TE-12 EMS Fresno Territory.pdf

FEM-4.4.4 (1)

THIS DOCUMENT IS UNCONTROLLED WHEN IN HARD COPY FORMAT

Controlled documents are posted on the AWSS REFM common drive folder

Environmental Management System Plan

Fresno IRS Campus

(FIRSC)

5045 E Butler Fresno, CA 93727

All Conractor Pesonnel, including Sub-Contractors are subject to the policies and procedures of the Fresno IRS Campus’ EMS Program

Note: In Sept. 2010, FIRSC’s EMS Program will be reviewed for compliance and certification. This document is under review and is pending approval by the Territory Manager.

7/30/2010

Table of Contents

1.0 Scope

2.0 Policy

3.0 Key Elements of the EMS

3.1 Aspects and Impacts

3.2 Legal and Other Requirements

3.3 Environment, Safety, and Health Objectives, Targets, and Programs

3.4 Management of Change

3.5 Resources, Roles, Responsibility, and Authority

3.6 Competence, Training, and Awareness

3.7 Communications

3.8 EMS Documentation

3.9 Control of Documents

3.10 Operational Controls

3.11 Emergency Preparedness and Response

3.12 Monitoring and Measuring

3.13 Evaluation of Compliance

3.14 Nonconformance, Corrective and Preventive Actions

3.15 Records

3.16 Internal EMS Audit

3.17 Management Review

1.0 SCOPE OF THE EMS

The scope of this EMS includes the buildings and grounds within the fence line of the Fresno IRS Campus (FIRSC) located at 5045 E. Butler Ave., Fresno, CA 93727. The EMS covers all the environmental aspects of the facility under the control, management, or influence of IRS.

On-site but excluded from the scope is TIGTA and the Golden 1 Credit Union.

2.0 POLICY

The IRS Occupational Safety, Health and Environmental Compliance Policy Statement P-1-28 is endorsed by management and is communicated to all employees in this facility. The policy statement addresses the safety and health of employees, contractors, and the public, and the impact of IRS activities on the environment and the community are leading priorities of the IRS.

The policy is posted at http://www.irs.gov/foia/content/0,,id=132341,00.html and in the Internal Revenue Manual (IRM) 1.2.10.1.7 which is available to the public.

3.0 KEY ELEMENTS OF THE EMS

The FIRSC EMS consists of key elements that structure the management system. These elements stipulate requirements that must be met to effectively implement the EMS.

3.1 ASPECTS AND IMPACTS

The environmental, safety and health aspects of all FIRSC activities, products and services will be identified and assessed to determine which are considered significant to the FIRSC This information will be kept up-to-date by implementing ancillary procedures for management of change and new project review. Aspect information will be used in setting objectives and targets, identifying training needs of personnel whose work may have a significant impact on the environment, safety and health, and the establishment and maintenance of operational controls on processes that may have significant environment, safety and health aspects and impacts.

Reference ISO 14001 Standards (4.3.1)

Applicable Procedures, Forms, and Records

• FIRSC Aspect Identification & Significance Determination Procedure

• Aspect/Impact List

3.2 LEGAL AND OTHER REQUIREMENTS

The legal and other requirements that apply to the FIRSC activities, products, and services are a combination of local, federal and state statutes, federal Executive Orders, Treasury Directives and internal IRS policies and manuals (IRM). The Facility EMS Management http://www.irs.gov/irm/part1/ch02s04.html http://www.irs.gov/foia/content/0,,id=132341,00.html

Representative and EMS Team may receive additional information on legal and other requirements from time to time from Headquarters staff or as a result of peer interaction with other IRS Sites.

Legal and other requirements are listed on FIRSC Legal and Other Requirements Table. This will be reviewed at least annually by the EMS Team to ensure the most current federal, state, local, and other requirements are current and applicable. Any changes to legal and other requirements will be communicated to appropriate management staff and employees during the annual self-assessment process.

Reference ISO 14001 Standards (4.3.2)

Applicable Procedures, Forms, and Records FIRSC Legal and Other Requirements Table FIRSC Legal and Other Requirements Procedure FIRSC Aspects/Impacts List

3.3 ENVIRONMENT, SAFETY AND HEALTH OBJECTIVES, TARGETS AND

PROGRAMS

The EMS Team shall develop objectives and targets for approval by Top Management. These objectives and targets define:

• the performance objectives (investigate/study, control/maintain, or improve);

• the specific, quantified targets which define those performance objectives;

• the planned deadlines for the achievement of those targets; and

• consistent with the environment, safety and health policy, including continual improvement, commitment to prevent pollution and compliance with applicable legal requirements and other requirements.

Objectives and targets are developed considering significant environment, safety and health aspects, technological options and financial, operational and business plans, and the views of interested parties. Project managers are assigned responsibility for achieving set objectives and targets, by developing and implementing Environmental Management Plans.

Reference ISO 14001 Standards (4.3.3)

Applicable Procedures, Forms, and Records FIRSC Objectives, Targets and Environmental Management Plans Procedure FIRSC List of Objectives and Targets

3.4 MANAGEMENT OF CHANGE

The FIRSC is not a static facility and the EMS will be designed to accommodate the changes in infrastructure, processes, procedures, activities, products and services necessary to support mission achievement. Proactive processes will be used to clearly understand how emerging and planned changes potentially impact the environment, safety and health so good business decisions may be made regarding planning and implementing change. The EMS will be appropriately modified and improved due to the decisions made. The FIRSC will develop and implement a procedure to manage change and institute an ESH review program.

