United States

Environmental Protection

Agency

Office of Enforcement and

Compliance Assurance

EPA 315-R-99-003

November 1999

Environmental Management

Review (EMR) National Report:

Lessons Learned in Conducting

EMRs at Federal Facilities
This document was prepared by EPA’s Federal Facilities Enforcement Office (FFEO)

in the Office of Enforcement and Compliance Assurance. The study was directed by

James Edward and Sarah Hart. Technical research, writing, editing, and document

design/layout support was provided by SAIC under EPA contract No. 68-C6-0027.

For additional copies of this document, please contact:

The Federal Facilities Enforcement Office (2261A)

U.S. Environmental Protection Agency

401 M Street, S.W.

Washington, DC 20460

Tel: (202) 564-2510

Fax: (202) 501-0069

Copies of the document also can be obtained on-line at the FFEO Web site:

http://www.epa.gov/oeca/fedfac/fflex.html

In addition, updates to the document will be available on-line.

Acknowledgment

The Federal Facilities Enforcement staff gratefully acknowledges the contributions of

EPA’s Program Offices and the Regions in reviewing and providing comments on this

document.

Limitations of This Document

This document is written to serve as a basic reference. Due to the rapidly changing

area of environmental law, the reader is advised to consult the current version of the

relevant statute or regulation for the most accurate information. Where the actual text

of a statute, regulation, executive order, policy, guidance or other document differs

from the description of such documents contained in this document, the actual text of

the statute, regulation, executive order, policy, guidance or other document should be

followed. This document does not constitute rule making by the Agency and may not

be relied upon to create a right or benefit, substantive or procedural, enforceable at law

or in equity, by any person. The Agency may take action at variance with this 

document and its internal implementation procedures.
TABLE OF CONTENTS

Section 1 - Overview ......................................................... -3-

1.0 Introduction ..................................................... -3-

1.1 The Future of EMRs .............................................. -4-

1.2 Purpose of this Report ............................................ –5-

1.3 EMRs and Their Role in Compliance Assistance Activities ............... -5-

1.4 EMRs and the CEMP ............................................. -6-

1.5 EPA Position Statement on EMSs and ISO 14001 ....................... –8-

1.6 Lessons learned ................................................. –8-

Section 2 - EMR Background .................................................. -11-

2.0 Policy Development ............................................. -11-

2.1 EMS Standards & Guidelines ...................................... –12-

2.2 Benefits of an EMR ............................................. -13-

Section 3 - EMR Pilot Program Methodology Assessment and Lessons Learned ........... -17-

3.0 Goals of the EMR Pilot Program ................................... -17-

3.1 Different Regional Approaches to EMRs ............................. -18-

3.1.a EPA Phase 3 Audit Protocol Approach ........................ -21-

3.1.b EPA Phase 3 Audit Protocol/CEMP approach ................... -21-

3.2 Lessons Learned ................................................ -21-

3.2.a The IVRP did not result in enforcement actions or penalties at any 

facility receiving an EMR during the pilot program ............... -21-

3.2.b Difficult to Stay within the Selected EMR Scope ................. -21-

3.2.c Ample preparation time is critical ............................ -22-

3.2.d Avoid surprises .......................................... -22-

3.2.e Conduct pre-site visit meetings with site representatives ........... -23-

3.2.f Post-EMR evaluations help build a better EMR program........... -23-

3.2.g Inform interview personnel of the EMR process as soon as possible . . -23-

3.2.h Neutral on-site escorts can facilitate candid discussions ........... -23-

3.2.i Mixed EMR team with management and technical expertise worked 

best .................................................... -24-

3.2.j Produce report in a timely manner ............................ -24-

3.2.k Note that an EMR is a snapshot in time ........................ -24-

3.3 Federal facility comments/feedback on the Pilot Program ................ -24-

3.4 How Lessons Learned Resulted in Changes in the EMR Policy ............ -25-

Section 4 - Summary of Federal Facility EMR Findings ............................. -27-

4.0 Overview of findings and recommendations in EMR reports .............. -27-

4.0.a Strengths of facility EMSs .................................. -27-

4.0.b Main areas for improvement of the facility EMSs ................ -28-

4.1 Recommendations implemented by facilities .......................... -31-

Section 5 - Conclusion ....................................................... -33-

Appendices ................................................................ -35-
2

APPENDIX A - EMR Case Studies ............................................. -37-

APPENDIX B - Final EMR Policy .............................................. -47-

APPENDIX C - Process steps for a sample EMR .................................. -59-

APPENDIX D - EMR Tools and Related Compliance Assistance Resources ............. -61-
Overview

3

SECTION1

OVERVIEW

1.0 Introduction

Since its inception in 1970, the Environmental

Protection Agency (EPA) has used a variety of

methods to help regulated organizations

understand and comply with environmental

regulations. During the agency’s formative

years, the regulated community primarily

sought explanations of the relatively new

regulations, as organizations reacted to changes

in the regulatory environment. However,

during the past decade, it has become

inefficient for organizations to simply react to

regulatory changes and issues of

noncompliance.

In increasing numbers, public and private

sector organizations changed their focus from

reactive to proactive, choosing to prevent

pollution at the source. With fewer resources

available to them, facility managers used

improved tools to address complex

environmental issues and to help ensure their

site’s long-term environmental compliance.

Many environmental managers chose to revise

their management systems to proactively

address environmental issues. In conjunction

with this paradigm shift, EPA increased the

types and numbers of compliance assistance

activities offered. One new tool added to

EPA’s compliance assistance tool kit for

federal facilities was the Environmental

Management Review (EMR). This report is

intended to give federal facility managers new

insights into the EMR process, describe how a

review can benefit managers, and provide

information on the results of and lessons

learned from EMRs conducted at federal

facilities during EPA’s EMR Pilot Program,

which began in May 1996 and ended in

September 1998.

As defined in EPA’s Final EMR Policy for

Federal Facilities, an EMR is “a review of an

individual facility’s program and management

An EMR is “a review of an individual

facility’s program and management

systems to determine the extent to which

a facility has developed and

implemented specific environmental

protection programs and plans which, if

properly managed, should ensure

compliance and progress towards

environmental excellence.”

EPA’s Final EMR Policy

December 1998

This section provides background information on EMRs, explains the purpose of this

report, and provides the primary EMR Pilot Program lessons learned.
Overview

4

systems to determine the extent to which a

facility has developed and implemented

specific environmental protection programs

and plans which, if properly managed, should

ensure compliance and progress toward

environmental excellence.” The majority of

the EMRs conducted during the pilot program

did not review a facility’s entire environmental

management system (EMS); rather, the focus

was generally on selected portions of the

facility’s systems. The facility staff and the

EPA Region determined how much of the

system was to be reviewed during each EMR.

1.1 The Future of EMRs

Given the increased interest in the pilot

program, EMRs are slated to be an integral

part of EPA’s compliance and technical

assistance toolbox at federal facilities for

years to come. Agencies appreciated the

technical assistance, the ways in which EMRs

heightened environmental awareness at

facilities, and how the EMRs focused on

addressing environmental issues via a

systematic approach. EPA and the regulated

community alike recognize that it is more

efficient to identify and address environmental

matters before they become compliance issues.

While compliance inspections will continue,

EPA will also emphasize working

cooperatively with federal facilities, using

management system-based approaches, to

reduce the facilities' environmental impacts in

the most effective manner possible. 

EMRs are not regulatory inspections.

However, when a facility volunteered to

participate in the EMR program, it also agreed

to abide by the program's Incidental Violations

Response Policy (IVRP). This policy

recognized that there may be circumstances

when an EMR incidentally uncovers violations

either through document review or while on

site. The IVRP described how violations

would be treated if they were incidentally

uncovered at a federal facility participating in

the EMR program. Although some of the

participants raised concerns about the policy,

there were no enforcement actions taken or

fines assessed as a result of EMRs conducted

during the pilot program. 

EPA encourages agencies to participate in the

EMR program. The primary audience for this

report is the federal facility managers

responsible for ensuring compliance with

applicable environmental regulations. The first

step in becoming a participant is to contact the

appropriate EPA Regional Federal Facility

Coordinator. Appendix D provides contact

Agencies Receiving an EMR 

During the Pilot Program

- Air Force

- Army (2)

- Army Corps of

Engineers(2)

- Army National Guard

- Bureau of Indian

Affairs

- Bureau of Prisons

- Coast Guard (2)

- Department of

Agriculture

- Department of Energy

- Department of the

Treasury

- Environmental

Protection Agency (3)

- Federal Aviation

Administration

- Federal

Emergency

Management

Agency

- Fish & Wildlife

Service (2)

- National

Aeronautics &

Space

Administration

- National Park

Service

- Navy (2)

- U.S. Postal Service

(3)

- U.S. Mint

- Veteran’s Health

Administration
Overview

5

information for those coordinators.

1.2 Purpose of this Report

To comply with Executive Order (EO) 12088

(Federal Compliance with Pollution

Standards), EPA’s national and regional

federal facility programs supply technical

assistance to federal facilities to ensure cost

effective and timely compliance with

environmental regulatory requirements. EPA

initiated a pilot program in 1996 to determine

if EMRs were a useful tool for EPA staff to

add to their compliance assistance toolbox for

federal facilities.

EPA Regions 1, 6, and 10 conducted EMRs for

several years prior to the pilot program.

Twenty-nine reviews were conducted at

federal facilities in seven EPA regions during

the nationwide two and a half year pilot

program. Twenty different federal agencies

participated. The pilot program enabled EPA

personnel to apply the lessons learned from

conducting EMRs and, in turn, modify the

program to better suit the needs of future

participants.

This report:

• Provides background information on

EMRs;

• Describes the essence of the EMR

Pilot Program;

• Highlights the lessons learned from the

program; and

• Forecasts the future of EMRs and their

role in EPA’s compliance assistance

program.

1.3 EMRs and Their Role in Compliance

Assistance Activities 

EPA compliance assistance information and

activities seek to ensure that the regulated

community understands its regulatory

obligations. An effective compliance

assistance program helps protect public health

and the environment by making it easier for

regulated entities to comply with applicable

regulations. EPA’s compliance assistance

tools often include compliance audits,

pollution prevention opportunity assessments,

and EMRs.

Compliance audit teams review a facility’s

activities and processes and determine if any

of the activities or their by-products meet the

applicable environmental regulatory

requirements. The subsequent audit report

identifies the compliance gaps. 

During a pollution prevention opportunity

assessment (PPOA), the technical assistance

providers review a facility’s processes,

focusing on material inputs and wastes

generated, and work with the facility personnel

to develop a list of projects that reduce or

eliminate waste at the source. 

Alternatively, an EMR focuses on the ways in

which a federal facility manages its activities

Examples of Compliance 

Assistance Activities

Activity

EMR

PPOA

Compliance Audit

-

-

-

Focus Areas

Management Activities

Processes & Materials

Compliance with

Environmental

Regulations
Overview

6

to decrease or eliminate the site’s

environmental impact, and how environmental

considerations are formally woven into its

processes and activities. It focuses on the

system of policies and procedures the facility

consistently uses to address environmental

issues and maintain compliance with

environmental regulations. The team reviews

documents and interviews facility personnel to

better understand the existing environmental

management system (EMS), analyzes the

system to identify and describe its strengths

and areas for improvement, and recommends

ways to enhance the effectiveness of the

system. While the areas of focus may differ,

all three of these compliance assistance

activities benefit the federal community by

assisting facility environmental management

efforts.

1.4 EMRs and the Code of

Environmental Management

Principles

The Code of Environmental Management

Principles for Federal Agencies (CEMP),

developed by EPA in response to Executive

Order (EO) 12856 (Federal Compliance with

Right-to-Know Laws and Pollution Prevention

Requirements), is a collection of five broad

principles (management commitment,

compliance assurance and pollution

prevention, enabling systems, performance and

accountability, and measurement and

improvement) and underlying performance

objectives that federal agencies can use as a

guide to move toward effective environmental

management.

Environmental management systems can be

based on and compared to different sets of

standards or guidelines. As the list below

demonstrates, a variety of EMS standards or

guidelines exist worldwide. Some of these are

used to develop systems for federal facilities

throughout the United States: 

• Generic Protocol (Phase 3) for

Conducting Environmental Audits at

Federal Facilities

• Code of Environmental Management

Principles for Federal Agencies

(CEMP)

• International Organization for

Standardization (ISO) 14001

• International Chamber of Commerce’s

(ICC) Business Charter for Sustainable

Development

• Chemical Manufacturer’s

Association’s Responsible Care

Guidelines

• Protocols for Conducting

Environmental Management

Assessments of DOE 

Organizations

EMR participants should take steps to

ascertain which standard or guideline should

be used during the system review. The facility

needs its parent agency or personnel at

headquarters to determine if one guideline

would be better than the rest. Federal facilities

should also keep in mind that 16 agencies

endorsed the CEMP, which may make the

CEMP the best choice for use in developing an

EMS. Lastly, each facility should determine

which one of the guidelines best matches the

site’s existing management system structure.

 Each standard or guideline examines a system

from a slightly different point of view and

emphasizes different parts of a management

system. Later in this report (Section 2.1), there

is an outline on the approach for three of the
Overview

7

primary standards. For example, the Generic

Protocol (Phase 3) for Conducting

Environmental Audits at Federal Facilities1

touches on but does not focus on a system’s

ability to address emergency management

issues, however, the Implementation Guide

for the Code of Environmental Management

Principles for Federal Agencies2 has an entire

section devoted to emergency preparedness.

Differences such as this do not make one

standard superior to another; they simply

provide examples of the various lenses through

which one can view an EMS. 

In early September and October 1996, the

International Organization for Standardization

published the first five standards in the ISO

14000 series of environmental management

system standards. On September 1, 1996, ISO

officially published ISO 14001,

“Environmental Management Systems -

Specification with Guidance for Use.” The

ISO 14001 standard specifies requirements for

establishing an environmental policy,

determining environmental aspects & impacts

of products/activities/services, planning

environmental objectives and measurable

targets, implementing and operating programs

to meet objectives & targets, establishing a

program for checking and correcting

environmental programs, and conducting

management system reviews.

