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June 22, 2009
In Reply Refer To:
1112, 1703 (850) P
Instruction Memorandum No.  2009-150
Expires: 09/30/2010
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: 07/31/2009
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) 2011. The FY 2008 status update resulted in over $400,000 of CASHE Corrective Action projects being programmed for FY 2009 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
The FY 2009 annual CASHE status update will cover the period from October 1993 through June 2009. Organizational units that have had a CASHE audit between October 1993 and March 2009, 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 were transmitted to each State Office Safety Manager, HAZMAT Program Lead, Radio Program Lead, the Washington Office, and National Centers on May 29, 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 April 2009, through June 2009, 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 2009 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 one year of their audit. 
Timeframe:  Please return the updated spreadsheets by July 31, 2009. 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 2, 2009. 
Please note that organizational units that do not respond by July 31, 2009, will:  have their corrective actions shown as incomplete; negatively affect the FY 2009 CASHE facility compliance performance measure; and be ineligible for deferred maintenance funding for CASHE Corrective Actions.
Background: In FY 2008, 89 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. 2008-134, 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.
Criteria for Annual CASHE Performance Rating: FY 2009 is the first year that findings from CASHE Radio Infrastructure (RI) audits are included in the determination of whether or not an
organizational unit is rated in good safety, health, and environmental condition. The BLM’s National Radio Communication Division (WO-410) and the Business Resources Division (WO-850) have been performing CASHE RI audits since the beginning of FY 2008. The criteria for determining if an organizational unit is rated in “good safety, health, and environmental condition” is defined as:
          In FY 2009 five or less incomplete high priority CASHE RI findings and zero traditional CASHE findings.
          In FY 2010 four or less incomplete high priority CASHE RI findings and zero traditional CASHE findings.
          In FY 2011 three or less incomplete high priority CASHE RI findings and zero traditional CASHE findings.
          In FY 2012 two or less incomplete high priority CASHE RI findings and zero traditional CASHE findings.
          In FY 2013 one or less incomplete high priority CASHE RI findings and zero traditional CASHE findings.
          In FY 2014 and subsequent years zero high priority CASHE findings of any type.
The phasing in of a zero-tolerance standard for incomplete high priority CASHE RI findings is consistent with the approach used with traditional CASHE findings. This good condition standard of zero incomplete traditional high priority findings was been phased in since FY 2000 when an organizational unit could have five incomplete traditional 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 2009 is that 82 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) and the Office Fire and Aviation Policy (WO-400).
Contact:  Ken Morin, Branch of Architecture and Engineering Services (OC-670), National Operations Center, at (303) 236-6418.
Signed by:                                                                    Authenticated by:
Laura Ceperley                                                            Robert M. Williams
Acting, Assistant Director                                             Division of IRM Governance,WO-560
Business and Fiscal Resources

Last updated: 10-20-2009