560 FW 7
Supersedes 560 FW 7, FWM 376, 09/28/01
Date: November 2, 2009
Series: Pollution Control
Part 560: Pollution at FWS Facilities
Originating Office: Division of Engineering
7.1 What is the purpose of this chapter? This chapter provides guidance for conducting environmental compliance and Environmental Management System (EMS) conformance audits at Service facilities.
7.2 What are the objectives of the environmental auditing program? The objectives of our auditing program are to:
A. Establish Servicewide standards for audits to ensure compliance with applicable environmental laws and regulations, and
B. Assure the Director and program managers that we effectively address environmental problems that could:
(1) Impact our mission effectiveness,
(2) Jeopardize the health of our personnel or the general public,
(3) Significantly degrade the environment,
(4) Expose the Service to avoidable financial liabilities as a result of noncompliance,
(5) Erode public confidence in the Service and the Department of the Interior (Department), and
(6) Expose individuals to civil and criminal liability.
C. Determine if the audited facility’s
7.3 What is an Environmental Management System (
7.4 What are the authorities for this chapter?
A. 515 DM 2, Environmental Auditing.
B. 515 DM 4, Environmental Management Systems.
C. Executive Order 13423, Strengthening Federal Environmental, Energy, and Transportation Management.
7.5 Who is responsible for administering the program? Table 7-1 shows the responsibilities for the program.
7.6 How does the Service run the program?
A. Types of Audits. We conduct four types of audits at Service
facilities to ensure environmental compliance and
(1) Every year, the RECCs determine the schedule for audits and provide copies of the schedule to the Environmental Compliance Branch no later than September 1. The Environmental Compliance Branch uses the schedule to allocate funding to the RECCS for conducting the audits.
(2) Frequency depends on the size and type of the facility. The Service must audit:
(a) Every facility at least every 5 years, and
(b) Facilities with an
(3) Some facilities, such as a stand-alone office with only two full-time employees, may not require an audit. The RECC determines this based on professional judgment of the environmental issues present at the station.
7.7 What are the types of findings from audits? Table 7-3 shows how we rank and classify audit findings.
A. The auditor/team must write a Draft Findings Report within 30 days after completing the audit. Auditors/teams use the following sections in their reports:
(1) Section One is an executive summary that describes:
(a) The facility/site audited,
(b) The audit date,
(c) What the auditor/team audited,
(d) A list of the members of the audit team, and
(e) A summary of findings.
(2) Section Two contains background information on the site.
(3) Section Three reports environmental compliance findings. This section explains the ratings and gives recommendations for corrections.
(4) Section Four is only in reports for
B. The auditor or audit team leader gives a copy of the Draft Findings Report to the Project Leader/Facility Manager.
(1) The Project Leader/Facility Manager has 60 days after receiving the report to develop corrective actions for each of the regulatory, required practice, and management practice findings and send them to the auditor/audit team leader.
(2) A reply can be as simple as "situation corrected on June 30" or "work order request submitted on May 30, 2010, for construction of cement pad." It can also be a detailed corrective action plan.
C. If the facility has received a significant regulatory finding, the auditor/audit team leader must also send a copy of the report to the Regional Director.
D. The auditor/audit team leader issues a final report within 30 days of receiving the reply on the draft report. If a reply/corrective action is not appropriate to the finding, the auditor/audit team leader contacts the facility to resolve the issue. The auditor/audit team leader sends final copies of the report to the Project Leader/Facility Manager.
E. The RECC must monitor the progress of corrective actions.
(1) The Project Leader/Facility Manager reports to the RECC 12 months after the Final Findings Report on the status of corrective actions. He/she must report to the RECC every 12 months until all corrective actions are complete.
(2) The RECC updates the status of corrective actions in EFCATS. We use this data to track the status of open deficient findings, to manage the auditing program, and to assist in developing budget requests for corrective actions.
(3) The RECCs brief higher management annually on the status of audit findings and corrections.
A. The Chief of the Environmental Compliance Branch is responsible for ensuring the most current versions of the Federal TEAM Guide and State and Service TEAM Guide Supplements are available for Service use. To establish consistency, all of the RECCs use the TEAM Guide and its established standards when they write compliance reports.
