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DOE G 450.1-5
05-27-05
Implementation Guide for
Integrating Pollution Prevention into
Environmental Management Systems
[This Guide describes suggested nonmandatory approaches for meeting requirements.
Guides are not requirements documents and are not construed as requirements in any
audit or appraisal for compliance with the parent Policy, Order, Notice, or Manual.]
U.S. Department of Energy
Washington, D.C. 20585
PREFACE
DOE G 450.1-5, Implementation Guide for Integrating Pollution Prevention into Environmental
Management Systems, is one in a series of Guides that suggest approaches to meeting
requirements of DOE O 450.1 (Change 1, 1-24-2005), Environmental Protection Program, dated
4-15-03, which requires all Department of Energy (DOE) elements to ensure that Integrated
Safety Management Systems include Environmental Management Systems that provide for the
systematic planning, integrated execution, and evaluation of pollution prevention (P2) actions.
DOE G 450.1-1, Implementation Guide for use with DOE O 450.1, Environmental Protection
Program, dated 2-18-04, and DOE G 450.1-2, Implementation Guide for Integrating
Environmental Management Systems into Integrated Safety Management Systems, dated 8-20-04,
provide an overview and a detailed guide to Integrated Safety Management System (ISMS) and
Environmental Management System (EMS) integration, respectively. This Guide provides
guidance on integrating P2 into ISMS/EMS.
INTRODUCTION
Purpose
This document provides discretionary guidance for implementing the P2 requirements of
DOE O 450.1, which requires implementation of sound stewardship practices that are protective
of the air, water, land, and other natural resources impacted by DOE operations. This objective
is to be accomplished by implementing EMSs as part of existing ISMSs. As part of that
integration, DOE O 450.1 requires DOE elements, and contractors whose contracts include the
CRD, to provide for the systematic planning, integrated execution, and evaluation of P2 and
reduce or eliminate waste, pollutants, and Class I ozone-depleting substances (ODS) at DOE
facilities through source reduction, reuse, segregation, and recycling and by procuring
recycled-content materials and environmentally preferable products and services. This Guide
suggests approaches to integrating P2 into ISMS/EMS.
Applicability and Scope
This Guide is for use by all DOE elements, including the National Nuclear Security
Administration (NNSA) and contractors required to implement DOE O 450.1. It can also be
used by DOE elements and contractors not subject to DOE O 450.1 as they prepare the EMS
required under Executive Order 13148, Greening the Government Through Leadership in
Environmental Management, or as they comply with Acquisition Letter AL-2002-05, Greening
the Government Requirements in Contracting.
Use of Guidance
DOE Guides are not requirements documents and should not be construed as requirements in any
audit or assessment of compliance with the associated Policy, Order, Notice, or Manual. This
Guide suggests acceptable methods for integrating P2 into site operations. Other methods that
are equally effective in meeting these requirements may be used.
Background
The Resource Conservation and Recovery Act (RCRA), amended by the 1984 Hazardous and
Solid Waste Amendments, made the elimination or reduction of hazardous waste generation a
national policy. Waste generators are required to develop and implement waste minimization
programs and Federal procuring agencies to develop affirmative procurement programs to ensure
that products composed of recovered materials will be purchased to the maximum extent
practicable and consistent with applicable provisions of Federal procurement law.
The Pollution Prevention Act of 1990 declared as national policy that
“…pollution should be prevented or reduced at the source whenever feasible;
pollution that cannot be prevented should be recycled in an environmentally safe
manner, whenever feasible; pollution that cannot be prevented or recycled should
be treated in an environmentally safe manner whenever feasible; and disposal or
other release into the environment should be employed only as a last resort….”
P2 is also promoted through a series of Executive Orders (E.O.) imposing requirements
on the activities of Federal agencies as follows:
* E.O. 13101, Greening the Government through Waste Prevention, Recycling and Federal
Acquisition;
* E.O. 13123, Greening the Government through Efficient Energy Management;
* E.O. 13221, Energy-Efficient Standby Power Devices;
* E.O. 13148, Greening the Government through Leadership in Environmental
Management;
* E.O. 13149, Greening the Government Through Federal Fleet and Transportation
Efficiency; and
* E.O. 13327, Federal Real Property Asset Management.
