Facility Compliance Status

UNITED STATES DEPARTMENT OF THE INTERIOR
BUREAU OF LAND MANAGEMENT
WASHINGTON, D.C. 20240
January 22, 2008

In Reply Refer To:
1112, 1703 (360) P
Ref. IM No. 2007-133

EMS TRANSMISSION 01/25/2008
Information Bulletin No. 2008-030

To: All Field Officials

From: Chief, Division of Business Resources

Subject: Facility Compliance Status

Compliance Assessment - Safety, Health, and the Environment (CASHE) status update responses were requested via Instruction Memorandum (IM) Washington Office (WO)
2007-133. The Division of Engineering and Environmental Services (WO-360) compiled the responses received from the field on the status of recommendations made during each organizational unit’s CASHE audit. This Information Bulletin informs field officials that compilation of the CASHE status updates is completed and has been sent to their State Offices.

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 the priority level/risk assessment code are included with the summary. These documents have been transmitted to the Associate State Directors, Center Directors (as appropriate), Deputy State Directors, State Office Hazardous Materials (HAZMAT) Program Leads, State Safety Managers, and State Engineers via email.

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

1. To 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) 2001-2007, the Division of Engineering and Environmental Services has dispersed approximately $6,500,000 of deferred maintenance funding to implement CASHE recommendations that had not already been identified for funding in the Bureau of Land Management’s (BLM) Deferred Maintenance and Capital Improvement 5-Year Plan. In FY 2008, $743,000 of CASHE Corrective Action funding has been committed to the field.2

2. To report on the BLM’s performance measure for facility compliance to the Department of the Interior. This goal calls for increasing the percentage of organizational units in “good safety, health, and environmental condition.” An IM to update the status of CASHE findings will be sent to the field in May 2008 with a due date of July 27, 2008, so the performance measure can be reported by the last week of September 2008, as required by the BLM.

In FY 2007, 87 percent of the BLM’s organizational units met the standard for “good safety, health, and environmental condition.” The performance measure goal for FY 2007 was to have 80 percent of the BLM’s organizational units rated in good safety, health, and environmental condition. Since FY 2005, an organizational unit is found to be 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 2007 performance exceeds FY 2006 performance, which was 83 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 2007 is the third year that an organizational unit 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 still be rated in "good" condition. In 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 Department’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. Nine States (Alaska, Colorado, Eastern States, Idaho, Montana, New Mexico, Oregon, Utah, and Wyoming) and the Washington Office met or exceeded the FY 2007 performance goal of 80 percent or more of their organizational units in good condition. The performance of Idaho and Montana is particularly outstanding. They reported zero incomplete findings for every organizational unit.

This improved performance trend is due to: (1) identification of a portion of deferred maintenance funding to implement CASHE recommendations; (2) conduction of regularly scheduled follow-up CASHE audits to verify performance; and (3) the annual issuance of this facility compliance progress report to all organizational units that summarizes their incomplete findings.

3

This is the seventh consecutive year for issuance of these facility compliance progress reports. The field should be proud of their long-term performance trend. The first year this report was compiled only 59 percent of organizational units were rated in good safety, health, and environmental condition compared with 87 percent in FY 2007. The field is also commended for their timely responses to the CASHE status update request.

Implementation of CASHE Recommendations: In accordance with IM WO 2007-133, Facility Compliance Management and Tracking of Compliance Assessment – Safety, Health and the Environment (CASHE) Findings, 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 any time. The CASHE Program Lead maintains a backlog of unfunded projects. The field is 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 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:
Ruth Welch Robert M. Williams
Division Chief Division of IRM Governance,WO-560
Business Resources

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