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November 3, 2008
In Reply Refer To:
1112, 1703 (850) P
Ref. IM No. 2008-134
Information Bulletin No. 2009-015
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 Washington Office (WO) Instruction Memorandum (IM) 2008-134. The National Operations Center has compiled the responses received from the field on the status of recommendations made during each organizational unit’s CASHE audit. This Information Bulletin (IB) 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 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, State Safety Managers, and State Engineers via email.
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) 2001-2008, the engineering program has dispersed approximately $7,700,000 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 2009, $619,000 of CASHE Corrective Action funding has been budgeted for distribution to the field. 
  2. Report on the 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 IM to update the status of CASHE findings will be sent to the field in May 2009 with a due date of July 31, 2009, so the performance measure can be reported by the last week of September 2008, as required by the BLM. 
In FY 2008, 89 percent of the BLM’s organizational units met the standard for “good safety, health, and environmental condition.” The performance measure goal for FY 2008 was to have 81 percent of the BLM’s organizational units rated 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 2008 performance exceeds FY 2007 performance, which was 87 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. Fiscal Year 2008 is the fourth year 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 be rated in "good" condition. The good condition standard has been reduced by one each FY since FY 2000.
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.” This is also consistent with the Department Inspector General Report Health and Safety Concerns at Department of Interior’s Facilities dated March 26, 2008. The Office of the Inspector General recommended “DOI develop and implement a Department-wide action plan with milestones to eliminate significant health and safety deficiencies”, and lauded the BLM CASHE program as a best practice for addressing facilities related health and safety deficiencies.
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 (Arizona, Colorado, Eastern States, Idaho, Montana, Nevada, New Mexico, Utah, and Wyoming) and the Washington Office met or exceeded the FY 2008 performance goal of 81 percent or more of their organizational units in good condition. Six states (Colorado, Eastern States, Idaho, Nevada, New Mexico, and Wyoming) and the Washington Office have 100 percent of their organizational units rated in good condition. 
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.
This is the eighth 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 89 percent in FY 2008. The field is also commended for their timely responses to the CASHE status update request.
Implementation of CASHE Recommendations: In accordance with IM WO 2008-134, 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 the CASHE Program Lead. 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 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:
Ruth Welch                                                                Robert M. Williams
Division Chief                                                             Division of IRM Governance,WO-560
Business Resources
1 Attachment

Last updated: 10-21-2009