DOE Acquisition Letter (AL) 002-05 describes the roles and responsibilities of the DOE
procurement community as they partner with other DOE personnel to implement the Federal
government’s Greening the Government initiatives. The Acquisition Letter cites Federal
Acquisition Regulation [(FAR) Title 48 Code of Federal Regulations (CFR), 23.705, which
requires that contracts for operation of government facilities contain the Waste Reduction
Program clause (48 CFR 52.223-10)]. That clause requires contractors to establish a program to
promote cost-effective waste reduction in all operations and facilities covered by the contract.
The Acquisition Letter also indicates that contracts for operation of a DOE facility should
contain the clause at Department of Energy Acquisition Regulations (DEAR)
48 CFR 970.5233-2 if the purpose of the contract includes the procurement of any such items
designated in the EPA Comprehensive Guidelines. That DEAR clause provides for the
contractor’s participation in the DOE Affirmative Procurement Program, now generally referred
to as environmentally preferable purchasing.
An additional DEAR regulation at 48 CFR 970.5223-1, Integration of Environment, Safety, and
Health into Work Planning and Execution, states that contractors “shall ensure that management
of environment, safety and health (ES&H) functions and activities becomes an integral but
visible part of the contractor’s work planning and execution processes.” The regulation clarifies
that safety includes P2 and waste minimization.
Many P2 opportunities at DOE sites have already been exploited through past efforts.
Identifying new, less-obvious opportunities may involve analysis, evaluation, and specialized
technical know-how to procure, design, or engineer products or processes that advance P2. The
EMS provides the framework that allows DOE elements to identify, implement, and evaluate
those opportunities.
Overview
This Guide is a companion piece to DOE G 450.1-2, Implementation Guide for Integrating
Environmental Management Systems into Integrated Safety Management Systems, to which users
should refer for information on integrating the EMS with the ISMS. This Guide is organized
around the four phases of establishing an EMS:
* Phase I, Planning and Aspects Identification
* Phase II, Implementation and Operation
* Phase III, Checking and Corrective Action
* Phase IV, Management Review and System Maintenance
In Chapters 2-5, this Guide employs the four-phase, ten-step format from DOE G 450.1-2 but
does not attempt to replicate its material. The Guide points out where and how P2 and related
activities such as environmentally preferable purchasing (EPP) and sustainable design can fit into
an ISMS/EMS.
CHAPTER 1. POLLUTION PREVENTION IN THE ISMS/EMS
DOE G 450.1-1, Implementation Guide for Use with DOE O 450.1, dated 2-18-04, describes the
ISMS and the EMS as similar because both systems strive for continual improvement through a
cycle of plan —> do —> check —> act.
Plans are made for programs and procedures to carry out the systems’ scope and purpose and then
emphasis is placed on doing them. During and after implementation, plans are checked to assess
their effectiveness, and any needed corrections are acted upon. Because of this similar cycle, the
two systems can be easily integrated into an ISMS/EMS.
1.1 P2 in the ISMS/EMS
P2 is inherent in an integrated ISMS/EMS because it is based on a similar cycle of continuous
improvement. DOE O 450.1 requires that the ISMS/EMS provide for P2 systematic planning,
integrated execution (doing), and evaluation and corrective action (checking and acting). P2
elements integrate with the ISMS/EMS elements as demonstrated in Figure 1.
A primary objective of DOE O 450.1 is implementation of sound stewardship practices that are
protective of the environment. The most effective way to implement those practices is to integrate
P2 policies, practices, and technologies into the ISMS/EMS continuous cycle of planning,
implementing, evaluating, and improving the organization’s environmental performance. Through
this integration, P2 is an ongoing process that is the responsibility of all workers and is routinely
considered at the front-end of the work-planning process for site operations and activities.
A commitment to P2 can further the EMS goals of addressing the environmental aspects of site
operations in a consistent and reliable manner through planned and implemented procedures and
programs. Reducing and/or eliminating an environmental risk is more efficient and effective than
mitigating or managing its consequences. Environmental risks can be eliminated or reduced most
easily by evaluating P2 opportunities for each existing or new activity before automatically
resorting to the more traditional alternatives of pollution management, treatment, control, and
disposition.
1.2 P2 as Site Policy
As shown in Figure 1, the policy statement sets the stage for the ISMS/EMS cycle. Incorporating
P2 in the ISMS/EMS policy statement demonstrates site management’s commitment to achieving
the DOE O 450.1 requirement for the systematic planning, integrated execution and evaluation of
P2.
