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June 30, 2008

In Reply Refer To:

1292 (850/410) P

Instruction Memorandum No. 2008-145
Expires: 09/30/2009
To:             Assistant Directors, State Directors, and Center Directors
From:         Assistant Director, Business and Fiscal Resources
Subject:     Compliance Assessment – Safety, Health, and the Environment (CASHE) Audits of Radio Sites                                                                               DD: 09/30/2009
Program Area: Radio, Facility Compliance, and Safety
Purpose: The purpose of this Instruction Memorandum (IM) is to inform the field that all Bureau of Land Management (BLM) owned and leased radio sites will be inspected by the CASHE Program. This will be accomplished in two phases. The first phase is performance of baseline audits. This will be accomplished using contractor support specializing in condition assessments of radio sites. These baseline CASHE audits are scheduled to be completed by the end of Fiscal Year (FY) 2013. 
The second phase consists of followup audits. These will be incorporated into the traditional CASHE audits. A representative sample of each BLM organizational unit’s radio sites will be inspected during its CASHE audit to verify whether corrective actions identified in the baseline audits were completed. These followup CASHE audits are currently performed on a 4-year cycle. 
Policy/Action: Field Responsibilities in Support of CASHE Radio Site Audits:   The field has the following responsibilities in regard to the CASHE Program:
  • Coordinate with National Radio Communication Division (WO-410) in the identification of radio sites to be inspected and in the development of an itinerary for the audit;
  • Provide access to each site and its records (e.g., radio frequency authorizations);
  • Participate in the audit;
  • Field management participation in exit presentation of audit findings;
  • Review and comment on CASHE audit reports;
  • Implement CASHE corrective actions within 1 year of receipt of the final report or request funding to implement those recommendations if required funding exceeds local funding availability; and
  • Annually report on the status of each CASHE finding by July 31. 
Implementation of CASHE Recommendations/Corrective ActionsConsistent 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. 
Annual Rating of CASHE Performance: Completion of CASHE radio findings will be included as criteria for determining if an organizational unit is rated in “good safety, health, and environmental condition.” Good safety, health, and environmental condition is defined as:
  • In FY 2009, five or less incomplete high priority CASHE radio findings and zero traditional CASHE findings.
  • In FY 2010, four or less incomplete high priority CASHE radio findings and zero traditional CASHE findings.
  • In FY 2011, three or less incomplete high priority CASHE radio findings and zero traditional CASHE findings.
  • In FY 2012, two or less incomplete high priority CASHE radio findings and zero traditional CASHE findings.
  • In FY 2013, one or less incomplete high priority CASHE radio findings and zero traditional CASHE findings.
  • In FY 2014 and subsequent years, zero high priority CASHE findings of any type. 
High priority CASHE findings are prioritized using different priority rating systems. Environmental high priority CASHE findings are as follows:
  • Class IA (significant and immediate threat to human health or the environment); and
  • Class IB (major threat to human health or the environment). 
Safety-related CASHE findings are prioritized using Risk Assessment Codes (RAC). Safety high priority CASHE findings are defined as follows:
  • RAC 1 (catastrophic); and
  • RAC 2 (serious). 
Making the standard for “good” condition more stringent is consistent with a recommendation in the Department of the Interior’s (DOI) Inspector General (IG) 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.”
Organizational Unit – Organizational unit is defined as the Washington Office, State Office, Field/District Office, and National Centers. The term includes all remote facilities that
administratively report to a field/district office (e.g., fire station, recreation site, wild horse and burro facility, field station, air tanker base, visitor center, national monument and radio site.)
Timeframe: Approximately 10 weeks of baseline CASHE radio audits will be performed each FY until they are completed in FY 2013. The intent is to have at least 1 week of baseline CASHE radio audits performed in each BLM State (except Eastern States) every year until the baseline audits are completed. Followup audits of radio sites will be incorporated into the existing traditional CASHE schedule. A representative sample of an organizational unit’s radio sites will be inspected during their followup CASHE audits. Those representative sites will include at least one mountain top site.  
Background: The DOI IG audit report “U.S. Department of the Interior, Radio Communication Program,” issued January 2007, report number C-IN-MOA-0007-2005, states, “The results of this audit demonstrate that radio communications in DOI are unsafe and unreliable because: The poorly maintained infrastructure poses physical safety hazards, and does not support reliable communications.” The WO-410 recognizes the States have made many improvements since the IG report was drafted to upgrade the condition of their radio sites. 
The DOI and the BLM have committed to performing comprehensive condition assessments at all owned and leased radio sites as recommended in the IG report. The scope of work for the CASHE radio site condition assessments was coordinated with all the State Office Radio Program Leads during monthly conference calls with WO-410. The DOI issued draft policy in May 2008 that when issued in final will require all bureaus to perform independent comprehensive audits of all owned and leased radio sites. 
The CASHE Program has been selected as the vehicle to perform condition assessments at radio sites because of its success in improving the safety, health, and environmental condition of BLM facilities and its acceptance by the field. The purpose of performing CASHE radio condition assessments are to (1) establish baseline conditions by auditing all radio sites against a consistent standard; (2) provide the field with the information necessary to develop estimates for upgrading their telecommunications sites so they may be budgeted for and implemented; (3) incorporate lessons learned from the radio condition assessments into the CASHE Program to facilitate their periodic independent inspection during followup CASHE audits; and (4) track and report on the completion of corrective actions at radio sites using the existing Annual CASHE Status Update process.   
Budget Impact: The CASHE radio site baseline audits for FY 2008 have already been funded. Funding for approximately two-thirds of the planned audits for FY 2009 is tentatively programmed. Central funding for the remainder of FY 2009 and beyond baseline audits is being pursued. Followup CASHE audits will be incorporated into the traditional CASHE audits that are already being performed by the National Operations Center and funded by the Division of Business Resources (WO-850). 
Each organizational unit will be responsible for funding any travel for their personnel who participate in CASHE audits.
Manual/Handbook Sections Affected: None. 
Coordination: Division of Business Resources (WO-850) and Safety Office (WO-740).
Contact: If you have any questions concerning the contents of this IM, please contact Annette Box at (208) 387-5822 or Jason Becker at (208) 387-5840, Division of National Radio Communications, or Ken Morin, 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

Last updated: 10-21-2009