Requirements of the EMS will be communicated to all relevant contractors and vendors through the contracting process. The appropriate COTRs and sub-COTRs shall ensure that contractors understand requirements and implement appropriate operational controls. When new requirements are deemed appropriate they will be instituted within contracts as soon as practical, but no later than at the time of contract renewal. COTRs and sub-COTRs shall notify the Facility EMS Management Representative when contracts are to be developed so the EMS Team may participate in the process to ensure EMS requirements are appropriately covered.

The EMS Team and COTRs and/or sub-COTRs shall conduct a review of each contract relevant to the EMS annually at a minimum.

Reference ISO 14001 Standards (4.3.1)

Applicable Procedures, Forms, and Records

• FIRSC Aspect Identification & Significance Determination Procedure

3.5 RESOURCES, ROLES, RESPONSIBILITY AND AUTHORITY

EMS roles, responsibilities and authorities shall be defined, documented, and communicated at relevant functions and levels within the organization. This will be accomplished by including them in procedures and environment, safety and health plans.

Reference ISO 14001 Standards (4.4.1)

FIRSC EMS Resources, Roles, Responsibility, and Authority

3.6 COMPETENCE, TRAINING AND AWARENESS

The EMS Team will use the NO Training Matrix and the applicable legal and other requirements to identify training needs throughout the facility. All FIRSC personnel will receive EMS Awareness Training to ensure:

• Appropriate communication of the Occupational Safety, Health and Environmental Policy

• General awareness to the EMS and its purpose

• Knowledge of the significant environment, safety and health aspects of the facility.

• Knowledge of the objectives and targets set by the facility.

Reference ISO 14001 Standards (4.4.2)

FIRSC Competences, Training and Awareness Procedure

3.7 COMMUNICATION

• The FIRSC shall use established mechanisms for internal communication to ensure personnel and contractors receive appropriate information on the EMS.

Essential communication on the EMS shall be conducted by the Territory Manager (TM) and the Facility EMS Management Representative with the other components within the scope of the EMS through:

• TM participation in Heads of Office meetings

• TM and Facility EMS Management Representative participation in the FIRSC

Campus Coordination meetings.

o Participants in these meetings shall disseminate information received on the

EMS as appropriate for their organizations.

External communication relevant to the EMS that is received by anyone within FIRSC shall be referred to the W&I Office of Communications. This office shall be responsible for documenting such communication and then determining who is best to investigate and develop an appropriate response. All responses shall go through the W&I Office of Communications and records shall be retained. The exception to these requirements shall be the routine communication with local, state, and Federal regulators by the Facility EMS Management Representative on environment, safety and health legal requirements.

Reference ISO 14001 Standards (4.4.3)

Applicable Procedures, Forms, and Records FIRSC Communication Procedure FIRSC Log of Communications with External Stakeholders

3.8 ENVIRONMENTAL MANAGEMENT SYSTEM DOCUMENTATION

The EMS documentation shall include:

• The environment, safety and health policy

• Objectives and targets

• A description of the scope of the EMS

• A description of the main elements of the EMS and their interaction, and reference to related documents (EMS Plan)

• Documents, including records, required by appropriate IRS Policies or Treasury Directives;

• Documents, including records, determined by the IRS or this facility to be necessary to ensure the effective planning, operation and control of processes that relate to its significant environment, safety and health aspects.

The FIRSC documentation will be organized according to the document hierarchy shown below:

Level 1 Documents – Policy and Procedures The Occupational Health, Safety and Environmental Policy and the EMS management procedures.

Level 2 Documents – Standard Operating Procedures Standard operating procedures (SOP) – Procedures that are instituted to ensure compliance with legal and other requirements, and to implement operational controls.

Level 3 Documents – Other Support Documents Plans and contracts relevant to the identified environment, safety and health aspects, forms, objectives and targets, and applicable external documents that will ensure the effective planning, operation and control of processes.

Level 4 Documents – Records EMS records document what is done and verify that the EMS is working as intended.

The Facility EMS Management Representative shall maintain an up-to-date listing of the EMS documents using FIRSC Form Document List.

Reference ISO 14001 Standards (4.4.4)

Applicable Procedures, Forms, and Records FIRSC Form Document List FIRSC Document Control FIRSC Records Control

3.9 CONTROL OF DOCUMENTS

The creation of all EMS documentation will be controlled by ensuring appropriate approval of newly created documents and modified documents. Documents will be periodically reviewed to ensure that they are still applicable to operations. Document formats will include control features to ensure that obsolete documents are destroyed and that only current documents are used in managing the EMS. This procedure is meant to ensure that personnel have the most current and accurate instruction to conduct their job responsibilities.

