous Chemicals
* Identify hazardous substances
I w!?tTne,Tte^al f°r substitutinS environmentally safe alternatives
. Work to reduce the generator status to conditionally exempt, wherever possible
4. Paint Spray Operations
• Minimize liability and reduce costs by reducing total number of paint sorav ooeratons
« Convert rema,ning operations to most efficient technologies IncKCw ffi vKe Low
Pressure Sstems HVLP CIUai"9 Migh Volume Low
Pressure Systems (HVLP) and low volatile organic paints
-------
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 P* plans at all plants. VMFs. and targe AOs
Establish procedures for wastestream assessment at all facilities
Select methods for recycling, e.g.. Southwest Area mode!
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)
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
-------
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 focal 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, DOD) and negotiating
with utility companies
-------
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 Universs
Postal Union.
Recycling and Pollution Prevention
* Developed a National Strategy.
• VMFs are reducing the number of chemical line items which has resulted in cc
avoidance related to hazardous materials management and cost savings throuj
waste reduction of less frequently used chemicals.
• Significantly expanded our recycling effort both in what we purchase and whs
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
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 eithc
discontinuing, consolidating, or upgrading their painting operations.
-------
Significant Achievements (continued)
Reduction of Hazardous Wast*
• 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
•
Quality Assurance Reviews
Completed the development of a QAR manual and ML
Conducted over 1O5 QARs in which 60 were conducted this year.
gOVernment and """-toy '«r environmental leadership and
House
-------
QCT 3
Mr. Steven A, Herman, Assistant Administrator
Office of Enforcement and Compliance Assurance
Environmental Protection Agency
4O1 M Street, SW
Washington, DC 20460
Dear Mr. Herman:
r
Program and the Code of Enwonmenta! Manaement Principles (CEMP)
TVA has developed and commenced implementation of a state-of-the-art
deve,oPmentof the .SO 140*01 S^me^
aligned to the extent practicable with both. as been
you
Sincerely,
VWIIiam H. Kennoy, P.E.
LRB;SC
ec: Craven CroweH, ET12A-K
Johnny H. Hayes, ET 12A-K
Alan Carmichael, ET 12A-K
Kathryn J. Jackson, WT 1 1A-K
Jon M. Lonev. WT 8C-K
Ronald J. Williams, CTR 2C-M
, -
Norman A. Zigrossi. ET 12A-K
ed " J°n approve
CTS Number 08O444
-------
OFFICE OF THE UNDER SECRETARY OF DEFENSE
300O DEFENSE PENTAGON
WASHINGTON DC 20301-3000
ACQUISITION AND
TECHNOLOGY
Mr. Steven Herman
Assistant Administrator 05 ^
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 folly 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.
•y yours,
Sherri Goodman
Deputy Under Secretary of Defense
(Environmental Security)
Enclosure
-------
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 Secretory 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 opportunities.
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
-------
> "* ***** °fE^s^ P^-ts made with recycled
a nT ^ ** ^^ °f «*««^ preferred products by
and distnbutag a catalogue of products, fa addition, it is the Department's policy
-%^^^
^^
s for compliance, poll ™
nsibilities would be evaluated on r perf
is °ne
the commander's performance appraisal.
The Department believes this is the appropriate interpretation of the phrase
orgamzatonal units should take steps to measure the organization's performance by
Principle 2: Compliance Assurance and Pollution Prevention
Performance Objectives
2.1 Compliance Assurance
anH 1 ?6 D°D>$ dilC!fe Md SUB>0rtillg ™^Qns «qui« compliance with federal state
and local enwoamental laws Annual budget guidance requires the full fading of
st y rn comphance ana to get mto compUance if currently out, and a prudem mita
actionsnecessarytomeetstandardswhoseeffectivedateisin theruL,
at 1 ?e
a least annually, and that the Semces report progress on specific compliance and poLion
l Environmental
IT ^ ^P^6111'8 ™c^ ^ablish Regional Environmental
Coordinators to work closely w,th federal, state and local environmentaheplators m identifying
po ent,al prob ems and seehng resolution. lUe Department requires that alfcontractors 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, ttese 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,
Princip!e3: 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 in 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 in 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. ^
DoDpersonnel regulations require that supervisors identify major job components in
emp qyees 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-anaually 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 turn,
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 svstem 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
-------
Hie Department is ciarently evaluating environmental operations in other government
and non-government organizations which have similar environmental challenges. The effort is
scheduled for completion by Januaiy 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, aregulator 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 environmentaliy 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
-------
DEPARTMENT OF VETERANS AFFAIRS
DEPUTY ASSISTANT SECRETARY FOR ACQUISITION AND MATERIEL MANAGEMENT
WASHINGTON DC 20420
DEC 24 !99o
Mr. Steven A. Herman
Assistant Administrator
U.S. Environmental Protection Agency
Office of Enforcement and Compliance Assurance
4O1 M Street, SW
Washington, DC 2046O
Dear Mr. Herman:
We are responding to your letter regarding the Code of Environmente
Management Principles (CEMP). The Department of Veterans Affairs (V,
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 managemen
of environmental programs at VA. We intend to develop a VA CEMP tha
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 (2O2) 273-5863.
Sincerely,
Gary J. Krump
Environmental Executive
------- |