B. The U.S. Army Corps of Engineers prepares and maintains the TEAM Guide. The guide includes protocols for compliance with applicable environmental standards that auditors and Project Leaders/Facility Managers use as a reference. The categories of protocols are:
(1) Air Emissions Management: air pollution from vehicles and equipment operated on the facility.
(2) Hazardous Materials Management: storage and handling of chemicals used at the facility.
(3) Hazardous Waste Management: generation, storage, transportation, treatment, and disposal of any type of hazardous waste on the facility.
(4) Other Environmental Issues: implementation of greening practices at the facility.
(5) Pesticide Management: use, storage, and handling of pesticides at the facility.
(6) Petroleum Oils and Lubricants (POL) Management: use, storage and handling of fuels and lubricating oils used at the facility.
(7) Solid Waste Management: collection, storage, and disposal of nonhazardous trash, rubbish, and garbage generated on the facility.
(8) Storage Tank Management: operation and maintenance of tanks (both aboveground and underground) that store hazardous materials, petroleum products, or hazardous waste.
(9) Toxic Substance Management: management of any asbestos, lead-based paint, radon, or polychlorinated biphenyls (PCBs) located at the facility.
(10) Wastewater Management: management of any wastewater that is discharged from the facility.
(11) Water Quality Management: management of drinking water systems on the facility.
(12) Environmental Management System: implementation of the facility’s
7.10 What training opportunities are available for employees involved in the environmental compliance audit program?
A. The Chief of the Environmental Compliance Branch:
(1) Is responsible for ensuring audit training is available, and
(2) Holds quarterly conference calls with the RECCs to evaluate program objectives, discuss any ongoing concerns, and address questions.
(1) The Environmental Compliance Branch conducts an environmental compliance/EMS conformance auditing class every 2 years, or more often if necessary. These courses are held at different Service field stations. Part of the class is an actual on-site environmental compliance/EMS conformance audit of the host facility. The class also includes EMS-specific training.
(2) Each trained auditor receives a certificate as a qualified auditor after successfully completing the class.
7.11 What does the Service do to ensure quality control of the program?
A. Once every 3 years, staff in the Environmental Compliance Branch accompany each RECC on at least one audit to evaluate their technical, organizational, and communication skills. Staff document these evaluations on FWS Form 3-2136, the Quality Assurance Environmental Team Evaluation Form.
B. To ensure auditors/audit teams are performing well, the RECCs request an evaluation from each facility being audited. The facility evaluates the audit using FWS Form 3-2135, the Quality Assurance Environmental Team Evaluation Facility Response, or similar form.
(1) The RECC gives the completed evaluation to the auditor/audit team lead.
(2) The RECC sends a copy to the Environmental Compliance Branch. Branch staff review the evaluation to determine if any positive or negative trends are apparent and if corrective actions are needed.
C. The Environmental Compliance Branch schedules an outside evaluator (e.g., Corps of Engineers) to accompany an audit team to at least one Service facility each year. This evaluator provides a report to the Environmental Compliance Branch and the audit team leader containing objective feedback on the Service’s audit process.
D. The Environmental Compliance Branch:
(1) Monitors EFCATS to ensure consistency and quality in report writing;
(2) Uses quality assurance/quality control (QA/QC) to measure the effectiveness of the program by reviewing replies from the Project Leaders/Facility Managers, self evaluations, and evaluations by people outside the Service; and
(3) Maintains a file of the results of the QA/QC program and evaluates it to monitor trends and determine if we need further corrective actions.
E. An important part of our QA/QC program is tracking open deficient audit findings and the accomplishment of their corrective actions. Achieving positive results from corrective actions reflects the commitment of managers to the program. Subsequent audits also reveal if repeat open deficient audit findings are occurring. Repeat deficient audit findings may be due to neglect or lack of funding.
For information on the content of this chapter, contact the Division of Engineering. For more information about this Web site, contact Krista Holloway of the Division of Policy and Directives Management.