Implementation of DOE Order 450.1: Self-Declaration and Report Letters

1. Implementation of DOE Order 450.1:Self-Declaration and Report Letters Steven R. Woodbury US Department of Energy March 9, 2005

2. Overview • DOE Order 450.1 and DOE Guide 450.1-1 • Role of Self-Declaration Protocol • Sample Report Letters • Summary

3. ResponsibilitiesUnder DOE Order 450.1 • PSOs: ensure that all their sites have implemented EMS by 12/05 • Site Managers: report by 12/31/05 to CSO the status of contractor implementation of EMS • Site Managers: ensure that contractors update ISM system description to reflect EMS

4. ISMS/EMS Frameworks DOE Guide 450.1-1 (§8) Framework 1: Self-Declaration • Implement elements of an EMS, within ISMS • Meet all EMS requirements of DOE O 450.1 • Self-declare conformity to DOE O 450.1 Framework 2: ISO 14001 Registration • Implement elements of an EMS, within ISMS • Meet all EMS requirements of DOE O 450.1 • Achieve third-party registration to ISO 14001

5. OFEE Self-Declaration Protocol • Developed by E.O. 13148 Inter-Agency Work Group • Issued by Office of the Federal Environmental Executive (OFEE) • Provides a framework for agencies to establish their self-declaration protocols • DOE has implemented the Protocol through DOE Guide 450.1-1

6. OFEE Clarification of Terms • Developed by E.O. 13148 Inter-Agency Work Group • Issued by Office of the Federal Environmental Executive (OFEE) • Will provide a basis for reporting EMS status to EPA • DOE has included the definitions in the revision to DOE Guide 450.1-1

7. OFEE Clarification of Terms • First-party audit • EMS audit conducted by participants within the scope of the EMS under consideration • External second-party audit • EMS audit conducted by reviewers from outside the scope of the EMS in question • External, third-party audit • EMS audit conducted by ANSI-RAB accredited independent auditor for conformance to ISO 14001 Standard

8. Self-Declaration: DOE Guide 450.1 (§9.1) • Site determines that it fully conforms to requirements of DOE O 450.1 • To be credible, determination should be based on a first-party EMS evaluation (at minimum) • Self-declaration procedure should • provide effective and objectiveassessment of EMS • be designed for ongoing evaluation and continual improvement

9. Additional Guidance DOE G 450.1-1 (attachments) • An acceptable procedure is outlined in Attachment 2 of DOE G 450.1 • Site may use alternative self-declaration procedure (e.g. existing review/evaluation/ audit process established under ISMS) • Must credibly establish and document the existence of EMS conforming to DOE O 450.1 • In any case, process must address DOE O 450.1 EMS requirements summarized in Attachment 3 of DOE G 450.1

10. Third-Party RegistrationDOE Guide 450.1 (§9.2) • DOE sites may choose to seek third-party registration to the ISO 14001 standard • Not required by DOE Order 450.1

11. Sample Report Letters • Guidance being issued as a revision to DOE G 450.1-1 • Includes three sample letters: • EMS in place – first-party or second-party assessment • EMS in place – third party assessment • EMS not yet fully implemented

12. Sample Report Letter #1:EMS in Place; Self-Declared • Declares conformance to EMS requirements of DOE O 450.1 • Identifies basis for declaration • First- or second-party assessment? • Describe assessment procedure

13. Sample Report Letter #2:ISO 14001 Registered EMS • Declares conformance to EMS requirements of DOE O 450.1 • Identifies basis for declaration • ISO 14001 registrar, and date of audit(s) • Affirms that site EMS meets the requirements of DOE O 450.1, e.g.: • scope • integration with ISMS

14. Sample Report Letter #3:EMS Not Fully Implemented • States that sites does not yet conform to the EMS requirements of DOE O 450.1 • Identifies EMS elements not yet developed, and EMS elements not yet implemented • Identifies basis for statements • Identifies planned completion dates

15. Sample Report Letters • All Sample Report Letters also address: • Incorporation of DOE O 450.1 CRD in site contract (§ 3.b.(2)) • Integration of EMS into updated ISM system description (§ 5.d.(2)) • Inclusion of appropriate environmental elements in Annual ISM review of ES&H perf. objectives, perf. measures, and commitments (§ 5.d.(17)) • Availability of supporting documentation for review

16. Other Reporting • DOE: Annual reports to EPA under Greening of the Government E.O.s • DOE O 231.1 requires reporting to EH • DOE O 450.1 provides for “input from Departmental elements” • Program Office: Quarterly report of site implementation status • Site: Annual Site Environmental Report • EMS status • progress toward objectives and targets

17. Program Office Role • Program Secretarial Officers are ultimately responsible for ensuring that their sites implement EMS • Some Program Offices have issued specific guidance to their sites on EMS assessment and reporting

18. Communication between DOE HQ Offices and Site Offices • DOE HQ Offices – should be communicating with their site offices about their expectations for EMS self-declaration • DOE Site Offices – should be communicating with their DOE Headquarters office about their expectations for EMS self-declaration • No surprises in December 2005

19. Communication at the Sites • DOE Field Offices – should be communicating with their contractors about their expectations for EMS self-declaration • DOE contractors – should be communicating with their DOE field office about their expectations for EMS self-declaration • No surprises in December 2005

20. Bottom Line Self-Declaration process should be • Credible • Based on objective evidence • Designed for ongoing evaluation and continual improvement Site Manager’s Report Letter should • Affirm DOE site management’s knowledge of EMS implementation • Be based on available supporting documentation

21. For additional information: Steven R. Woodbury 202-586-4371 steven.woodbury@eh.doe.gov