The P2 component of the ISMS/EMS policy statement does not have to be lengthy. DOE sites
have established commitments to P2 in their policy statements by including concepts such as the
following:
* including pollution prevention concepts in site research, operations, and community
activities,
Figure 1: Integration of P2/ISMS/EMS.
* applying national and DOE goals and policies that will make pollution prevention an
integral part of site operating philosophy, and
* an environmental stewardship policy that is committed to integrating pollution prevention
and waste minimization, resource conservation, and compliance into site planning and
decision-making and to seeking cost-effective means to minimize environmental
impacts.
1.3 Putting P2 to Work
P2 works effectively when EPP and P2 operational assessments are imbedded in the ISMS/EMS.
Integrating P2 with the ISMS/EMS will be easier if the ISMS/EMS team includes people with
experience in areas such as EPP, sustainable design, waste reduction, ODS use, chemical
procurement, and recycling.
Team members’ training, knowledge, and experience will be helpful in identifying
environmental aspects and opportunities for cost-effective P2 operational assessments and
solutions.
P2 operational assessments can lead to solutions when new or existing operations and activities
are approached as assessment opportunities for possible pollution prevention. Paragraph 5d(6)
of DOE O 450.1 and paragraph 9 of the CRD require conducting operational assessments to find
source reduction, material segregation, and recycle/reuse opportunities.
P2 operational assessments will vary in scope and scale but all share the same goal:
To identify methods, services, or products that prevent pollution at the source, or, if that
is not feasible or cost-effective, minimize the amount of wastes generated, and recycle
those that are created.
As part of the life-cycle analysis of existing, new or changing operations, P2 operational
assessments can range from routinely scanning lists of required chemical purchases and
identifying and recommending less toxic substitutes, to implementing site protocols requiring
incorporation of sustainable design principles in new buildings, to formally structured pollution
prevention opportunity assessments (PPOAs).
A PPOA is a systematic assessment of a process or activity to identify opportunities to
* eliminate or reduce wastes,
* conserve natural resources,
* reduce toxic chemical or hazardous material use, and
* reuse and/or recycle materials.
It involves
* understanding the process being reviewed,
* identifying environmental aspects and their impacts,
* developing alternative processes or materials,
* evaluating the cost and technical feasibility of the alternatives,
* choosing the best alternative, and
* documenting the findings.
The conduct of a PPOA should include the people who plan and actually operate the process
under review, and people with experience in areas such as EPP, sustainable design, waste
reduction, recycling, and environmental compliance. A PPOA sample worksheet is included in
Appendix A. Some commonly used P2 terms and concepts related to P2 operational assessments
may be found in the glossary.
CHAPTER 2. P2 IN PHASE I—PLANNING AND ASPECTS IDENTIFICATION
Current Location on the P2-ISMS/EMS Integration Road Map
Phase I
Planning & Aspects
Identification Phase II Phase III Phase IV
Phase II
Implementation &
Operation
Phase III
Checking &
Corrective Action
Phase IV
Management
Review & System
Maintenance
Step 1—Identify Environmental Aspects
Sites identify and list their activities, products, and services and how they interact with the
environment to identify environmental aspects and identify the impact of each environmental
aspect.
Environmental aspects can be identified through records review, walk-throughs, interviews, and
activity reviews. Walk-throughs and employee interviews enhance the record review, reveal
additional activities that have environmental aspects, and sensitize employees to the
environmental impact of their activities.
Helpful records that should be readily available include chemical and materials procurement
information, toxic release inventory (TRI) reports, material safety data sheets (MSDSs), waste
management and disposal cost information, and regulatory permits.
Methods can be organized to be more productive by using an interview or walk-through checklist
or questionnaire that could ask for the following information.
* Are new processes or construction projects planned? Do the plans for these processes or
projects address energy and water efficiency and consider the substitution of
environmentally preferable materials or processes?
* Are facility renovations planned which could promote pollution prevention and energy or
water efficiency through improved lighting, more efficient heating/cooling, or
environmentally preferable products or processes?
* Are projects slated for termination or facilities slated for demolition?
* What is the process for project planning and how are life-cycle costs and impacts
considered?
* What chemicals, radiological sources, or hazardous substances are used and in what
amounts?
* What wastes are produced and in what amounts?
* How are wastes managed and disposed?
