Root Cause EPAS Program Overhaul November 2017 UNCLASSIFIED

Root Cause EPAS Program Overhaul November 2017 UNCLASSIFIED / FOUO Leadership. Energy. Execution. 1

Welcome: EPAS & Root Causes • Purpose ‒ Environmental Management Systems ‒ Root Causes ‒ EPAS & Root Causes UNCLASSIFIED / FOUO Leadership. Energy. Execution. 2

EMS Overview UNCLASSIFIED / FOUO Leadership. Energy. Execution. 3

Environmental Management System (EMS) • EMS is the organizational structure, responsibilities, practices, procedures, processes and resources for implementing and maintaining environmental management • Plan, Do, Check, Act - a model for continual improvement • ISO (International Organization for Standardization) 14001 is the best-known EMS standard in the world UNCLASSIFIED / FOUO Leadership. Energy. Execution. 4

What is an EMS? • An EMS is the part of an organization’s overall management system that integrates environmental concerns and issues in the organization’s management processes. • An EMS addresses organizational structure, planning activities, responsibilities, practices, procedures, processes, and resources for developing, implementing, achieving, reviewing, and maintaining environmental policy. • An EMS enables an organization of any size or type to control the environmental impact of its activities, products, or services, allowing it to not only achieve and maintain compliance with current environmental requirements, but to recognize and proactively manage future issues that might impact mission sustainability. • Many EMS elements of an EMS are already in place. – By definition, it is not possible to have an environmental program without some parts of an EMS. UNCLASSIFIED / FOUO Leadership. Energy. Execution. 5

EMS Elements SUPPORT & OPERATION • Resources • Competence • Awareness • Communication • Documented Information • Operation Planning & Control • Emergency Preparedness & Response PLANNING • Risks & Opportunities • Environmental Aspects • Compliance Obligations • Objectives & Plans LEADERSHIP • Leadership & Commitment • Environmental Policy • Roles, Responsibilities & Authority ACT • UNCLASSIFIED / FOUO IMPROVEMENT Nonconformity & Corrective Action • Continual Improvement Leadership. Energy. Execution. DO PERFORMANCE EVALUATION • Monitoring, Measurement, Analysis & Evaluation • Evaluation of Compliance • Internal Audit • Management Review CHECK 6

Root Causes UNCLASSIFIED / FOUO Leadership. Energy. Execution. 7

Root Cause • Root Cause. A root cause is a factor that caused a nonconformance and should be permanently eliminated through process improvement UNCLASSIFIED / FOUO Leadership. Energy. Execution. 8

Root Cause View vs. Compliance Only • Root cause view: ‒ Systems-based ‒ Objective evidence gathering based on observation, interview, and documents ‒ Determination of conformance to environmental: • Plans • Processes • Conditions ‒ Class I, III and MP findings UNCLASSIFIED / FOUO • Compliance Only: ‒ Outcome-based ‒ Objective evidence gathering based on data, observation, interview, and documents ‒ Determination of compliance to: • Regulations ‒ Class I, III findings Leadership. Energy. Execution. 9

Why worry about Root Cause? • The management process behind the non-compliance is critical – Safety programs have studied this and found clear relationships between near-misses and fatalities – Environmental is different but the thought process is the same • Bad practices and programs eventually lead to breaking the law • Need to fix bad practices before this happens – Maximum fines per day per violation: • RCRA >$70, 000 • Clean Air Act >$90, 000 • Clean Water Act >$50, 000 UNCLASSIFIED / FOUO Leadership. Energy. Execution. 10

Evaluating Root Cause • Root cause analysis can use an acceptable tool or method, such as the “ 5 Whys” technique. • Example: Stormwater permit violation (1) Why did you have a noncompliance (permit violation)? Because sample was not taken (2) Why wasn’t sample taken? Because person was out sick (3) Why didn’t someone else take sample? Because no one else knew how (4) Why didn’t someone else know how? Because no one else had been trained on when it needed to be done (5) Why wasn’t someone else trained? Because no backup has been assigned the responsibility UNCLASSIFIED / FOUO Leadership. Energy. Execution. 11

Evaluating Root Cause, cont. • Therefore, the lack of backup resource would be a root cause – CM 03 Environmental responsibilities are not clearly defined in position standards or understood by personnel • Establishing the environmental responsibilities of a backup person and the training of that backup person would be the corrective action UNCLASSIFIED / FOUO Leadership. Energy. Execution. 12

Root Causes and EPAS UNCLASSIFIED / FOUO Leadership. Energy. Execution. 13

Root Causes and EPAS • How do you currently determine root causes? • What do you think are the most common root causes? • What do you expect Program Managers and ARMID to see with the root cause information? – How should root cause metrics support budget planning and requests? UNCLASSIFIED / FOUO Leadership. Energy. Execution. 14

Root Causes for Internal EPAS (abridged) TT 02 -Env media specific training is not conducted/ inadequate TT 01 -General env awareness training is not conducted/ inadequate RR 04 -Supplies/contracted deliverables not properly identified or not received RR 02 -Staffing levels for env-related activities not sufficient IP 03 -Process to review/update plans or procedures is not established/ inadequate IP 02 -Env management plans/ procedures are not properly implemented IP 01 -Env management plans or procedures are not in place/inadequate II 04 -Follow-up on env problems not conducted/ inadequate II 03 -Personnel not following established env plans/ procedures II 02 -Personnel ignore established env plans/ procedures II 01 -Document control is absent/inadequate CP 01 -Formal policies of env stewardship are not established/ deficient CM 04 -Management functions are not afforded priority to support env CM 03 -Env responsibilities not clearly defined or understood by personnel CM 02 -Management review process supporting operations is absent/inadequate CM 01 -Management is not aware of/ misinterpreted regulations D UNCLASSIFIED / FOUO C B A Blank 0 Leadership. Energy. Execution. 50 100 15

