Implementation of DOE Order 450.1: Self-Declaration and Report Letters Steven R. Woodbury US Department of Energy March 9, 2005

Overview DOE Order and DOE Guide Role of Self-Declaration Protocol Sample Report Letters Summary

Responsibilities Under DOE Order PSOs: ensure that all their sites have implemented EMS by 12/05 Site Managers: report by 12/31/05 to CSO the status of contractor implementation of EMS Site Managers: ensure that contractors update ISM system description to reflect EMS

ISMS/EMS Frameworks DOE Guide (§8) Framework 1: Self-Declaration –Implement elements of an EMS, within ISMS –Meet all EMS requirements of DOE O –Self-declare conformity to DOE O Framework 2: ISO Registration –Implement elements of an EMS, within ISMS –Meet all EMS requirements of DOE O –Achieve third-party registration to ISO 14001

OFEE Self-Declaration Protocol Developed by E.O Inter-Agency Work Group Issued by Office of the Federal Environmental Executive (OFEE) Provides a framework for agencies to establish their self-declaration protocols DOE has implemented the Protocol through DOE Guide

OFEE Clarification of Terms Developed by E.O Inter-Agency Work Group Issued by Office of the Federal Environmental Executive (OFEE) Will provide a basis for reporting EMS status to EPA DOE has included the definitions in the revision to DOE Guide

OFEE Clarification of Terms First-party audit –EMS audit conducted by participants within the scope of the EMS under consideration External second-party audit –EMS audit conducted by reviewers from outside the scope of the EMS in question External, third-party audit –EMS audit conducted by ANSI-RAB accredited independent auditor for conformance to ISO Standard

Self-Declaration: DOE Guide (§9.1) Site determines that it fully conforms to requirements of DOE O To be credible, determination should be based on a first-party EMS evaluation (at minimum) Self-declaration procedure should –provide effective and objective assessment of EMS –be designed for ongoing evaluation and continual improvement

Additional Guidance DOE G (attachments) An acceptable procedure is outlined in Attachment 2 of DOE G Site may use alternative self-declaration procedure (e.g. existing review/evaluation/ audit process established under ISMS) –Must credibly establish and document the existence of EMS conforming to DOE O In any case, process must address DOE O EMS requirements summarized in Attachment 3 of DOE G 450.1

Third-Party Registration DOE Guide (§9.2) DOE sites may choose to seek third-party registration to the ISO standard Not required by DOE Order 450.1

Sample Report Letters Guidance being issued as a revision to DOE G Includes three sample letters: 1.EMS in place – first-party or second-party assessment 2.EMS in place – third party assessment 3.EMS not yet fully implemented

Sample Report Letter #1: EMS in Place; Self-Declared Declares conformance to EMS requirements of DOE O Identifies basis for declaration –First- or second-party assessment? –Describe assessment procedure

Sample Report Letter #2: ISO Registered EMS Declares conformance to EMS requirements of DOE O Identifies basis for declaration –ISO registrar, and date of audit(s) –Affirms that site EMS meets the requirements of DOE O 450.1, e.g.: scope integration with ISMS

Sample Report Letter #3: EMS Not Fully Implemented States that sites does not yet conform to the EMS requirements of DOE O Identifies EMS elements not yet developed, and EMS elements not yet implemented Identifies basis for statements Identifies planned completion dates

Sample Report Letters All Sample Report Letters also address: –Incorporation of DOE O CRD in site contract (§ 3.b.(2)) –Integration of EMS into updated ISM system description (§ 5.d.(2)) –Inclusion of appropriate environmental elements in Annual ISM review of ES&H perf. objectives, perf. measures, and commitments (§ 5.d.(17)) –Availability of supporting documentation for review

Other Reporting DOE: Annual reports to EPA under Greening of the Government E.O.s –DOE O requires reporting to EH –DOE O provides for “input from Departmental elements” Program Office: Quarterly report of site implementation status Site: Annual Site Environmental Report –EMS status –progress toward objectives and targets

Program Office Role Program Secretarial Officers are ultimately responsible for ensuring that their sites implement EMS Some Program Offices have issued specific guidance to their sites on EMS assessment and reporting

Communication between DOE HQ Offices and Site Offices DOE HQ Offices – should be communicating with their site offices about their expectations for EMS self- declaration DOE Site Offices – should be communicating with their DOE Headquarters office about their expectations for EMS self-declaration No surprises in December 2005

Communication at the Sites DOE Field Offices – should be communicating with their contractors about their expectations for EMS self- declaration DOE contractors – should be communicating with their DOE field office about their expectations for EMS self-declaration No surprises in December 2005

Bottom Line Self-Declaration process should be Credible Based on objective evidence Designed for ongoing evaluation and continual improvement Site Manager’s Report Letter should Affirm DOE site management’s knowledge of EMS implementation Be based on available supporting documentation

For additional information: Steven R. Woodbury