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Incorporation of EMS audits into EPAS. Michael N. Noah, Compliance Program Manager, IMCOM-E Charles R. Georgius, URS International Inc. . Agenda. Environmental Programs and EPAS Introduction of EMS to the US Army Performing combined EMS and Compliance Assessments.
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Incorporation of EMS audits into EPAS Michael N. Noah, Compliance Program Manager, IMCOM-E Charles R. Georgius, URS International Inc.
Agenda • Environmental Programs and EPAS • Introduction of EMS to the US Army • Performing combined EMS and Compliance Assessments
Importance of Sustainability to Environmental Performance • Sustainability in terms of environmental performance is: • ability to train and conduct peace/war actions in a modern environment under shrinking global resources and regulatory encroachment • achieved through compliance with requisite laws and proactive management of resources
EPASEnvironmental Performance Assessment System • Primary objective of the EPAS program is to ensure that U.S. Army facilities are compliant with: • Final Governing Standards (FGS) • Department of Defense (DoD) Directives • Department of Army (DA) Regulations • U.S. Army in Europe (AER) Regulations IMCOM-Europe centrally conducts the EPAS program to: • evaluate • achieve • maintain and • monitor compliance with environmental requirements.
EPAS: A Program for Continuous Environmental Improvement Identify fix the the problem Implement Re-evaluate every 3 years (DoD 14715.5 requirement) Resources Develop a and $$$ Corrective Action Plan Program
External EPAS Process • Pre-Assessment • - Pre-visit questionnaire • - Collect information • - Workplan • On-Site Assessment • - In-Brief • - Interviews • - Records Review • - Site Visits • - Write Findings • Assessment Wrap-up • - Corrective Action Review • - Cost Estimates • - Out-Brief • Report • - Draft • - Final
Typical Findings • Poor HazMat/HazWaste Management • Poor solid waste management and recycling • Insufficient recordkeeping and monitoring Typical Root Causes • Lack of command awareness and support • Lack of management plans or implementation • Lack of training
Environmental Management Systems An EMS is a set of processes and practices that enable an organization to reduce its environmental impacts and increase its operating efficiency U.S. Environmental Protection Agency EPA
EMS Interfaces with other Environmental Programs • EMS incorporates existing environmental programs & regulations • HM, HW, asbestos, POL, cultural resources, etc. • ERG (Environmental Review Guide)ISR (Installation Status Report)and funding are all tied to EMS
Sustainability through EMS implementation • IMCOM-Europe strives to achieve sustainability through EMS implementation regionwide • An EMS procedure is required to properly address the Emergency Preparedness & Response aspects • Continual Improvement: Demonstrated by results of successive internal and external audits demonstrates EMS effectiveness
US Army Europe EMS Implementation • 2000: • EO 13148 Issued requiring EMS implementation • 2001: • First EMS review during EPAS assmements • 2002: • First EMS Gap Analysis performed at Region Garrison • 2003: • IMCOM-E wide EMS implementation plan produced • 2004: • Risk-Rating added to EPAS findings to help correlate with significant EMS aspects • 2006: • EMS performance audits included in EPAS
Incorporation of EMS into EPAS • EMS approach was incorporated into EPAS in response to Executive Order (EO) 13148 Greening the Government through Leadership in Environmental Management (22 Apr 00 ) • EO 13148 was replaced by EO 13423 (Strengthening Federal Environmental, Energy, & Transportation Management) on 24 Jan 07 • New EO still emphasizes EMS
Incorporation of EMS into EPAS • EPAS program was adapted to support EMS implementation and thus sustainability • Provides the Army a more transparent and cost-effective approach to managing increasingly finite resources • Helps focus on identification and correction of root causes
Incorporation of EMS into EPAS • A full conformance audit of the Garrison’s EMS was added to EPAS in FY06 • Compliance status is still assessed and is considered a barometer of how effective the EMS is • In the past, during an assessment, an attempt was made by the EPAS Teams to visit all relevant facilities. • Through the new EMS-oriented approach a representative sampling of facilities is visited by the EPAS Team. • More comprehensive assessment of the Garrison’s overall environmental performance • Approach may result in fewer compliance findings
Benefits of EMS Incorporation of EPAS • Single Audit – Less disruptive to Garrison operations • More cost-effective than conducting two audits • Ensures performance-based EMS Implementation • Provides Garrison with external observations and guidance on their EMS
Contact Information Michael N. Noah Compliance Program Manager IMCOM - Europe Region / Environmental Branch E-mail: michael.d.noah @eur.army.mil Phone: DSN (314) 370-6073 Fax: DSN (314) 370-8693 Charles R. Georgius DoD Program Manager URS International Inc. E-mail: chuck_georgius@urscorp.com Phone: ++49-6103-9389-12 Fax: ++49-6103-9389-99 David Barber EMS Program Manager IMCOM - Europe Region / Environmental Branch E-mail: david.barber @eur.army.mil Phone: DSN (314) 370-6536 Fax: DSN (314) 370-8693