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DOE Response

to the

Environmental Compliance Management Improvement Initiative

of the

Presidents Management Council

Steven R. Woodbury
US Department of Energy March 8, 2005

PMC Environmental Compliance Management Improvement Initiative
PMC Report Recommendations DOE Implementation Plan

PMC Environmental Compliance Management Initiative Timeline

4/03 Presidents Management Council (PMC) launches Envtl Compl Initiative 8/15/03 DOE submits response to Federal Agency Envtl Program Survey 10/6/04 Report presented to PMC; PMC approves recommendations 12/16/04 Federal Envtl Executive briefs DOE Agency Envtl Executive 4/1/05 DOE Implementation Plan due to CEQ/OFEE/OMB 4/05 start to implement Plan

PMC Report
Identifies 4 major Root Causes
Provides 54 Recommendations Includes requirements for Agency Implementation Plan

Report Identifies Four Root Causes to Address Compliance Issues

1. Top leadership commitment 2. Clear responsibilities and accountability 3. Integration of management systems and support mechanisms 4. Checking and follow-up

Root Causes
1. Top Leadership Commitment: Leadership needs to demonstrate a clearer and more sustained commitment to achieve and maintain compliance. 2. Clear Responsibilities & Accountability: Roles and responsibilities related to envtl performance can be more adequately defined and/or monitored; management procedures to address compliance issues need to be more robust.

Root Causes (cont.)

3. Integration: Program planning and procedures, if better integrated and planned, could ensure effective compliance Management (includes issues of funding and awareness training). 4. Checking and Follow-up: Compliance must be monitored and, where an element of the organization falls short, corrective actions must be identified and implemented.

Report Includes 54 Recommendations

Report includes recommendations at
administration level (8) department level (13) program / sub-agency level (21) facility level (12)

Recommendations address
policy planning support mechanisms accountability monitoring and follow-up

Role of EMS
Where agencies, organizations or facilities have or are developing an environmental management system, the recommendations should be reflected in that environmental management system.
(PMC Report, page 2)

Requirements for Department Implementation Plan

Recommendations require more detailed subtasks and action plans If a recommendation is not implemented, Agency must affirmatively justify why not Whenever possible, involve EMS process in developing plans Existing or planned EMS efforts must integrate these recommendations DOE Implementation Plan is due April 1

Key Elements of DOE Implementation Plan

Action Plan
Ten action areas Specific actions (responsibilities and dates) Each is tied to several PMC recommendations Also describes what DOE has already done

Discusses each recommendation Details the DOE policies and actions which already address the recommendation.

Draft Action Plan Topics

Reaffirm senior management commitment Better integrate compliance into DOE Strategic Plan Better integrate compliance into DOE budget formulation Clarify roles and responsibilities Training DOE compliance Audit program DOE corrective action process Environmental program metrics Expand use of environmental performance data in program reviews Share best practices and lessons learned

Example (DRAFT)
Compliance Audits
Action: identify current DOE practices regarding compliance audits collect data from programs and sites on frequency, protocols, corrective action tracking, etc Action: identify improvements based on data collected

Example (DRAFT)
Budget process
Action: sites review recent NOVs and determine whether inadequate funding is a root cause Action: explore altering the current budget formulation process to include explicit discussion of funding for ES&H activities Action: explore opportunities to better address environmental compliance in DOE budget planning

How Does This Relate to Environmental Management Systems?

1. Facility-level recommendations largely addressed by implementing site EMSs 2. Action Plan is built around management system elements, such as
Planning and budgeting Roles, responsibilities and accountability Assessment and corrective action Performance measurement

DOE Schedule for Completion of Implementation Plan

Work Group has developed draft Implementation Plan Undergoing review and comment
DOE: through program office WG members EFCOG: through Task Team members

March 15 final WG meeting on proposed Plan. April 1 Plan submitted by DOE Agency Environmental Executive

Need your support at the Headquarters and Field level to meet IP commitments Ensure that regulatory compliance is included in your site EMS Want to show demonstrable improvement in DOE regulatory compliance We want to share DOE success stories and lessons learned with other Federal agencies

For additional information: Steven R. Woodbury