Green Environmental Managment System Memo No. SAFE-11-34.pdf

VETERANS AFFAIRS PALO ALTO HEALTH CARE SYSTEM

3801 Miranda Avenue Palo Alto, CA 94304

Effective Date: July 30, 2008 Issue Date: July 30, 2011

HEALTH CARE SYSTEM MEMORANDUM No. SAFE-11-34

SUBJECT: GREEN ENVIRONMENTAL MANAGEMENT SYSTEM (GEMS)

1. SUMMARY: Health Care System Memorandum No. SAFE-08-34, Green Environmental Management System (GEMS), dated July 30, 2008, is rescinded. Changes have been made.

2. PURPOSE: To improve environmental performance by embracing and emphasizing pollution prevention principles and ensuring compliance with Federal, State, County, and City environmental regulations.

3. POLICY: It is the policy of the Veterans Affairs Palo Alto Health Care System (VAPAHCS) to implement proactive programs that can decrease generation of waste to comply with applicable environmental and worker safety regulations while continuing to provide high quality health care to our veterans.

4. PROCEDURES:

a. Pollution prevention is the primary method to achieve and maintain environmental compliance at VAPAHCS. Pollution prevention is also the primary method to reduce waste generated, encourage recycling, and order “green” products. Programs will be established in coordination with Service Chiefs to establish goals and strategic actions to ensure continuous improvement in the environmental programs.

b. VAPAHCS is committed to preventing unlawful discharges to the storm drain and sanitary sewer systems. VAPAHCS is also committed to reducing the use of toxic chemicals to the extent feasible. Service Chiefs are encouraged to review their processes to prevent unlawful discharges to the storm and sanitary sewer systems, reduce the use of toxic chemicals and substitute “green” products whenever possible to reduce the generation of waste. The goal is to reduce pollution, which impacts the environment. Effecitve facility management and good acquisition and procurement practices can assist with these issues.

c. Action plans will be developed for any environmental deficiencies identified during environmental rounds, by the VISN 21 Occupational Safety and Health (OSH) Program Manager, during the Annual Workplace Evaluation (AWE), and by inspections conducted by Federal, State, County, or City agencies.

d. Documentation of environmental aspects and impacts is managed by the GEMS

Subcommittee. Environmental policies and procedures will be made available to all employees on the local network drive through the Environment of Care Committee (EOCC) and will comply with Federal, State, County, and City regulations. This memorandum will be made available to the public upon request.

e. Service Chiefs or committee members will be trained in the provisions of the GEMS and in the Greening of the Government Executive Orders.

f. The GEMS Coorrdinators shall report their activities on a quarterly basis their activities and submit an annual assessment to the EOCC.

g. Employee suggestions for pollution prevention initiatives are strongly encouraged by reporting to the GEMS Subcommittee. Employees can submit their suggestions via email to the GEMS Coordinator.

h. The Palo Alto GEMS Coordinator is the GEMS Subcommittee Chair.

i. Membership of the GEMS Subcommittee is as follows:

Associate Chief of Staff (ACOS), Nursing Service or Designee ACOS, Research and Development or Designee Chief, Logistics Management Service or Designee Chief, Engineering Service or Designee Chief, Environmental Management Service or Designee Chief, Office of Information and Technology (OI&T) or Designee Chief, Pathology and Laboratory Medicine Service or Designee Chief, Pharmacy Service or Designee Chief, Radiology Service or Designee Chief, Nutrition and Food Services or Designee Emergency Management Coordinator Facility Industrial Hygienist Facility Safety Representative GEMS Coordinator, Menlo Park GEMS Coordinator, Livermore Infection Control Practitioner American Federation of Government Employees (AFGE) Union Representative

j. Attendance at meetings is mandatory for committee members. If a Service Chief designates a representative, the designation must be submitted in writing to the Chair. A list of current members by name and title will be published in the minutes of the GEMS Subcommittee.

5. RESPONSIBILITIES:

a. The GEMS Subcommittee:

(1) Reports activities to the EOCC on the 2nd month of each quarter.

(2) Develops organizational goals and objectives.

(3) Identifies environmental liabilities and risks.

(4) Identifies aspects and impacts in setting goals, objectives and targets using a system approach.

(5) Conducts an annual facility GEMS self-assessment and provides recommendations and findings to the EOCC. Findings from the assessment will be used to establish goals and objectives, performance monitors and program planning initiatives.

(6) Will meet on a monthly basis.

b. The GEMS Coordinator:

(1) Ensures compliance with environmental regulations.

(2) Provides technical knowledge and facilitates the development and implementation of environmental policies.

(3) Provides awareness training to all levels of management, committee members and employees.

(4) Facilitates annual compliance audits.

c. Service Chiefs:

(1) Conduct self assessments to improve environmental performance in their respective service and incorporate evaluations of environmental activities into their decision making process.

(2) Establish specific pollution prevention and waste minimization initiatives as pertinent for their respective service.

(3) Use source reduction, reuse and recycle materials when possible, and use selective procurement of hazardous substances and other pollutants in the purchasing process.

(4) Reward employees for exceptional environmental performance.

(5) Develop, review and update procedures for processes within their service that have possible environmental aspects and impacts.

(6) Continually reinforce to each employee the VA mission to minimize environmental and human health effects while maintaining quality patient care and reducing waste management costs as a key responsibility for each employee.

d. Logistics Management Service is responsible to develop, implement and monitor an affirmative procurement program for environmentally preferable and recycled content products.

e. The Contracting Officer’s Technical Representative (COTR) or Resident Engineer from the Office of Construction and Facilities Management will be responsible for ensuring contractors comply with environmental specifications and requirements during all phases of construction.

f. All employees must perform their functions consistent with regulatory requirements, agency environmental policies and agency mission.

g. Service Safety Coordinators / Service Compliance Officers are responsible for additional oversight in their services.

6. REFERENCES:

a. Pollution Prevention Act of 1990.

b. Resource Conservation and Recovery Act of 1976.

c. Executive Order (EO) 13423, Strengthening Federal Environmental, Energy, and

Transportation Management, dated January 26, 2007.

d. EO 13514, Federal Leadership in Environmental, Energy, and Economic

Performance, dated October 8, 2009.

e. VHA Directive 2001-036, Pollution Prevention P2 Program.

f. VHA Directive 0052, Affirmative Procurement, Recycling, and Waste/Pollution

Prevention Programs.

g. Health Care System Memorandum No. SAFE-09-12, Hazardous Materials

Management Program.

h. Health Care System Memorandum No. SAFE-09-09, Hazardous Waste

Management Program.

i. Health Care System Memorandum No. SAFE-09-10, Environment of Care/Safety

Management Program.

7. RESCISSION DATE: July 31, 2014.

8. RESPONSIBLE OFFICIAL: Chief, Safety and Emergency Management.

Elizabeth Joyce Freeman