DOE 450.1 IMPLEMENTATION WORKSHOP

1. 1 DOE 450.1 IMPLEMENTATION WORKSHOP ASSESSING MY EMS Steven R. Woodbury 202-586-4371 steven.woodbury@eh.doe.gov

2. 2 Why Assess My EMS? Initial Assessment � I know I have an EMS Third-party registration Self-declaration Periodic Ongoing Assessment � I know my EMS is still appropriate and effective Good management ISO 14001 standard E.O. 13148: conduct management system audits Integrated Safety Management ISMS Guide, Chapter IV �Maintaining an Approved ISMS� DEAR clause: ISMS annual review Good Management ISO 14001 E.O. 13148 ��comply with environmental regulations by establishing and implementing environmental compliance audit programs �� [202] �develop and implement a program to conduct facility environmental compliance audits�[401(a)] �may elect to conduct environmental management system audits ��(401(b)) Facility environmental audits shall be conducted periodically. Each agency is encouraged to conduct audits not less than every 3 years from the date of the initial or previous audit. The cope and frequency of audits shall be based on facility size, complexity, and the enviornmental aspects of facility operations.� (401( c)) DEAR Clause Good Management ISO 14001 E.O. 13148 ��comply with environmental regulations by establishing and implementing environmental compliance audit programs �� [202] �develop and implement a program to conduct facility environmental compliance audits�[401(a)] �may elect to conduct environmental management system audits ��(401(b)) Facility environmental audits shall be conducted periodically. Each agency is encouraged to conduct audits not less than every 3 years from the date of the initial or previous audit. The cope and frequency of audits shall be based on facility size, complexity, and the enviornmental aspects of facility operations.� (401( c)) DEAR Clause

3. 3 Compliance Audits and Management System Assessments Compliance Audits Am I complying with applicable regulatory requirements and permit conditions? Management System Assessments Is my management system functioning well? Are my goals, objectives and targets still appropriate? How can I improve the management system? Both are important, but they are not the same thing!

4. 4 Existing Assessment Framework DOE P 450.5, Line ES&H Oversight Contractor is to have a �robust, rigorous, and credible� ES&H self-assessment program addresses compliance with applicable requirements results are available to DOE DOE role(s) ensure that contractor has strong self-assessment program operational awareness review of performance periodic appraisals This is just a summary � I have highlighed certain elements; this is not meant to minimize or overlook other aspects of these policies and guides.This is just a summary � I have highlighed certain elements; this is not meant to minimize or overlook other aspects of these policies and guides.

5. 5 Existing Assessment Framework (cont.) ISMS Guidance (DOE G 450.4-1A Chapter IV) contractor�s self-assessment process DOE line oversight of contractor�s ISMS implementation and performance Assess DOE�s performance in compliance with organizational and departmental ISM requirements

6. 6 Existing Assessment Framework (cont.) DEAR 970.5223-1 Integration of ES&H into Work Planning and Execution contractor shall review and update annually ES&H performance objectives ES&H performance measures ES&H commitments DOE contracting officer provides guidance on preparation , content, review, and approval of ISMS Program and budget execution guidance and direction DNFSB Interest in process (and concern about inconsistency) EM direction to annually certify ISMSDNFSB Interest in process (and concern about inconsistency) EM direction to annually certify ISMS

7. 7 DOE Order 450.1 and Compliance Audits O 450.1 requirements EMS must provide for ��evaluation � of programs for compliance with applicable environmental protection requirements� [4.a.(1)] must �assess performance and implement corrective actions where needed� [4.a.(2)]

8. 8 DOE Order 450.1 and EMS Assessments O 450.1 requirements DOE Field Managers must report to CSO the status of implementation of EMS by 12/05 [5.d.(1)] DOE Field Managers must ensure (through annual ISM review process) that contractor ES&H performance objectives, performance measures, and commitments include appropriate environmental elements [5.d.(17)] DOE is to assess implementation of EMSs as part of implementing DOE P 450.5 [5.b.] DOE is to ensure that contractor ES&H self-assessment programs are established under DOE P 450.5 and continue to be effective [5.d.(16)]

9. 9 Tools For Assessment Training Assessing management systems ISO 14001 facility auditor ISO 14001 lead auditor Guidance Assessment Protocols EMS assessment protocols ISMS annual review protocols Revised ISMS verification CRADs Order 450.1 talks about guidance EH is to issue, and specifically requires guidance to include �instruction for integration of EMS self-assessment requirements into ISMS self-assessment protocols� This is high on our list.Order 450.1 talks about guidance EH is to issue, and specifically requires guidance to include �instruction for integration of EMS self-assessment requirements into ISMS self-assessment protocols� This is high on our list.