Reference ISO 14001 Standards (4.4.5)

FIRSC Control of Documents

3.10 OPERATIONAL CONTROLS

Those activities needing operational control(s) will be identified by managers, supervisors, and contractors using the identified significant environment, safety and health aspects in FIRSC Aspects List. These activities, including maintenance activities, will be assessed to determine whether or not additional controls must be developed and implemented, and what type of controls are appropriate. If the absence of standard operating procedures (SOP) may cause deviation from the environment, safety and health policy commitments, objectives and targets, or there may be an increase in the environment, safety and health impact of the subject operation, then SOPs will be developed that include stipulated operating criteria. The Facility EMS Management Representative and the EMS Team shall ensure that all needed operational controls are identified, and that all necessary operational controls are implemented.

Reference ISO 14001 Standards (4.4.6)

Applicable Procedures, Forms, and Records

• FIRSC Operational Controls Procedure

• FIRSC Aspects List

3.11 EMERGENCY PREPAREDNESS AND RESPONSE

The results of environment, safety and health aspect assessment shall be used as a primary source to identify the potential accidents and emergency situations. The EMS Team shall be responsible for communicating the potential for accidents and emergency situations to appropriate parties identified as the owners of the emergency preparedness and response documents identified below. These procedures are included in the following plans:

• Occupant Emergency Plan (OEP) owned by Physical Security and Emergency

Preparedness Program Office

• Emergency Response Plan (ERP) owned by REFM

• Spill, Prevention, Countermeasure and Control Plan owned by REFM

• Incident Management Plan owned by the SCR managed by the Site Coordinator

Emergency preparedness and response plans shall be developed to prevent and mitigate the environmental impacts that may be associated with accidents and emergency situations. Plan Owners shall ensure that relevant plans are complete and up-to-date by conducting periodic reviews, testing plans, and improving plans as appropriate, particularly after events when plans are implemented in response to accidents and emergencies.

Reference ISO 14001 Standards (4.4.7) Applicable Procedures, Forms, and Records FIRSC Aspects Identification and Significance Determination Procedure Occupant Emergency Plan (OEP) Spill Prevention, Countermeasure and Control Plan (SPCC) Emergency Response Plan (ERP) Incident Management Plan (IMP)

3.12 MONITORING AND MEASUREMENT

FIRSC shall monitor and measure its key operations and activities that can have an impact on the environment, safety and health. Additional information to track environment, safety and health performance will be recorded as appropriate, including information on relevant operational controls, and conformance with environment, safety and health objectives and targets. COTRs will have a central responsibility to coordinate with the Facility EMS Management Representative on providing monitoring and measurement data from relevant contractor activities. Monitoring and measuring equipment shall be calibrated or verified to ensure accurate readings are being produced.

Reference ISO 14001 Standards (4.5.1)

FIRSC Monitoring and Measurement Procedure Various logs and reports

3.13 EVALUATION OF COMPLIANCE

The Facility will conduct various types of compliance inspections and self assessments. Every third year IRS HQ will perform a regulatory compliance audit.

Reference ISO 14001 Standards (4.5.1)

Applicable Procedures, Forms, and Records FIRSC Evaluation of Compliance Procedure FIRSC Environmental Compliance Self Assessment FIRSC Legal and Other Requirements Table

FIRSC Monitoring and Measurement

3.14 NONCONFORMANCE AND CORRECTIVE AND PREVENTIVE ACTION

When nonconformities with the EMS and noncompliance with legal and other requirements are identified, responsibility will be assigned for completion of root cause analysis, and development and implementation of corrective action and any appropriate preventive action.

Identification of nonconformity and noncompliance is everyone’s responsibility and the process will be open to all personnel. A problem solving approach will be pursued that includes an appropriate level of root cause analysis so repeat deficiencies will be eliminated.

Reference ISO 14001 Standards (4.5.3)

• FIRSC Nonconformity/Noncompliance Corrective Action and Preventive Action

3.15 RECORDS

EMS records consist of those records required by legal and other requirements, and those required to verify that the EMS is operating in conformance with the requirements of the ISO 14001 standard, and internal plans made by OIRSC Main, and IRS Policies and Treasury Directives.

The Facility EMS Management Representative shall maintain a list using FIRSC Records List that identifies specific records to be maintained by the Facility EMS Management Representative and a general list of record types to provide guidance to others who may be required to maintain EMS records, specifically FIRSC contractors.

The list shall identify the location, required retention times and disposal method, and the party responsible for maintaining the records. EMS records shall be managed so they are legible, identifiable to the process they record, traceable to the event they record, readily retrievable and protected against damage, deterioration and loss.

Persons/organizations designated in FIRSC Records List as responsible parties for maintenance of EMS records shall determine what records are necessary and maintain them as required above.

Reference ISO 14001 Standards (4.5.4)

Applicable Procedures, Forms, and Records FIRSC EMS Records List FIRSC Control of Records Procedure

3.16 INTERNAL ENVIRONMENTAL MANAGEMENT SYSTEM AUDIT

Management system audits will be conducted annually to determine whether or not the EMS conforms to planned arrangements for environment, safety and health management including the requirements of the ISO 14001 standard. Audits will conclude whether or not the EMS meets all requirements and has been effectively implemented and properly maintained.

Reference ISO 14001 Standards (4.5.5)

FIRSC Internal EMS Audits

3.17 MANAGEMENT REVIEW

Top Management shall review the FIRSC EMS to ensure its continuing suitability, adequacy and effectiveness. Reviews include assessing opportunities for improvement and the need for changes to the Environmental Management System including the local EMS policy and environment, safety and health objectives and targets.

