Enhancing compliance at Department of Defense facilities: comparison of three environmental audit tools. (Features).

Introduction

Achieving environmental compliance at U.S. Department of Defense (DOD) and other federal facilities has become a national priority. Passage of the 1992 Federal Facility Compliance Act clearly established the authority of the U.S. Environmental Protection Agency (U.S. EPA) to levy fines against federal facilities. In fiscal year 1994, U.S. EPA and the states issued 40 administrative orders totaling more than 6.5 million dollars in penalties (U.S. EPA, 1994). Past failures by DOD agencies to meet environmental laws and regulations have resulted in site contamination, civil and criminal prosecution of employees, and a loss of public confidence. In addition, the inability of federal agencies to comply with environmental standards has made private-sector interests question whether a level "playing field" exists in the regulated community (U.S. EPA, 2001a). To help address these concerns, on April 21, 2000, President Clinton signed Executive Order #13148, "Greening the Government Through Leadership in Environmental Management" (Federal Register, 2000). This executive order required federal agencies to implement environmental management and compliance systems within prescribed timeframes.

Many environmental audit tools currently are being used in the federal sector. Some of the more dominant include the Code of Environmental Management Principles for Federal Agencies (U.S. EPA, 1996a), the National Environmental Performance Track (U.S. EPA, 2001b), the Global Reporting Initiative (GRI, 2000), U.S. EPAs Generic Environmental Audit (U.S. EPA, 1996b), the International Organization for Standardization's (ISO's) 14001, Environmental Management System (EMS) Audit (ISO, 1998), and the Environmental Assessment and Management Guide (TEAM) (U.S. Army Corps of Engineers [USACE], 2001). It is not within the scope of this paper to compare all of these audit tools. Two of the most widely used tools, however, the ISO 14001 Environmental Management System (EMS) Audit and U.S. EPAs Generic Environmental Audit, will be described and compared with DOD'S TEAM Audit. The objective of this comparison is to assess whether DOD'S TEAM audit is the most appropriate and effective tool for all DOD facilities, in partic ular those operated by USACE.

ISO 14001 Environmental Management System Audit

EMS Audits approach compliance from a management perspective. The desired outcome is continual improvement in environmental management (Martin, 1998). Of paramount concern is that a facility have a functional process in place to monitor, achieve, and improve compliance. ISO 14001 is the core management systems specification document in the ISO 14000 series (ISO, 1998). The ISO 14001 EMS Audit uses five "essential elements" as shown in the sidebar at top left (DOD, 2002). The first element, "Environmental Policy," is the starting point for the audit. This element involves a commitment from management to compliance with standards, pollution prevention, and continuous improvement. The second element, "Planning," considers environmental aspects of the organization. Based on these aspects, pertinent legal and regulatory requirements are identified. This process leads to the establishment of environmental objectives and targets and ultimately an Environmental Management Plan. The third element, "Implementation and Operation," involves an auditor examining the organization's structure, training, communication, document control, and overall operations capability. The fourth element, "Checking and Corrective Action," examines monitoring of the organization's EMS. This element includes information on how nonconformance and corrective actions are handled, examination of record-keeping procedures, and information on how internal EMS audits are performed. The fifth element, "Management Review," is an "External Audit and Certification." Here the organization performs an external review of the program and ensures that a process exists for continued performance and improvement.

The ISO 14001 Audit makes use of the terms "environmental aspects" and "environmental impacts." According to Martin (1998), environmental aspects are those elements of an organization's activities, products, services, or physical resources that may have potentially beneficial or harmful effects on the environment. An environmental impact is the change that takes place from the occurrence of any given aspect. Examples of environmental aspects would include solid waste disposal and energy consumption. If properly managed, neither aspect represents a significant environmental impact. In an EMS audit, however, both of these aspects would be evaluated. Environmental aspects of an organization that cause adverse environmental impacts would typically include air emissions, water discharges, hazardous waste disposal, and other uncontrolled environmental releases. The ISO 14001 EMS Audit requires that all aspects and impacts be identified and integrated into the environmental management plan.

U.S. EPA Generic Environmental Audit

U.S. EPA's Generic Environmental Audit (EPA Generic Audit) examines facilities from three perspectives, or "Phases." Phase 1 is "Auditing for Compliance," which focuses on compliance with regulatory standards. These standards are divided into 16 separate programs as shown in the sidebar at bottom left.