Currently, federal facility EMRs are based on

either the Generic Protocol (Phase 3) for

Conducting Environmental Audits at Federal

Facilities or the CEMP. Thus, EMR teams

used either one of the two standards or a

combination of the two to guide them through

the review process. Section 2.1 of this report

provides details on the linkages between the

two standards, and Section 3.1 describes the

different methods and standards used by the

EPA regions.

1.5 EPA Position Statement on EMSs

and ISO 14001

On March 12, 1998, EPA published in the

Federal Register (63 FR 12094) its Position

Statement on EMS and ISO 14001. In that

Position Statement, EPA encourages:

• The use of EMSs that focus on

improved performance, compliance,

source reduction, and system

1 This document (EPA Document No.

300-B-96-012 A&B) can be obtained by

contacting the U.S. EPA Federal Facilities

Enforcement Office at 202-564-2461.

2 This document (EPA Document No.

315-B-97-001) can be obtained by contacting the

U.S. EPA Federal Facilities Enforcement Office at

202-564-2461.

Standards and Guidelines By Which 

U.S. EMSs Are Developed

- Federal Facilities Phase 3 Protocol for

Conducting Environmental Audits at

Federal Facilities

- CEMP

- ISO 14001

- International Chamber of Commerce’s

(ICC) Business Charter for Sustainable

Development

- Chemical Manufacturer’s Association’s

Responsible Care Guidelines

- Protocols for Conducting

Environmental Management

Assessments of DOE 
Overview

8

performance;

• Organizations to maintain

accountability for the performance

outcomes of their EMSs through

measurable objectives and targets;

• The development of EMSs through an

open and inclusive process with

relevant stakeholders;

• Dissemination of information on the

actual performance of EMSs to the

public and government; and

• The review of EMSs to achieve

superior environmental performance.

The Position Statement quotes verbatim from

the North American Commission on

Environmental Cooperation (CEC) Council

Resolution #97-05 which states that, “adoption

of EMSs based on ISO 14001 may foster

improved compliance and performance, but

does not constitute or guarantee compliance or

in any way prevent governments from taking

enforcement action where appropriate.” At

this time, EPA does not base any regulatory

incentives solely on the use of EMSs, or

certification to ISO 14001.

The Federal Register notice also solicits

comment on the categories of information and

data that will be gathered through ISO 14001

pilot projects, including environmental

performance, compliance, pollution

prevention, environmental conditions,

costs/benefits to implementing facilities, and

stakeholder participation and the effect that

such participation has on the public credibility

of EMS implementation.

1.6 Lessons Learned

During the course of the pilot program, many

lessons were learned about the EMR process

itself, and common strengths and weaknesses

of environmental management systems at

federal facilities. The information below

highlights what is explained in greater detail

throughout the rest of this report.

EMR Process Lessons Learned

• The IVRP did not result in enforcement

actions or penalties at any facility

receiving an EMR during the pilot

program,

• It is difficult to stay within the selected

EMR scope,

• Ample preparation time is critical,

• Avoid surprises,

• Conduct pre-site visit meetings with

site representatives,

• Post-EMR evaluations help build a

better EMR program,

• Inform personnel to be interviewed of

the EMR process as soon as possible,

• Neutral on-site escorts can facilitate

candid discussions,

• Combine management and technical

expertise in an EMR team for best

results,

• Produce reports in a timely manner,

and

• Note that an EMR is a snapshot in time.

Common EMS strengths among federal

facilities

• Personnel acknowledge their

environmental responsibilities and are

committed to protecting the

environment;

• Field staff routinely review facility

environmental performance;

• Agencies participate in cooperative
Overview

9

environmental programs with other

organizations; and

• Environmental considerations are

incorporated into most planning

processes.

Common EMS areas for improvement

among federal facilities

• Agencies and facilities lack adequate

environmental staff and formal, annual

training plans and mechanisms to track

individual training needs and

accomplishments;

• Facilities lack formal environmental

management programs;

• Facilities lack facility-specific

environmental policies, goals,

objectives, or targets;

• Facilities lack commitment to going

beyond compliance; facilities seek

only to meet compliance requirements;

• Work being done does not match job

descriptions and performance

evaluations;

• Lessons learned (positive and

negative) are not shared with other

federal facilities, let alone with

facilities within the same agency;

• Line and staff personnel are not asked

for their opinion during the policy

development process;

• Tenant organizations are not held

responsible for adhering to a site’s

EMS; and

• Management is not aware of the work

being done to minimize the site’s

impact on the environment. 
Overview

10

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EMR Background

11

SECTION2

EMR BACKGROUND

2.0 Policy Development

Following a six-month development effort, the

EMR Workgroup, which included staff of the

Federal Facilities Enforcement Office (FFEO),

the EPA Assistant Administrator for

Enforcement and Compliance Assurance, and

Federal Facility Coordinators from eight EPA

regions, issued the Interim EMR Policy on May

31, 1996. Prior to issuance, the Interim Policy

was formally reviewed by staff of the Office of

Enforcement and Compliance Assurance

(OECA) and the Regions. 

The EMR Pilot Program began shortly

thereafter to test the policy and guidance at

individual federal facilities. Twenty-nine

EMRs were conducted by seven Regional

offices during the pilot program. Comments on

the draft Final EMR Policy and guidance were

received from OECA and regional offices, and

revisions were made based on the concerns

raised. A list of the major changes made to the

Interim EMR Policy is included below, and

those changes are further explained in Section

3.3 of this report. The Final EMR Policy (Appendix B)

incorporates the lessons learned from the pilot

program reviews. 

Changes Made To The 

Interim EMR Policy

- Facilities must disclose within 10

days violations incidentally

discovered through the EMR

process.

- EPA will generally not conduct

inspections at the participating

facility for six months after the

EMR.

- The facility must submit only one

report to EPA.

- Only EPA’s signature is needed on

the EMR confirmation letter.

- EPA can take various enforcement

responses in response to discovered

violations.

- EMR’s relationship to ISO 14001

and the Code of Environmental

Management Principles (CEMP)

This section discusses the development of the Final EMR Policy, shows the relationships

between different EMS standards and guidelines, and describes the benefits and the future

of EMRs.
EMR Background

12

2.1 EMS Standards & Guidelines

As noted earlier, there are numerous standards

and guidelines used by organizations to guide

them through the EMS development process.

The Generic Protocol (Phase 3) for

Conducting Environmental Audits at Federal

Facilities breaks a system into seven parts, or

disciplines:

1. Organizational Structure

2. Environmental Commitment

3. Formality of Environmental Programs

4. Internal and External Communications

5. Staff Resources, Training, and

Development

6. Program Evaluation, Reporting, and

Corrective Action

7. Environmental Planning and Risk

Management

The Code of Environmental Management

Principles (CEMP), developed by EPA in

response to the President’s Executive Order

(EO 12856) and in conjunction with personnel

from 16 federal departments and agencies,

breaks environmental management into five

primary components of an effective EMS:

1. Management Commitment

2. Compliance Assurance and Pollution

Prevention

3. Enabling Systems

4. Performance and Accountability

5. Measurement and Improvement

Lastly, the ISO 14001 standard views an EMS

from a different set of five areas:

1. Environmental Policy

2. Planning

3. Implementation and Operation

4. Checking and Corrective Action

5. Management Review

Even though the primary EMS standard and

guideline headings are not an exact match,

there are a great number of similarities among

the standards and guidelines. Table A

provides information on the correlation

between the EMR protocols, ISO 14001

sections, and the CEMP.
EMR Background

13

TABLE A 

CORRELATION BETWEEN EMR DISCIPLINES, THE CEMP PRINCIPLES, AND SECTIONS OF ISO 14001

EMR DISCIPLINE CEMP PRINCIPLE ISO 14001 SECTION

Organizational Structure 1 3

Environmental Commitment 1 1

Formality of Environmental

Programs

2 & 3 1, 3, & 4

Internal & External

Communications

3 3

Staff Resources, Development,

and Training

3 & 4 3

Program Evaluation, Reporting, &

Corrective Action

3 & 5 4 & 5

Environmental Planning & Risk

Management

2 & 3 2 & 3

2.2 Benefits of an EMR

A facility will discover that its EMS becomes

a much more powerful management tool if

continuous improvement is woven into the

management system’s framework. A system

should be dynamic, with procedures, policies,

job descriptions, and performance reviews all

changing as the organization evolves. There

are numerous ways to update a facility’s

management system; two of the more common

are: 1) an annual internal EMS review and

revision, and 2) an annual review conducted by

an outside party. An EMR is an example of the

second method (the EMR process steps are

located in Appendix B).

By working collaboratively with EPA, a

facility can obtain many benefits from a review

of its system. The first benefit is that it is a

voluntary and inexpensive way to determine

the health of a facility’s EMS. A compliance

inspection is a reactive, mandatory method

used by EPA to address a facility’s

environmental problems. However,

Benefits of an EMR

- It is a collaborative & inexpensive

means to enhance a facility’s EMS

- An outside party can discover issues

overlooked by busy facility staff

- EPA’s wealth of regulatory and

technical environmental expertise is

made available to the facility 

- The facility benefits from EPA’s

ability to facilitate root cause

analysis exercises

- It can lead to long-term

environmental 

compliance and enhanced

management accompanied by

resource reduction

- It provides feedback on the

effectiveness of a facility's system,

benchmarks the facility's

performance, and identifies

opportunities for improvement.
EMR Background

14

volunteering for a free EMR creates a

partnership between the facility and EPA. In

fact, EPA officials view the reviews as a way

to work together with facility staff to enhance

the way they have chosen to systematically

address environmental issues. The partnership

created or improved by the EMR often helps

break down communications barriers and

provides evidence that EPA is no longer

simply a command-and-control organization.

EPA views federal facilities as customers and

believes that EMRs are yet another useful way

to partner in the effort to reduce the

government’s environmental impact. EPA has

transitioned from a command-and-control

agency to one encouraging collaboration and

cooperation with other agencies. 

Second, it is relatively easy for a facility to

overlook an EMS’s deficiencies, especially if

there are no current noncompliance issues

attributed to them. Many organizations find

that a management system review conducted by

an outside party uncovers areas of the EMS

that could be improved, even after an internal

review did not reveal such problems. 

A third benefit to the facility is the opportunity

to take advantage of EPA’s regulatory and

technical knowledge in a non-threatening

environment. Granted, the official scope of an

EMR is generally confined to the review of

management systems that are designed to

address environmental matters. However,

while the EPA team is on-site, facility

personnel are encouraged to open the lines of

communication by asking questions about

environmental issues, e.g., compliance issues

and pollution prevention opportunities, in

order to tap into the wealth of environmental

knowledge and expertise available to the

facility. In addition, the on-site portion of the

review facilitates discussions between the

Regional Federal Facility Coordinator and the

facility personnel. These conversations often

introduce facility personnel to many of the

initiatives, conferences, and outreach activities

offered by EPA of which facility staff are often

unaware. 

Fourth, in addition to uncovering deficiencies

not yet discovered, an EMR team also can help

the facility work through root cause analysis,

identifying underlying causal factors which

may contribute to environmental program

deficiencies. For example, it is generally easy

to find that a staff member has not been

properly trained on environmental matters.

However, it takes more time and effort to

determine that the root cause of the problem is

a faulty training schedule database. EPA’s

management system review experience,

combined with the facility personnel’s

background knowledge of the facility’s EMS,

produce a strong team that can efficiently

identify a deficiency’s origin. Facilities

become better equipped to proactively identify

and minimize environmental impacts, in the

context of shrinking budgetary allocations.

With a trend toward downsizing in the

government, facility managers need better tools

to handle complex issues when resources

decrease. EMRs enable a facility to optimize

its system, which in turn helps to ensure longterm environmental compliance and

improvements in environmental issue

resolution. 

Another benefit is that EMRs often provide

feedback on the effectiveness of a facility's

environmental management system. It can help

a facility establish baselines so that it can

benchmark its performance, and identify

opportunities for improvement.
EMR Background

15

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EMR Pilot Program Methodology Assessment and Lessons Learned

16

SECTION3

EMR PILOTPROGRAM

METHODOLOGYASSESSMENT AND LESSONS LEARNED

3.0 Goals of the EMR Pilot Program

EPA is always searching for better ways to

serve its customers. After passage of the

Pollution Prevention Act of 1990 and the

signing of Executive Order 12856 in 1993, the

agency focused its efforts on creating programs

to help federal facilities conduct PPOAs,

develop pollution prevention plans, train

personnel, and implement projects. In a

similar fashion, EPA developed the EMR Pilot

Program in response to the growing interest in

environmental management systems. During

the mid-1990s, environmental experts

worldwide were touting the advantages of the

facility environmental management system. In

response to international interests, ISO 14001

was drafted and the standard became final in

September 1996. On a parallel path, EPA

issued the Interim Final EMR Policy and began

the EMR Pilot Program in May 1996.

EMRs were conducted at federal facilities in

the early 1990s in EPA Regions 1, 6, and 10.

In addition, one of the recommendations in the

1994 Civilian Federal Agency (CFA)

Environmental Task Force Report was that

EPA provide more on-site compliance

assistance via a comprehensive EMR program

in all ten EPA Regions.

 One of the goals of the pilot program was to

determine how federal facilities would react to

a nationwide review program. It was unclear

how receptive they would be and how willing

they would be to voluntarily grant EPA access.

The facilities targeted for the pilot program

were generally smaller sites, which may not

have the resources to develop an EMS on their

own. Since some of the CFA sites had limited

experience interacting with EPA prior to the

EMR Pilot Program, another goal was to

determine how they would react to EPA’s

outreach efforts. 

