Pollution Prevention

Draft 1/11/2006

Suggested lines of inquiry and review approach

PERFORMANCE OBJECTIVE 1: Contractor Program Documentation

Contractor EMS adequately documents the protocols, policies, and procedures that will ensure that P2 is integrated in facility operations in order to achieve the DOE P2 and Sustainable Environmental Stewardship goals.

Lines of Inquiry:

• Has the ISMS been modified to incorporate an EMS?
• How does the EMS/ISMS incorporate P2 to achieve the Department's P2 and Sustainable Environmental Stewardship goals to prevent waste, reduce environmental releases, purchase environmentally preferable products and services, incorporate environmental stewardship in program planning and operational design, and recycle post-consumer materials?
• Does the EMS/ISMS require building P2 operational assessments into work planning documents, research approval processes or similar processes?
• What examples (i.e., forms, procedures) demonstrate how P2 operational assessments are built into those planning processes?
• Does the EMS/ISMS establish objectives and measurable targets related to P2 and sustainable environmental stewardship?
• Are the procedures for evaluating and reporting P2 performance documented?
• How is environmentally preferable purchasing incorporated in procurement policies?
• How are environmental sustainability principles incorporated in procurement policies?
• What criteria have been established and documented to determine which subcontractors will be subject to the CRD requirements?
• Is there a written procedure for notifying subcontractors of the CRD applicability to them?
• Are procedures documented for what happens if subcontractors with CRD responsibilities fail to meet them?

PERFORMANCE OBJECTIVE 2: Contractor Program Implementation

Lines of Inquiry:

• Is training in planning and conducting operational assessments required?
• If training on conducting P2 operational assessments is required, who is required to take it and how is its effectiveness evaluated?
• How are P2 operational assessments incorporated into work planning processes?
• How many P2 operational assessments have been conducted?
• How many P2 activities been implemented as a result of operational assessments?
• How is the Green Acquisition Advocate involved in procurements?
• How do procurement policies and practices incorporate environmentally preferable purchasing?
• How do procurement policies and practices incorporate sustainable design principles?
• What programs been developed and implemented to reduce the use of ozone depleting sources?
• How has "green" landscaping been incorporated in site policies and practices?
• Is there compliance with the reporting requirements of EPCRA and the PPA?
• How are the impacts of P2 monitored and assessed (e.g., amount of materials recycled, percentage of procurements that were environmentally preferable, progress in reducing ODS use)?
• How is information on P2 activities and outcomes made available to DOE?
• Have the P2 CRD requirements flowed down to subcontractors?
• How is subcontractor P2 performance assessed when the P2 requirements have flowed down to them?
• How is the ISMS/EMS updated after its initial development?

PERFORMANCE OBJECTIVE 3: P2 Oversight and Requirements

3.1 Line Management Oversight of Contractor Integration of P2:

Lines of Inquiry:

• What has been done to ensure that contractors have taken all necessary actions to integrate P2 into day-to-day activities?
• Was the appropriateness of developing a centralized procurement and distribution program for materials with hazardous or toxic chemicals determined?
• If such a centralized program was determined to be appropriate, was it implemented?
• How have environmentally and economically beneficial landscape practices been incorporated by the contractor?
• Has the contractor appropriately monitored P2 progress and reported it?
• How is the contractor's incorporation of P2 in the EMS to achieve the Department's P2 and Sustainable Environmental Stewardship goals evaluated?

3.2 Headquarters Oversight of Contractor Integration of P2:

Lines of Inquiry:

• How is the contractor's incorporation of site-specific goals in the ISMS/EMS to achieve the Department's P2 and Sustainable Environmental Stewardship goals determined?
• How do the site's specific goals contribute to
  • a. preventing waste generation;
  • b. reducing environmental releases;
  • c. purchasing environmentally preferable products and services;
  • d. incorporating environmental stewardship in program planning and operational design; and
  • e. recycling post-consumer materials?
• What programs or procedures are used to determine that sites have developed and implemented cost-effective P2 programs?
• What is done to ensure that sites monitor and report their P2 progress?
• What procedures are used to ensure that contractor EMS implementation is evaluated?

3.3 Line Management Requirements to Ensure P2 Integration

Lines of Inquiry:

• What procedures are used to ensure that contracting officers are notified to include the CRD in contracts?
• What procedures are followed to ensure that the O 450.1 CRD has been incorporated into appropriate contracts?
• How many P2 operational assessments have been conducted?
• How many cost-effective P2 activities been implemented as a result of operational assessments?
• What procedures are used to ensure that the annual budgetary process includes the funding and resources necessary to implement and monitor P2 site activities?
• What programs and/or procedures been developed and implemented to reduce the use of ozone depleting sources?
• How is the Green Acquisition Advocate involved in acquisitions?
• How do procurement policies and practices incorporate environmentally preferable purchasing?
• Have the required EPCRA and PPA reports been submitted?

3.4 Headquarters Elements' Requirements to Ensure P2 Integration

Lines of Inquiry:

• What has been done to ensure that all necessary actions to integrate P2 into DOE's day-to-day activities have been taken?
• What procedures are in place to ensure that the O 450.1 CRD is incorporated into appropriate contracts?
• What mechanisms are used to determine whether the O 450.1 CRD has been incorporated into appropriate contracts?
• What procedures are in place to ensure that the FAR waste reduction clause at 48 CFR 52.223-10 is incorporated into appropriate solicitations and contracts?
• What mechanisms are used to determine whether the FAR clause has been incorporated into appropriate solicitations and contracts?
• What activities has EH-1 completed to accomplish the phasing out of ODS?
• How have directives, policies, and documents been revised or developed to ensure procurement of environmentally preferable products and services?
• Has training on the requirements of EO 13101 and EO 13148 been made available to the appropriate personnel?
• How have the goals and requirements of EO 13148 been incorporated in DOE directives, policies, and documents?
• What awards programs have been created pursuant to EO 13101 and EO 13148?
• What procedures are used to ensure that PSOs and Administrators select their "best in class" recipients from site P2 nominations?
• Have the annual corporate reports been prepared and appropriately submitted in a timely fashion?
• What procedures are used to ensure that the annual budgetary process includes the funding and resources necessary to implement and monitor P2 site activities?

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