Facility Compliance Management and Tracking of Compliance Assessment Safety, Health and the Environment (CASHE) Findings

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

June 11, 2019

In Reply Refer To:
1112, 1703 (850) P    

EMS TRANSMISSION 06/14/2019
Instruction Memorandum No. 2019-036
Expires: 9/30/2020

To:                   Assistant Directors, State Directors, and Center Directors

From:               Assistant Director, Business, Fiscal and Information Resources Management

Subject:           Facility Compliance Management and Tracking of Compliance Assessment – Safety, Health and the Environment (CASHE) Findings           DD: 07/31/2019  

Program Area:  Facility Compliance and Safety.

Purpose:  The purpose of this Instruction Memorandum (IM) is to request status updates from the Washington Offices, State Offices, and National Centers on the implementation status of recommendations and corrective actions resulting from their CASHE audits.  This information will be used to identify projects for Deferred Maintenance CASHE Corrective Action funding in Fiscal Year (FY) 2020.  The Bureau of Land Management (BLM) will use this data to measure facility compliance, evaluate risk related to facility compliance, and make decisions related to future funding, policy, and training needs. 

Administrative or Mission Related:  Mission.

Policy/Action:  Updating Status of CASHE Recommendations/Corrective Actions

Organizational units with traditional, Radio Infrastructure (RI), or Sustainability Inspection (SI) CASHE audits between October 1993 and June 2019 are asked to update the status of those recommendations/corrective actions.  Spreadsheets for capturing the updates will be emailed separately by State Office Safety Managers, Hazard Management and Resource Restoration (HMRR) Program Leads, Radio Program Leads, or State Engineers. The points of contact for each of the programs are provided in Attachment 1.

Each organizational unit is to submit the completed CASHE status spreadsheet to the CASHE contractor with a copy to their appropriate points of contact.  The status of recommendations/corrective actions for traditional CASHE audits completed during the period April 2019 through June 2019 will be the field’s response from the reports prepared for those audits. 

Please note that the instructions (to be sent with the spreadsheets on which the updated status of CASHE findings is to be reported by the field) clarify that a CASHE Corrective Action may be considered complete or reduced to a lower-priority finding under one of the following conditions: 

(1)  A properly completed Hazard Abatement Plan is prepared and approved in accordance with BLM Handbook 1112-1, Safety and Health Management, and appropriate interim hazard mitigation measures have been implemented. (Note:  If an office or center indicates a finding is completed because a Hazard Abatement Plan has been prepared, a copy of the Plan must be submitted with the completed CASHE status update spreadsheet.  Failure to provide a properly completed Plan will result in those findings being listed as incomplete.  The instructions for completion of the CASHE status update spreadsheet provide additional details.); or

(2)  The corrective action is under design or is programmed for construction during the current or next FY.

Implementation of CASHE Recommendations/Corrective Actions

Consistent with available budget resources and other programmatic concerns, organizational units are to implement CASHE recommendations/corrective actions or request funding for implementation within one (1) year of their audit. 

Timeframe: Please return the spreadsheets, with the updated status of CASHE findings provided by each organizational unit, to the CASHE contractor, Aarcher Incorporated, by July 31, 2019. Updated spreadsheets should be emailed to bwisniewski@aarcherinc.com. 

Organizational units that do not respond by July 31, 2019, will  have their corrective actions shown as incomplete, which will negatively affect the FY 2019 CASHE facility compliance performance measure.  Non-responsive units will also be ineligible for deferred maintenance funding for CASHE Corrective Actions.

Budget Impact: None.

Background: In FY 2018, 97 percent of the BLM’s organizational units were rated in good safety, health, and environmental condition.  This performance was based on information received in response to IM No. 2018-065, which asked the field to update the status of incomplete CASHE findings. The performance goal for FY 2019 is to have 98 percent of the BLM organizational units rated in good safety, health, and environmental condition. 

Criteria for Annual CASHE Performance Rating:  FY 2019 is the third year SI CASHE audits are included in the determination of whether or not an organizational unit is rated in good safety, health, and environmental condition.  The BLM’s Assessment Management Branch (WO 854) and the National Operations Center, Architecture and Engineering Branch (OC 670) have been performing SI CASHE audits since 2013. An organizational unit is rated in “good safety, health, and environmental condition” in FY 2019 if it has zero incomplete high-priority CASHE and RI CASHE findings and up to four or five incomplete high-priority SI CASHE findings depending on when the report was written.  The number of incomplete high-priority SI CASHE findings that an organizational unit may have and still be rated in good condition will be reduced by one each subsequent year until it is reduced to zero. See table below for a breakout of the number of allowable incomplete high-priority SI CASHE findings to be rated in good safety, health, and environmental condition.

Manual/ Handbook Sections Affected: None.

Coordination: The BLM Safety Office (WO-740), the Division of Environmental Quality and Protection (WO 280), the Division of Business Resources (WO 850), and the Office of Fire and Aviation Policy (WO-400) have coordinated in the development of this IM.

Contact:  If you have questions, please contact Ken Morin, Branch of Architecture and Engineering Services (OC-670), National Operations Center, at (303) 236-6418.

Signed by:                                                                   Authenticated by:
Ann DeBlasi                                                               Robert M. Williams
Acting, Assistant Director                                          Division of Business Resources,WO-850
Business, Fiscal and Information
  Resources Management

1 Attachment
   1 -State/Center/WO Points of Contact for the FY 2019 CASHE Status Update (1 p)