EMR Pilot Program Goals

- Determine types/sizes of facilities

where EMRs are most effective

- Determine federal facility’s

reaction to/willingness to

participate in the program

- Determine if future EMRs had to

include the entire facility EMS

- Test different EMR methodologies

- Gain experience and incorporate

lessons learned into the Final EMR

Policy

This section describes the goals of the EMR Pilot Program, describes the different

approaches to conducting EMRs, explains the lessons learned, and identifies the major

changes to the EMR Policy.
EMR Pilot Program Methodology Assessment and Lessons Learned

17

A third goal of the pilot program was to

ascertain whether or not a facility’s EMS could

be reviewed discipline-by-discipline.

Depending on the size and complexity of the

facility, a comprehensive management system

audit could take more than a week to complete

and cost more than double of what a traditional

EMR costs. As noted earlier, the majority of

the pilot program EMRs did not review entire

systems, instead they focused only on certain

management system disciplines (e.g.,

Communications, Environmental Commitment).

Closely related to the third goal was the fourth

goal, which was to test different EMR

methodologies to determine if one methodology

was more successful than another. Section 3.1

further explains the different approaches used

by EPA Regional Federal Facility

Coordinators.

A final goal of the pilot program was to

identify areas within the interim EMR policy

that could be improved upon in order to craft a

more complete final policy. That goal was

achieved by identifying the pilot program’s

lessons learned and using them to develop the

final policy. The team charged with interim

policy development relied on the experience

gained from the limited number of reviews

conducted in the early 1990s and the

experience gained from being part of the ISO

14001 development process. However, there

were still questions to be answered: What

should be the process for conducting EMRs?

How would the Incidental Violation Response

Policy (IVRP) affect the program and its

acceptance? Upon which standard should the

EMRs be based - the Federal Facilities Phase

3 Protocol for Conducting Environmental

Audits at Federal Facilities, the CEMP, or

ISO 14001? What should be the format of the

follow-up reports? Who should sign the

confirmation letter (and should there even be a

confirmation letter)? EPA’s plan was to

answer these and other questions by conducting

EMRs and basing its answers on facts rather

than supposition. EPA took full advantage of

the nationwide program by allowing each

Regional Federal Facility Coordinator to

determine the ways in which EMRs would be

conducted in the region. By providing regions

with this flexibility, EPA could then understand

the strengths and identify the weaknesses of

each unique approach.

3.1 Different Regional Approaches to

EMRs

Each Regional Federal Facility Coordinator

had a slightly different vision regarding how

EMRs should be conducted. The matrix in

Table B summarizes the methodologies used by

each region during the pilot project. Once

again, the pilot program provided an

opportunity to use different review

methodologies and use the lessons learned

from the different approaches to formulate the

final EMR policy.

Some of the facilities that were asked to

participate in the pilot program were

Questions To Be Answered 

By The Pilot Program 

- What should be the process for

conducting EMRs?

- How would the Incidental Violation

Response Policy (IVRP) affect the

program and its acceptance? 

- Upon which standard (i.e., the

Federal Facilities Phase 3 Protocol

for Conducting Environmental

Audits at Federal Facilities, the

CEMP, or ISO 14001) should the

EMRs be based? 

- What should be the format of the

follow-up reports? 

- Who should sign the confirmation

letter (and should there even be a

confirmation letter)?
EMR Pilot Program Methodology Assessment and Lessons Learned

18

concerned about the IVRP. It should be noted

that no enforcement actions were taken and no

fines were issued under the IVRP during the

pilot program. However, EMRs were

instrumental in highlighting ways in which

facilities could improve their processes and

potentially reduce their environmental

liabilities. During the course of the interview

and document review process, EPA teams

helped facilities identify potential

environmental problems. In addition, the EMR

assisted EPA personnel in focusing on which

compliance assistance tools and activities

would most benefit the facility in the future.
EMR Pilot Program Methodology Assessment and Lessons Learned

* Regions 3, 7, and 10 did not conduct EMRs during the 2.5 year EMR Pilot Program. However,

Region 10 conducted one EMR in FY 93.

3 As requested by the customer, EPA Region 2 created a new discipline (Environmental Policy

Implementation) based on the seven existing EPA Phase 3 Audit Protocol disciplines, for the United States

Postal Service (USPS) EMRs.

19

TABLE B

REGIONAL EMR METHODOLOGIES

Region Protocol Used

Average

On-site

Time

Average

Number of

Disciplines

Reviewed

Number of

Pilot EMRs

IVRP

Incidents

Region 1

Combination of the

EPA Phase 3 audit

Protocol and the

CEMP

One day All (5) 12 None

Region 2

Developed a unique

protocol for the USPS3

based on EPA Phase 3

audit Protocol

Two days 1 3 None

Region 3* N/A N/A N/A N/A N/A

Region 4

Combination of the

EPA Phase 3 audit

Protocol and the

CEMP

Two days All (5) 3 None

Region 5 EPA Phase 3 audit

Protocol

Two days 2 2 None

Region 6 EPA Phase 3 audit

Protocol

Two days 3 5 None

Region 7* N/A N/A N/A N/A N/A

Region 8 EPA Phase 3 audit

Protocol

Two days 3 2 None

Region 9 EPA Phase 3 audit

Protocol

Two days 3 2 None

Region 10* N/A N/A N/A N/A N/A
EMR Pilot Program Methodology Assessment and Lessons Learned

20

3.1.a EPA Phase 3 Audit Protocol

Approach

The column labeled “Protocol Used” in Table

B indicates the type(s) of protocol used by

each EPA region. Of the seven EPA Regions

participating in the EMR Pilot Program, five

used the Generic Protocol (Phase 3) for

Conducting Environmental Audits at Federal

Facilities as the basis for their review, while

the other two Regions elected to use a protocol

that was a hybrid of the Generic Protocol

(Phase 3) for Conducting Environmental

Audits at Federal Facilities and the CEMP. In

general, those Regions opting to solely use the

Generic Protocol (Phase 3) for Conducting

Environmental Audits at Federal Facilities

elected to limit the review to two or three of

the seven disciplines. All but one of the EMRs

were conducted with the understanding that the

facility already had an environmental

management system and the EPA team was

tasked to critique it. However, one facility

told the team prior to its on-site arrival that the

facility did not have an EMS; this facility

asked EPA to assess the facility’s processes

and recommend how the facility should create

a management system.

3.1.b EPA Phase 3 Audit Protocol/CEMP

approach

Two regions (Regions 1 & 4) chose to create

and use a protocol that was a hybrid of the

Generic Protocol (Phase 3) for Conducting

Environmental Audits at Federal Facilities

and the CEMP; this approach split an EMS into

five disciplines. In addition, these regions also

reviewed each facility’s entire system, instead

of focusing on certain parts of the EMS. By

giving the regions flexibility in the EMR

methodology they used, EPA was able to

determine the strengths and weaknesses of the

different approaches. 

3.2 Lessons Learned

One of the primary goals of the EPA pilot

program is to determine how the program

could be optimized and where EMR team

members should look for potential pitfalls.

The 29 pilot program reviews not only

identified areas for program improvement, but

also highlighted potential problem areas in the

EMR process of which team members should

be aware. The following, in no particular

order, describes these areas.

3.2.a The IVRP did not result in

enforcement actions or penalties at

any facility receiving an EMR during

the pilot program

Some facilities raised concerns about the IVRP

prior to the EMR team going onsite. The

primary concern was that by voluntarily

allowing an EPA representative onsite, the

facility would increase the likelihood of

incurring a fine or having an enforcement

action brought against it. However, there were

no cases where the IVRP was invoked, and no

enforcement actions, fines, or penalties were

issued during the pilot program. These data

underscore the point that an EMR is not an

enforcement inspection and does not increase

a participant's environmental liability.

3.2.b It is difficult to stay within the

selected EMR scope

It was difficult to stay within the confines of

the EMR scope in instances where only partial

EMS reviews were conducted. For example,

in one review, two disciplines (Organizational

Structure and Communications) were the focus.

However, after reviewing certain documents

and interviewing a few key personnel, it

became apparent that a lack of formality in

environmental programs was one root cause

for the problems in the two focus areas. Thus,

the EMR was altered in mid-course, with a

third discipline added to the scope to help

benefit the facility as much as possible. 
EMR Pilot Program Methodology Assessment and Lessons Learned

21

In addition, it takes a great amount of effort to

stick to the EMR scope because there is

overlap among the seven disciplines. For

example, questions concerning training

(discipline number five) link with questions

pertaining to environmental commitment

(discipline number two). If there is a lack of

environmental commitment, then often there are

lapses in the facility’s environmental training

regimen. In this instance, the team must decide

whether to ask questions pertaining to the

facility’s lack of environmental commitment

(out of the scope’s boundaries), or stick to the

prescribed disciplines for review and risk

doing a disservice to the customer. Since the

final policy did not change on this matter in that

it still describes an EMR as a partial system

review, team members should be flexible and

willing to alter the scope of the review if it is

agreeable to all parties involved (i.e., the

facility and the EMR team). 

3.2.c Ample preparation time is critical

Since the EMR is usually something facility

personnel have to do in addition to their daily

duties, it is best to start the review process two

months prior to the on-site visit. Facilities

unfamiliar with environmental management

reviews need extra time to understand the EPA

program’s goals and objectives, answer the

pre-site visit questionnaire (see Appendix D

for a sample questionnaire developed by

Region 1), gather relevant documentation and

send it to the EMR team, assist in the creation

of an interview list, and confirm the

availability of the potential personnel to be

interviewed. 

It is also beneficial for everyone involved if a

list of milestones is developed prior to

commencement of the EMR process; this helps

reduce confusion regarding submittal dates.

3.2.d Avoid surprises

Trust is a key issue in EMRs. The facility has

volunteered access to its site. It is very

important to obtain facility buy-in to the EMR,

and to ensure the facility is not surprised by

any part of the review process. For example,

the facility should know well in advance which

federal and state EPA staff is anticipated to

participate. In addition, the EMR’s scope

Lessons Learned

- The IVRP did not result in

enforcement actions or penalties at

any facility receiving an EMR

during the pilot program

- It is difficult to stay within the EMR

scope

- Ample preparation time is

critical/create milestones

- Avoid surprises

- Conduct pre-site visit meetings with

site representatives

- Post-EMR evaluations help build a

better EMR program

- Inform personnel to be interviewed

of the EMR process as soon as

possible

- Neutral on-site escorts facilitate

candid discussions

- Combine management and technical

expertise in an EMR team for best

results

- Produce report in a timely manner

- Note that an EMR is a snapshot in

time
EMR Pilot Program Methodology Assessment and Lessons Learned

22

should be well established prior to the team’s

arrival, and should be changed only after

consulting with appropriate facility personnel.

If substitutions or changes must be made close

to the on-site visit date, the facility must be

given the chance to veto the change or cancel

the review. Surprising a facility can lead to a

long-term distrust of EPA and its associated

activities, which is the exact opposite of the

EMR program’s intentions.

3.2.e Conduct pre-site visit meetings with

site representatives

Each federal agency has its particular mission

and each facility is unique. It is important that

EMR team members understand both the

agency’s mission and the facility’s daily

activities (especially those activities linked

with potential or actual environmental impacts)

prior to arriving for the on-site visit.

Gathering and reviewing this vital information

prior to the on-site visit allows the team to

focus on confirming through document review

and interviews what they know should be

happening. In addition, site representatives are

usually the people supplying the team with the

information; the time spent talking with team

members about the facility eases facility

personnel’s anxiety and gives the facility staff

a sense of ownership of the review EMR

process.

3.2.f Post-EMR evaluations help build a

better EMR program

Continuous improvement concepts should also

be built into the EMR process. After

conducting the review, EPA Federal Facility

Coordinators should solicit facility's responses

to the management review process. For

instance, EPA could encourage facilities to

incorporate their thoughts on the value of the

EMR into the six-month facility report

submitted to EPA, or the participants could fill

out a post-review evaluation form (see

Appendix D for a form used in EPA Region 8).

The ensuing comments and insights can identify

which elements of the EPA program are

strongest and which could be improved.

3.2.g Inform personnel to be interviewed

of the EMR process as soon as

possible

Since the EMR team is usually on-site for only

a day or two, time management is a key

ingredient of a successful review. The ultimate

scenario is for the team members to interview

personnel who 1) comprehend the EMR

process and understand why the review is

being conducted, and 2) have copies of

tangible evidence (e.g., pages from a training

database and associated procedures to keep the

database updated) of a formal EMS that they

can provide to the EPA team members. This

scenario permits the team members to ask

questions instead of answer them.

3.2.h Neutral on-site escorts can facilitate

candid discussions

A facility usually has one or two people (e.g.,

environmental managers) who are in charge of

the site’s environmental programs. Facility

personnel recognize this and sometimes tout the

environmental manager’s accomplishments

during an interview if the manager is in the

same room as the person being interviewed.

Personnel being interviewed tend to be more

candid and forthcoming with information and

anecdotes about the environmental program

when a neutral person acts as the team's escort.
EMR Pilot Program Methodology Assessment and Lessons Learned

23

3.2.i Combine management and technical

expertise in an EMR team for best

results

Although an EMR is focused on the ways in

which a facility manages activities to achieve

and maintain environmental compliance,

technical environmental questions often arise

during the course of an EMR site visit. It

benefits both the team and the facility if, prior

to the on-site visit, the facility identified its

environmental permits/compliance

requirements. The team leader could then

ensure one of the EMR team members is

knowledgeable of the facility’s processes or of

its permits/compliance requirements (or both).

3.2.j Produce report in a timely manner 

It is beneficial to complete the EMR report in

a timely manner and submit it to the facility for

their review and response. Facility personnel

often have numerous duties, so it is important

to report as quickly as possible on the strengths

of a facility's EMS as well as its areas for

improvement. Facilities are more apt to

implement EPA's recommendations if the onsite review experience is still familiar to

facility personnel. 

3.2.k Note that an EMR is a snapshot in

time

The beginning of an EMR confirmation letter

should stress that a review is a snapshot in

time and will discover items of concern that in

the future may not be problems at all. A few

facilities requested that EPA delete certain

negative report findings because the facility

was either "planning on working on the

problem," or "working on the problem."

