Risk management applies to many aspects of Defense Logistics Agency Energy’s mission, from operations to security, but the organization also applies similar practices to maintaining environmental compliance.
DLA Installation Support for Energy’s Environmental division staff uses a variety of tools and processes to mitigate risks and help make sure that DLA Energy continues to conform to environmental standards.
“The environmental protection specialists that represent DLA Energy work diligently every day to ensure we are maintaining environmental compliance,” said Carmela Spasojevich, a DLA Installation Support for Energy environmental protection specialist. “Of course, our goal is to proactively deal with potential areas of concern and changing regulations, but when we do have an issue or noncompliance situation, we work with the stakeholders to not only regain compliance, but to prevent reoccurrence.”
Compliance with environmental regulations supports warfighters and protects the environment. A major secondary benefit allows DLA Energy to avoid being issued notices of violation with possible fines or being shut down by local, state or federal regulators, Spasojevich said, adding that environmental compliance is critical to DLA Energy’s mission.
“We are an integral part of the DLA Energy team, and our work is often behind the scenes,” she said. “Our primary goal is to support the warfighter, but we must also protect the environment since environmental noncompliance could halt our mission. Unfortunately, our work can be seen as a hurdle in processes or projects.
“We work very hard to minimize the impacts of the environmental requirements,” Spasojevich continued. “Our jobs exist solely to support DLA Energy in preventing environmental noncompliance.”
Marcia Kicos, another DLA Installation Support for Energy environmental protection specialist, said the first reason for compliance is because it is the law. Compliance is tied to enforcing laws such as Clean Water Act and the Clean Air Act, as well as Department of Defense regulations, but environmental work is more than enforcing laws and regulations.
“Most importantly, like other federal agencies, the DoD is responsible for managing public lands and it is DLA Energy’s responsibility to protect the environment for future generations,” Kicos said. “It has been proven through lessons learned since the 1960s and 1970s that considering the environment in decisions and paying attention to how we affect the environment before we take action saves money, keeps projects on schedule and protects the environment.”
Protecting the environment is the job of 16 environmental staff members who work on compliance and restoration issues to make sure DLA Energy’s day-to-day operations are performed in an environmentally compliant manner.
To help the agency be good environmental stewards, an environmental, safety and occupational health management system is used to ensure the proper internal controls are in place.
“One of the primary goals of the ESOH management system is to make environmental compliance the responsibility of all employees,” Kicos said. “DLA Energy’s ESOH Management System policy establishes proactive management practices that encourage environmental compliance, while avoiding risk, preventing pollution and promoting environmental stewardship throughout the organization.”
“Our ESOH management system requires us to identify the aspects, or areas of risk, of our mission that could impact the environment, and we must review the list annually,” Spasojevich said. “This is a very important process, because you have to know what your potential risks are before you can manage them.
“The aspects are evaluated for their potential impacts and then racked and stacked by severity of risk based on several criteria,” she continued. “Our aspects are then managed through objectives and targets with the areas of highest risk being addressed first.”
Kicos emphasized that the ESOH management system is not a stand-alone program, but a management practice that helps organize processes so an organization can mitigate risk.
“It is basically getting credit for what we already do as normal business practice,” Kicos said.
She also described a management approach called the “plan, do, check, act” cycle that focuses on risk reduction and continuous improvement.
In the planning step, aspects of fuel operations that might affect the environment are identified. Targets and objectives are established to focus management on these significant areas before any actions are taken.
“It begins with the identification of activities that are of highest concern or are the riskiest,” Kicos explained. “In order to reduce the risk for a potential spill, DLA Energy has a response plan that resides with each employee responsible for spill response. We conduct annual training and we routinely maintain and inspect our facilities and equipment.”
Spasojevich said the framework follows through with planning, implementation and operation, checking progress, making adjustments to actions as needed and keeping management informed.
“The framework has proven to be very successful for DLA Energy,” Spasojevich said.
The ESOH management system framework is supported by three pillars, Spasojevich said. The environmental pillars of compliance, pollution prevention and continual improvement are complementary to one another and go hand-in-hand.
“Our ESOH management system plan ensures we incorporate all of the pillars when resolving our issues,” she said.
The themes of compliance, pollution prevention and continual improvement help the team apply the ESOH management system to several processes around the agency. One such process is the corrective action plan, which focuses on discovering the root causes of a potential issue.
“In the past, the cause of a spill might have been attributed to a valve failure,” Spasojevich explained. “Our process makes us look deeper by determining why the valve failed and how to prevent reoccurrence. The CAP process can involve the entire Installation Support for Energy team, to include engineering and Sustainment, Restoration and Modernization personnel to resolve our issues and help prevent reoccurrence.”
Two other elements include the quarterly Steering Committee meeting and the annual management review, Spasojevich said. Key stakeholders gather for these meetings to remain informed about the issues and to be updated on the status of the various CAPs for each site. To ensure all stakeholders are included, steering committee membership is reevaluated at each meeting.
In response to this re-evaluation, the quality assurance representatives and contracting officer representatives for each of the four permitted sites were recently added to the membership, Spasojevich added. The participation of the QARs and CORs will provide valuable on-site perspectives for each location.
Keeping key stakeholders and members of the workforce in general informed is vital to the success of environmental compliance, Kicos said.
“The management process can only be truly successful with buy-in from the lowest level employee to the top level managers,” Kicos said. “The ESOH management system incorporates input from everyone.”
Facility operations employees at the most basic level have input into what is significant and how things should be performed to reduce risk and environmental liability, she continued. Processes are implemented and refined along the way. Top-level managers review the processes and tweak them to improve on efficiencies.
On an annual basis, programs are reviewed, areas of improvement are identified along with funding requirements, and the process begins again, Kicos said.
When it comes time to implement the targets and objectives, more than the environmental staff members are involved in their success, Kicos said. Environmental compliance responsibilities extend to facility operations contractor staff, contracting officers, CORs, QARs, distribution facility management and engineers.
“To be successful, everyone should be actively involved, from the person turning the valves on the ground to the managers making decisions regarding inventory and funding,” she said.
Managing environmental risks using the ESOH management system construct is a powerful tool for maintaining environmental compliance, but the processes could be easily learned from or applied to other areas where non-environmental risk is commonly seen in an organization, Spasojevich said. Establishing and maintaining strong internal controls are essential elements in maintaining compliance and also in preventing noncompliance.
“Our purpose is to ensure DLA Energy is truly an environmental steward while maintaining environmental compliance with minimal impact to mission accomplishment,” she said. “We have a vested interest in DLA Energy’s success.”