U.S. DEPARTMENT OF THE INTERIORBUREAU OF LAND MANAGEMENT
EMS TRANSMISSION 06/11/2007
Instruction Memorandum No. 2007-133
To: ADs, SDs and CDs,
From: Assistant Director, Minerals, Realty and Resource Protection
Subject: Facility Compliance Management and Tracking of Compliance Assessment – Safety, Health and the Environment (CASHE) Findings DD: 07/31/2007
Program Areas: Facility Compliance and Safety
Purpose: The purpose of this Instruction Memorandum (IM) is to ask all Washington, State and Field Offices and National Centers to provide an update on the implementation status of recommendations or other corrective actions related to findings from their CASHE audits. This information will be used to identify projects for Deferred Maintenance CASHE Corrective Action funding in Fiscal Year (FY) 2008. Last fiscal year’s status update resulted in $743,000 of CASHE Corrective Action projects being programmed for FY 2008 funding. In addition, the Bureau of Land Management (BLM) will make use of this data to:
§ manage and minimize risk related to facility compliance; and
§ identify future funding, policy, and training needs.
Accurate information about the facility compliance is necessary for the BLM to achieve its strategic planning goal to “Protect Lives, Resources, and Property.”
Policy/Action: Updating Status of CASHE Recommendations/Corrective Actions: This year’s annual CASHE status update will cover the period from October 1993 through June 2007. Organizational units that have had a CASHE audit between October 1993 and March 7, 2007, are asked to update the status of those recommendations/corrective actions on the spreadsheet that will be transmitted separately to every Field Office Safety Officer and Hazardous Material (HAZMAT) Coordinator by their State Office Safety Manager or HAZMAT Program Lead. The spreadsheets and instructions for updating them will be transmitted to each State Office Safety Manager and HAZMAT Program Lead, the Washington Office, and each National Center by June 8, 2007, via email. Each organizational unit is to submit the completed CASHE status update spreadsheet to the CASHE contractor with a copy to their State Office Safety Manager
and HAZMAT Program Lead. The status of recommendations/corrective actions for audits completed during the period March 8, 2007, through June 29, 2007, will be obtained via the comments received from those organizational units on the CASHE reports prepared for those audits.
Please note that the instructions for completion of the FY 2007 CASHE status update clarify that a CASHE Corrective Action may be considered complete under one of the following conditions:
(1) If a properly completed Hazard Abatement Plan is prepared and approved in accordance with BLM Manual 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 abatement plan must be submitted with the completed CASHE status update spreadsheet. Failure to provide a properly completed abatement 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) If the corrective action is under design or is programmed for construction during the current or next fiscal year.
Implementation of CASHE Recommendations/Corrective Actions: Consistent with available budget resources and other programmatic concerns, organizational units are to implement CASHE recommendations/corrective actions and/or request funding for implementation within one year of the audit.
Timeframe: Please return the updated spreadsheets by July 31, 2007. This due date is necessary to allow time for the status updates to be completed and provided to the Department of the Interior (DOI) by the first week of October 2007.
Please note: Organizational units that do not respond by July 31, 2007, will:
§ have their corrective actions shown as incomplete,
§ negatively affect the FY 2007 performance for the CASHE Performance Measure, and
§ be ineligible for deferred maintenance funding for CASHE corrective actions.
Background: In FY 2006, 83 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 Washington Office IM No. 2006-164, which asked the field to update the status of incomplete CASHE findings. The field is complemented on the 100 percent response rate to last year’s IM.
Organizational units will be considered in good condition if they do not have any incomplete corrective actions related to high priority CASHE findings. This good condition standard of zero incomplete high priority findings has been phased in since FY 2000 when an organizational unit could have five incomplete high priority findings and be in good condition. The standard was decreased by one each year until it reached zero for FY 2005 and subsequent years. 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 goal, “we believe that the number of high priority uncorrected findings should be zero before a facility is classified as being in “good” condition.”
The performance measurement data specification that defines high priority CASHE findings and describes how the data will be used is located at:
The performance goal for FY 2007 is that 80 percent of the BLM organizational units be rated in good safety, health, and environmental condition.
Budget Impact: None.
Manual/Handbook Sections Affected: None.
Coordination: The BLM Safety Office (WO-740).
Contact: Ken Morin, Division of Engineering and Environmental Services (WO-360) at (303) 236-6418.