Records of the management review shall be retained according to the requirements of the FIRSC Records List.

Reference ISO 14001 Standards (4.6)

Applicable Procedures, Forms, and Records FIRSC Management Review Procedure FIRSC Management Review Agenda FIRSC Records List

Document Title: Aspect/Impact Identification and Significance Ranking Document Control Number: FEM 4.3.1 (1) Responsible Organization: REFM Authorized by: REFM TM Document Owner: EMS Facilities Management Representative (EMR) Date: 05/4/2010

REV: 0

1.0 Purpose: To provide a method to identify the environmental, safety, and health (ESH) aspects and the associated impacts and to rank these impacts according to their degree of significance.

The results of the analysis will be used to develop objectives and targets to manage ESH impacts.

2.0 Scope: This procedure applies to all activities and processes the IRS has control over either directly or indirectly within the scope of the EMS at the FIRSC.

3.0 Responsibilities:

3.1 EMS Team: The EMS Team will identify the ESH aspects and impacts associated with the activities and process within the scope of the EMS and make recommendations to REFM Territory Manager on how to mitigate the negative impacts with the highest significance ranking. The EMS Team shall be responsible for identifying aspects and impacts of new or altered materials and processes through the EHS Review Program.

3.2 Contracting Officer Technical Representatives, Contracting Officers, Project Managers or other IRS personnel involved in initiating purchases of new materials, equipment or services and/or process changes shall ensure that changes are reviewed by the EMS Team.

3.3 Management: Management, including REFM Territory Manager, Building Manager, Logistics Chief, Real Estate Chief, and business Directors shall support the activities of the EMS Team by ensuring that there are sufficient resources to fulfill their function.

4.0 Identification of ESH Aspects and Impacts: Each process or activity performed in or at the behest of the IRS at the FIRSC will have one or more environmental, safety and/or health aspects. This procedure is used to identify aspects of various processes and activities that have significant environmental, safety, and/or health impacts.

4.1 A process, activity or service may have one or more of the following environmental, safety and/or health aspects:

a. Environmental Aspects

i. Air Emissions

ii. Wastewater

iii. Depletion of Natural Resources

iv. Cultural Resource Modification

v. Solid Waste

vi. Hazardous Waste

vii. Material/Energy Consumption

viii. Potential Uncontrolled Release to Air, Land or Water

b. Health and Safety Aspects

i. Chemical Exposure

ii. Uncontrolled Release of Energy

iii. Ergonomic Hazards

iv. Structural Hazard

v. Biological Exposure

vi. Mechanical Hazard

4.2 Each of the above aspects has concurrent impacts upon the environment and/or the health and safety of exposed people. On the Aspect/Impact worksheet (List 4.3.1 (2)), for each process or activity under analysis, list the appropriate aspects and the possible impacts that may result.

5.0 Determine the Significance Ranking of ESH Impacts: The significance of the identified impacts is ranked according to the expected frequency, severity, probability, and potential legal risk.

5.1 Determine the frequency of aspect or operation:

1 = continuous

0.8 = frequent

0.5 = occasional

0.2 = infrequent

5.2 Determine the severity of impact:

5 = high (potential to result in serious damage to the environment and/or human health and safety)

4 or 3 = medium (moderate damage to environment/human health and safety) 2 or 1 = low (little or no impact)

5.3 Determine the likelihood of impact:

5 = high probability 4 or 3 = medium probability 2 or 1 = low probability

5.4 Determine the legal risk of impact:

5 = high risk (notice of violation, permit violation, civil liability) 4 or 3 = medium (regulatory concerns, visibility) 2 or 1 – low risk

5.5 Calculate the Impact Significance Score:

Frequency x (Severity + Probability + Legal Risk) = Impact Significance

5.6 The result of the calculation will provide a score on a scale of <1 to 15 with 15 being an impact of the highest significance. The FIRSC considers a ranking of 6 or above to be significant. Aspects that have a ranking lower than 6 may also be identified as significant when they are closely associated with a significant aspect.

6.0 Records/Forms: FIRSC Aspects/ Impacts Listing 4.3.1 (1)

7.0 Related Documents

7.1 FIRSC Aspects/Impacts Listing 4.3.1 (1)

REVISION PURPOSE OF REVISION EFFECTIVE DATE

Document Title: Identification of Legal and Other Requirements Document Control Number: FEM 4.3.2 (1) Responsible Organization: REFM Authorized by: REFM TM Document Owner: EMS Management Representative (EMR)

1.0 Purpose: This procedure describes the methods for identifying legal and other requirements and ensuring that the FIRSC has the means to incorporate and disseminate, to the affected components, changes in those requirements. Applicable requirements will be identified in the Legal and Other Requirements Matrix.

2.0 Scope: This procedure applies to Federal and local laws, Executive Orders and Standards incorporated by policy or references that are relevant to the Environmental, Health and Safety (EHS) aspects of the FIRSC.

EHS laws and regulations, permits, executive orders and standards that govern the FIRSC have been identified in the Legal and Other Requirements List. Any new requirements that may be issued by federal or local government or changes to standards to which the FIRSC subscribes will be identified and reflected in the list.

