IGD 1014: Evaluation of Compliance

1.0

PURPOSE




This IGD identifies procedures used to periodically evaluate compliance of our ESOHMS with applicable Legal and other requirements. This document applies to all of our employees, support departments, and those working on our behalf whose operation activities are subject to environmental, safety and health measuring and monitoring.



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2.0

PROCESS






2.1

Areas of Applicability





a)

Collaborating with the office of counsel to periodically evaluate legislative and regulatory compliance information





b)

Periodically evaluating environmental compliance and environmental programs through internal and external audits, such as the triennial Environmental Performance Assessment System ( EPAS) audits





c)

Periodically evaluating  safety and health compliance through internal audits







 


2.2    Environmental Monitoring




a)    Hazardous waste manifests at our depots to document the generation, transport, and disposal of solid and hazardous waste from the installation




 b)   Internal and External Environmental Compliance Audits, which are consolidated with internal and external ESOHMS Conformance audits and internal health and safety audits




DLA requires a triennial external Environmental Compliance and ESOHMS Conformance audit, or “EPAS”, for each depot every three years. During EPAS audits, DLA Strategic Materials depots are evaluated against the following media areas, as documented in the Environmental Compliance and ESOHMS Conformance Protocols provided in Section 3.0:

  • Air Emissions
  • Asbestos
  • Cultural Resources
  • Environmental Impacts/NEPA
  • ESOHMS
  • Hazardous Materials
  • Hazardous Waste
  • Installation Restoration Program
  • Lead-based Paint
  • Environmental Noise
  • Natural Resources
  • Polychlorinated Biphenyls
  • Pesticides
  • Environmental Program Management
  • Petroleum, Oils, and Lubricants
  • Pollution Prevention
  • Radon
  • Solid Waste
  • Wastewater
  • Water Quality

An EPAS typically includes the following:

  • Desktop review of records, management plans, documents, permits, training certificates, registrations, inspection forms, waste manifests, monitoring results, and notifications, as well as documentation identified within audit protocols and procedure; 
  • Interview of Depot personnel with significant environmental responsibilities (such as the Depot manager and personnel that handle hazardous materials or conduct environmental inspections); 
  • Site walk-through to include shops, storage and disposal facilities, and other areas of environmental concern.

Upon completion of each audit, the EMR/CAC and designated action officers will follow IGD 1015 and the Root Cause Analysis Procedure to document audit findings, determine the root cause of certain findings, and to identify corrective actions and preventative actions. In addition, the EMR/CAC and designated action officers will follow the steps documented in the Management of Change Procedure during evaluation of findings and implementation of corrective actions, taking into consideration the review and update of applicable DLA Strategic Materials procedures.


c)   Audit Tracking Systems

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2.3

Safety & Health Monitoring





Mishaps are tracked by DLA's Enterprise Safety Applications Management System (ESAMS). If a violation is found in the field during internal safety audits, those findings are entered into ESAMS. When the item is entered, ESAMS assigns a risk code for it (i.e., severity). Procedures that require corrective and preventive actions are reviewed through the risk assessment process in ESAMS. Confirmation of effectiveness is accomplished during subsequent periodic safety audits.

 

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3.0

EXAMPLES OF ESOHMS SUPPORTING DOCUMENTATION REFERENCES





The references listed below are not intended to be all inclusive but rather to provide examples of typical documentation and records, illustrative of the ESOHMS and are not necessarily controlled by this ESOHMS Manual.





3.1

Environmental Internal Compliance Audit Protocol




3.2

ESOHMS Internal Conformance Audit Protocol
     

3.3

Root Cause Analysis Procedure




3.4

Safety and Health Checklist




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