Phase 2 is "Auditing for Effective Management of Specific Environmental Programs," and it examines the strengths and weaknesses of management systems within each of the same 16 programs considered in Phase 1. Phase 3 is "Conducting Environmental Management Assessments of Federal Agencies" and is designed "to assure high-quality sustained management of environmental operations throughout entire facilities/agencies rather than focusing on any specific environmental programs (e.g., air quality, waste management)" (U.S. EPA, 1996b).

Using the EPA Generic Audit, an organization would be expected to conduct Phase 1 activities until it achieved a high degree of compliance. It would then shift to Phase 2 auditing, examining management systems within each program. Finally, as the effectiveness of the organization matured, Phase 3 auditing would be performed, considering the management effectiveness of the entire program. Conceptually the EPA Generic Audit follows a logical pattern. Performing an EPA Generic Audit, is, however, a complex task. The guidance document is 1,611 pages long and demands expert familiarity The Phase 1 section is essentially a compilation of the laws and regulations of each of the 16 specific programs. There also is no guidance on determining severity levels of "Findings of Noncompliance" (hereafter referred to as "Findings"). Audits of this type would be expected to produce voluminous "Findings" (in Phase 1) but might not produce organizational change until management issues are identified in later phases of the process.

U.S. Department of Defense TEAM Audit

TEAM Audit is closely related to the EPA Generic Audit in that it uses the same burdensome checklist format, but it attempts to customize the document for DOD facilities. As shown in the sidebar above, it also uses 13 commonly understood compliance categories based on descriptive terms.

This is a distinct improvement over U.S. EPA's confusing mixture of descriptive and regulatory categories. At least three other positive features of TEAM Audit, all borrowed from the USAGE ERGO program (discussed below) can be identified. The first is the addition of a hierarchy of severity for audit "Findings" (Management Practice, Minor, Major, and Significant). The second is the addition of a "Suggested Corrective Action" section to each "Finding." The third is inclusion of a photograph or digital image, when possible, on the audit "Finding" page. All three features represent added expenses and time for the audit team but tend to facilitate the corrective action process. An example of a USACE TEAM Audit "Major Finding" is provided as Figure 1 (USACE, 2001). TEAM Audit has significant limitations as well. The most obvious is the lack of emphasis on environmental management. TEAM Audit focuses on simple compliance and prioritized severity levels.

U.S. Army Corps of Engineers TEAM Audits

General Design

In November 1994, USACE transitioned from its existing environmental assessment tool called "Environmental Review Guide for Operations," or ERGO, to TEAM Guide. The two documents were very similar, both having been developed at the USACE Construction Engineering and Research Laboratory (CERL) in Champaign, Illinois. ERGO contained inspection checklists including references not only to state and federal law, but also to USACE and Army regulations. This inspection checklist made the document highly specific to USACE. After TEAM Guide was developed, ERGO was reduced to a compendium of Army and Corps regulations. Because most federal managers have a greater concern for compliance with state and federal law than they have with internal regulations, ERGO became a document with limited use after 1994.

DOD sought to standardize environmental auditing within the different branches of the service by producing TEAM Guide. Originally TEAM Guide was available only as a printed document. Later, TEAM Guide was converted to an electronic format and now is available as a searchable compact disk. In 1998, TEAM Guide was made available to other civilian agencies and was poised for expansion of its application to other sectors of government. TEAM Guide is organized into 13 chapters (see sidebar on page 19). The 13 chapters cover a wide range of subjects beyond air, water, soil, and solid and hazardous waste compliance. TEAM Guide uses a checklist format, with two columns of information, as shown by example in Figure 2 (USACE, 2001). The left-hand column describes "Regulatory Requirements," and the right-hand column describes "Reviewer Checks." The authors of TEAM Guide attempted to provide enough information to enable a non-professionally trained auditor to conduct a very detailed facility audit.

