Department of the Interior
Departmental Manual
Effective Date: 9/8/97
Series: Environmental Quality Programs
Part 515: Environmental Management
Chapter 2: Environmental Auditing
Originating Office: Office of Environmental Policy and Compliance
515 DM 2
2.1 Purpose. This chapter provides Departmental policy, responsibilities, and functions regarding environmental auditing as a means to assure compliance with applicable Federal, State, and local environmental requirements that affect Departmental lands, facilities, operations and the uses thereof.
2.2 Scope. The responsibilities and requirements for the use of environmental auditing as specified in this chapter shall apply, where applicable, to all Departmental lands, facilities, and operations. Departmental lands and facilities are defined as any Departmental site or area, including all agency lands contiguous to the site or area, other appurtenances and improvements on lands including, but not limited to, all buildings, structures, installations, equipment, pipeline (including any pipe into a sewer or publicly owned treatment works), well, pit, pond, lagoon, impoundment, ditch, landfill, and storage unit.
2.3 References. In terms of compliance with environmental requirements for the Department, the following statutes, Executive Orders, and Departmental Manual Chapters are referenced and include but are not limited to: The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), 42 U.S.C. § 9601 et seq; Clean Air Act, 42 U.S.C. § 7401-7671q, as amended; Clean Water Act, 33 U.S.C. § 1251 et seq, as amended; Hazardous Materials Transportation Act, 49 U.S.C. § 1801-1812; Oil Pollution Act, 33 U.S.C. § 2701-2761; Atomic Energy Act, 42 U.S.C. § 2011 et seq; Hazardous Waste Operations and Emergency Response and Hazard Communication requirements under the Occupational Safety and Health Act, 29 U.S.C. § 651 et seq; Pollution Prevention Act, 42 U.S.C. § 13101 et seq; Resource Conservation and Recovery Act (RCRA), 42 U.S.C. § 6901 et seq; Safe Drinking Water Act, 42 U.S.C. § 300f - 300j-26; Toxic Substances Control Act, 42 U.S.C. § 2601 et seq; Emergency Planning and Community Right-To-Know Act, 42 U.S.C. § 1101 et seq; Federal Compliance with Pollution Standards, Executive Order 12088; Superfund Implementation, Executive Order 12580; Federal Acquisition, Recycling and Waste Prevention, Executive Order 12873; Federal Compliance With Right-to-Know Laws and Pollution Prevention Requirements, Executive Order 12856; Occupational Safety and Health Programs for Federal Employees, Executive Order
2196; Amendment to Executive Order 12580, Executive Order 13016; Comprehensive Waste Management, 518 DM 1; Compliance with Waste Management Requirements, 518 DM 2; and Real Property Pre-Acquisition Environmental Site Assessments, 602 DM 2.
2.4 Policy. It is Departmental policy that each bureau and office shall develop, implement, and document an environmental auditing program. Environmental auditing programs shall be conducted in order to:
A. Assure compliance with applicable Federal, State, and local environmental requirements.
B. Promote sound environmental practices.
C. Monitor environmental compliance of the user's activities (e.g., contractors, concessionaires, etc.).
D. Identify and assign environmental compliance responsibility.
2.5 Program Criteria. A documented environmental auditing program must include the following: (1) periodic review of operations and development of a schedule for periodic audits; (2) a protocol for environmental auditing procedures; (3) verification of timely and effective actions to address environmental audit findings; and (4) a mechanism for reporting environmental auditing program activities. In addition to the above program criteria, each environmental auditing program must include the following:
A. Environmental Auditing Protocol. An environmental auditing protocol is a plan that systematically documents how and when an environmental audit will be conducted. In general, an environmental auditing protocol should include: (i) a description of the responsibilities of the auditor, (ii) identification of the audited entity and other users, (iii) schedules, (iv) expectations for site visit activities, (v) auditor obligations regarding disclosure and release reporting, and (vi) measures to address confidentiality issues with respect to the audit in accordance with applicable laws, regulations and government policy. Environmental auditing protocols may take a number of different formats. At a minimum, however, environmental auditing protocols should address the following areas: air pollution; water pollution; solid waste management; hazardous materials management; spill control; hazardous substance release response; hazard communication; emergency planning and community right-to-know; aboveground and underground storage tank management; wastewater management; drinking water management; oil pollution control; asbestos containing materials; management of polychlorinated biphenyls (PCBs); pesticide management; and pollution prevention activities. Bureaus and offices may include additional areas within their environmental protocols to support specific mission requirements.
B. Qualifications of Environmental Auditing Personnel and Training. Bureaus and offices shall establish qualifications and training requirements for environmental auditors.
C. Baseline Environmental Audits. All bureaus and offices shall conduct baseline environmental audits within five years of the issuance of this Departmental Manual Chapter. The baseline environmental audit team leader shall be independent from the facility being audited as defined in the bureau and office environmental auditing program.
D. Environmental Auditing Findings and Corrective Actions. All environmental auditing findings shall be documented in accordance with bureau and office environmental auditing programs. Any conditions identified in an audit finding which may pose an imminent and substantial endangerment to the public health or welfare or to the environment must be addressed immediately. Conditions identified in audit findings requiring response in accordance with applicable environmental legal requirements should be addressed in a timely manner.
2.6 Responsibilities.
A. Office of the Solicitor. The Office of the Solicitor is responsible for providing legal review and guidance in implementing and complying with 515 DM 2.
B. Assistant Secretary - Policy, Management and Budget. The Assistant Secretary - Policy, Management and Budget, through the Office of Environmental Policy and Compliance, is responsible for policy and oversight of Departmental compliance with 515 DM 2.
C. Assistant Secretaries. Assistant Secretaries are responsible for ensuring adequate program support in terms of resources and budget for the development and implementation of the environmental auditing programs.
D. Office of Environmental Policy and Compliance. The Office of Environmental Policy and Compliance is responsible for oversight, assisting, and coordinating policy guidance and instructions to implement 515 DM 2.
E. Heads of Departmental Bureaus and Offices. Heads of Departmental bureaus and offices having responsibility for environmental management operations and programs under their jurisdiction will ensure that adequate resources and funding are available for the development and implementation of the environmental auditing programs.
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