NOAA Environmental Audit
Policy
September 30, 1997
Revised September 30, 1998b NOAA Environmental Compliance Policy 97-01
1.0 Policy
1.1 The National Oceanic and Atmospheric Administration (NOAA) is committed
to operating facilities in full compliance with environmental law.
1.2 To accomplish this goal, facility managers must be able to assess
the status of environmental compliance at the facilities under their
control, and develop and track solutions to any discovered compliance
problems. NOAA supports this need by conducting systematic, comprehensive
environmental audits and/or surveys at its facilities.
1.3 The short term objectives of these audits are to determine compliance
with environmental laws and regulations, to determine conformance with
NOAA environmental compliance standards, to assess strengths and weaknesses
of NOAA's environmental compliance management systems, and to assess
knowledge of NOAA's internal policies and procedures. The ultimate objectives
of these audits are to improve NOAA's environmental compliance and management,
and to build supporting financial programs and budgets appropriate for
environmental compliance requirements.
1.4 The audits will not only identify potential compliance issues, but
will recommend, as applicable, pollution prevention process changes to
assist the facility in achieving and sustaining compliance.
2.0 Definitions and Guidelines
2.1 An environmental compliance assessment is a systematic, documented,
periodic and objective assessment of facility operations and practices
subject to environmental requirements, which includes audits and surveys.
During a typical calendar year, the assessment process naturally follows
a planning and preparation phase, a field activity phase, and a review
of lessons learned phase (see Attachment 1). Environmental assessments
are scheduled and managed by NOAA's Environmental Compliance Staff (ECS)
and are implemented through the Regional Environmental Compliance Officers
(RECOs). The Line and Staff Offices will be part of the scheduling process
each year. The frequency of NOAA's assessments (audits and surveys) is
projected in Attachment 2. The same environmental media areas are the
basis of both audits and surveys.
2.2 An environmental audit is a formal periodic assessment conducted
on site using established protocol. NOAA schedules audits for those facilities
which possess a higher likelihood of a compliance violation and/or a
higher magnitude of consequence if a violation occurs. These facilities
are designated as first tier facilities. The NOAA audit process decision
tree is presented in Attachment 3. Audit findings are described under
three classes. Class 1 findings indicate a deficiency where the facility
is currently out of compliance or has received an enforcement action.
Class 2 findings indicate a deficiency not presently out of compliance,
but which will be in the relatively near future. Class 3 findings indicate
important environmental activities recommended, but not presently regulated.
Audits may be either external or internal.
2.2.1 External audits are more formal and are conducted by individuals
from outside the facility being audited. The ECS manages external audits.
2.2.1.1 Personnel conducting external audits may be from the servicing
Administrative Support Center (ASC), another Line Office (LO), from the
ECS headquarters, from a contracted source, or a combination of these
resources. A NOAA representative/advocate will be part of each audit
team.
2.2.1.2 A standard national Statement of Work (SOW) will be developed
annually. This SOW shall be used for all NOAA external contracted audits
to ensure consistency. Certain sections shall be tailored, as appropriate,
for specific contract actions.
2.2.1.3 The use of personnel external to the facility ensures objectivity
of the audit process.
2.2.1.4 Auditors will possess a good working knowledge of the environmental
laws and regulations, as well as a good working knowledge of the operations
being assessed. Collectively, the team must have the knowledge and background
required to efficiently and effectively conduct all aspects of a facility
audit. Minimum qualifications for audit personnel are found in Attachment
4.
2.2.1.5 The size and composition of the audit team is based on the size
and mission of the facility being evaluated.
2.2.2 Internal audits, or self-assessments, are recommended as a best
management practice and will be conducted under the oversight of the
facility environmental coordinator (FEC) with the assistance of the servicing
RECO. An FEC is responsible for ensuring the activities carried out at
a facility are conducted in accordance with Federal, State, and local
environmental regulations.
2.2.2.1 Internal audits will be conducted at a frequency determined
by the FEC and the Designated Responsible Official (DRO) as appropriate
to facility operations and compliance status. A DRO is the senior NOAA
official on-site at a NOAA facility. In some cases, this may result in
internal audits as frequently as once a quarter.
2.2.2.2 The internal audit will use checklists (see Attachment 5 for
a Sample Checklist) developed from the NOAA-accepted protocol (see Attachment
6) with particular attention paid to areas that were found to be in non-compliance
during previous external and internal audits.
2.2.2.3 Internal audits are not formally tracked. If an internal audit
is conducted, findings and corrective action status should be informally
passed (telephone call, conversation, e-mail) to the servicing RECO.
Any findings should be addressed, recorded, and maintained in facility
files, along with records of any corrective actions taken. Facility Condition
Surveys, conducted periodically by NOAA's Administrative Support Centers,
are considered internal audits and can be helpful tools in determining
a facility's environmental compliance.