If a checklist item does not appear to meet the standard, the auditor may decide to issue a "Finding." These "Findings" range from "Management Practice" to "Minor Finding" to "Major Finding" to "Significant Finding" in order of increasing severity. For the USACE Portland District, responsible for facilities in Oregon, only the latter two Finding levels, "Major" and "Significant," were utilized. In an attempt to standardize "Findings" determinations, USACE included an "ERGO Findings Ratings Consistency Table" in its ERGO Supplement Document (USACE, 2000). Within this document, "Significant Findings" are defined as follows: "A problem categorized as significant requires immediate attention. It poses, or has a high likelihood to pose, a direct and immediate threat to human health, safety, the environment, or the facilities' mission." Likewise, "Major Findings" are defined as follows: "A major deficiency requires action, but not necessarily immediate action. Major deficiencies may pose a threat to human health, safety or the environment." Although the use of this table adds some degree of consistency to the "Findings" determination process, the authors' experience has been that the knowledge base of the audit team was a more significant factor in appropriately determining levels of severity.

Audit Teams

During the years that preceded TEAM Guide, internal USACE staff conducted environmental audits using ERGO. The types of facilities audited included hydroelectric plants, navigational locks, ship repair stations, recreational parks, and fish hatcheries. In the Portland District, these audits were marginally successful. Senior management had yet to commit to the program and was reluctant to "let go" of valued employees for months at a time to conduct audits. Also, most of the staff had never conducted an environmental audit. Finally, USACE's own bureaucratic structure prevented rapid execution of travel orders, field supplies, reproductive services, and internal approval of reports. With outside pressure from government to "contract out" services, USACE hired an environmental contractor (Woodward Clyde and Associates) to perform the second "cycle" of audits in 1994 and 1995. What previously took up to two years to complete, and with relatively poor quality, the first contractor team provided in nine months with much higher quality The contractor also provided photographs of each "Finding" and follow-up consulting services. The contractor used a team of three individuals with backgrounds in environmental engineering, health and safety, and natural resources, respectively This team structure later proved to be the minimum size that could embrace the full spectrum of coverage found in a TEAM Audit.

Field Applications

In the USACE Portland District, independent and professional contractor teams were utilized between 1994 and 1999 to audit major facilities. These included both USACE and non-USACE facilities (leased areas such as state and local parks). The timeframe included two entire "cycles" of auditing (most facilities were visited twice). The author of this paper who served as a government team leader managed audit teams. A contractor audit team usually had three to four members, and its size was determined by the uniqueness of the facility and the specialization necessary to perform the audit. Each team member had professional credentials, generally including graduate degrees in science or engineering and prior experience in performing environmental audits. The contractor "team leader" provided all direction to his or her team, and the government team leader coordinated site access, arranged employee interviews, determined the scope of the audit, and ensured safe work practices. Each team had maximum freedom to enter workspaces but had limited opportunities to interview employees. The contractor independently determined audit "Findings" without external influence from USACE employees. At the end of each field audit, a courtesy briefing was conducted with onsite management who were given the opportunity to add information to the audit team's understanding of the issues. After departing from the facility each audit team performed an extensive amount of follow-up investigation that ultimately led to a completed product. One of the highlights of these audit reports is the "Suggested Corrective Action" section of each "Finding." These provide a facility manager with independent and expert recommendations on what to do to correct the deficiency TEAM Audit reports prepared for the Portland District included color photographs or digital images of all "Findings" and bound reports for distribution. Each report was sent to the respective facility manager, the chief of operations who oversees these facilities, and the district comman der. Facility managers were expected to implement corrective actions. With this format, 66 TEAM Audits were completed during the period 1994-1999.

Postaudit Activities

In USACE, follow-up audits are planned on a five-year cycle. This is in contrast to other DOD elements, which typically use a three-year cycle. Under ideal conditions, all prior "Findings" would have been corrected. Only new "Findings" would be cited on subsequent audits. Correction of "Findings" was, however, far from assured because the five-year return cycle is so long that each new USACE district commander who served a three-year tour of duty would depart before a follow-up audit could be performed. During the period 1994-1999, 66 TEAM audits were performed and no Operations Division chief or USACE commander attended a single audit team "In-Brief" or "Out-Brief" in Portland District. This "hands-off" approach by senior management provided minimal oversight, and many "Findings" were not acted upon.

A graphic example of this problem can be found in the USACE audits of leaseholders between 1992 and 1995. The majority of these audit reports were never transmitted to their respective facility managers. This omission was due to an internal concern that USACE was attempting to "be EPA" and did not have the authority to audit its rental properties. Ironically U.S. EPA has very clear policy on whom it holds accountable for environmental violations, and that policy most definitely includes the landowner. Recently, USACE has recognized the problem of ensuring environmental compliance among USACE leaseholders and has proposed new regulations.