3.0 Roles and Responsibilities: The FIRSC EMS Management Representative (EMR) has primary responsibility for ensuring the Legal and Other Requirements List is updated as needed.

The EMS Management Representative will stay abreast of changes in laws, regulations or standards that affect the conduct of their programs through reviewing, on a regular basis:

publications; internet resources; regulatory reference resources; newsletters; correspondence from local, state and federal regulatory agencies; and available databases. The EMS Management Representative will forward relevant information on these changes to the affected components. The EMS Management Representative will ensure the affected components have the appropriate interpretations and direction to effectively implement necessary changes.

Any FIRSC Management Representative, COTR and/or employee initiating modifications to processes, the facility, or the use of new chemicals must submit a request for review by the EMS Management Representative prior to implementing any such changes or purchasing new chemicals.

Managers and Supervisors are responsible for the timely implementation of any changes made necessary by changes in legal and other requirements.

4.0 Resources: Include, but are not limited to the following:

4.1 Regulations and Standards include:

a. 40 CFR regulations applicable to FIRSC;

b. 29 CFR regulations applicable to FIRSC;

c. ISO 14001 EMS Standard;

d. EO’s 12196, 13423, 13513, 13514; and

e. Best management practices for all the above

4.2 Federal Register.

4.3 Code of Federal Regulations.

4.4 www.ofee.gov; www.epa.gov; www.osha.gov ; www.nara.gov

5.0 Procedure

5.1 Identification of Environmental and Health and Safety Regulatory Requirements:

a. The EMS Management Representative will utilize the available regulatory reference resources to periodically and systematically review regulations and determine their applicability to the aspects of processes and operations at the FIRSC; and

b. Prior to the addition or modification of any processes, operations, or to the facility, regulatory requirements will be reviewed by the Management Representative. It is the responsibility of the person proposing the change to submit the change for review.

5.2 Interpretation of Legal and Other Requirements:

a. The EMS Management Representative, with assistance from the NO, will interpret regulatory, legal and other requirements in regard to aspects and potential impacts of new and modified processes and chemicals and make a determination of applicability;

b. The EMS Management Representative will forward these interpretations to affected components and provide guidance on the implementation of changes to meet these requirements; and

c. Components affected by changes in legal or other requirements will adjust their activities as necessary to remain compliant with all relevant requirements.

6.0 Related Documents:

Legal and Other Requirements List Significant Environmental Aspects & Impacts Listing

7.0 Document Revision History

Rev.

Purpose of Revision Eff. Date

Document Title: Objectives, Targets and EMPs Document Control Number: FEM 4.3.3 (1) Responsible Organization: REFM Authorized by: REFM TM Document Owner: EMS Management Representative (EMR) Date: 05/12/2010

1.0 Purpose: This procedure defines the method by which the FIRSC will establish and periodically review environmental, health and safety objectives and targets. It also establishes a method and criteria to develop Environmental Management Plans (EMP).

2.0 Scope: This procedure is to be used when setting objectives and targets for the FIRSC.

Objectives and targets are developed for all significant environmental, health and safety (EHS) aspects and additionally may be set for other elements of the EMS such as training, auditing, employee awareness etc. The objectives and targets extend to all levels and functions, whether facility wide or specific to individual operations of the FIRSC where applicable.

3.0 Roles and Responsibility: The primary responsibility for implementing this procedure lies with the FIRSC.

3.1 The EMS Management Representative will have primary responsibility for reviewing, approving and establishing objectives and targets recommended by individuals or groups who may submit proposed environmental and/or health and safety objectives and targets.

In the case of objectives and targets that require a major capital investment or those that would require cooperation among several organizational components, the EMS Management Representative will forward objectives, targets and EMPs to the appropriate members of executive management. The EMS Management Representative will have primary responsibility for developing and documenting the EMPs necessary to reach objectives and targets.

3.2 The Executive Management of the FIRSC will review EMPs that have been forwarded to them by the EMS Management Representative. Once an EMP has been approved to move forward management of affected components hold primary responsibility for ensuring the necessary resources are available for full implementation.

3.3 Facility personnel will be assigned as appropriate to carry out EMPs. The EMS

Management Representative in conjunction with Managers and Supervisors will identify employees with the necessary knowledge, skill and abilities to carry out EMPs and meet targets and objectives.

4.0 Procedure: Objectives and targets are met through the implementation of EMPs. The FIRSC will establish and maintain written objectives and targets for those aspects that are determined to be significant and have been identified as a potential opportunity for improvement. Other improvement opportunities that are not necessarily connected to significant aspects may be appropriate for the establishment of objectives and targets if they have the potential for improving environmental and/or health and safety performance or improve the effectiveness of the EMS.

4.1 Identifying Aspects for EHS Performance Improvement

a. The FIRSC Significant Aspect/Impact Listing and the Aspect/Impact Analysis records will serve as the primary guide for identifying opportunities for EHS improvement. Those aspects that are deemed significant will be screened and prioritized for the purposes of setting objectives and targets.

b. For each aspect deemed significant or otherwise selected for the development of objectives and targets a listing will be developed. The list will include the resources needed for achieving the objectives and targets, the dates of expected completion, the individuals responsible for each action of the EMP and the relevant financial implications.