* What emissions are produced?
* What are the water or energy demands involved? Do the plans for these demands address
the potential for energy and water efficiency?
* Are pesticides and herbicides used?
These methods are valuable for identifying existing potential environmental aspects. Table 1
gives examples of identifying environmental aspects and the impacts they have on the
environment.
Table 1: Identify Environmental Aspects (Example)
Aspect
Activity
Impact
Air Emissions
Fire extinguishers using Class-I
ozone-depleting substances
(ODS)
Degrading effect on air quality
Hazardous Waste Generation
Use of formamide in genetic
sequencing
Degrading effect on air, soil, and
water; hazardous waste storage
and disposal
Activity planning forms and process diagrams are valuable tools for identifying any new
potential environmental aspects. Some sites use activity planning forms (e.g., operations plans,
project approval forms, work permits) as a routine practice.
For example, the experiment safety review form (Appendix B) used at one of the Department’s
laboratories requires applicants to provide information on the chemicals, controlled substances,
gases, cryogens, radioactive materials, and biological materials that will be used; the types and
amounts of wastes that will be generated; and the expected waste disposal method. Applicants
also are asked to describe how they plan to minimize waste generation and to identify pollution
prevention opportunities. They are asked to order or use the smallest amount of materials
possible, use recycled materials, and substitute non-hazardous materials.
A work permit form (Appendix C) requires applicants to identify safety and environmental
concerns such as whether chemicals or toxic materials will be used. Applicants also must
indicate if a PPOA has been done or is not needed.
Process flow diagrams are often used to identify environmental aspects of existing and new
activities. The advantage of a process flow diagram is that it graphically demonstrates materials
used, resources needed, wastes and emissions created, and the disposal path for the wastes.
Appendix D illustrates a process flow for an electrical discharge machine.
Step 2—Determine Significant Aspects
Step 2 involves identifying all the environmental aspects that are regulated or have regulatory
implications in addition to determining which aspects have significance based on environmental
or organizational considerations.
Paragraph 2.1.1 of DOE G 450.1-2 recommends that all environmental aspects subject to
regulation should be managed through the ISMS/EMS. The Guide defines these regulatory
authorities as Federal, host nation, State, or local government agency statutes, laws, or
regulations or Executive Orders and DOE regulations or directives that include requirements.
Because of the potential impact of a violation of any regulated environmental aspect, the Guide
suggests that all regulated aspects be automatically considered significant. Table 2 provides
examples of determining significant environmental aspects.
Table 2: Determine Significant Aspects (Example)
Aspect
Activity
Impact
Significance
Air Emissions
Fire extinguishers using
Class-I ozone-depleting
substances (ODS)
Degrading effect on air
quality
Significant: based
on regulatory score
(CAA, E.O. 13148
and O 450.1
provisions)
Hazardous Waste
Generation
Use of formamide in
genetic sequencing
Degrading effect on air,
soil, and water; hazardous
waste storage and disposal
Significant: based
on regulatory and
overall score
Walk-throughs, interviews, and activity reviews can lead to identifying significant aspects
resulting from the on-going or proposed activity. Environmental aspects that do not carry a
regulatory implication may still be significant and warrant being addressed. Environmental
aspects could be significant because of the potential harm that could result from high water or
power needs, an accident, expensive product or waste management costs, or high volume of
generated waste. Environmental aspects could also be significant for programs that are crucial to
fulfillment of a site’s mission. Again, the presence of experienced P2 personnel on the
ISMS/EMS team can aid in identifying and ranking significant environmental aspects.
Including these experienced personnel on the ISMS/EMS teams, implementation review teams,
and in line management is advantageous because they will be able to see the opportunity for P2
operational assessments at the earliest part of work planning. The possibility of including a
PPOA or P2 solution is at its greatest in the earliest stage of activity planning because it will be
perceived as a benefit to site operations and mission accomplishment from the start rather than a
possibly expensive add-on after activity planning has progressed and important decisions have
been made.
Step 3—Set Objectives and Targets
In this step, objectives and targets are established to address significant environmental factors.
Objectives are environmental performance goals and targets are specific, measurable steps to
achieve objectives. The environmental objectives and targets must be formalized, which means
management must agree with the findings and associated resource needs.