Whether these regulations will be approved and have a corrective effect remains unknown. What is known is that the USACE TEAM Audit program has successfully provided independent and professional reports to senior management. Implementation of corrective actions found within these reports by USACE has not received the leadership support and accountability that would promote their full use. What has emerged, however, is a better understanding of the distinct advantages and disadvantages of the USACE TEAM Audit program as listed in Table 1.

Discussion

Environmental audits, whether focused on management or compliance, must have the ability to improve the "environmental performance" of an organization. What is environmental performance, though? Is it simply compliance with existing laws and regulations? Is it development of an effective environmental management plan? Or is it both? To answer this question, U.S. EPA provides new and promising guidance, which is found in the agency's recently published "National Environmental Performance Track Program" (U.S. EPA, 2001b). In summarizing past efforts, U.S. EPA states: "We learned that innovations in environmental management can be used to create strategic business opportunities and advantages while maximizing the health and productivity of our ecosystems and communities." This statement can be used to derive a useful new definition of environmental performance, that as follows: "Environmental performance is the generation of goods and services while impacts upon the health and productivity of ecosystems and comm unities are minimized." This new definition of environmental performance is a significant step forward from past measures that stressed only compliance and minimization of impacts.

For example, U.S. EPAs Generic Environmental Audit would attempt to find noncompliance issues that could be documented and cited. By correcting these deficiencies the facility would presumably become more compliant. Could the facility be considered to be achieving a high level of environmental performance? In the author's opinion it is unlikely Regulatory audits of these types have their place in policing nonconforming facilities, but they have limitations as well. The most significant is that the audit may not discover the root cause of noncompliance and be able to direct change in that area. Under the worst conditions, the audit may not even offer alternative solutions. Audits of this type are not expected to achieve high levels of environmental performance. According to Cahill (1998), "Identifying deficiencies is only the first step. Real audit value accrues when proactive benefits are built into the process." In a study examining business aspects of environmental compliance, Singh (2000) states that comp anies must take two important first steps: 1) They must depart from traditional modes of thinking, and 2) they must begin to use techniques and tools that help them work in a truly integrated manner. The EPA Generic Audit, though exhaustive in size, does not appear to support value-added benefits or integration of problems and solutions.

TEAM Audit incorporates a more straightforward organization than does the U.S. EPA Generic Environmental Audit, and it makes good use of severity levels for "Findings" and suggested corrective actions. Despite these positive changes, TEAM Audit still suffers from a compliance-focused checklist with little emphasis on environmental management. Adding to this burden is the absence of guidance concerning how the auditors assess "Findings," unclear distinctions between safety and health versus environmental issues, and a lack of consideration for "environmental aspects."

In contrast to the EPA Generic Audit and the TEAM Audit, the ISO 14001 EMS Audit compares an organization's environmental management system to the ISO 14001 EMS Standard. An organization may become "certified" if it has in place all of the elements contained in the standard. The ISO 14001 EMS Audit uses a nonregulatory approach by evaluating environmental aspects and impacts rather than referencing an unending collection of compliance regulations. It is also media based, because most aspects and impacts occur within air, soil, or water resources, and it is geared toward pollution prevention and elimination rather than strict compliance. According to the National Academy of Public Administration (2001), EMS audits and compliance audits are related--and may even be complementary--but EMS audits should be evaluated with criteria different from those used for compliance audits. Many organizations recognize this concern and use two separate audits, one for environmental compliance and one for environmental managem ent. This option may not, however, increase environmental performance, because it fails to consider cause and effect. An integrated environmental audit would identify "Findings" of noncompliance and at the same time determine the root cause. Because many root causes fall into the domain of environmental management, it is intuitive that the two audit systems should be integrated. A properly designed and executed environmental management plan, considering both management and compliance issues, would lead the organization into resource conservation and produce high levels of environmental performance.

The ISO 14001 EMS Audit seems to incorporate all of the key elements necessary for high-level environmental performance. The only apparent limitation is a structured framework for conducting the "environmental aspects and impacts" analysis. This limitation could be overcome by use of the Global Reporting Initiative (GRI) "Environmental Performance Table," provided as Table 2 (GRI, 2000). The table is concise and offers an excellent structure for evaluating a broad range in environmental aspects in an organization. The Environmental Performance Table would identify many of the same compliance issues as the EPA Generic Environmental and TEAM Audits, but in a more efficient manner. Therefore, the advantages of using an ISO 14001 EMS Audit, supplemented as described, appear to be overwhelming.