2.2.2.4 If warranted by a finding, a Project Prospectus Sheet should
be completed and submitted to the servicing RECO. Guidance on completing
and submitting Project Prospectus Sheets is included in sections 4.1
and 4.2 of NOAA Environmental Compliance Policy 97-02.
2.2.2.5 Internal environmental audits may be incorporated into existing
facility assessment programs, such as the ongoing fleet inspection program
for NOAA ships.
2.3 An environmental survey is a periodic assessment conducted through
contact, normally by telephone, with knowledgeable personnel without
an onsite visit. NOAA considers those facilities scheduled for surveys
to possess a moderate or lower likelihood of a compliance violation and
a moderate or lower magnitude of consequence if a violation occurs. These
facilities are designated as second tier facilities. The NOAA environmental
survey process is presented in Attachment 7.
2.4 Environmental audits and surveys are designed to identify deficiencies
prior to their discovery by a regulatory agency. Discovery of an environmental
problem during an environmental audit or survey allows the facility to
correct the problem without the immediate threat of adverse action. Discovery
of an environmental problem during a regulator's inspection normally
leads to a formal Notice of Violation.
2.5 Environmental management reviews are used to determine whether an
organization or facility is following Departmental and NOAA guidelines
and has institutional controls in place to respond effectively to changing
environmental conditions and new environmental requirements. The management
review may be conducted at the same time as an audit.
3.0 Procedures: For specific procedures and time frames relevant
to conducting assessments in NOAA, refer to the generic statement of
work at Attachment 3.
3.1 Preparatory Activities:
3.1.1 An audit and/or survey schedule will be established and published
on the ECS Web Page annually prior to commencement of any assessment
activity.
3.1.2 The objective of the audit or survey must be clearly understood
and the protocol to be used established. For environmental audits and
surveys, NOAA presently uses the media areas established by the Environmental
Protection Agency (with minor revision) as the universe against which
facility compliance status is to be assessed (see Attachment 6), although
only a subset may be used for any given audit or survey.
3.1.3 An occupational safety and health audit may be included to determine
the facility level of safety and health risk and compliance, and to establish
any action(s) required to be taken to bring the facility into compliance
with applicable environmental and occupational safety and health standards.
3.1.4 A pre-audit questionnaire will be provided to the facility prior
to the audit. The facility information provided will help focus the site
visit.
3.2 Onsite Activities:
3.2.1 Onsite activities include an entrance briefing, physical assessment
of the facility, and an exit briefing.
3.2.2 The DRO should receive regular feedback throughout the site visit
to monitor problems discovered and initiate immediate corrective actions,
if possible or mandated.
3.3 Follow-up Activities:
3.3.1 Following the site assessment, the audit team will prepare an
environmental audit report. The report will first be distributed in draft
form for review and comment by the FEC, RECO, Safety and Environmental
Compliance Officer (SECO) (if applicable), and Line Office Environmental
Compliance Officer (LECO). The LECO will consolidate all comments and
present them to the ECS. The ECS will provide a written response to each
documented comment in the final report.
3.3.2 The final audit or survey report serves as documentation of findings,
a basis for follow-up actions, a rough guideline for determining corrective
action costs and financial environmental liabilities, and justification
for future funding requests.
3.4 Disclosure: The final audit report and all associated documents
contain sensitive information and may not be released to persons or agencies
outside of NOAA without consulting with and securing the permission of
NOAA's Office of General Counsel for Natural Resources (OGCNR).
3.5 Corrective Action Plan:
3.5.1 Within 45 days of the receipt of the final environmental audit
or survey report, the LO will submit a corrective action plan for all
class 1 findings to the RECO and the ECS. (See NOAA Environmental Compliance
Policy 97-02 for other related activities.)
3.5.2 The plan will outline how the facility will fix non-compliant
items, listing those actions already taken and those that require more
time or funding to accomplish, and will include project descriptions
and project completion schedule. Pollution prevention will be the first
consideration in determining corrective actions.
3.5.3 The findings reported during the assessment process will form
the basis of this plan.
3.5.4 The corrective action plan (except in the case of an Environmental
Management Review) will lead directly to the preparation and submission
of Project Prospectus Sheets by the LO, with assistance provided by the
servicing RECO.
3.5.5 To track NOAA's progress in completing corrective actions, the
LO will submit corrective action status reports to the RECO quarterly.
3.5.6 The status reports will be brief, in memorandum format, with most
of the information contained in tables (see Attachment 8 for a sample
report).
3.5.7 On completion of a corrective action, the LO will notify the RECO
who will verify proper closure of the audit finding.
3.6 Quarterly Reviews:
3.6.1 NOAA reports open environmental compliance findings and regulatory
actions during quarterly reviews presented to the Under Secretary. Only
those findings resulting from external assessments or regulatory inspections
shall be reported. Reporting heightens senior management's awareness
of environmental compliance issues, facilitates corrective action, highlights
environmental management systemic problems, supports budget development,
and measures performance. (See NOAA Environmental Compliance Policy 97-02
for related information.) |
