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November 9, 2010

In Reply Refer To:
1112, 1703 (850) P
Ref. IM No. 2010-139
Information Bulletin No. 2011-009
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) 2010-139. The National Operations Center has compiled the responses received from the field on the status of recommendations made during each organizational unit’s CASHE and Radio Infrastructure (RI) CASHE audit.  This Information Bulletin informs field officials that the compilation of all 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, State Engineers, and State Radio Program Leads 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 other program funding for their implementation. This will be done in close coordination with State and Field Offices’ engineering, HAZMAT, radio, and safety staffs. From fiscal year (FY) 2001-2011, the engineering program has dispersed approximately $9,350,000 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 2012 between $600,000 and $900,000 of CASHE Corrective Action funding will be budgeted for distribution to the field. 

2.      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 all CASHE findings will be sent to the field in May 2011 with a due date of July 30, 2011, so that the performance measure can be reported by the last week of September 2012, as required by the BLM. 

In FY 2010, 111 of 120 or 92.5 percent of the BLM’s organizational units met the standard for “good safety, health, and environmental condition.” The performance measure goal for FY 2010 was to have 93 percent of the BLM’s organizational units rated in good safety, health, and environmental condition. To be rated in good condition in FY 2010 an organizational unit must have all its high priority CASHE findings completed and may have up to four incomplete high priority RI CASHE findings. High priority CASHE and RI CASHE findings are those findings with priority levels IA or IB, or risk assessment codes of 1 or 2. 
The FY 2010 performance is the same as the FY 2009 performance. This year’s performance is excellent, but could have been even better. Four of the nine organizational units not rated in good condition have a single incomplete high priority environmental CASHE finding that was written several years ago, but little to no progress has been made towards addressing the recommended corrective actions.    
FY 2010 is the second year incomplete high priority RI CASHE findings are counted when determining if an organizational unit is rated in good condition. The field was informed that RI CASHE findings would count when determining if an organizational unit is rated in good condition by WO IM 2008-145. 
In FY 2011 an organizational unit must have all its high priority traditional CASHE findings completed and have three or less incomplete high priority RI CASHE findings to be rated in good condition. The number of incomplete high priority RI CASHE findings an organizational unit may have and be rated in good condition will continue to be reduced by one each subsequent FY until FY 2014 when an organization unit must have all of its high priority CASHE and RI CASHE findings completed to be rated in good condition.  

FY 2010 is the sixth year an organizational unit must have all its high priority CASHE findings completed to be rated in good safety, health, and environmental condition.   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. Seven states (Arizona, Colorado, Eastern States, Idaho, New Mexico, Utah, and Wyoming) and the WO have 100 percent of their organizational units rated in good condition.  

The BLM’s continued excellent performance is due to: (1) identification of a portion of deferred                                                                                                                                                                                                                                      maintenance funding to implement CASHE recommendations; (2) conducting 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 tenth 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 92 percent in FY 2010. The field is also commended for their timely responses to the CASHE status update request.
Implementation of CASHE Recommendations: In accordance with WO IM 2010-139, organizational units are expected to complete or request funding for completion of all high priority CASHE and RI 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:
Corey Grant                                                                 Robert M. Williams
Division Chief                                                               Division of IRM Governance,WO-560
Business Resources
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Last updated: 11-29-2010