4.2 Screening Criteria for Establishing Objectives and Targets

a. Objectives and targets must be achievable, financially viable and measurable.

b. Objectives and targets must be consistent with commitments in the IRS Policy P-

1-28 and consideration will be given to:

i. The views of interested parties

ii. The prevention of pollution

iii. The reduction of risk to employee health and safety

iv. Compliance with applicable regulations and other requirements to which the IRS is subject

v. Continual improvement

vi. The technological options

vii. Financial, operational and organizational requirements

5.0 EMP Records shall be created and maintained by the individual responsible for EMP implementation. Upon completion of the EMP records shall be forwarded to the EMS Management Representative.

6.0 Related Documents;

6.1 Significant Aspect and Impact Listing

6.2 EMP/Targets/Objectives Listing

REVISION PURPOSE OF REVISION

EFFECTIVE

DATE

common drive folder

Document Title: Document Title: Resources, Roles, Responsibility and Authority Resources, Roles, Responsibility and Authority Document Control Number: FEM 4.4.1 (1) Responsible Organization: REFM Authorized by: REFM TM Document Owner: EMS Facilities Management Representative (EMR)

1.0 Purpose: This document establishes the roles, responsibilities and authority to establish, implement, maintain and improve the FIRSC Environmental Management System (EMS). It also defines the means by which management will provide the resources necessary to implement and maintain the EMS. This will be accomplished by including them in procedures and environmental plans.

2.0 Scope: This document applies to all personnel throughout the various levels of the FIRSC, as well as contractors working on-site at the FIRSC.

3.0 Roles and Responsibilities: The following two charts outline the FIRSC EMS organizational structure, and the roles and responsibilities which are established for the purpose of implementing and maintaining an

EMS.

FIRSC

EMS Organizational Structure

Top Management REFM Territory Manager (TM) Chief, Building Delegation Chief, Logistics Management

Facilities Environmental Management

Representative (EMR)

FIRSC

Site Coordinator

Field Director BU Heads of Office

EMS Team

FIRSC

Employees

EMS Roles and Responsibilities

EMS Responsibilities Title of Responsible Person(s) Top Management

Establish overall definition of EMS and provide resources:

• Human Resources

• Training

• Specialty Services

• Financial Resources

• Technical and Informational Services

Monitor overall EMS performance at planned intervals Review reports of environmental assessments, audits, and tracking Convey and coordinate EMS with FIRSC Site Coordinator, Field Director, BU Heads of Office

Fresno REFM Territory Manager (TM) Chief, Building Delegation Chief, Logistics

EMS Facilities Management Representative (EMR) Ensure that EMS requirements are:

• Established

• Implemented

• Maintained in accordance with ISO 14001

Report to Top Management on the performance of EMS for review Make recommendations for continual improvement Document and Records Control and Management Ensure that changes in regulations and the campus environmental effects are monitored and the system modified to meet these changes

Appointed by Fresno REFM TM

• EMS Facilities Management

Representative (EMR) / Environmental Coordinator

EMS Team Support EMR in the functional development, implementation, and maintenance of the EMS Work with EMR to identify environmental aspects, evaluate significance, and identify critical processes, training needs, and necessary operational controls In coordination with the EMR, develop environmental objectives and targets and any needed EMS procedures for approval by the Fresno

REFM TM

Overall responsibility for compliance with legal and other requirements Meet as often as required – but no less than monthly

Appointed by Fresno REFM TM Logistics Management

• Senior Safety Officer/EMR Building Delegation

• Janitorial & Landscaping

COTR

FIRSC Employees

• Practice pollution prevention, reducing resource consumption and recycling.

• Support the green purchase guidelines when requesting goods and services.

• Identifying opportunities for continual improvement contributing to the achievement of objectives and targets relevant to his/her job.

• Identifying opportunities to share information with coworkers regarding the FIRSC environmental policy and EMS requirements.

• Recognizing the importance of performing their duties consistent with defied procedures.

• Ensuring compliance with all environmental regulations and requirements.

Document Title: Competence, Training and Awareness Document Control Number: FEM 4.4.2 (1) Responsible Organization: REFM Authorized by: REFM TM Document Owner: EMS Management Representative (EMR)

1.0 Purpose:

This procedure describes the methods used at the FIRSC to ensure employees receive ESH and EMS related training.

It is the intent of the FIRSC to ensure that employees and contractors working on its behalf are aware of the FIRSC EMS and the policies and procedures that are applicable to individuals assigned to carry out tasks. It is also the intent of the FIRSC that employees and contractors are competent to perform tasks and activities that have the potential to cause significant environmental, health and safety (ESH) impacts.

2.0 Scope:

This procedure applies to all ESH and EMS related training required by federal or local regulations, and the IRS’s EMS. Contractors working on-site are required to participate in applicable EMS related training, as well as, provide their employees with the applicable regulatory EHS training.

3.0 Roles and Responsibilities:

3.1 Senior Management is responsible for ensuring that resources, including time for employees to complete required training, are available to implement this procedure.

3.2 The EMS Management Representative has primary responsibility for EMS related training records consolidated in ELMS for FIRSC employees. Individual Program Managers within the FIRSC have primary responsibility for identifying; planning, coordinating and recording EHS related training required by FIRSC policies or regulations.