10. 10 Options for Initial EMS Assessment -- I Know I have an EMS Independent third-party audit e.g. ISO 14001 registration Self-Declaration Other Recognition Programs EPA�s National Environmental Performance Track State Programs

11. 11 Federal Environmental Executive�s EMS Self-Declaration Protocol Developed by EO 13148 Inter-Agency Workgroup Provides a framework for facilities to �self-declare� their EMS Purpose: provide a process for ensuring the credibility of self-declaration of EMS at Federal facilities DOE expects to develop guidance within the framework of this protocol Provides a common-sense framework by identifying what elements need to be addressed Provides a common-sense framework by identifying what elements need to be addressed

12. 12 FEE EMS Self-Declaration Protocol �Agency Responsibilities Establish one or more acceptable EMS �evaluation guides� (e.g. ISO 14001, CEMP, or other appropriate EMS framework) Establish a procedure for use of guide frequency of self-evaluations self-declaration statement frequency of independent reviews make up of review team In our case �agency� means the Department of Energy For DOE, ISMS can provide an �appropriate framework� if it meets the scope and requirements of DOE O 450.1.In our case �agency� means the Department of Energy For DOE, ISMS can provide an �appropriate framework� if it meets the scope and requirements of DOE O 450.1.

13. 13 FEE EMS Self-Declaration Protocol �Agency Responsibilities (cont.) Establish procedure for documenting and using results of EMS evaluations acknowledging adequate facility EMSs follow-up for inadequacies in facility EMSs reporting for agency-wide annual EMS reviews Establish a procedure and schedule to review self-declaration procedures Communicate decisions and procedures

14. 14 Periodic EMS Assessment -- I know my EMS is still appropriate and effective �Competent annual reviews of ISM systems are essential for effective implementation and continuous improvement� � Secretary Abraham Integrate into ISMS review and improvement process (ensure that E is fully addressed) Third-party registration audits provide an additional mechanism

15. 15 Some Things to Assess about my EMS Identification of environmental impacts Identification of applicable requirements Environmental goals, targets and objectives Operational controls Checking and corrective action What is the process? Is is working? And is it effective? The following lists are not comprehensive, and are just a starting point for the kinds of questions you will need to be asking. What is the process? Is is working? And is it effective? The following lists are not comprehensive, and are just a starting point for the kinds of questions you will need to be asking.

16. 16 Assessing Identification of Environmental Impacts What is the process for identifying the significant impacts of environmental activities? Who is involved? How do we identify new aspects? How do we include impacts on cultural resources? On ecosystems? Did we examine the impacts of accidents? How do we assess the impacts of new facilities or new activities? How are these impacts (�hazards�) integrated into planning for work at the site?

17. 17 Assessing Identification of Applicable Requirements How does my organization track laws, regulations and directives related to our activities? Is there a list of applicable requirements? Is a specific person in charge of updating that list? How are new laws, regulations and directives communicated?

18. 18 Assessing Environmental Goals, Objectives, and Targets What environmental goals, objectives, and targets have we identified? How are these reflected in our budget and annual work plan? How are these tracked by our performance measures? Were they reviewed and updated annually?

19. 19 Assessing Operational Controls How are environmental requirements and other controls flowed down into procedures/work packages for individual work activities? How are environmental training needs identified and training tracked? What workers perform activities which could have a significant impact on the environment? How is my management system (policies and procedures) documented?

20. 20 Assessing Checking and Corrective Action What deficiencies have been identified (incidents, assessments, enforcement actions)? How were root causes and corrective actions identified? Were the corrective actions effective in remedying the deficiency? How am I monitoring and trending these?

21. 21 Summary Management system assessment is an integral part of EMS and ISMS Regulatory compliance self-assessments are also required DOE already has an assessment framework in place We will work with you to develop EMS assessment guidance and protocols to ensure successful implementation of DOE O 450.1