Objectives and targets will flow from the P2 solutions identified through assessments of existing
and new projects or activities or will be based on DOE Orders and DOE’s pollution prevention
goals (Appendix E), and Executive Orders. For example, DOE O 450.1 requires sites to develop
and implement programs and procedures to maximize the use of safe alternatives to ODS.
(NOTE: Class I ODS for all nonexcepted uses will no longer be procured after December 31,
2010.)
An objective could be to comply with the Order’s requirement and targets could include phasing
out Halon portable fire extinguishers by 2005 and replacing all nonexempt chillers by 2008.
Gaining management approval of the objectives and targets will probably be easier when they
are based on the Department’s P2 goals and DOE O 450.1. Table 3 provides examples of setting
objectives and targets.
Table 3: Set Objectives and Targets (Example)
Aspect
Activity
Impact
Significance
Objective/Target
Air
Emissions
Fire
extinguishers
using Class-I
ozone-
depleting
substances
(ODSs)
Degrading
effect on air
quality
Significant:
based on
regulatory
score (CAA,
E.O. 13148 and
O 450.1
provisions)
Objective: discontinue procurement of Class I
ODS for all but non-excepted uses by 12-31-10.
Target 1: inspect all fire extinguishers for Class
I ODS use in 1st quarter of FY05
Target 2: develop prioritized list of fire
extinguishers using Class I ODS for replacement
by end of 3rd quarter of FY05
Target 3: using list, replace all fire
extinguishers using Class I ODS by end of FY10
Hazardous
Waste
Generation
Use of
formamide in
genetic
sequencing
Degrading
effect on
air, soil, and
water;
hazardous
waste
storage and
disposal
Significant:
based on
regulatory and
overall score
Objective: identify possible alternatives to
formamide
Target 1: form P2 opportunity assessment team
in 1st quarter of FY05
Target 2: complete P2 opportunity assessment
by end of 3rd quarter of FY05
ISMS/EMS objectives and targets should be developed and described specifically to ensure that
they can and will be implemented and that progress and outcomes can be measured as required in
the checking and corrective action phase of the ISMS/EMS (see step 8 in chapter 4). Specificity
also makes it easier to develop the processes, plans, resources, training needs, and timelines
necessary to ensure that the targets, and ultimately, the objectives are achieved.
Even though environmental aspects subject to regulation are normally evaluated as significant,
P2 opportunities should still be considered. If the operational controls built into the ISMS/EMS
are geared solely to compliance, opportunities to eliminate or reduce a waste stream and its
associated cost advantage could be lost. A PPOA might reveal that use of an environmentally
preferred product could result in regulatory compliance through a reduction in waste generation
thereby contributing to the site’s progress in achieving its P2-related ISMS/EMS objectives and
targets and moving beyond compliance.
A PPOA could lead to removing an activity from regulatory control. Los Alamos National
Laboratory found that using a mixture of absorbents and microbes that digest oil-contaminated
soil resulted in soil that no longer had to be specially managed and disposed of as a New Mexico
special waste and could be used as base fill for the construction or renovation of vehicle parking
lots and equipment storage areas.
Conducting PPOAs can be ISMS/EMS objectives and targets. An objective could be the
completion of a PPOA on an operation and/or process with significant waste stream generation.
Or, the objective could be to reduce the generation of a hazardous waste stream by 25 percent
over a 2-year period, with the first target being the completion of a PPOA of the operation and/or
process creating that waste stream.
CHAPTER 3. P2 IN PHASE II—IMPLEMENTATION AND OPERATION
Current Location on the P2-ISMS/EMS Integration Road Map
Phase I
Planning &
Aspects
Identification Phase II Phase III Phase IV
Phase II
Implementation &
Operation
Phase III
Checking &
Corrective Action
Phase IV
Management
Review & System
Maintenance
Step 4—Document the ISMS/EMS
In this step, team members ensure that the EMS requirements in DOE O 450.1 are documented
and fully incorporated into the existing ISMS.