3.3 Managers and supervisors must ensure that new hires take the ESH Mandatory Briefing as part of their training. They must review ESH informational documents and fliers from the N.O. Safety and Environmental Staff and the FIRSC EMR/Safety Officer during employee meetings and ensure that employees comply with any requirements. Specialized training, such as powered industrial truck certification training, will be provided by the business units.

3.4 Managers and supervisors must ensure that existing employees complete any ESH refresher training as required. They must review with employees any ESH informational documents and fliers developed by N.O. Safety and Environmental and the FIRSC EMR/ Safety Officer. Specialized training, such as powered industrial truck certification training, will be provided by the business units.

3.5 Managers and Supervisors are responsible for ensuring personnel have adequate time and resources to complete required EMS/EHS training, as well as, ensuring all employees receive relevant EMS communications. They are also responsible for ensuring employees are competent, based on training and experience, to carry out tasks that have the potential for a significant impact on the environment and/or health and safety of other employees.

3.6 COTRs are responsible for coordinating with Contract Project Managers to ensure that on-site contract employees receive applicable EMS training. Contract Project Managers are responsible for ensuring their employees are competent, based on training and experience, to carry out tasks that have the potential to impact the environment and/or the health and safety of others. The Contract Project Managers are also responsible for training their employees on relevant EHS training and maintaining records.

3.7 Employees are responsible for completing assigned training, and informing their supervisors of any difficulties encountered that prevent the timely completion of training.

4.0 Procedure:

4.1 New Employee Initial Training: The new employee will complete all EHS/EMS training identified as necessary by the Management Representative prior to reporting to their job.

The new employee must take the ESH Mandatory Briefing as part of their initial training.

They must review ESH informational documents and fliers from the N.O. Safety and Environmental Staff and the FIRSC EMR/Safety Officer and comply with any requirements.

They must also complete any specialized training if required for their job duties.

Annual Training: The NO ESH Staff maintains a comprehensive training matrix that identifies training requirements based on job title and functional area. The matrix identifies training required by regulations, policy, best management practice and EMS.

Contractors are identified by the closest job title and functional area.

a. Annually, the Management Representative will coordinate with Supervisors and

Managers to generate a training schedule for all EHS and EMS related training.

b. Attendance rosters of each live training event will be kept along with the training materials, curriculum, and instructor Management Representative.

4.2 Refresher training: Refresher training includes training that is required on a periodic basis, as well as, training deemed necessary as part of a corrective action or through routine evaluation of the adequacy of employee training.

4.3 Significant Environmental Aspect Training: Training specific to controlling the FIRSC significant environmental aspects will be identified for work area and job title. The training may take the following forms:

a. EMS awareness events

b. EMS communications (facility wide e-mails and the EMS Bulletin)

c. Training targeted to a specific significant aspect for groups of employees most likely to have the potential for an EHS impact

d. Training conducted by Supervisors and Managers on specific tasks related to significant EHS aspects

e. Training specific to procedures and other operational controls implemented to reduce and/or control EHS impacts of the FIRSC activities.

4.4 Evaluation of Training: The FIRSC uses an integrated approach to evaluating the effectiveness of EHS/EMS training and the competence of employees carrying out tasks associated with significant EHS aspects. Methods include:

a. Recorded assessments embedded in the On-Line Training curriculum;

b. Written assessments or practical assessments after a live training;

c. Regular EHS Inspections;

d. Observations of supervisors and managers; and

e. Observations by employees

5.0 Related Documents:

FIRSC Training Needs Matrix, FEF 4.4.2.1 HazCom Program and Training Plan, ESH 4.4.6.2

6.0 Document Revision History

Rev.

Purpose of Revision Eff. Date

Document Title: Communications Document Control Number: FEM 4.4.3 (1) Responsible Organization: REFM Authorized by: REFM TM Document Owner: EMS Management Representative (EMR)

1.0 Purpose: This procedure governs internal and external communications, regarding the FIRSC

Environmental Management System (EMS).

2.0 Scope: This procedure applies to all components, employees and contractors within the FIRSC.

It addresses internal communications regarding FIRSC EMS activities between the various levels and functions in the FIRSC organization. This procedure also addresses external communication regarding FIRSC environmental aspects and EMS activities including communications with other IRS facilities, the Department of Treasury, other federal, state and local government agencies, contractors, customers, visitors, other organizations and interested parties and the general public.

3.0 Policy: As a federal facility, the FIRSC is required and has an obligation to share certain information on its activities and operations including those related to environmental, health and safety externally to various parties that may include but is not limited to the Department of Treasury, other federal agencies, the federal executive, U.S. Congress, state and local government agencies, associations, customers, and the general public. It is the FIRSC policy to respond, as soon a practicable, to mandated external inquires regarding environmental and/or health and safety matters at the facility. It is also the FIRSC policy to respond as soon as practical, to external inquires where response is not required but which are deemed by the FIRSC as reasonable and appropriate. The FIRSC may also initiate external communications to share information on its environmental aspects and EMS activities as a federal facility committed to sound environmental stewardship for the public good.

4.0 Roles and Responsibilities:

4.1 The Fresno REFM Territory Manager shall be responsible for approval, or designating an approving official, for all external EHS and/or EMS external communications.