Instead of deleting these items, EPA generally

noted at the beginning of the report that an

EMR was an assessment of a dynamic

organization and that EPA is reporting on the

state of the facility's EMS at a given point in

time based on interviews with select personnel

and document reviews. 

3.3 Federal Facility Comments/

Feedback on the Pilot Program

The following are general comments from

personnel whose facilities participated in the

EMR Pilot Program:

Federal Facility EMR Feedback

(+)

• It gave the environmental staff a forum to

advance EMS ideas within a structured

framework. 

• It is easier to “sell” an EMS [to upper

management] that is looked on favorably

by EPA.

• The EMR team was very well regarded

• Communication was highly rated.

• The EMR was helpful and better than

expected.

• The EMR was a great tool for federal

facilities to build relations with the

regional EPA federal programs.

• The EMR is also a good program to

receive a friendly environmental

management audit, which ultimately will

help the facility’s environmental

programs succeed.

(-)

• Some of the evaluation results were

difficult to assess.

• The site would have benefitted from more

information on the EMR protocol.

• Better planning and coordination would

have given the EMR team a better

snapshot picture of the site.

• We encourage all EMR members to sign

the confirmation letter.

• The facility should provide a neutral

escort for the EMR team interviews.

• The process needs to be explained in a

laymen's format. Higher managers that

are not environmentally trained don't

understand the concept of EMS.
EMR Pilot Program Methodology Assessment and Lessons Learned

24

• Upper management likes to focus on the

areas for improvement, not on the

strengths of the EMS. EPA should find

some way to highlight the positives (e.g.,

a proclamation or certificate signed by

the EPA Region Director).

• Get buy-in from top management as soon

as possible. 

3.4 How Lessons Learned Resulted in

Changes in the EMR Policy

Once the EMR pilot program was completed,

EPA Regional Federal Facility Coordinators

and other regional staff, and OECA HQ

personnel submitted comments regarding

changes that should be made to the interim

EMR policy. Numerous changes were made to

the interim policy and guidance, many of which

were editorial revisions for clarification, or

were the result of merging the originally

separate EMR Policy and the EMR guidance.

However, there were six significant revisions:

• Changing the number of days the

facility has to disclose incidentally

discovered violations

The interim EMR policy required

facilities to disclose violations

incidentally discovered during the

review within 30 days. The final EMR

policy and guidance changed that

requirement to 10 days to ensure

greater consistency with the EPA audit

and self-disclosure policy.

• Adding that inspections may be

waived for six months after an EMR

Facilities were concerned that

voluntarily allowing EPA on-site could

potentially subject the facility to a

subsequent inspection. To allay

concerns, EPA added a provision to

the final EMR policy which states that

EPA generally will not conduct

inspections at the facility receiving the

review for six months, while the

facility prepares its plan in response to

EPA's EMR report. The policy also

describes certain exceptions to this

six-month window (e.g., statutory or

regulatory mandates, tips or

complaints).

• Changing the number of facility

reports

The interim EMR policy required the

facility to submit two reports to EPA

after the review; a recommendation

implementation plan within 60 days,

and an implementation status report six

months later. The final EMR policy

reduced the number of reports to one.

The facility must submit an

implementation status report six months

after receiving the final management

review recommendations.

• Changing the number of required

signatures on the confirmation letter

During the pilot program, EPA

required a signature from both the

facility and from EPA on the ground

rules letter. In the final EMR policy,

the letter is now being referred to as

the "confirmation letter," and only one

(EPA's) signature is required, although

a facility representative may sign it as

well.

• Clarifying that EPA has various

enforcement options under the EMR

Program

Facilities were concerned by the

wording of the IVRP in the interim

policy which implied that formal

enforcement actions are taken for all

types of violations. Considering that

not all violations are the same, EPA
EMR Pilot Program Methodology Assessment and Lessons Learned

25

clarified in the final EMR policy that

there are various enforcement actions,

both formal and informal, that EPA can

take in response to violations

discovered during a review.

• Adding the relationship between the

EMR protocols, ISO 14001, and the

Code of Environmental Management

Principles (CEMP) 

During the pilot program, many facility

personnel asked the EPA teams how

EMRs related to the CEMP or ISO

14001. The existence of different EMS

standards and guidelines show that

there are many ways to analyze an

EMS. The final EMR policy contains a

discussion on the correlation between

the EMR protocols, ISO 14001, and

the CEMP.
Summary Of Federal Facility Findings

26

SECTION4

SUMMARYOFFEDERAL FACILITYEMR FINDINGS

4.0 Overview of findings and

recommendations in EMR reports

The facility EMSs reviewed during the course

of the EMR pilot program differed markedly in

thoroughness, formality, and complexity. The

systems ranged from a set of disparate

environmental programs in need of a formal

program, to comprehensive, well documented,

and formal systems. The following information

discusses some common strengths and

weaknesses encountered during the 29 pilot

program EMRs.

4.0.a Strengths of facility EMSs

• Personnel acknowledge their

environmental responsibilities and

are committed to protecting the

environment

Facility staff acknowledge their environmental

responsibilities and care about their site’s

and/or their job’s environmental impacts. If

given access to appropriate resources and

training, interview results indicate that federal

facility personnel are generally committed to

protecting the environment.

• Field staff routinely review facility

environmental performance

Some agencies require audits or formal

reviews of environmental performance on a 

three- or five-year schedule. Interview results

from some of the EMRs indicate that facility

managers and/or key staff conduct informal

reviews more frequently. However,

implementation of recommendations from these

reviews is inconsistent because of limited

access to funds and technical assistance.

• Agencies participate in cooperative

environmental programs with other

organizations

Many federal facilities support a variety of

environmental tracking and outreach efforts in

cooperation with other federal organizations.

For example, federal facility staff monitor air

Strengths of Facilities' EMSs

- Personnel acknowledge their

environmental responsibilities and

are committed to protecting the

environment

- Field staff routinely review facility

environmental performance

- Agencies participate in cooperative

environmental programs with other

organizations

- Environmental considerations are

incorporated into most planning

processes

This section summarizes the common findings of the majority of the pilot program EMRs

in terms of the strengths and weaknesses of the facilities reviewed.
Summary Of Federal Facility Findings

27

quality, track migratory birds, and provide

educational programs for local schools.

• Environmental considerations are

incorporated into most planning

processes

Federal facilities often undertake new projects;

some are insignificant to the environment,

while others have potentially significant

environmental impacts. A mature EMS

incorporates the environmental manager into

the project planning process. The earlier the

environmental manager is able to review

project plans, the less time is wasted on

project revisions and stop-work issues. Many

of the facilities participating in the pilot

program EMRs incorporated environmental

considerations into the project planning

process. However, facilities did this

coordination mainly to satisfy NEPA

requirements, not because it was part of a

larger process of integrating environmental

considerations into everyday activities.

4.0.b Main areas for improvement of the

facility EMSs

• Agencies and facilities lack adequate

environmental staff and formal,

annual training plans and

mechanisms to track individual

training needs and accomplishments

Environmental staffing levels at the facility,

regional, and agency level are inadequate to

ensure compliance with environmental

regulations, let alone to provide technical

assistance in pollution prevention and

proactive environmental programs. In

addition, while individual training records

generally are maintained in personnel files,

federal facilities may enhance environmental

performance by reviewing environmental

training needs and developing and monitoring

annual training plans to ensure that staff attend

environmental training necessary or

appropriate to their work assignments.

• Facilities lack formal environmental

management programs

The majority of facility personnel described

actions that they take to reduce their site’s

environmental impacts. However, the

personnel often indicated that the procedures

described to the EMR team were informal, that

is, not actually written anywhere. While this

method of informal environmental management

may work as long as the personnel remain

constant, it is vulnerable to personnel turnover.

For instance, if a person were to stop working

at a facility, the experience and informal

procedures designed to reduce the employee’s

environmental impact would leave with that

person. Anyone replacing that employee

would then have to start from the beginning and

develop new procedures. Facilities should

examine their processes and activities, identify

which have the potential to create significant

environmental impacts, and develop formal,

written procedures to minimize those impacts.

A continuous improvement element also should

be incorporated into the procedures to ensure

the facility periodically looks for ways to

further minimize the processes' impacts.

Facilities can use the Generic Protocol (Phase

3) for Conducting Environmental Audits at

Federal Facilities, the CEMP, or ISO 14001

to develop the procedures.
Summary Of Federal Facility Findings

28

• Facilities lack facility-specific

environmental policies, goals,

objectives, or targets

Many agencies manage environmental issues

via a “top-down” approach. Environmental

policies are often developed at the

headquarters level and distributed through

organizational channels. However, the

general policies written at the headquarters

level lack detailed guidance on implementation

procedures for field facilities as well as sitespecific oversight. Facilities should develop

facility- and process-specific short- and longterm goals, objectives and targets, and

implementation plans to support and

complement the policies developed by agency

headquarters.

• Facilities lack commitment to going

beyond compliance; facilities seek

only to meet compliance

requirements

Most of a federal facility’s environmental

metrics are based on the number of violations

or findings of non-compliance issued to a

facility in a given year. Facilities thus take a

reactive, rather than a proactive, approach to

environmental management. 

While an EMS is designed to assist a facility in

achieving and maintaining compliance, the

EMRs detected a lack of measurement

elements that can help the facility look beyond

its environmental compliance requirements and

focus on continuous improvement. By initiating

reductions in a site’s environmental burdens

and liabilities, an environmental manager can

demonstrate cost savings. A facility can save

money by eliminating hidden costs and seeking

pollution prevention solutions. In addition,

focusing only on compliance can sometimes

cloud an environmental manager's vision as to

the source of a waste or emission problem. A

properly designed EMS employs root cause

analysis techniques to address immediate and

long-term environmental issues.

• Work being done does not match job

descriptions and performance

evaluations

Facility personnel's environmental compliance

responsibilities should be incorporated into

basic job descriptions or shop responsibilities

so that performance evaluations are based on

Areas for Improvement 

for Facility EMSs

- Agencies and facilities lack adequate

environmental staff and formal,

annual training plans and

mechanisms to track individual

training needs and accomplishments

- Facilities lack formal environmental

management programs

- Facilities lack facility-specific

environmental policies, goals,

objectives, or targets

- Facilities lack commitment to going

beyond compliance; facilities seek

only to meet compliance

requirements

- Work being done does not match job

descriptions and performance

evaluations

- Lessons learned (positive and

negative) are not shared with other

federal facilities, let alone with

facilities within the same agency

- Line and staff personnel are not

asked for their opinion during the

policy development process

- Tenant organizations are not held

responsible for adhering to a site’s

EMS

- Management is not aware of the

work being done to minimize the

site’s impact on the environment
Summary Of Federal Facility Findings

29

an accurate job description. Many of the

facility staff interviewed described

responsibilities that were not part of their

position description. Managers usually had

environmental responsibilities as part of their

position descriptions, but environmental

responsibilities were not included in the job

descriptions of other personnel. A complete

EMS effectively delegates environmental

responsibilities to appropriately trained

personnel.

Federal facilities should work with Office of

Personnel Management (OPM) (or supplement

OPM forms) by developing facility-specific

position descriptions and performance

evaluation forms to accurately portray the

responsibilities and expectations of facility

staff.

• Lessons learned (positive and

negative) are not shared with other

federal facilities, let alone with

facilities within the same agency

Technology and information transfer was an

afterthought to many of the facilities visited

during the EMR pilot program. Numerous

facilities implemented pollution prevention

projects that both reduced the site’s

environmental impacts and saved money.

Successful processes and activities at one site

can be disseminated in the form of case

studies, allowing staff at similar facilities

throughout the country to learn from the lessons

learned. Thus, it would make sense to share

the success stories with fellow federal

facilities both inside and outside individual

agencies. In addition, line and staff were not

familiar with basic environmental information

sources available electronically, such as

Enviro$en$e and the Joint Service P2

Technical Library. The sharing of lessons

learned can be done via electronic bulletin

boards, WWW sites, e-mail, and memoranda.

• Line and staff personnel are not

asked for their opinion during the

policy development process

Successful environmental management

programs often have buy-in both at the top of

the organization and also at the line and staff

level. Worker’s attitudes about implementing

a new policy change dramatically when the

line and staff worker has been given the

opportunity to help shape that policy. In

addition, line and staff personnel are often the

most knowledgeable about a process and are

best able to determine how a proposed policy

will affect operations and environmental

management issues. Facilities should create

policy development procedures that solicit

employee input through the use of committees

or open suggestion processes.

• Tenant organizations are not held

responsible for adhering to a site’s

EMS

Federal agencies often share building space

with other federal agencies or have tenant

organizations located within their installation's

boundaries. If the site’s landlord has not fully

integrated all tenants into its EMS, the landlord

may not know when/if a tenant is in danger of

environmental noncompliance. All tenants,

contractors, and concessionaires should be

active members of the installation's

environmental committees and communications

distribution lists to ensure tenants receive the

same environmental information as other

installation personnel. 

To facilitate oversight, tenants also should be

required to comply with consistent, facilitywide reporting requirements.

• Management is not aware of the

work being done to minimize the

site’s impact on the environment 
Summary Of Federal Facility Findings

30

Top management’s environmental commitment

is critical to a successful EMS. If top

management is not familiar with the work of

the facility or regional environmental manager,

commitment and support, both in policy and

funding, may be difficult to obtain. It is crucial

for the environmental manager to report

regularly to the site/facility manager. Top

management should meet with environmental

staff quarterly. Environmental managers

should submit regular reports or provide

briefings documenting progress in compliance

and prevention, as well as current cost savings

and short and long-term policy and funding

needs. A representative of management should

read and sign these reports to indicate

awareness of the environmental status of each

facility.