DOE O 450.1 lists several P2 requirements for inclusion in the ISMS/EMS, some of which will fit
into the site’s policy statement, objectives and targets, or operational controls and environmental
management programs. P2 requirements that should be addressed in the ISMS/EMS by DOE
elements are as follows (DOE O 450.1 paragraph references are shown in brackets):
* Provide for the systematic planning, integrated execution, and evaluation of P2 [4a(1)];
* Reduce or eliminate the generation of waste, the release of pollutants to the environment, and
the use of Class I ozone-depleting substances (ODS) through source reduction, re-use,
segregation, and recycling and by procuring recycled-content materials and environmentally
preferable products and services [4b(3)];
* Obtain, as appropriate, local community advice relative to requirements of Executive Orders
13101, 13221, 13123, 13148, and 13149 [5d(3)];
* Incorporate, where appropriate, environmentally and economically beneficial landscape
practices into all new landscaping programs, policies, and practices [5d(4)];
* Ensure, where appropriate, implementation of centralized procurement and distribution
programs (e.g., pharmacy) for purchasing, tracking, distributing, and managing materials with
toxic or hazardous content [5d(5)];
* Conduct operational assessments, such as PPOAs, of site operations to identify opportunities
for source reduction, material segregation, recycle/reuse, or other P2 projects and implement
cost-effective P2 projects, using life-cycle assessment concepts and practices in determining
return-on-investment (5d(6)];
* Ensure site annual budgetary processes include the funding and resources necessary to
implement P2 program implementation and monitoring [5d(7)];
* Monitor progress toward meeting the P2 requirements spelled out in paragraph 4b(3) (see
second item in this list) and make the information available on an annual basis [5d(9)];
* Develop and implement a program and procedures to maximize the use of safe alternatives to
ODS whereby procurement of Class I ODS for all nonexcepted uses is discontinued by
December 31, 2010 and ODS removal or reclamation is coordinated with the Department of
Defense (DoD) [5d(10)];
* Consider P2 in the specification and acquisition of departmental supplies to cost effectively
maximize procurement of environmentally preferable products [5d(11)];
* Coordinate all acquisitions with DOE’s “Green Acquisition Advocates” established pursuant to
Acquisition Letter, AL-2000-03, superseded by AL-2002-05 dated 07/10/02, as appropriate
[5d(12)]; and
* Comply with the requirements of the Emergency Planning and Community Right-to-Know Act
(EPCRA or Title III of Superfund Amendments and Reauthorization Act of 1986) and the
Pollution Prevention Act of 1990 [5d(13)] .
The DOE O 450.1 CRD lists the P2 requirements for contractors whose contracts contain it. Those
requirements are listed below with the paragraph reference shown in brackets:
* Provide for the systematic planning, integrated execution, and evaluation of P2 [1(a)];
* Reduce or eliminate the generation of waste, the release of pollutants to the environment, and
the use of Class I ozone-depleting substances (ODS) through source reduction, re-use,
segregation, and recycling and by procuring recycled-content materials and environmentally
preferable products and services [2(c)];
* Assist DOE in its efforts to obtain, as appropriate, local community advice relative to
requirements of Executive Orders 13101, 13221, 13123, 13148, and 13149 [4];
* Assist DOE in meeting its requirements under EO 13148 by ensuring, where appropriate,
implementation of centralized procurement and distribution programs (e.g., pharmacy) for
purchasing, tracking, distributing, and managing materials with toxic or hazardous content [5];
* Incorporate, where appropriate, environmentally and economically beneficial landscape
practices into all new landscaping programs, policies, and practices [6];
* Monitor progress toward meeting the P2 requirements spelled out in paragraph 2(c) (see
second item in this list) and make the information available on an annual basis [7];
* Consider P2 in the specification and acquisition of departmental supplies to cost effectively
maximize procurement of environmentally preferable products and coordinate, as appropriate,
all acquisitions with DOE’s “Green Acquisition Advocates” established pursuant to
Acquisition Letter, AL-2000-03, superseded by AL-2002-05 dated 07/10/02, as appropriate
[8];
* Conduct operational assessments, such as PPOAs, of site operations to identify opportunities
for source reduction, material segregation, recycle/reuse, or other P2 projects and implement
cost-effective P2 projects, using life-cycle assessment concepts and practices in determining
return-on-investment [9];
* Develop and implement a program and procedures to maximize the use of safe alternatives to
ODS whereby procurement of Class I ODS for all nonexcepted uses is discontinued by
December 31, 2010 and ODS removal or reclamation is coordinated with the Department of
Defense (DoD) [12]; and
* Assist DOE with the requirements of the Emergency Planning and Community Right-to-Know
Act (EPCRA or Title III of Superfund Amendments and Reauthorization Act of 1986) and the
Pollution Prevention Act of 1990 [13] .
