Incorporation of EMS audits into EPAS

1. Incorporation of EMS audits into EPAS Michael N. Noah, Compliance Program Manager, IMCOM-E Charles R. Georgius, URS International Inc.

2. Agenda • Environmental Programs and EPAS • Introduction of EMS to the US Army • Performing combined EMS and Compliance Assessments

3. Importance of Sustainability to Environmental Performance • Sustainability in terms of environmental performance is: • ability to train and conduct peace/war actions in a modern environment under shrinking global resources and regulatory encroachment • achieved through compliance with requisite laws and proactive management of resources

4. EPASEnvironmental Performance Assessment System • Primary objective of the EPAS program is to ensure that U.S. Army facilities are compliant with: • Final Governing Standards (FGS) • Department of Defense (DoD) Directives • Department of Army (DA) Regulations • U.S. Army in Europe (AER) Regulations IMCOM-Europe centrally conducts the EPAS program to: • evaluate • achieve • maintain and • monitor compliance with environmental requirements.

5. EPAS: A Program for Continuous Environmental Improvement Identify fix the the problem Implement Re-evaluate every 3 years (DoD 14715.5 requirement) Resources Develop a and $$$ Corrective Action Plan Program

6. External EPAS Process • Pre-Assessment • - Pre-visit questionnaire • - Collect information • - Workplan • On-Site Assessment • - In-Brief • - Interviews • - Records Review • - Site Visits • - Write Findings • Assessment Wrap-up • - Corrective Action Review • - Cost Estimates • - Out-Brief • Report • - Draft • - Final

7. Typical Findings • Poor HazMat/HazWaste Management • Poor solid waste management and recycling • Insufficient recordkeeping and monitoring Typical Root Causes • Lack of command awareness and support • Lack of management plans or implementation • Lack of training

8. Environmental Management Systems An EMS is a set of processes and practices that enable an organization to reduce its environmental impacts and increase its operating efficiency U.S. Environmental Protection Agency EPA

9. EMS Interfaces with other Environmental Programs • EMS incorporates existing environmental programs & regulations • HM, HW, asbestos, POL, cultural resources, etc. • ERG (Environmental Review Guide)ISR (Installation Status Report)and funding are all tied to EMS

10. Sustainability through EMS implementation • IMCOM-Europe strives to achieve sustainability through EMS implementation regionwide • An EMS procedure is required to properly address the Emergency Preparedness & Response aspects • Continual Improvement: Demonstrated by results of successive internal and external audits demonstrates EMS effectiveness

11. US Army Europe EMS Implementation • 2000: • EO 13148 Issued requiring EMS implementation • 2001: • First EMS review during EPAS assmements • 2002: • First EMS Gap Analysis performed at Region Garrison • 2003: • IMCOM-E wide EMS implementation plan produced • 2004: • Risk-Rating added to EPAS findings to help correlate with significant EMS aspects • 2006: • EMS performance audits included in EPAS

12. Incorporation of EMS into EPAS • EMS approach was incorporated into EPAS in response to Executive Order (EO) 13148 Greening the Government through Leadership in Environmental Management (22 Apr 00 ) • EO 13148 was replaced by EO 13423 (Strengthening Federal Environmental, Energy, & Transportation Management) on 24 Jan 07 • New EO still emphasizes EMS

13. Incorporation of EMS into EPAS • EPAS program was adapted to support EMS implementation and thus sustainability • Provides the Army a more transparent and cost-effective approach to managing increasingly finite resources • Helps focus on identification and correction of root causes

14. Incorporation of EMS into EPAS • A full conformance audit of the Garrison’s EMS was added to EPAS in FY06 • Compliance status is still assessed and is considered a barometer of how effective the EMS is • In the past, during an assessment, an attempt was made by the EPAS Teams to visit all relevant facilities. • Through the new EMS-oriented approach a representative sampling of facilities is visited by the EPAS Team. • More comprehensive assessment of the Garrison’s overall environmental performance • Approach may result in fewer compliance findings

15. Benefits of EMS Incorporation of EPAS • Single Audit – Less disruptive to Garrison operations • More cost-effective than conducting two audits • Ensures performance-based EMS Implementation • Provides Garrison with external observations and guidance on their EMS

16. Questions ?

17. Contact Information Michael N. Noah Compliance Program Manager IMCOM - Europe Region / Environmental Branch E-mail: michael.d.noah @eur.army.mil Phone: DSN (314) 370-6073 Fax: DSN (314) 370-8693 Charles R. Georgius DoD Program Manager URS International Inc. E-mail: chuck_georgius@urscorp.com Phone: ++49-6103-9389-12 Fax: ++49-6103-9389-99 David Barber EMS Program Manager IMCOM - Europe Region / Environmental Branch E-mail: david.barber @eur.army.mil Phone: DSN (314) 370-6536 Fax: DSN (314) 370-8693