4.1 Recommendations implemented by

facilities

EPA Regional Federal Facility Coordinators

are just beginning to receive feedback from

facilities that participated in the EMR pilot

program. It is too early in the program to

measure its overall effectiveness and/or to

determine whether or not EPA’s

recommendations have been implemented.

EPA plans to follow up with selected facilities

which had EMRs during the pilot program to

examine the impact of actions taken on their

environmental management systems and overall

performance.
Summary Of Federal Facility Findings

31

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Conclusion

32

Section 5

CONCLUSION

After reviewing some of the environmental

impacts of processes and activities at federal

facilities, it has become obvious that

environmental regulations alone are not enough

to ensure against environmental degradation.

In addition to enforcing the environmental

regulations, EPA also is expanding its role as

compliance assistance provider - - helping

facilities prevent pollution so that clean-up is

not required at a later date. EMRs are one

element of that compliance assistance process.

The EMR pilot program was created to assist

federal facilities in their environmental

management activities and to implement EPA’s

interim final EMR policy. Based on feedback

from the participating facilities, the program

appears to have been a success.

Based on this success, EPA plans to conduct

more EMRs at federal facilities, and will

continue to offer the reviews as an integral part

of EPA’s overall compliance assistance

efforts. EPA’s goal is to use the management

system reviews to further develop partnerships

with other federal agencies, increase EPA’s

accessibility to federal facilities, and help

those facilities move beyond compliance in a

systematic manner. As the program matures

and more EMRs are conducted, facilities can

expect a more streamlined and efficient review

process that will offer recommendations

focused on the root causes of environmental

concerns.

EPA looks forward to the opportunity to

continue working cooperatively with federal

facilities through the use of EMRs and other

tools to further reduce their environmental

impacts through a proactive approach to

environmental management.
Conclusion

33

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Appendices

34

Appendices
Appendix A - EMR Case Studies

35
Appendix A - EMR Case Studies

36

APPENDIX A

EMR CASE STUDIES

This Appendix contains synopses of four EMRs conducted at federal facilities during the

pilot program. The information is provided to help the reader better understand the benefits of

participating in the EMR program and the types of findings and recommendations that can be

expected from the EMR process. Although the actual EMR reports are a matter of public record,

i.e., they can be accessed under FOIA, we chose to highlight only the EMRs findings and

recommendations in a generic manner.
Appendix A - EMR Case Studies

37

Site/Facility A

A. Facility overview

The mission of the 35,000 acre site is to conserve

and provide for the enjoyment of the scenery, the

natural and historic objects and the wildlife on

certain federal lands and to leave them unimpaired

for the enjoyment of future generations. 

B. EMR Logistics and Scope

During the two-day EMR, the two person team

consisting of the EPA Regional Federal Facility

Coordinator and an EPA contractor analyzed the

site’s EMS in conjunction with the site’s Chief of

Maintenance, a Maintenance Management

Technician, and the Fire Management

Coordinator/Spill Coordinator.

The protocol used for this EMR was a combination

protocol containing elements of the Code of

Environmental Management Principles (CEMP)

and EPA’s Generic Protocol for Conducting

Environmental Audits at Federal Facilities, Phase

3. All five of the protocol’s disciplines were

included in this EMR. Those disciplines are: 1)

Management Commitment, 2) Compliance

Assurance and Pollution Prevention, 3) Enabling

Systems, 4) Performance and Accountability, and

5) Measurement and Improvement.

C. EMR Findings and Recommendations

Strengths of the EMS

• If funds are available in a department's

operating budget, Maintenance can simply

purchase equipment or initiate new

environmental projects. If funds are not

available in the operations budget, the

Superintendent must pursue funding through

the region and headquarters.

• Site staff work very closely with the public in

a continuous effort to enhance the public’s

experience at the site. Conservation easements

represent an ongoing local tax issue. The

organization has land use and zoning

information available in GIS format. Recently,

the site completed a visitor experience and

resource protection study focusing on

measurable indicators of and standards for

visitor use that can be used to develop

management strategies. This analysis of visitor

perception of crowding on the carriage road

system utilized computer simulations to analyze

visitor perceptions of resource use. The study

suggested that enforcement of appropriate trail

behavior and visitor education could resolve

concerns. The site produced a video on trail

behavior that is available through local bicycle

shops and on local access television.

• The site has clearly defined, routine

mechanisms to share information.

• Each employee creates an annual performance

plan and goals, against which performance is

measured. The system is flexible enough to

allow a Supervisor to incorporate

environmental tasks into the review criteria.

For example, the Chief of Maintenance added

responsibility for identifying less toxic product

substitutes to the performance review criteria

for the Maintenance Foreman. 

Areas where the EMS needs improvement

• The site’s HQ’s Office of Environmental

Affairs published pollution prevention fact

sheets on a variety of topics including

automotive service stations. According to site

staff participating in the EMR, they do not

utilize HQ as an information resource and are

not familiar with the HQ’s Commitment or fact

sheets. The site does not have a Solid Waste

Management Plan.

• The site does not have a full-time staff position

responsible for coordination of environmental

compliance. The site’s Administrative Officer,

whose duties include personnel, procurement

and budget, receives written policy updates and

places the information into three ring binders.

It is his responsibility to notify Maintenance

and other Divisions of changes that may affect

their operations. Neither the headquarters or

regional office appears to provide

implementation follow-up to ensure that site

staff has received policy and program updates

and has access to the expertise to identify
Appendix A - EMR Case Studies

38

responsibilities and implement them.

• The site has not implemented a facility-wide,

formal environmental training plan.

Recommendations

1. Hire a minimum of one FTE to manage the

overall environmental compliance program,

 provide on-site technical assistance and

promote pollution prevention at the site.

2. Establish more formal procedures for

environmental management planning and

budget development.

3. Establish formal procedures for annual

environmental compliance audits.

4. Establish a formal, annual training plan

and track individual environmental training

needs and accomplishments to ensure that

all training requirements for staff

performing duties with environmental

impacts are met. Provide additional

funding and opportunities for personnel

environmental training development.
Appendix A - EMR Case Studies

39

Site/Facility B

A. Facility overview

The site provides environmental oversight to 36

facilities. The site's primary mission is flood

control for more than 4,600 acres. It maintains

only about 300 total acres; the State Department of

Environmental Management (DEM), Division of

Fish and Wildlife leases 4,000 acres and DEM’s

Division of Forests and Parks leases another 200

acres. There are some privately owned properties

within the flood control area, but there are no

habitable structures on these easement lands. DEM

is responsible for public recreation areas and

fisheries on the leased lands; the site provides

oversight but lessees are not required to comply

with the site's regulations.

B. EMR Logistics and Scope

During the two-day EMR, the two person team

consisting of the EPA Regional Federal Facility

Coordinator and an EPA contractor analyzed the

site’s EMS in conjunction with the site’s

Environmental Compliance Coordinator; the River

Basin Manager; a Project Manager; and a Park

Ranger.

The protocol used for this EMR was a combination

protocol containing elements of the Code of

Environmental Management Principles (CEMP)

and EPA’s Generic Protocol for Conducting

Environmental Audits at Federal Facilities, Phase

3. All five of the protocol’s disciplines were

included in this EMR. Those disciplines are: 1)

Management Commitment, 2) Compliance

Assurance and Pollution Prevention, 3) Enabling

Systems, 4) Performance and Accountability, and

5) Measurement and Improvement.

C. EMR Findings and Recommendations

Strengths of the EMS

• The site's environmental policies and

procedures are codified in the Environmental

Review Guide for Operations (ERGO).

ERGO is a manual containing a series of

checklists that guide staff through the relevant

environmental laws and regulations. The site

published a sub-manual specific to

environmental issues relevant to Civil

Engineering activities.

• The site has a career training plan based on job

title requirements.

• The staff has initiated a number of community

outreach efforts focusing on the environment.

For example, staff operate a booth at the local

Environmental Expo each year. Staff provide

environmental programs and facility tours for

local schools. The Junior Project Manager

program brings students to the site for a day of

role-playing. During Earth Day, staff traveled

to a nearby town where they supported tree

plantings and water quality education activities.

• Project staff conducts an annual internal

review and develops a Corrective Action Plan.

Project staff submits the Plan to a Manager

who reviews it and sends it on to the District

Environmental Coordinator. Staff updates the

Corrective Action Plan every six months, in

October and April. This requirement is spelled

out in the site's Facilities Environmental

Compliance Guidance Letter, "Environmental

Compliance Assessments." During audits,

performance is measured against established

Environmental-Natural Resources and/or

Environmental Compliance Performance

Measures. ERGO checklists guide the

assessment process.

Areas where the EMS needs improvement

• Facility employees do not appear to have a

formal method for providing input to

environmental decision making. They are not

represented on the Environmental Steering

Committee. 

• While an official suggestion program allows

employees to complete a form and send it to

the District, such suggestions may not be

reviewed by staff with authority to proceed

toward implementation of suggestions.

• The District Environmental Compliance

Coordinator tries to pass along regulatory

information via e-mail to the four Managers in
Appendix A - EMR Case Studies

40

his District and to the local facilities. He issues

memoranda asking whether local offices have

certain listed regulatory information. If they

respond that they do not have the information,

he will provide it. Given his other duties and

limited staff, however, there is not always time

for a comprehensive review of information

needs to ensure that each facility has access to

the appropriate federal, state and local

compliance information as well as the site's

policy memos and updates. 

• There is no required environmental training for

field personnel. Staff complete annual

Individual Development Plans that may

identify general training interests. However,

there is no specific determination of

environmental training needs. Park Rangers are

regarded as generalists and receive training for

broad responsibilities. The training for this title

is not focused on environmental awareness,

although the individual Ranger may have

responsibility for hazardous waste management

and may sign manifests. 

Recommendations

1. Develop a formal environmental policy

and program priority statement for the

project.

2. Improve communications and access to

regulatory information.

3. Seek additional environmental staff

positions at the District and River Basin

levels.

4. Provide additional environmental

training.

5. Pursue additional funding for

environmental programs.
Appendix A - EMR Case Studies

41

Site/Facility C

A. Facility overview

The main laboratory complex examined during the

EMR occupies one building which houses offices

and laboratories. The site also maintains a boat

storage pad, fuel storage area, and a hazardous

waste storage area in the back parking lot. The site

conducts field sampling investigations and

laboratory analysis. The planning of the field

investigations and the laboratory analyses take place

at the site. The facility is approximately one year

old.

The site employs 138 people, about half of whom

work in one of the 60 laboratories at the facility.

The remainder of the facility is occupied by offices

for the laboratory and non-laboratory personnel.

To comply with the Solid Waste Disposal Act

(SWDA), non-hazardous solid wastes from all siteoccupied facilities are collected by a contracted

disposal service and disposed of at the local landfill.

The site's main laboratory complex established a

recycling program for mixed-grade waste paper and

for beverage cans. For the paper, each office is

provided with a collection bin while centralized

collection containers are located in Branch offices

and hallways throughout the site. Janitorial staff

collect paper from the centralized bins for pickup

by the local recycling program. 

The site has a program to properly dispose of

biomedical wastes, in particular, sharps (e.g.,

needles, syringes with needles, scalpel blades).

B. EMR Logistics and Scope

During the two-day EMR, the two person team

consisting of the EPA Regional Federal Facility

Coordinator, an Army representative, and two EPA

contractors analyzed the site’s EMS in conjunction

with the site’s full-time Safety, Health, and

Environmental Management Program (SHEMP)

Coordinator, the Maintenance contractor, and

numerous laboratory personnel.

The protocol used for this EMR was a combination

protocol containing elements of the Code of

Environmental Management Principles (CEMP)

and EPA’s Generic Protocol for Conducting

Environmental Audits at Federal Facilities, Phase

3. All five of the protocol’s disciplines were

included in this EMR. Those disciplines are: 1)

Management Commitment, 2) Compliance

Assurance and Pollution Prevention, 3) Enabling

Systems, 4) Performance and Accountability, and

5) Measurement and Improvement.

C. EMR Findings and Recommendations

Strengths of the EMS

• The site has a full-time Safety, Health, and

Environmental Management Program

(SHEMP) Coordinator who works with an

Occupational Safety and Health Committee

(OHSC) comprised of safety, health, and

environmental management representatives

from each of the three branches and three

program offices within the Division. These

representatives set policy for and resolve any

management problems regarding safety, health,

and environmental management. New

environmental initiatives can be implemented

by the OHSC with the approval of senior

management. In addition, there are two people

on staff who act as the Pollution Prevention

Committee. All of these representatives

conduct these duties in addition to the duties

listed in their respective job descriptions.

• The site implemented an excellent system used

to track hazardous components of samples to

ensure their proper disposal. This system

provides a foundation for the entire EMS.

• Management sets the priorities to ensure that

the EMS is vital to the organization as a whole.

Areas where the EMS needs improvement

• The site has established goals and a baseline

for the pollution prevention program, but there

is some question whether other programs, such

as the solvent recycling, are being accurately

measured and benchmarked. 

• The majority of the environmental

responsibility at the site falls essentially to one
Appendix A - EMR Case Studies

42

employee (the SHEMP Coordinator). It may

benefit the site to either delegate those

responsibilities among several employees or

document and formalize all of the

environmental responsibilities to ensure

continuity.

• Many procedures are established and acted on

by verbal agreement; sometimes the verbal

procedures confuse employees with minimal

amounts of environmental compliance training.

Recommendations

1. Formalize the verbal agreements and

document these systems so they may be

reviewed and revised, as necessary. 

2. Determine whether it is feasible to create a

formal chemical adoption plan. Develop

procedures for working with local labs to

use the site's excess chemicals and materials

if liability and RCRA issues can be

overcome.

3. Create a procedure to have the

Maintenance contractor coordinate with the

SHEMP Coordinator on facility

work/routine maintenance that has an

environmental impact.
Appendix A - EMR Case Studies

43

Site/Facility D

A. Facility overview

There are over 20 different organizations using the

site’s facilities. These tenants, referred to as

"Resident Agencies," are taking advantage of the

many resources found at the site. The

Environmental Office is in charge of both

overseeing environmental compliance activities and

addressing environmental issues for the site.