4.2 The FIRSC EMS Management Representative has primary responsibility for coordinating external EMS communications per this procedure.

a. The EMS Management Representative will consult with the Management Representative on appropriate non-routine external communications related to the FIRSC EMS. The EMS Management Representative will have primary responsibility for coordinating the responses to written or verbal environmental/health and safety related inquiries, complaints, or other communications from parties external to the FIRSC. This includes inquiries from the news media and members of Congress. The EMS Management Representative will also have responsibility for coordinating any proactive external communications that might be undertaken for the FIRSC.

b. The EMS Management Representative shall ensure records are retained of all external EMS communications.

c. The EMS Management Representative will provide the Management

Representative with copies of all relevant incoming and outgoing EMS correspondence.

4.3 Executive Management will review relevant external communications received, at management review meetings, and make recommendations on actions relative to these communications.

4.4 The EMS Management Representative has primary responsibility for developing and disseminating internal communications on EMS related matters to the FIRSC employees and contractors and developing internal responses to written or verbal environmental, health and safety related inquiries, complaints, or other communications from parties internal to the Fresno Campus.

4.5 The EMS Management Representative shall also be responsible for routine external communication with regulatory bodies and counterparts in other Federal agencies.

4.6 FIRSC Managers and Supervisors are responsible for conducting day-to-day communication with their employees, answering employee questions, ensuring EMS information and news are posted or otherwise disseminated, collecting and forwarding employee requests and information to the Management Representative.

4.7 COTRs are responsible for communicating applicable policies and requirements of the

FIRSC EMS to both on-site and off-site contractors and ensuring those contractors adhere to the policies and requirements.

5.0 Procedure:

5.1 Internal Communications:

a. The IRS Policy and EMS documentation and procedures, including the FIRSC significant aspects shall reside in the Safety & Environmental Office. The policy shall be included in materials provided to new employees and to contractors.

b. Internal communications about matters that are relevant to the EMS may occur through several existing forums, including, but not limited to:

• Bulletin board postings;

• Period town hall meetings;

• Blast e-mails;

• Executive memoranda;

• Safety meetings; and

• IRS publications.

c. All FIRSC employees and contractors are encouraged to openly communicate environmental issues of concern, incidents or practices that may result in adverse environmental impacts, or opportunities for improving practices or reducing impacts. Communications should be directed to immediate supervisors, or in their absence, to the Management Representative.

d. Information on relevant elements and requirements of the FIRSC EMS are provided to contractors and vendors through written documentation such as scopes of work and other contract documents, project initiation meetings and other verbal communications.

e. Procedures for internal and external communications during emergency conditions are outlined in the FIRSC emergency plans, which supersede this procedure in the event of an emergency.

5.2 External Communications: All inquiries, communications or complaints from external parties concerning environmental/health and safety matters will be referred to the EMS Management Representative at the FIRSC.

a. Non-routine external communications (verbal or written) that are received by the

FIRSC will be forwarded to the EMS Management Representative and will be recorded in the EMS Communications file.

b. The EMS Management Representative, in coordination with the Public Affairs

Specialist, W & I Communications, will determine the appropriate response to the external communication.

c. Procedures for external communications during emergency conditions are outlined in the FIRSC emergency plans, which supersede this procedure in the event of an emergency.

5.3 Review: During the management review of the FIRSC EMS, Executive Management shall consider the appropriate level of public disclosure of its significant environmental aspects and will record the decision as part of the documentation of the management review.

6.0 Related Documents: Log of Communications with External Stakeholders, FEF 4.4.3.1

7.0 Revisions

REVISION PURPOSE OF REVISION

EFFECTIVE

DATE

Document Title: Environmental Mgmt. System Documentation Document Control Number: FEM 4.4.4 (1) Responsible Organization: REFM Authorized by: REFM TM Document Owner: EMS Management Representative (EMR) Date: 05/20/2010

1. Purpose and Scope The purpose of this document is to provide a cohesive outline of the FIRSC Environmental Management System Documentation. The EMR maintains the FIRSC Document Index (FEF 4.4.4.1) and FIRSC Records List (FEF-4.5.4.1). EMS documentation shall include:

• Environmental, Safety & Health Policy Statement,

• Objectives and targets;

• Scope of the Environmental Management System;

• Main elements of the Environmental Management System and their interaction, and reference to related documents;

• Documents, including records, required by appropriate IRS Policies or Treasury Directives;

• Documents, including records, determined by the IRS or this facility to be necessary to ensure the effective planning, operation and control of processes that relate to its significant environmental aspects

The FIRSC documentation will be organized according to the following levels:

Level 1 Documents – Policy and Procedures The Occupational Health, Safety and Environmental Policy and the EMS management procedures.

Level 2 Documents – Standard Operating Procedures Standard operating procedures (SOP) – Procedures that are instituted to ensure compliance with legal and other requirements, and to implement operational controls.

Level 3 Documents – Other Support Documents Plans and contracts relevant to the identified environment, safety and health aspects, forms, objectives and targets, and applicable external documents that will ensure the effective planning, operation and control of processes.

Level 4 Documents – Records EMS records document what is done and verify that the EMS is working as intended.

The EMR is responsible for ensuring that the document hierarchy is maintained when developing and improving EMS documentation.