Enhancing Compliance at Department of Defense Facilities: Comparison of Three Environmental Audit Tools. (Features)
Hepler, Jeff A., Neumann, Cathy, Journal of Environmental Health
Achieving environmental compliance at U.S. Department of Defense (DOD) and other federal facilities has become a national priority. Passage of the 1992 Federal Facility Compliance Act clearly established the authority of the U.S. Environmental Protection Agency (U.S. EPA) to levy fines against federal facilities. In fiscal year 1994, U.S. EPA and the states issued 40 administrative orders totaling more than 6.5 million dollars in penalties (U.S. EPA, 1994). Past failures by DOD agencies to meet environmental laws and regulations have resulted in site contamination, civil and criminal prosecution of employees, and a loss of public confidence. In addition, the inability of federal agencies to comply with environmental standards has made private-sector interests question whether a level "playing field" exists in the regulated community (U.S. EPA, 2001a). To help address these concerns, on April 21, 2000, President Clinton signed Executive Order #13148, "Greening the Government Through Leadership in Environmental Management" (Federal Register, 2000). This executive order required federal agencies to implement environmental management and compliance systems within prescribed timeframes.
Many environmental audit tools currently are being used in the federal sector. Some of the more dominant include the Code of Environmental Management Principles for Federal Agencies (U.S. EPA, 1996a), the National Environmental Performance Track (U.S. EPA, 2001b), the Global Reporting Initiative (GRI, 2000), U.S. EPAs Generic Environmental Audit (U.S. EPA, 1996b), the International Organization for Standardization's (ISO's) 14001, Environmental Management System (EMS) Audit (ISO, 1998), and the Environmental Assessment and Management Guide (TEAM) (U.S. Army Corps of Engineers [USACE], 2001). It is not within the scope of this paper to compare all of these audit tools. Two of the most widely used tools, however, the ISO 14001 Environmental Management System (EMS) Audit and U.S. EPAs Generic Environmental Audit, will be described and compared with DOD'S TEAM Audit. The objective of this comparison is to assess whether DOD'S TEAM audit is the most appropriate and effective tool for all DOD facilities, in partic ular those operated by USACE.
ISO 14001 Environmental Management System Audit
EMS Audits approach compliance from a management perspective. The desired outcome is continual improvement in environmental management (Martin, 1998). Of paramount concern is that a facility have a functional process in place to monitor, achieve, and improve compliance. ISO 14001 is the core management systems specification document in the ISO 14000 series (ISO, 1998). The ISO 14001 EMS Audit uses five "essential elements" as shown in the sidebar at top left (DOD, 2002). The first element, "Environmental Policy," is the starting point for the audit. This element involves a commitment from management to compliance with standards, pollution prevention, and continuous improvement. The second element, "Planning," considers environmental aspects of the organization. Based on these aspects, pertinent legal and regulatory requirements are identified. This process leads to the establishment of environmental objectives and targets and ultimately an Environmental Management Plan. The third element, "Implementation and Operation," involves an auditor examining the organization's structure, training, communication, document control, and overall operations capability. The fourth element, "Checking and Corrective Action," examines monitoring of the organization's EMS. This element includes information on how nonconformance and corrective actions are handled, examination of record-keeping procedures, and information on how internal EMS audits are performed. The fifth element, "Management Review," is an "External Audit and Certification." Here the organization performs an external review of the program and ensures that a process exists for continued performance and improvement. …