The site is also host to a variety of temporary users,

with short-term agreements, using specified

facilities for specified periods of time. These range

from a few days to a few months. The main point

to remember is that the site has a wealth of

capabilities to be used and management is flexible

about the terms of use.

As a shared federal facility, operation costs are

shared by the site and all Resident Agencies on a

pro-rated reimbursable basis. As the airfield

manager, the site is ready, willing and able to

provide additional services to Resident Agencies as

requested. 

There are numerous operations and activities at the

site which could create environmental impacts. For

instance, the site is a fully functional federal airport

with all the necessary facilities needed for aircraft

operations. It also maintains a wide variety of

facilities available for military personnel and their

families. Of the site’s major activities, the four

which have the greatest potential environmental

impact include: 1) Facility Modifications and Site

Maintenance; 2) Wind Tunnel Testing; 3) Life

Sciences; and 4) Space Sciences.

On September 5, 1995, the site’s HQ issued an

Agency-wide environmental policy. In response to

that directive, the site’s Environmental Office

worked together with other organization offices in

developing issue-specific environmental policies for

a number of areas.

B. EMR Logistics and Scope

During the two-day EMR, the three person team

consisting of two EPA Regional Federal Facility

personnel and an EPA contractor analyzed the

site’s EMS together with staff from the site’s

Environmental Office.

The protocol used for this EMR was EPA’s

Generic Protocol for Conducting Environmental

Audits at Federal Facilities, Phase 3. The

protocol consists of seven disciplines: 1)

Organizational structure; 2) Environmental

commitment; 3) Formality of environmental

programs; 4) Internal and external communication;

5) Staff, resources, training, and development; 6)

Program evaluation, reporting, and corrective

action; and 7) Environmental planning and risk

management. The goal of the EMR was to

determine how well the site’s EMS compared to the

following two disciplines: 1) environmental

commitment, and 2) environmental planning and

risk management.

C. EMR Findings and Recommendations

Strengths of the EMS

• The site indicates its pursuit of environmental

excellence through the development of issuespecific policies, through top management

support, and by delegating environmental

responsibilities to the line and staff level. 

• Environmental considerations are generally

incorporated into the site’s planning processes.

Facility projects and research and development

projects go through an Environmental Division

review prior to commencement. 

Areas where the EMS needs improvement

• Since the line and staff personnel are in charge

of addressing environmental issues, the site

must ensure that their EMS contains a formal

system to track environmental deficiencies

through closure. Currently, the Environmental

Office is wary of environmental deficiencies,

but it does not formally track those deficiencies

nor how the deficiencies were addressed.

• One way the site could improve its

environmental risk management program is to

conduct root cause analysis on environmental

deficiencies to help ensure similar problems do

not arise in the future.
Appendix A - EMR Case Studies

44

Recommendations

1. Develop procedures to routinely distribute

environmental information to all site

personnel.

2. Identify what regulations apply to each

activity and ensure the courses provided to

the staff performing task associated with

that activity receive the right type of

training.

3. Create a procedure to update

environmental courses as regulations

change.

4. Develop procedures to ensure

environmental issues have been properly

addressed by line and staff personnel and

contractors once projects are complete.

5. Modify existing hazardous material

procedures to ensure all materials are taken

back during the appropriate time frame.
Appendix A - EMR Case Studies

45

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Appendix B - Final EMR Policy

46

APPENDIX B

Final EMR Policy

Environmental Management Review Policy and Guidance for Federal Facilities

In accordance with Executive Order 12088, our national and regional federal facility program has the

responsibility to provide technical advice and assistance to federal facilities to ensure their cost effective and

timely compliance with applicable requirements. In addition, the President called on the federal government to be

the leader in achieving and maintaining a clean environment. The provision of an Environmental Management

Review (EMR) is one increasingly important means of providing this technical assistance for federal sector

leadership.

An Interim EMR Policy was issued in May 1996, and a pilot program was undertaken to test out the

Interim Policy. Numerous EMRs were conducted as part of the pilot program, and this EMR Policy constitutes

the final policy and is based upon revisions determined to be necessary after the pilots. The EMR Policy lays out

the definition of an EMR, the operating principles under which EMRs are to be conducted by the EPA Federal

Facility Program, and the context in which EMRs will be conducted by EPA. The EMR Guidance is a technical

accompaniment to the EMR Policy, and is intended to assist EPA personnel in conducting EMRs.

A. EMR Policy

I. Definition and Benefits of an Environmental Management Review

An Environmental Management Review is a review of an individual facility’s program and management

systems to determine the extent to which a facility has developed and implemented specific environmental

protection programs and plans which, if properly managed, should ensure compliance and progress towards

environmental excellence. Because of the programmatic nature of an Environmental Management Review (EMR),

the focus of this review is on the quality and/or implementation of the program, not on actual compliance

requirements. EMRs provide the federal facility information pertaining to:

o Strengths and areas for improvement of environmental management systems and programs at federal facilities;

o Identification of underlying causal factors which may contribute to the occurrence of compliance

deficiencies, and development of long-term environmental compliance by helping to build an environmental

management program foundation;

o Review of each of the individual components of an environmental management system (such as those listed

below); and

o Assistance on the effectiveness of their systems, bench marking their performance, and identification of

opportunities for improvement.

EMRs are not enforcement inspections. The EMRs are technical assistance site visits. They differ from a

compliance inspection or audit, which aim to capture a facility’s compliance picture at a given point in time. 

EMRs attempt to facilitate an understanding of the underlying causes of current or potential compliance problems

and to develop suggestions for actions to correct them. They attempt to facilitate an understanding of the

environmental management system (EMS) process and identify some of the more obvious weaknesses and

strengths of the facility’s existing EMS. EMRs assist federal facilities in developing long-term environmental

compliance by helping to build an environmental management program foundation. EMRs are intended to help

facility personnel understand how real environmental improvements can be achieved, by probing beyond the

immediate symptoms of non-compliance and attempting to identify and address underlying causes such as
Appendix B - Final EMR Policy

This document (EPA Document No. 300-B-96-012 A&B) can be obtained by contacting U.S. EPA

Federal Facilities Enforcement Office at 202-564-2461.

47

management system deficiencies. Further, they are not intended nor should they replace a facility’s own efforts to

self-audit. Finally, an EMR is not a

Pollution Prevention Opportunity Assessment, although a review of a facility’s pollution prevention program as it

relates to their environmental management system (EMS) may be conducted during an EMR.

EPA has conducted technical assistance visits at federal facilities as part of its pollution prevention

opportunity assessments program. Now, by conducting Environmental Management Reviews, EPA hopes to

cooperatively provide facilities with advice about effective environmental management. The facility has the choice

as to whether and how to use the advice, but EPA believes that engaging in an EMR visit will foster a good working

relationship between the Agency and the federal facility, encourage a continued dialogue on environmental issues,

and help improve environmental performance. 

II. Scope of an Environmental Management Review

The scope of an EMR includes disciplines that are based on key characteristics and elements of effective

environmental management systems. There are a number of common elements for most EMS models. For

example, the Code of Environmental Management Principles for Federal Agencies (CEMP), developed by EPA in

response to Executive Order 12856 and in conjunction with representatives from 16 federal departments and

agencies, includes management commitment, compliance assurance and pollution prevention, enabling systems,

performance and accountability, and measurement and development. The ISO 14001 EMS standard includes

environmental policy, planning, implementation and operation, checking and corrective action, and management

review. The seven EMR disciplines listed below (along with the corresponding CEMP Principles and ISO 14001

Sections) are from Phase 3 of the Generic Protocol for Conducting Environmental Audits of Federal Facilities.

They are:

o Organizational Structure (CEMP Principle 1 and ISO 14001 Section 4.4)

o Environmental Commitment (CEMP Principle 1 and ISO 14001 Section 4.2)

o Environmental Planning and Risk Management (CEMP Principles 2 & 3 and ISO 14001 Sections 4.3 & 4.4)

o Staff Resources, Training, and Development (CEMP Principles 3 & 4 and ISO 14001 Section 4.4)

o Formality of Environmental Programs (e.g. p2, auditing, compliance) (CEMP Principles 2 & 3 and ISO 14001

Sections 4.2, 4.4 & 4.5)

o Internal and External Communication (CEMP Principle 3 and ISO 14001 Section 4.4)

o Program Evaluation, Reporting, and Corrective Action (CEMP Principles 3 & 5 and ISO 14001 Sections 4.5

& 4.6)

While the wording of the EMR disciplines and the elements of CEMP and ISO 14001 are not identical,

the overlap, correlation and similarity are great. An EMR is a tool that can help facility personnel attain the CEMP

and move toward conformance with ISO 14001. This is because an EMR will provide a review of the individual

components of the facility’s EMS, as well as provide the facility with information regarding areas for improvement

of the EMS, feedback on the effectiveness of their systems, and bench marking their performance.

An EMR is not a full-fledged Environmental Management Systems Audit. A management systems audit

would provide a thorough, systematic evaluation of all elements of a facility’s implementation of an environmental

management system. EPA currently does not have the resources to conduct an in-depth environmental

management systems audit, which most often requires a week or several weeks stay at a given facility, and

significant resources depending on the size and type of facility. EPA envisions that an EMR may cover anywhere

from one to seven areas depending on EPA and the needs of the facility. The determination of this need can be

accomplished through consultations between EPA and the federal facility.
Appendix B - Final EMR Policy

48

An EMR is based on a combination of staff interviews, pre-site visit document reviews and a site visit at

the facility. Interviews are especially important in conducting an environmental management review. They provide

the primary means of understanding the organizational relationships, roles and responsibilities, policies, and

systems that form the framework for the management of environmental matters. More importantly, they often

reveal differences in the actual versus the documented practices. Document review is important to verify the

formality of the system and confirm interview information. A site visit is necessary to verify an EMS’

implementation and effectiveness.

Depending on the characteristics of the federal facility such as the degree of sophistication of the

environmental management program, the EMR could take place over the course of a day’s visit or up to a week. 

Those participating may include representatives from the EPA Regional Federal Facility program, Headquarters

and Regional technical assistance offices, other federal Agencies, contractors, and/or State Environmental

Agencies. As appropriate, EPA regional offices can conduct joint EMRs with their states, and should contact the

appropriate state technical assistance program as part of the development process for an EMR.

Where EMRs Are Likely to Be Conducted

Federal facility participation in an EMR under all circumstances is voluntary. In general, EPA would

prefer to conduct EMRs at facilities where there is a potential for environmental impact (e.g., facility is a permit

holder or notifier under one or more environmental statutes), and/or at facilities that have limited resources for

hiring a private consultant or where their Agency does not already have an internal environmental management

system audit program. This is more likely to be the case at smaller agencies such as civilian federal agencies

(CFAs). This is consistent with the nature of the overall findings of the Strategy for Improving Environmental

Management Programs at CFAs, which recommended training, technical support, and compliance assistance for

CFAs. However, EPA may conduct an EMR at larger facilities if invited by the facility or where an EMR will be

useful to follow-up on an enforcement action to identify root causes.

There may be some factors that could prohibit EPA from conducting an EMR at a facility. If a facility is

subject to an open criminal investigation, it should not be selected for an EMR. However, if a facility is a recent

recipient of an enforcement action, this would not prohibit EPA from conducting an EMR at that facility. In fact,

an EMR may be helpful in determining the root cause(s) of the violation(s). In cases of a state enforcement

action, EPA should contact the state as part of the development process for the EMR.

III. Operating Principles

The following are intended to provide EPA staff with general guidelines or operating principles for

conducting EMRs at federal facilities:

a. An EMR visit is not an inspection.

b. Participation in an EMR by a federal facility is voluntary, and facilities are invited to request an EMR. A

federal facility may also be contacted at least one to two months in advance of a visit to solicit interest,

and to ask for appropriate written documentation of their environmental management system.

c. While the primary focus and intent of the EMR program is at the facility level, EMRs may also

be appropriate at the regional and/or agency headquarters level. Agency headquarters are

encouraged to contact EPA about having an EMR conducted at the headquarters and/or regional

level. It would be helpful if agency headquarters would encourage individual facilities to

participate in an EMR.

d. The date for the EMR is mutually arranged between the federal facility and EPA. Information regarding

the topics that will be covered in the review will be discussed prior to the visit.

e. The facility will receive a confirmation letter prior to the EMR visit which will generally lay out the
Appendix B - Final EMR Policy

49

ground rules for the EMR. The confirmation letter will be signed by the appropriate EPA Regional

manager, and may be co-signed by the facility manager as well (See Attachment One for examples of

suggested components of a confirmation letter.) The confirmation letter will also ensure that EMR staff

have access to the appropriate personnel and documents at the facility, as well as summarize the

conditions of the Incidental Violations Response Policy (See Section IV).

f. Each EMR visit will include an in-briefing and an exit-briefing or close-out session in which preliminary

EMR results are shared with the host facility. Provisions for additional technical assistance such as a

future pollution prevention assessment can be discussed at this time. 

g. Within 60 days after the visit, the EPA regional office will provide the facility with a written report

regarding the facility’s environmental management system and provides recommendations for further

activities. EPA and the facility can make arrangements for the sharing of draft findings prior to issuance

of the final report. This EMR report will not contain information on incidental violations. All

communication with the federal facility with respect to incidental violations will be conducted separate

from the EMR report. 

h. To better inform the federal facility’s headquarters office about the potential resource needs that may

result from the EMR report, EPA may share a copy of the final report with headquarters, unless the

federal facility requests EPA to do otherwise.

i. The facility will, no later than six months after receipt of the EPA EMR report, produce a response plan

that lays out how they plan to address the EMR findings and reports on progress made to that point. 

