Facility Compliance Status

UNITED STATES DEPARTMENT OF THE INTERIOR
BUREAU OF LAND MANAGEMENT
WASHINGTON, D.C. 20240
http://www.blm.gov

November 15, 2006

In Reply Refer To:
1112, 1703 (360) P
Ref. IM No. 2006-164

EMS TRANSMISSION 12/18/2007
Information Bulletin No. 2007-021

To: All Field Officials

From: Assistant Director, Minerals, Realty and Resource Protection

Subject: Facility Compliance Status

Compliance Assessment - Safety, Health, and the Environment (CASHE) status update responses were requested by Instruction Memorandum (IM) WO 2006-164. The Division of Engineering and Environmental Services (WO-360) has compiled the responses received from the field on the status of recommendations made during each organizational unit’s CASHE audit. This Information Bulletin provides field officials with the response compilation.

The CASHE status updates have been summarized by State to show the number of incomplete findings broken out by their priority level or risk assessment code for each organizational unit. Separate tables that describe each organizational unit’s incomplete findings along with its priority level/risk assessment code are included with the summary. These documents have already been transmitted to the Associate State Directors, Center Directors (as appropriate), Deputy State Directors, State Office Hazardous Materials (HAZMAT) Program Leads, and State Safety Managers via e-mail.

The CASHE status update has and will continue to be used to:

1. Identify CASHE recommendations that are eligible for deferred maintenance funding and program funding for their implementation. This will be done in close coordination with State and Field Offices’ engineering, HAZMAT, and safety staffs. From Fiscal_Year (FY) 2001 - 2006, the Division of Engineering and Environmental Services has dispersed approximately $5,600,000 of deferred maintenance funding to implement CASHE recommendations that had not already been identified for funding in BLM’s Deferred Maintenance and Capital Improvement 5-Year Plan. In FY 2007, $900,000 of CASHE Corrective Action funding has been committed to the field.

2. Report BLM’s performance measure for facility compliance to the Department of the Interior (DOI). This goal calls for increasing the percentage of organizational units in “good safety, health, and environmental condition.” An Instruction Memorandum to update the status of CASHE findings will be sent to the field in May 2007 with a due date of July 27, 2007, so that the performance measure can be reported by the last week of September 2007 as required by the BLM.

In FY 2006, 83 percent of BLM organizational units met the standard for “good safety, health, and environmental condition.” The performance measure goal for FY 2006 was to have 79 percent in good safety, health, and environmental condition. Since FY 2005, an organizational unit is in good condition if it has completed all of its high priority CASHE findings. High priority CASHE findings are those findings with priority levels IA or IB, or risk assessment codes of 1 or 2.

The FY 2006 performance exceeds FY 2005’s which was 78 percent in good condition. The improved performance is attributed to the field proactively requesting CASHE Corrective Action funding and their preparation of Hazard Abatement Plans. FY 2006 was the second year the field must have all its high priority findings completed to be rated in good safety, health, and environmental condition. Phasing in of this zero tolerance standard for incomplete high priority findings began in FY 2000 when an organizational unit could have five incomplete high priority findings and be rated in "good" condition. Each fiscal year since FY 2000 the good condition standard has been reduced by one.

Making the standard for “good condition” more stringent is consistent with a recommendation in the DOI’s Inspector General Report Improvements Needed In Developing and Reporting on GPRA Goals and Measures dated September 2002. This report stated the following related to the CASHE performance measure, “we believe that the number of high priority uncorrected findings should be zero before a facility is classified as being in “good” condition.”

Attachment 1 is a table showing the number of organizational units in each State and the Washington Office rated in good safety, health, and environmental condition. Eight States (Colorado, Idaho, Montana, Nevada, New Mexico, Oregon, Utah, and Wyoming) and the Washington Office exceeded the FY 2006 performance goal of 79 percent or more of their organizational units in good condition.

The BLM’s long-term goal is to increase the percentage of organizational units in good condition by 1 percent a year over the previous year’s result. Improvements in performance are expected as a result of: (1) identification of a portion of Deferred Maintenance funding to implement CASHE recommendations; and (2) the annual issuance of a Facility Compliance Progress Report to all organizational units that summarizes their incomplete findings.

This is the sixth consecutive year for issuance of these facility compliance progress reports. The Field Offices should be proud of their long-term performance trend. In the first year only 59 percent of organizational units were rated in good safety, health, and environmental condition compared with 83 percent in FY 2006. The Field Offices are also commended for their timely responses to the CASHE status update request.

Implementation of CASHE Recommendations: In accordance with IM WO 2006-164, organizational units are expected to complete or request funding for completion of all high priority CASHE recommendations within one-year of their CASHE audit. Requests for CASHE Corrective Action funding can be made anytime. A backlog of unfunded projects is maintained by WO-360. Field offices are reminded that requests for CASHE Corrective Action funding should be made by the end of February. This is necessary to allow the projects to be coordinated with the State Engineers and ensure that the corrective actions are included in the next fiscal year’s Planning Target Allocation that is sent to the States in April.

Questions on the CASHE status update or CASHE Corrective Action funding should be directed to Ken Morin, CASHE Program Lead at (303) 236-6418.

Signed by:
Authenticated by:
Ted A. Murphy
Robert M. Williams
Acting, Assistant Director
Division of IRM Governance,WO-560
Minerals, Realty and Resource Protection

1 Attachment
1 - Number of Organizational Units in Good Safety, Health, and Environmental Condition (1 p)