and a waiver of certain potential penalties,
subject to formal disclosure of the violation by
the facility and the initiation of appropriate
corrective action. The IVRP is included
within EPA's Interim Technical Guidance on
EMRs and should be reviewed to obtain more
details.
At the conclusion of the site visit, the
EMR team may provide an exit briefing in
which preliminary findings are presented to
facility management.
Within 60 days after the site visit, the EPA
Regional Office will provide the facility with a
written report or letter discussing the
conclusions of the EMR and making
recommendations for follow-up activities.
The facility must prepare a written response
to the EMR report within 60 days explaining
how it intends to address any issues raised by
the report. In addition, six months after this
response, EPA will ask the facility to provide
a brief progress report on the status of any
follow-up activities.
How will EMR reports be used?
The final EMR report is a public
document, and as such may be obtained by
any member of the public who follows proper
procedures. However, it is not EPA's intent
to actively distribute or otherwise make a
report available to the general public or
State/local officials, In addition, the EMR can
serve as a foundation for on-going technical
and compliance assistance activities between
EPA and the Federal agency or facility.
Who can I contact to obtain more
information?
If your facility is interested in participating
in an EMR, or would like to obtain more
information on the program, please contact
your Regional Federal Facility Coordinator.

EPA Regional EMR
Contacts
I
Anne Fenn	
(617)565-3927
II
John Gorman	
(212) 637-4008
III
Eric Ashton	
(215)566-2713
IV
Dave Holroyd .......
(404) 562-9625
V
Lee Regner .........
(312)353-6478
VI
Joyce Stubblefield
(214) 665-6430
VII
Jamie Bernard-Drakey .
(913)551-7400
VHI Dianne Thiel		
(303)312-6389
IX
Sara Segal .........
(415)744-1569
X
David Tetta	
(206) 553-1327
EPA Headquarters
Federal Facilities Enforcement Office
Andrew Cherry 		(202) 564-5011
Related Guidance
The following reference materials provide
more detailed information on the EMR
program and its implementation and can be
obtained from EPA's Federal Facilities
Enforcement Office.
Interim Final Policy on Environmental
Management Reviews at Federal
Facilities, May 31, 1996.
Interim Technical Guidance for
Conducting EMRs at Federal Facilities,
May 31, 1996.
Generic Protocol for Conducting
Environmental Audits of Federal
Facilities, Volumes I & II (EPA 300-B-
96-012A & B).
Code of Environmental Management
Principles (CEMP) for Federal Agencies
(61 FR 54062, October 16, 1996)
Guide for Implementing the CEMP —
Available Winter, 1997.
These documents can be obtained from
Enviro$en$e, EPA's free, public, integrated
information system. Enviro$en$e may be
accessed via modem at (703) 908-2092 or on
the World Wide Web at http//es.inel.gov.
United Slates
Environmental
Protection Agency
January 1997

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&EPA Environmental
Management
Reviews (EMRs) at
Federal Facilities

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What are Environmental
Management Reviews?
An Environmental Management Review
(EMR) is an evaluation of an individual
Federal facility's program and management
systems to determine how well the facility has
developed and implemented specific
environmental protection programs to ensure
compliance.
Two EPA Regions (I and VI) have been
conducting EMRs over the past few years.
Encouraged by the success of their efforts,
EPA Headquarters recently issued (May 31,
1996) an interim final policy and technical
guidance on conducting EMRs at Federal
facilities. The interim policy stipulates that
EMRs will be conducted as part of a pilot
program. Upon completion of the pilot at the
end of FY 1997, EPA intends to identify any
lessons learned, modify the policy as
appropriate, and implement a final EMR
policy.
How do EMRs compare with
other on-site assessments?
EMRs are consultative technical
assistance visits intended to identify root
causes of environmental performance
problems. EMRs are not compliance-
oriented assessments, audits, or
inspections, nor are they pollution
prevention opportunity assessments. They
are voluntary and are initiated by the recipient
agency or facility.
How can my facility benefit from
an EMR?
EMRs help Federal facilities improve
long-term environmental compliance by
developing a sound foundation for an
environmental management program. They
assiat Federal facility personnel in moving
beyond immediate symptoms of
noncompliance and address underlying
problems or root causes. In addition, they
may provide an early warning of potential
compliance problems. EMRs foster improved
working relationships with EPA and
encourage an open dialogue on environmental
concerns. EMRs also provide informal
assessments that are less costly than
management assessments conducted by a
facility's contractor, and they provide an
independent perspective on prior self-
assessment activities.
How is the scope of an EMR
determined?
EMRs are collaborative efforts between
EPA and a Federal facility in which the facility
has ultimate authority in determining the
scope of the review. There are seven
potential areas of inquiry for an EMR:
•	organizational structure;
•	management commitment;
•	resources;
•	formality of program;
•	communications;
•	evaluation and reporting; and
•	planning and risk management.
A typical EMR may address any of these
areas, and will take from one to three days to
conduct. Once EPA evaluates the results of
the EMR, the facility receives a written
report.
Who actually conducts the EMR?
EMRs are conducted by a team of EPA
Regional staff with the assistance of qualified
contractors, when appropriate. Throughout
the EMR process, the team will coordinate
closely with Federal facility personnel.
How does the EMR process work?
The EMR process typically begins either
with an expression of interest by a Federal
facility or an EPA inquiry. If, after
preliminary discussions, the facility elects to
proceed, the EMR planning stage begins.
During the planning stage, EPA staff and
Federal facility management will discuss the
purpose and scope of the EMR, the ground
rules and operating principles for conducting
the review, and they may sign a ground rules
letter.
EPA and Federal facility personnel may
continue regular telephone discussions and
correspondence (e.g., pre-site visit
questionnaire) to further refine the scope and
content of the EMR. During these
communications, EPA and the Federal facility
will identify technical points of contact. In
addition, EPA may work with facility staff to
develop a list of information needs (e.g.,
documents) and persons to be interviewed as
part of the site visit, as well as a schedule for
the on-site portion of the EMR. The schedule
will be customized to address the size and
complexity of the facility.
Prior to the site visit, EPA staff will
review and evaluate the environmental
management program documents identified
during the planning stage (e.g., environmental
policies, directives, protocols, and standard
operating procedures). Careful review prior
to the site visit will ensure that EMR staff are
sufficiently familiar with facility operations to
conduct effective on-site interviews and
evaluations.
Although compliance assessment is not
the intent, occasionally during the course of
an EMR, the team may discover a potential
violation. To address this issue, EPA has
developed an Incidental Violations Response
Policy (IVRP). In situations that may cause
an imminent and substantial endangerment to
public health or the environment, or serious
actual harm, the facility must address the
situation immediately. In other cases, EPA
allows the facility a 60-day correction period

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