During this six-month period, EPA generally will not conduct inspections at the facility receiving the

EMR unless such inspection is required by statute, regulation, or EPA policy involving compliance with

environmental statutes, or unless good cause exists including belief of misrepresentation or falsification

of any report required by law, to determine whether the facility may present an imminent and substantial

danger to public health or the environment, or to investigate a tip, complaint or other information

concerning potential civil or criminal violations at the facility.

j. Within approximately twelve months of the EPA EMR report, the EPA regional office will

informally contact the facility to get an update on, for example, the areas of change that resulted

from the EMR, any staffing or resources changes, and any other appropriate information

regarding the facility’s response to the recommendations made in the EPA EMR report.

IV. Incidental Violations Response Policy (IVRP)

The purpose of an EMR is not to assess the compliance status of a federal facility. There may, however,

be circumstances when an EMR incidentally uncovers violations either through document review or while on site.

EPA’s Office of Enforcement and Compliance Assurance (OECA) has developed enforcement response policies

for several programs with industry such as the Environmental Leadership Program, the Common Sense Initiative,

and Project XL that detail how violations will be treated if they are discovered as part of these programs. The

Incidental Violations Response Policy (IVRP) described below details how violations will be treated that are

incidentally uncovered at a federal facility that is participating in the EMR program. As previously stated, EMRs

are not enforcement inspections. In fact, situations presenting enforcement issues have occurred very infrequently

in the EMRs conducted at federal facilities to date.

Imminent and Substantial Endangerment

In cases where the EMR team finds situations that may cause an imminent and substantial endangerment to

public health or the environment or serious actual harm, EPA expects the facility to address the situation

immediately and retains the right to respond as necessary.

Other Violations
Appendix B - Final EMR Policy

Identification of a potential violation can either occur during the EMR visit or after the EPA staff on

the EMR team consults with other appropriate regional staff. EPA will generally take no longer than 10 days

after the EMR visit to contact the federal facility with information about any additional violations that result

from this consultation.

In special cases an EPA region may grant a facility more than a year to correct violations due to the

particular budget constraints at the facility. A region must first make the Federal Facilities Enforcement

Office aware of the situation prior to granting additional time to the facility. A region should also make a

facility aware that such facility may be inspected to verify that the facility has corrected violations pursuant

to this IVRP.

See also the Audit Policy Interpretive Guidance for additional definitions and information

concerning the EPA Audit Policy.

The specific violation (or closely related violation) can not have occurred previously within the past

three years, or is not part of a pattern of federal, state or local violations by the facility’s parent Agency,

which have occurred within the past five years. A violation is: (a) any violation of federal, state or local

environmental law identified in a judicial or administrative order, consent agreement or order, complaint, or

notice of violation, conviction or plea agreement; (b) any act or omission for which the regulated entity has

50

OECA’s Federal Facilities Enforcement Office (FFEO) is responsible for ensuring that federal facilities

take all necessary actions to prevent , control and abate environmental pollution. FFEO uses a comprehensive

approach encompassing compliance assistance, compliance oversight and enforcement , and systematic reviews of

federal agency environmental plans and programs to ensure that federal agencies are in compliance and taking

steps toward pollution prevention. Generally, EPA bases its initial response to a violation on the type of violation

and the potential risk posed by the violation. Although the pertinent statute/regulation and media-specific or

program-specific guidance governs the type of initial EPA response, they can vary from a Notice of Violation

(NOV)/Notice of Noncompliance (NON), to an Order or Compliance Agreement without penalties, to a Complaint

or Order assessing penalties.

Consistent with EPA’s Audit Policy (Incentives for Self-Policing, 60 FR 66706, December 22, 1995),

and in the context of the EMR program and the IVRP, following the identification of a violation(s) as a result of an

EMR, the federal facility will be required to disclose the violation(s) in writing to EPA within 10 days of its

identification. In addition, the federal facility must correct the violation(s) within 60 days of its disclosure to

EPA, certifying in writing that the violation(s) has been corrected, and take appropriate measures as determined by

EPA to remedy any environmental or human harm due to the violation(s).

If more than 60 days will be needed to correct the violation(s), the federal facility must notify EPA in

writing before the 60-day period has passed. The facility must then enter into a written compliance agreement

that:

 o establishes a specified period for correcting all outstanding violations; and

o incorporates interim milestones that demonstrate reasonable progress toward compliance and sets forth the

additional correction period and any additional steps to be undertaken by the facility to achieve compliance.

The total period of time for correction is not to exceed one-year, except in cases where pollution

prevention is used as the means of correction, in which case the facility could have a total of 18 months for

correction. The correction period may be limited based on statutory/regulatory requirements, as well as mediaspecific policy and guidance regarding significant non-compliers.

Consistent with EPA’s Audit Policy, this IVRP does not apply to criminal violations, repeat violations,
Appendix B - Final EMR Policy

previously received penalty mitigation from EPA or a state or local agency.

51

violations that resulted in serious actual harm (or may have presented an imminent and substantial endangerment

to) human health or the environment, violations of the specific terms of any judicial or administrative order or

consent agreement, or actions to address recurrences of violations.

In those instances where the media-specific or program-specific guidance calls for the assessment of a

penalty, EPA will completely waive the gravity-portion of such penalty for federal facilities that disclose and

correct violations detected during the EMR as described above. EPA reserves the right to collect any economic

benefit that may have been realized as a result of noncompliance. Economic benefit may be waived, however,

where EPA determines that it is insignificant.

Where EPA and or the state is concerned about appropriate response from the facility, EPA reserves its

rights to respond as it deems appropriate to instances of non-compliance. Except where explicitly noted, nothing

in this policy should be construed to limit any legal authority EPA may have.
Appendix B - Final EMR Policy

52

B. EMR Guidance

I. Purpose:

This guidance is intended as a technical accompaniment to the EPA Environmental Management Review

Policy for Federal Facilities. Its purpose is to assist EPA Headquarters and EPA Regional personnel in conducting

Environmental Management Reviews (EMRs). This document will outline key areas of performance that should be

considered when EPA staff and contractors are conducting EMRs. The guidance refers the users of this guidance

to the Generic Protocol for Conducting Environmental Audits of Federal Facilities (EPA Document No. 300-B96-012 A&B) for reference to expected performance criteria during the conduct of an EMR ( performance

objectives, key evaluative concerns, and criteria) and are therefore not restated within this guidance. The

definition of an EMR as well as the scope of these reviews are discussed in Section II of the EMR Policy. This

technical guidance will not define a specific technical approach to be followed in all circumstances. Instead, the

guidance emphasizes the planning (Section II) and communications (Section III) aspects of the EMR process, and

also provides discussion on the use of protocols and checklists during the EMR process (Section IV). These

sections were developed to help ensure consistency in the quality of the work to be performed, and to ensure that

the expectations between the EPA regions and the participating federal facilities on the outcome of the EMR

process are one and the same. 

To a great extent, the success of the EMR program will depend on the quality of the products and service

provided to federal facility participants. For this reason, FFEO strongly recommends that EPA staff and EPA

contractors participating in the EMRs are trained in environmental audit procedures, and especially in the

techniques of auditing environmental management systems. To help ensure an appropriate degree of expertise,

Section VI of this guidance outlines training considerations (e.g., skills) needed by EPA staff and contractors.

II. Planning:

EPA regional staff responsible for organizing and conducting the EMR should spend a significant amount

of time planning for the site visit. Careful planning is crucial to ensuring that the limited time typically available

for the site visit is used most effectively. Careful planning also minimizes the time necessary for follow-up

activities after the site visit, and reduces the burden on facility management by efficiently utilizing the time and

talents of their staff during the EMR process. The factors to consider in planning an EMR: (1) the goals and scope

of the EMR; (2) the size and complexity of the facility operations; (3) the regional staff’s familiarity with the site;

(4) resources available for conducting the EMR; and (5) the desired form and content of the final EMR report.

If a contractor will be accompanying the EPA regional staff while conducting the EMR, regional staff

should develop a scope of work that clearly establishes roles and protocols for each phase of the EMR (i.e., previsit, on-site, post-visit). If in-house regional staff are conducting the EMRs, the Federal Facility Coordinator or

other regional member in charge of the EMR should select team members and assign roles and responsibilities. 

Regardless of who performs the EMRs, as part of the planning phase, EPA regional staff should ensure that the

members of the EMR team: 

1. clearly understand the goals and scope of the EMR; 

2. upon reviewing preliminary information, are familiar with the facility’s operations, environmental

management policies, compliance history, waste streams and other environmental releases;

3. have the correct checklists and protocols and understands how to use them;

4. agree to follow the detailed EMR agenda formulated specifically for that facility; 

5. are aware of potential health and safety issues and are prepared to handle them on-site; and

6. understand how information collected on-site will be presented in the EMR final report.
Appendix B - Final EMR Policy

53

III. Communications With Facility Management:

Once contact is initiated by either EPA, the facility management, or federal agency headquarters staff

who have expressed an interest in having an EMR conducted at a particular site, EPA staff and federal facility

management should discuss, in detail, the purpose and scope of the EMR, especially the ground rules for engaging

in the process. Additionally, facility management should be briefed on the Operating Principles contained in

Section III of the EMR Policy, including the outcome of the process (i.e., development of a written report) and the

time frame under which that occurs. Following these discussions, a confirmation letter/ground rules letter will be

sent to the facility prior to conducting the EMR planning process and site visit (see Section III (e) and Attachment

One of the EMR Policy) to ensure that all parties understand the conditions under which the EMR will be

conducted. This letter will also ensure that EMR staff have access to the appropriate personnel and documents at

the facility, and also document that all participants are aware of terms and conditions of the Incidental Violations

Response Policy (IVRP) discussed in Section IV of the EMR Policy. Examples of suggested components of a

sample confirmation letter are included as Attachment One of the EMR Policy document. 

EPA regional environmental staff should also use the confirmation letter to confirm the scope and dates

of the EMR site visit, and to establish points of technical contact (POC) for both parties. In addition, EPA staff

involved in the EMR will have an opportunity to propose an agenda for the site visit, and to send a pre-site visit

questionnaire which will be helpful in determining the specific focus of the EMR. All EPA regional staff

members involved in the EMR should be mindful of the fact that the facility to be visited is volunteering for this

effort and, therefore, developing and maintaining a positive relationship with the facility POC is vital to the

success of the EMR. Taking care to set the right tone when contacting facility personnel is critical. Important

points to communicate to facility management include:

1. The purpose of the EMR: Both facility management and EPA regional staff assigned to conduct the EMR

should be fully aware of the EMR’s goals and scope, and the EPA EMR Policy document. In addition, facility

management and staff should understand how the EMR results will be used both by their agency headquarters

personnel ( if appropriate) and by EPA. Facility understanding of how the EMR results will be used and how it

may impact facility operations and relationship with EPA is particularly important. 

2. Information needs and critical persons needed for interview: EPA regional staff conducting the EMR should

work with facility management to develop a list of information needs and persons to be interviewed as part of

a site visit, including management and line and staff personnel at all levels at the facility. To accomplish this

task, a pre-site visit questionnaire should be forwarded to facility management in advance of the site visit to

alert facility management of the documents that should be available for review (e.g., organizational charts,

job-descriptions and environmental planning documents), and the facility staff that the EMR team will want to

interview during the site visit. A timely and well crafted pre-site visit questionnaire will save EPA regional

staff considerable time by answering fundamental questions about the facility practices and policies, and

allowing the regional staff to focus the site visit on the critical issues and matters requiring a more in-depth

review. FFEO has provided an appendix to the EPA Phase III protocol, Selecting Documents to Review and

Individuals to Interview for Environmental Management Assessments, to assist personnel in this phase of

the EMR process. EPA Region 1 has also developed a pre-site visit questionnaire that may prove useful for

other Regions (See Attachment Two).

3. Time schedules: Regional environmental staff should work with the facility to develop an appropriate agenda

and schedule for the EMR. The time schedule will depend on the size and complexity of the facility and the

number of individuals that need to be interviewed.

IV. Protocols/Checklists:

Because the scope of the EMR site visit will likely involve a review and assessment of more than one of

the environmental organizational disciplines outlined in Section II of this technical guidance and Section II of the
Appendix B - Final EMR Policy

54

EMR Policy, FFEO recommends that Phase III of the EPA Generic Protocol For Conducting Environmental

Audits of Federal Facilities be consulted by EPA regional staff when developing the actual working documents

and specific tools for a given site. The Phase III Protocol will provide specific guidance to EMR team members in

evaluating the facility activities, and in documenting the procedural elements that are to be reviewed during the

EMR. The Protocol also identifies performance objectives, and key evaluative concerns and criteria related to

each of the organizational disciplines to be evaluated. Once the scope of the EMR is agreed upon by EPA regional

staff and facility management, the EMR team conducting the review should select the appropriate performance

objectives and criteria needed from the Phase III Protocol, and develop the appropriate protocols and checklists

for that site. EPA Region 1 has also developed an EMR protocol which incorporates many items from the Phase

III Protocol, and is organized around the Code of Environmental Management Principles for Federal Agencies

(CEMP) (See Attachment Three). Both of these documents may be helpful to EMR team members in other

Regions developing protocols and checklists for a specific site.

A checklist is an actual on-site tool developed specifically for the facility that is being reviewed. A

checklist is dynamic, and should reflect only the areas to be evaluated for a particular facility based upon

information gathered from the pre-site visit questionnaire, and pre-site visit communications with facility

management. FFEO recommends that EPA staff conducting EMRs either develop a unique checklist for each

facility undergoing a review, or annotate and modify existing checklists to reflect the specific scope agreed upon

for a particular facility visit. Points to consider in developing or using a checklist include:

o Is the checklist applicable to the type of facility being evaluated?

o Is it pertinent to the organizational disciplines being reviewed?

o Is it consistent with the goals and scope of the EMR for that particular facility ? 

Protocols and checklists are essential tools for assuring that an EMR has adequately addressed all issues

that need to be examined during an EMR. However, they are not static (i.e., one size fits all), and should reflect the

unique considerations and differences attributable for each federal facility program and management system being

reviewed. Protocols and checklists also are not a substitute for critical and independent judgement or decision

making, and should only be used as a reference point to affirm that key criteria and evaluative areas have been

examined.

