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 6, 2008

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

EMS TRANSMISSION 06/11/2008
Instruction Memorandum No. 2008-134
Expires:  09/30/2009

To:             ADs, SDs and CDs

From:         Assistant Director, Business and Fiscal Resources

Subject:     Facility Compliance Management and Tracking of Compliance Assessment – Safety, Health and the Environment (CASHE) Findings, DD:  07/31/2008

Program Area:  Facility Compliance and Safety

Purpose:  The purpose of this Instruction Memorandum (IM) is to ask the Washington Office, State 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) 2010.  Last FY’s status update resulted in over $1.2 million 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:

• measure the facility compliance performance of the BLM’s organizational units;
• 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 2008.  Organizational units that have had a CASHE audit between October 1993 and March 5, 2008, are asked to update the status of those recommendations/corrective actions         on the spreadsheet that will be transmitted separately to every 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 6, 2008, 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 6, 2008, through June 27, 2008, 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 2008 CASHE status update clarify that, in addition to addressing the recommendations, 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 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)  If 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 and/or request funding for implementation within 1 year of their audit. 

Timeframe:  Please return the updated spreadsheets by July 31, 2008.  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 October 3, 2008. 

Please note that organizational units that do not respond by July 31, 2008, will:

• have their corrective actions shown as incomplete;
• negatively affect the FY 2008 CASHE facility compliance performance measure; and
• be ineligible for deferred maintenance funding for CASHE Corrective Actions.

Background:  In FY 2007, 87 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. 2007-133, which asked the Field to update the status of incomplete CASHE findings.  The Field is complimented on the 100 percent response rate to last year’s request. 

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 Office of 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 goal for FY 2008 is that 81 percent of the BLM organizational units be rated in good safety, health, and environmental condition. The CASHE Program’s tracking of the status of corrective actions and the funding provided annually to facilitate their implementation are why the DOI’s Office of Inspector General report “Health and Safety Concerns at Department of the Interior Facilities,” dated March 2008, suggests the CASHE Program “be looked at as a possible best practice for the Department.”

Budget Impact:  None.

Manual/Handbook Sections Affected:  None.

Coordination:  The BLM Safety Office (WO-740).

Contact:  Ken Morin, Branch of Architecture and Engineering Services (OC-510), National Operations Center, at (303) 236-6418.

Signed by:                                                                   Authenticated by:

Michael A. Ferguson                                                  Robert M. Williams

Assistant Director                                                       Division of IRM Governance,WO-560

Business and Fiscal Resources