Root Causes and EPAS • Appendixes A, B, and C in the EPAS Guidance Manual cover root causes in detail – A Root Cause Flow Chart – B ACSIM Mandated Root Cause Codes and ISO/EMS References – C Root Cause Codes with Full EMS Text UNCLASSIFIED / FOUO Leadership. Energy. Execution. 16

USAR Root Cause Flow Chart UNCLASSIFIED / FOUO Leadership. Energy. Execution. 17

SUPPORT & OPERATION • Resources • Competence (TT 02) • Awareness (TT 01) Communication (IC 01, IC 02) • Documented Information (IP 01 IP 03, II 01) Operation Planning & Control (CM 02, IP 01, IP 02, II 03, RR 04) Emergency Preparedness & Response (OO 01, OO 02) • • PLANNING • Risks & • Opportunities • Environmental Aspects • Compliance Obligations (CM 01) • Objectives & Plans ACT • UNCLASSIFIED / FOUO LEADERSHIP Leadership & Commitment (RR 01, RR 02) • Environmental Policy (CP 01 & CP 02) • Roles, Responsibilities & Authority (CM 03, CM 04, IP 02, II 03) IMPROVEMENT • DO PERFORMANCE EVALUATION Monitoring, Measurement, Analysis, & Evaluation (CM 02) • Evaluation of Compliance • Internal Audit • Management Review (CM 02, IP 03) • CHECK Nonconformity & Corrective Action Continual Improvement (II 04) Leadership. Energy. Execution. 18

Tracing Root Causes • As you think about root cause: 1. Has the Army or RD produced a plan, policy, SOP, or written guidance document on the subject that applies to the finding? 2. Has the plan/policy/guidance been disseminated/communicated to the appropriate personnel (classroom or on-the-job training, email, Share. Point, etc. ? 3. Are they regularly evaluating effectiveness of their communication methods (did they confirm whether the “responsible party” had the appropriate opportunity/ access to the information)? 4. Only if all of that is YES, start looking at implementation findings UNCLASSIFIED / FOUO Leadership. Energy. Execution. 19

Group Exercise 1 – What is a potential root cause? • Staff cannot verify MVAC technicians have received appropriate training. According to 40 CFR 82. 34(a)(2), no person repairing or servicing motor vehicle air conditioners (MVACs) for consideration, and no person repairing or servicing MVAC-like appliances, may perform any service involving the refrigerant for such MVAC or MVAC-like appliance unless any such person repairing or servicing an MVAC has been properly trained and certified by a technician certification program approved by the Administrator pursuant to 40 CFR 82. 40. Also, according to 40 CFR 82. 42(b)(2), any person who owns approved refrigerant recycling equipment must retain records demonstrating that all persons authorized to operate the equipment are currently certified under § 82. 40. The ECO was not aware of these requirements. UNCLASSIFIED / FOUO Leadership. Energy. Execution. 20

Group Exercise 2 – What is a potential root cause? • Excess/unserviceable material stocks are not managed with waste minimization techniques. In accordance with AR 200 -1, para 10 -1 a(1)(a), excess or expired hazardous materials are to be handled in accordance with AR 710 -2, Supply Policy Below National Level. Excess/expired hazardous material should be promptly turned in to the supporting SSA or agency identified by the environmental coordinator. Staff were unsure who was supposed to get rid of the excess or expired hazardous materials. UNCLASSIFIED / FOUO Leadership. Energy. Execution. 21

Workbook Exercise 3 – What is a potential root cause? • Containers used to store used oil are not clearly labeled with the words "USED OIL". In accordance with 40 Code of Federal Regulations (CFR) 279. 20(a) and 279. 22(c), the label USED OIL must be clearly marked on containers used to store used oil and fill pipes used to transfer used oil into underground storage facilities. The facility Hazardous Waste Hazardous Material Management Plan did not cover used oil handling. UNCLASSIFIED / FOUO Leadership. Energy. Execution. 22

Workbook Exercise 4 – What is a potential root cause? • The outside of the Haz. Mat cabinet was not marked in any way to indicate the storage of flammable liquids. In accordance with 29 Code of Federal Regulations (CFR) 1910. 106, storage cabinets used for the storage of flammable/ combustible liquids should meet specific requirements. UNCLASSIFIED / FOUO Leadership. Energy. Execution. 23

Questioning – Root Cause Factors • Identification of root cause factors during interviews is oftentimes overlooked • Remember the “Why” question! – For example, Why do we care about root cause? UNCLASSIFIED / FOUO Leadership. Energy. Execution. 24

Summary • Need to understand root causes to improve the environmental program – Take the time to truly understand the situation and document what you find – Leave the roots and the weed will grow again! UNCLASSIFIED / FOUO Leadership. Energy. Execution. 25

Questions? UNCLASSIFIED / FOUO Leadership. Energy. Execution. 26