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Implementation of Recommendations and Prevention of Future Noncompliance

  1. CASHE and Safety Management Module
  2. CASHE Process
  3. Statues of the Program
  4. Typical Findings
  5. Implementation of Recommendations and
    Prevention of Future Noncompliance 
  6. Compliance Areas
  7. Audit Schedule
The CASHE process has been designed to facilitate prompt correction of noncompliance identified during an assessment, to prevent the recurrence of noncompliance, and to protect human health and the environment. This is accomplished in several ways:
  • Including personnel responsible for the area being assessed in the assessment team and discussing the findings and suggested corrective actions directly with them (i.e., fire station manager participates with the team while assessing the fire station). Their participation facilitates them buying into the assessment process and implementation of recommendations made as a result of the CASHE visit.

  • Providing on the spot training to field personnel during a CASHE audit on how they can improve their operations and on the specific regulations that apply to their facilities.

  • The comprehensive scope of the CASHE process helps to ensure BLM Field Offices are complying with the regulation or standard that is most protective of human health and the environment. The CASHE process includes compliance with OSHA, DOT, State, local, and nationally recognized standards such as NFPA, in addition to EPA regulations. As a result EPA's regulatory exemptions that allow facilities to avoid being subject to a particular regulation are generally not applicable.

    As an example, the vast majority of BLM facilities do not have a single fuel tank with a capacity greater then 660 gallons or total storage capacity greater than 1,320 gallons. Therefore, the secondary containment provisions of 40 CFR 112, Spill Prevention Control and Countermeasure regulations are not applicable. However, OSHA and NFPA regulations require secondary containment regardless of volume stored. EPA and State only regulate drinking water systems that serve at least 25 people, therefore over half the Bureau's water systems at recreation sites and at all of its fire stations and other remote facilities are not regulated. However, OSHA regulations apply to all places of employment and those regulations require that potable water be provided for drinking and other uses. There are many other examples of EPA regulatory exemptions related to personnel training, drinking water, sampling, or hazardous material/waste storage and handling that aren't provided for in OSHA, DOT, UFC, State and local regulations. The comprehensive scope of the CASHE process helps to ensure that BLM Field Offices go beyond compliance with EPA regulations.

  • Greening of the government and environmental stewardship initiatives (e.g., Executive Orders 13423 and OMB Environmental Stewardship Scorecard) are being incorporated in the CASHE process to assist the field in understanding their role and actions related to purchase of environmentally preferable products and services, energy and water conservation, and environmental sustainability.

  • Identifying root causes of violations and making recommendations to establish, modify, or eliminate policies or practices that caused the violations to occur.

    The identification of root causes has lead to the issuance of new Bureau policy and development of Bureau specific training. Training on the operation and sampling of the BLM’s drinking water systems and procurement of environmentally preferable products and services has been developed. Contact the CASHE Program Lead if you are interested in this training.

  • The CASHE review process encourages Field Offices to begin to plan for the implementation of CASHE recommendations immediately while the momentum from the CASHE visit is still fresh. This results in the issuance of a final report that also serves as a corrective action plan.

    The field is asked to assign a point of contact for CASHE finding and provide the current status of each recommendation with their comments on the Draft Final CASHE Report that is issued at the end of each of the field visit. The final report incorporates that information, making the report a corrective action plan that can be used by field managers to track the statue of the corrective actions.

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