Conclusions and Recommendation

Achievement of high levels of environmental performance will be unlikely unless an environmental management plan is first developed. This statement is equally true at the facility, corporate, and agency levels. TEAM audits performed by USACE produce standardized, detailed documents at five-year intervals. When performed by independent, professional auditors, these documents are without question an excellent resource for the sponsoring agency. TEAM audits, however, often fall short of effectiveness--not because they lack detail or accuracy, but because they lack context. They are conducted without being integrated into any environmental management structure. More often than not, they become elegant paperweights rather than agents of change. This condition does not have to prevail into the future, however, especially in light of President Clinton's Executive Order on Greening the Government (Federal Register, 2000).

The following recommendations are made with respect to enhancing environmental audits at all DOD facilities:

1. For each facility, an Environmental Management Plan should be developed by the senior leadership. The plan should be based on the ISO 14001 Standard and should use clear and concise tools such as the Global Reporting Initiative Environmental Performance Table.

2. To help achieve environmental compliance, TEAM audits should be continued. To protect quality and integrity, professionally trained and independent auditors should conduct TEAM audits.

3. Audit intervals should be reduced from five years to three years.

4. Severity levels for audit Findings, photographs, and suggested corrective actions are value-added features that should be continued.

5. Postaudit results should be communicated to all levels of the organization, with special emphasis on senior level officials.

6. Labor representatives and common workers should be informed and participate in the audit process to better understand work conditions and opportunities for improvement.

Editor's note: This work was conducted while Jeff Hepler was a graduate student in the Department of Public Health at Oregon State University and a district environmental compliance coordinator with USACE.

FIGURE 2

Example of a DOD TEAM Audit Checklist

Sample Checklist Items [Revised June 1998]


Regulatory Requirements      Reviewer Checks
                             September 1998

SQGs

HW.25
Personnel Training

HW.25.1. SQG personnel are   Verify that personnel are
required to be thoroughly    thoroughly familiar with
familiar with proper waste   waste handling and emergency
handling and emergency       procedures relevant to their
procedures (40 CFR 262.34    responsibilities during normal
(d)(5)(iii))[February 1995]. facility operation and
                             emergencies.

HW.25.2. Training records    Examine training records and
should be maintained for     verify that they include the
all SQG staff who manage     following:
hazardous waste (MP).        - Job title and description
                             for each employee by name
                             - Written description of how
                             much training each position
                             will obtain
                             - Documentation of training
                             received by name.

                             Determine if training records
                             are retained for 3 years
                             after employment terminates
                             at the federal-facility or
                             until closure of the facility.

Source: U.S. Army Corps of Engineers (2001).

TABLE 1

Advantage and Disadvantages of the USACE TEAM Audit

Advantages                          Disadvantages

* Comprehensive checklist of        * Extremely difficult to use if
  pertinent laws and regulations      auditor isn't already
                                      professionally trained in
                                      subject area

* Standardized for most DOD         * Document is so exhaustive
  facilities                          (several thousand pages) as
                                      to preclude implementation

* Uses fixed time frames for        * "Findings" are subjective
  return audits (5 years for USACE    and may not be comparable
  facilities)                         between facilities or regions

* When performed by qualified       * "Findings" are regulatory
  professional teams, provides        in nature and generally ignore
  useful report                       environmental management

* When performed by independent     * Costs to produce a professional
  professional teams, provides        audit report range from
  unbiased report                     $10,000 to $50,000

* Facilitates corrective actions    * Management-labor collaboration
  when included in audit report       has yet to be achieved
                                      concerning corrective actions

                                    * Senior leaders do not
                                      participate in the audit
                                      process and managers are
                                      not held accountable for
                                      corrective actions

                                    * Five-year intervals do not
                                      motivate managers to perform
                                      corrective actions promptly

                                    * Suggested corrective actions
                                      are optional rather than mandatory

TABLE 2

Global Reporting Initiative, "Environmental Performance Table"

Category                  Aspect

Energy use                Total energy use

Water use                 Total water use

Materials use             Total materials use
                          Hazardous materials use
                          Recycled/reused materials use