V. Training and Development of Expertise:

The success of the EMR program depends on the quality of the service being provided to facility

management. Since federal agencies and their facilities will be looking to EPA for guidance in improving their

overall environmental management systems, EPA staff and contractors conducting EMRs should be able to

demonstrate having both appropriate knowledge of the issues included in the scope of the EMR, and sufficient

training and proficiency prior to participating in EMRs. 

The qualifications of the staff assigned to conduct EMRs should be commensurate with the objectives,

scope and complexities of that particular EMR assignment. Although EMRs will vary in scope, they all require

some degree of professional assessment of apparent problems as well as some verification and documentation of

the facility’s systems for the full range of potential hazards - not just those related to compliance requirements. 

While the balance between assessment and verification will vary, in general the EPA staff member’s background

should include at a minimum:

o technical training and experience appropriate to the work called for by the particular EMR;

o an understanding of basic auditing theory and procedures, and the experience needed to apply it in

particular situations;

o a working knowledge of environmental regulations, evaluation criteria in the Phase 3 Protocol, and
Appendix B - Final EMR Policy

55

general EMS standards appropriate to the scope of the EMR; and

o general familiarity with the type of operations to be reviewed, and the issues likely to be encountered

within the scope of the EMR.

While the precise mix of experience and knowledge that is desirable can vary, the EMR team as a whole should

represent sufficient depth in these four areas of experience.
Appendix B - Final EMR Policy

56

Attachment One

Examples of Suggested Components of a Sample Confirmation Letter

The confirmation letter for an EMR could include the following elements:

a. specific objectives of the EMR--a brief discussion of which components of an environmental

management system the review will focus on;

b. a statement that an EMR is not an inspection. 

c. brief discussion of EPA’s expectations of the federal facility with respect to requests for access to

specific staff, parts of the facility, access to info, etc.

d. a brief explanation of the Incidental Violations Response Policy (IVRP) and any necessary definitions. 

Emphasize that instances involving the IVRP are very infrequent.

e. a brief explanation of how the site visit will be conducted, what documents will be requested in advance,

what federal facility personnel will be interviewed, etc.

f. a disclaimer that the facility is responsible for compliance with all applicable regulations regardless of

whether or not they have an EMR.

g. a statement that the facility will, no later than six months after receipt of the EPA EMR report, produce a

response plan that lays out how they plan to address the EMR findings and reports on progress made to

that point. 

h. a statement that the EMR is available through FOIA.
Appendix B - Final EMR Policy

57

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Appendix C-Process Steps For A Sample EMR 

58

APPENDIXC

Process steps for a sample EMR

TASK # TASK DATE OF COMPLETION

1 U.S. EPA provides federal facility with a draft

Confirmation Letter for comment and a pre-site visit

questionnaire for completion

May 18, 1998

2 Federal facility provides U.S. EPA with Confirmation

Letter comments

June 1, 1998

3 Federal facility submits to U.S. EPA completed EMR

pre-site visit questionnaire

June 1, 1998

4 Federal facility submits to U.S. EPA samples and

copies of documents requested in the Confirmation

Letter

June 8, 1998

5 Confirmation Letter is signed by both U.S. EPA and

federal facility

June 15, 1998

6 Federal facility submits to U.S. EPA a list of

personnel available for on-site interviews

July 10, 1998

7 U.S. EPA submits EMR protocol to federal facility

for distribution to personnel who will be interviewed July 13, 1998

8 U.S. EPA submits to federal facility EMR logistical

plan

July 20, 1998

9 U.S. EPA develops draft interview schedule and

submits to federal facility for comment

July 27, 1998

10 Federal facility submits to U.S. EPA interview

schedule comments

July 30, 1998

11 U.S. EPA submits to federal facility final interview

schedule

August 7, 1998

12 On-site portion of the EMR - document review and

interviews

Two days during the week of

August 17, 1998

13 U.S. EPA submits to federal facility EMR findings

and recommendations

60 days after on-site portion

of the EMR

14 Federal facility submits to U.S. EPA a plan to

implement certain EMR recommendations

60 days after receipt of the

U.S. EPA report

15 Federal facility submits to U.S. EPA an implementation

progress report

Six months after submitting

initial report
Appendix C-Process Steps For A Sample EMR

59

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Appendix D-EMR Tools And Related Compliance Assistance Resources

60

APPENDIX D

EMRTOOLS AND RELATED COMPLIANCE ASSISTANCE RESOURCES

Regional Federal Facility Coordinator Contact Information

Anne H. Fenn

US EPA Region I (CT, MA, ME, NH, RI, VT)

One Congress St.-Suite 1100

Mail: SPP

Boston, MA 02114-2023

Tel: 617-981-1805

Fax: 617-918-1810

fenn.anne@epa.gov

Bill Arguto

US EPA Region III (DE, DC, MD, PA, VA, WV)

841 Chestnut St.

Philadelphia, PA 19107

Tel: 215-814-3367

Fax: 215-566-2783

arguto.william@epa.gov

Lee Regner

US EPA Region V (IL, IN, MI, MN, OH, WI)

77 West Jackson Blvd.

Chicago, IL 60604

Tel: 312-353-6478

Fax: 312-353-5374

regner.lee@epa.gov

Diana Jackson

US EPA Region VII (IA, KS, MO, NE)

901 N. 5th St.

Mail: RA/ECO

Kansas City, KS 66101

Tel: 913-551-7744

Fax: 913-551-7941

jackson.diana@epa.gov

Sara Segal

US EPA Region IX (AZ, CA, HI, NV, AS, GU,

TTP)

75 Hawthorne St., CMD-2

San Francisco, CA 94105

Tel: 415-744-1569

Fax: 415-744-1598

segal.sara@epa.gov

Jeanette Dadusc

US EPA Region II (NJ, NY, PR, VI)

290 Broadway - 21th Fl.

New York, NY 10007

Tel: 212-637-3492

Fax: 212-637-4086

dadusc.jeanette@epa.gov

Stacy Howard

US EPA Region IV (AL, FL, GA, KY, MS, NC, SC,

TN)

61 Forsyth St., SW

Atlanta, GA 30303

Tel: 404-562-9633

Fax: 404-562-9598

howard.stacy@epa.gov

Joyce Stubblefield

US EPA Region VI (AR, LA, NM, OK, TX)

Mail: 6EN-XP

1445 Ross Ave.

Dallas, TX 75202

Tel: 214-665-6430

Fax: 214-665-7446

stubblefield.joyce@epa.gov

Dianne Thiel

US EPA Region VIII (CO, MT, ND, SD, UT, WY)

999 18th St. - Ste. 500

Mail: 8P-P3T

Denver, CO 80202-2466

Tel: 303-312-6389

Fax: 303-312-6044

thiel.dianne@epa.gov

Michele Wright

US EPA Region X (ID, OR, WA, AK)

1200 6th Ave., OEC-157

Seattle, WA 98101

Tel: 206-553-1747

Fax: 206-553-7176

wright.michele@epa.gov
Appendix D-EMR Tools And Related Compliance Assistance Resources

61

ENVIRONMENTAL MANAGEMENT REVIEW (EMR)

Process Evaluation -- Team

Thank you for participating in this management system review. In an effort to continuously improve

our process, we are asking for your evaluation and suggestions. Your candid insights will be

extremely helpful to us.

How well prepared did you feel you were for the EMR?

Knowledge of objectives and process very somewhat not at all

Understanding of organization to be reviewed very somewhat not at all

Understanding of EMR criteria very somewhat not at all

How efficient was the process?

Preparation very somewhat not at all

On-site very somewhat not at all

Synthesis of data very somewhat not at all

How effective were communications?

Within the team very somewhat not at all

With organization being reviewed very somewhat not at all

Were your views and ideas heard and accommodated? very somewhat not at all

How useful were the tools we used? very somewhat not at all

How thorough was the process? very somewhat not at all

How useful was the outcome to the organization reviewed? very somewhat not at all

How challenging was the process? very somewhat not at all

How close was the actual experience to your expectations? better close worse

How useful to you was the process as a learning experience? very somewhat not at all

How could the process be improved? (Please be specific. Continue on reverse if necessary)
Appendix D-EMR Tools And Related Compliance Assistance Resources

62

ENVIRONMENTAL MANAGEMENT REVIEW (EMR)

Process Evaluation -- Site

Thank you for participating in this management system review. In an effort to continuously improve

our process, we are asking for your evaluation and suggestions. Your candid insights will be

extremely helpful to us. (Feel free to skip questions that do not apply.)

How well prepared did you feel you were for the EMR?

Knowledge of objectives and process very somewhat not at all

Understanding of EMR criteria very somewhat not at all

How efficient was the process?

Preparation very somewhat not at all

On-site very somewhat not at all

How disruptive to the organization was the activity? very somewhat not at all

How effective were communications from the team? very somewhat not at all

Were your views and ideas heard and accommodated? very somewhat not at all

How useful were the tools we used? very somewhat not at all

How thorough was the process? very somewhat not at all

How accurate were the observations? very somewhat not at all

How useful were the recommendations? very somewhat not at all

How timely was the report? very somewhat not at all

How helpful was the overall experience? very somewhat not at all

How close was the actual experience to your expectations? better close worse

How professional were the team members? very somewhat not at all

How knowledgeable were the team members? very somewhat not at all

How objective were the team members? very somewhat not at all

How flexible were the team members? very somewhat not at all

How responsive were the team members? very somewhat not at all

How could the process be improved? (Please be specific. Continue on reverse if necessary)
Appendix D-EMR Tools And Related Compliance Assistance Resources

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Appendix D-EMR Tools And Related Compliance Assistance Resources

64

EPA ENVIRONMENTAL MANAGEMENT REVIEWS 

FOR FEDERAL FACILITIES

 FACILITY PRE-SITE QUESTIONNAIRE

I. FACILITY CONTACT INFORMATION

NAME OF FACILITY: ____________________________________________________

FACILITY

DIRECTOR/COMMANDER:____________________________________________________

ADDRESS: ________________________________________________________________

________________________________________________________________

TELEPHONE:______________ FAX:_______________ E-MAIL:_______________

FACILITY ENVIRONMENTAL COORDINATOR:___________________________________

ADDRESS: _______________________________________________________________

_______________________________________________________________

TELEPHONE:______________ FAX:_______________ E-MAIL:______________

PARENT ORGANIZATION:

__________________________________________________________

PARENT ORGANIZATION 

ENVIRONMENTAL MANAGER:

_______________________________________________________________

ADDRESS: _______________________________________________________________

_______________________________________________________________

TELEPHONE:______________ FAX:_______________ E-MAIL:_______________

II. FACILITY ORGANIZATIONAL STRUCTURE
Appendix D-EMR Tools And Related Compliance Assistance Resources

65

1. Please describe your facility's mission/major activities:

2. How does your facility fit into the organizational structure of your parent agency? 

3. Has your parent agency issued a formal, organization-wide environmental policy and

standards? When?

4. Does your parent agency provide environmental assistance and/or oversight? How does

your parent agency collect reporting data from and/or provide environmental information to

your facility? Who is your facility's point of contact with your parent agency?

5. How does your Environmental Program fit into your facility's organizational structure? 

What is the facility's annual budget? What is the level of funding for the Environmental

Program?

6. Do any other facility staff or programs have environmental management responsibilities? 

If yes, please explain.

7. How is your facility Environmental Management Program organized? How many staff at

your facility have full-time or part-time environmental responsibilities? Briefly describe

the general responsibilities of your Environmental Program.

8. What is the internal process for implementing new environmental initiatives? What is the

approval process and how are funds allocated for new environmental initiatives?

9. What methods are used to track and measure facility environmental performance? How

frequently is such measurement performed?

PLEASE PROVIDE COPIES OF THE FOLLOWING:

_____ Parent agency organization chart
Appendix D-EMR Tools And Related Compliance Assistance Resources

66

_____ Parent agency environmental policy and standards

_____ Staffing and organization chart for your facility

_____ Samples of supporting documentation for reporting and communication

networks such as meeting notices, meeting minutes, memoranda, etc.

_____ Samples of written Environmental Program performance and status reports

_____ Samples of facility-specific environmental policies and procedures

Please complete the following chart. The information will help the EMR team determine what

environmental issues should be planned for and taken into account by your facility. When

completing the chart, please indicate the policies, procedures, and personnel that are pertinent to

the various aspects of the media/program.
Appendix D-EMR Tools And Related Compliance Assistance Resources

67

III. FACILITY BACKGROUND INFORMATION

 MEDIA PROGRAM REVIEW

MEDIA/

PROGRAM

PLANS/

PERMITS

SOURCES/

DISCHARGES

UNDERSTAND

REGS?

MGMT.

PROCEDURES

PERSONNEL 

TRAINING

RECORDKEEPING/

REPORTING

OVERSIGHT/

EVALUATION

CAA

SDWA

UIC

FIFRA
Appendix D-EMR Tools And Related Compliance Assistance Resources

 MEDIA PROGRAM REVIEW

MEDIA/

PROGRAM

PLANS/

PERMITS

SOURCES/

DISCHARGES

UNDERSTAND

REGS?

MGMT.

PROCEDURES

PERSONNEL 

TRAINING

RECORDKEEPING/

REPORTING

OVERSIGHT/

EVALUATION

68

NPDES

WETLANDS

RCRA

Generator

Status:
Appendix D-EMR Tools And Related Compliance Assistance Resources

 MEDIA PROGRAM REVIEW

MEDIA/

PROGRAM

PLANS/

PERMITS

SOURCES/

DISCHARGES

UNDERSTAND

REGS?

MGMT.

PROCEDURES

PERSONNEL 

TRAINING

RECORDKEEPING/

REPORTING

OVERSIGHT/

EVALUATION

69

TSCA/PCBS

UST
United States

Environmental Protection Agency(2261A)Washington, DC 20460Official BusinessPenalty for Private Use$300

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