Air emissions             Greenhouse gases
                          Ozone depleting gases
                          Volatile organic compounds
                          Nitrogen oxidizing compounds
                          Sulfur dioxide
                          Particulate matter
                          Carbon monoxide
                          Toxics

Waste                     Total solid waste
                          Hazardous solid waste
                          Toxic releases to land

Preservation/restoration  Removal
                          Remediation
                          Habitat impacts

Discharges to water       COD discharges
                          BOD discharges
                          Toxic discharges

Accidental releases       Release history
                          Vulnerability and potential

Product performance       Expected lifetime energy use
                          Expected waste
                          Packaging materials
                          Waste for disposal/recovery

Category                  Measure

Energy use                Btu, KwH, megawatts

Water use                 Gallons

Materials use             Tons, pounds
                          Tons, pounds
                          Tons, pounds

Air emissions             Tons, pounds, ppm
                          Tons, pounds, ppm
                          Tons, pounds, ppm
                          Tons, pounds, ppm
                          Ions, pounds, ppm
                          Tons, pounds, ppm
                          Tons, pounds, ppm
                          Tons, pounds, ppm

Waste                     Tons, pounds, drums
                          Tons, pounds, drums
                          Tons, pounds, drums

Preservation/restoration  Cubic yards, tons, square feet
                          Acres, square feet
                          Acres

Discharges to water       Pounds
                          Pounds
                          Pounds, gallons/day

Accidental releases       Number, RQ number
                          Acres, drums, gallons

Product performance       KwH, Btu, megawatts
                          Tons, pounds
                          Tons, pounds
                          Tons, pounds, gallons, ppm

BOD = biological oxygen demand.

Btu = British thermal units.

COD = chemical oxygen demand.

KwH = kilowatt hours.

ppm = parts per million.

RQ reportable quantity.

Source: Global Reporting Initiative, 2000.

Cahill, L.B. (1998). The value-added compliance audit. Internal Auditor, 55(3), 1.

Executive Order 13148: Greening the Government Through Leadership in Environmental Management, 65 Federal Register 24595 (2000).

Global Reporting Initiative. (2000). Sustainability reporting guidelines on economic, environmental and social performance. Boston, MA: Author. http://www.globalreporting.org/AboutGRI/ISO14001.pdf (5 Nov. 2002).

International Organization for Standardization. (1998). The ISO 14000 family of international standards. Geneva, Switzerland: ISO Central Secretariat. http://www.iso.-ch/iso/en/iso900014000/pdf/iso14000.pdf (21 June 2002).

Martin, R.M. (1998). ISO 14001 guidance manual (Technical Report NCEDR/98-06, pp. 9, 14, 22). Knoxville, TN: National Center for Environmental Decision Making Research.

National Academy of Public Administration. (2001). Third-party auditing of environmental management systems: U.S. registration practices for ISO 14001. Washington, DC: Author.

Singh, J. (2000). Making business sense of environmental compliance. Sloan Management Review, 41(3), 10.

U.S. Army Corps of Engineers. (2000). The environmental review guide for operations supplement (Special Report 97/62, p. 13). Champaign, IL: U.S. Army Construction Engineering Research Laboratory.

U.S. Army Corps of Engineers. (2001). The environmental assessment and management guide (Special Report EC-95/05, p. 36). Champaign, IL: U.S. Army Construction Engineering Research Laboratory.

U.S. Department of Defense, Defense Environmental Network and Information Exchange. (2002). ISO 14001-Essential elements.http:www.denix.osd.mil/denix/Public/Library/EMS/Documents/el ements.html (21 June 2002).

U.S. Environmental Protection Agency (1994). FY 1994 enforcement and compliance assurance accomplishments report.http://www.epa.gov/Compliance/resources/reports/planning/resul ts/accomplishments/fy94accomplishment.pdf (1 Nov. 2002).

U.S. Environmental Protection Agency (1996a). Implementation guide for the code of environmental management principles for federal agencies. Washington, DC: Author.

U.S. Environmental Protection Agency (1996b). Generic protocol for conducting environmental audits of federal facilities (EPA Report 300-B-96-012 A/B). Washington, DC: Office of Enforcement and Compliance Assurance.

U.S. Environmental Protection Agency (2001a). Letter from EPA Director Christine Todd Whitman to U.S. Senate regarding: Federal facility compliance. Washington, DC: Author.

U.S. Environmental Protection Agency (2001b). National environmental performance track. http://www.epa.gov/performancetrack/(21 June 2002).

RELATED ARTICLE:

Essential Elements of an ISO 14001-Compliant EMS

1 Environmental policy
2 Planning

  2.1 Environmental aspects

  2.2 Legal and other requirements

  2.3 Objectives and targets

  2.4 Environmental management program(s)

3 Implementation and operation

  3.1 Structure and responsibility

  3.2 Training, awareness, and competence

  3.3 Communication

  3.4 Environmental management system documentation

  3.5 Document control

  3.6 Operational control

  3.7 Emergency preparedness and response

4 Checking and corrective action

  4.1 Monitoring and measurement

  4.2 Non-conformance and corrective and preventive action

  4.3 Records

  4.4 Environmental management system audit

5 Management review

Source: U.S. Department of Defense, Defense Environmental Network
and information Exchange (2002).

U.S. EPA Generic Environmental Audit Protocols--Phase I Programs

Section  1: Air Pollution Control

Section  2: Water Pollution Control

Section  3: Nonhazardous Waste Management

Section  4: Hazardous Waste Management

Section  5: CERCLA/SARA

Section  6: Spill Control and Response

Section  7: Management of Environmental Impacts

Section  8: Hazardous Materials Management

Section  9: EPCRA

Section 10: Cultural and Historical Resource Management

Section 11: Storage Tank Management

Section 12: Drinking Water Management

Section 13: PCB Management

Section 14: Pesticides Management

Section 15: Groundwater Protection

Section 16: Environmental Radiation

Source: U.S. Environmental Protection Agency (1996b).

DOD TEAM Guide Programs

Section  1:     Air Emissions Management

Section  2:     Cultural Resources Management

Section  3:     Hazardous Materials Management

Section  4:     Hazardous Waste Management

Section  5:     Natural Resources Management

Section  6:     Other Environmental Issues

Section  7:     Pesticide Management

Section  8:     Petrol, Oil, Lubricant Management

Section  9:     Solid Waste Management

Section 10:      Storage Tank Management

Section 11:      Toxic Substances Management

Section 12: Wastewater Management

Section 13: Water Quality Management

Source: USACE (2001).

Practical Stuff!

* Achieving environmental compliance at U.S. Department of Defense (DOD) and other federal facilities has become a national priority.

* Passage of the 1992 Federal Facility Compliance Act established the authority of the U.S. Environmental Protection Agency (U.S. EPA) to levy fines against federal facilities.

* DOD recently developed a standardized environmental audit tool--The Environmental Assessment and Management (TEAM) Guide.

* The authors compared DOD'S TEAM Guide with two other environmental audit tools:

-- U.S. EPA's Generic Protocol for Conducting Environmental Audits of Federal Facilities (EPA Generic Audit) and

-- ISO 14001.

* The purpose was to assess the appropriateness of these tools for DOD facilities.

* The EPA Generic Audit guidance document is 1,611 pages long.

* Audits produce voluminous "findings" but may not produce organizational change until management issues are identified in later phases of the process.

* TEAM Audit is closely related to the EPA Generic Audit.

* It uses the same burdensome checklist format, but it attempts to customize the document for DOD facilities.

* TEAM Audit focuses on simple compliance and prioritized severity levels.

* TEAM audits often do not become agents of change because they are not integrated into an environmental management structure.

* The ISO 14001 Audit uses the terms "environmental aspects" and "environmental impacts":

-- Environmental aspects are elements of an organization's activities, products, services, or physical resources that may have beneficial or harmful effects on the environment.

-- An environmental impact is the change that takes place as the result of any given aspect.

* ISO 14001 requires that all aspects and impacts be identified and integrated into an environmental management plan.

* An organization may become "certified" if it has in place all of the elements contained in the ISO 14001 Standard.

* The authors conclude that

1. The senior leadership of each facility should develop an environmental management plan based on the ISO 14001 Standard.

2. TEAM audits should be continued. Professionally trained and independent auditors should conduct the audits.

3. Audit intervals should be reduced from five years to three years.

4. Results should be communicated to all levels of the organization, with special emphasis on senior level officials.

5. Labor representatives and common workers should participate in the audit process to better understand work conditions and opportunities for improvement.

Corresponding Author: Catherine M. Neumann, Associate Professor, Department of Public Health, Oregon State University, Corvallis, OR 97331-6406. E-mail: [e-mail].