Step 5—Develop Environmental Management Programs
An Environmental Management Program (EMP) is created to achieve goals, objectives, and
targets set for significant environmental aspects. The EMP records the significant aspect
being addressed, explains why it is significant, and describes the objectives and targets established
to address the aspect. The EMP will also describe required organizational resources, timeframes,
and performance indicators to track progress, operational controls, roles and responsibilities, and
training that might be required. The scope of the EMP will depend on the site’s preference. An
EMP could be developed for each significant aspect or several related aspects could be addressed
by a single EMP. Alternatively, an EMP could be facility- or process-specific.
The EMP should contain all the elements necessary to implement the P2 opportunities discovered
through the PPOA or to undertake the suggested PPOA. Just as the ISMS/EMS objectives and
targets should be described with specificity, the elements necessary to achieve them should also be
described clearly and thoroughly in the EMP.
Step 6—Develop Operational Controls
Operational controls are either engineering controls or administrative controls put in place
through the EMS to address objectives and targets. Engineering controls are mechanical
interventions (e.g., replace hose fittings with a more durable fitting to reduce air emissions)
whereas administrative controls rely on procedural approaches (e.g., procurement specifies
purchase of particular fittings.) Operational controls spell out what will be done to achieve the
objectives and targets.
The operational controls required to achieve the P2 objectives and targets should be developed by
a team consisting of the people who will carry out the control as well as experienced EPP,
sustainable design, waste reduction, and recycling personnel. These individuals may be able to see
P2 opportunities in the way the controls are developed and carried out. Table 4 provides examples
of operational controls.
Table 4: Develop Operational Controls (Example)
Aspect
Activity
Impact
Significance
Objective/Target
Operational
Controls
Air
Emissions
Fire
extinguishers
using Class-I
ozone-
depleting
substances
(ODS)
Degrading
effect on
air quality
Significant:
based on
regulatory
score (CAA,
E.O. 13148
and O 450.1
provisions)
Objective: discontinue
procurement of Class I ODS
for all but non-excepted uses
by 12-31-10.
Target 1: inspect all fire
extinguishers for Class I ODS
use in 1st quarter of FY05
Target 2: develop prioritized
list of fire extinguishers using
Class I ODS for replacement
by end of 3rd quarter of FY05
Target 3: using list, replace
all fire extinguishers using
Class I ODS by end of FY10
Operational Control 1:
replace all fire
extinguishers using
Class I ODS
Operational Control 2:
develop procurement
process to ensure use
of approved fire
extinguishers only
Hazardous
Waste
Generation
Use of
formamide in
genetic
sequencing
Degrading
effect on
air, soil,
and water;
hazardous
waste
storage
and
disposal
Significant:
based on
regulatory
and overall
score
Objective: identify possible
alternatives to formamide
Target 1: form P2
opportunity assessment team
in 1st quarter of FY05
Target 2: complete P2
opportunity assessment by
end of 3rd quarter of FY05
Modify standard
operating procedure for
genetic sequencing to
replace formamide
with a non-toxic
chemical
Step 7—Integrate P2 into ISMS/EMS Procedures
Standard operating procedures that are related to the ISMS/EMS need to be developed or
existing procedures should be modified as needed to support the ISMS/EMS.
Paragraph 4a(1) of DOE O 450.1 and paragraph 1(a) of the CRD require integrated execution of
P2. Operational controls and standard operating procedures are the methods that can satisfy this
Order requirement. Standard operating procedures describe what will be done, and how and
when it will be done, and can serve two P2 purposes. First, new standard operating procedures
should be written, or existing ones should be modified, to ensure that the operational controls
developed to execute the PPOA or P2 solution are actually implemented.
Second, new standard operating procedures can ensure incorporation of P2 into ongoing site
operations. For example, in furtherance of DOE O 450.1 paragraph 5d(6) and paragraph 9 of the
CRD, a site standard operating procedure should require P2 operational assessments of site
operations that create waste and/or releases to the environment to identify opportunities for
source reduction, material segregation, recycle/reuse or other P2 projects. The use of
environmentally preferable products and sustainable building design principles should also
become a site standard operating procedure. Sandia National Laboratories/NM and Los Alamos
National Laboratory modified their standard operating procedures to include sustainable design
principles and energy efficiency criteria in their construction specifications, engineering
standards, and operations and maintenance manual.
Other potential standard operating procedures, in addition to the requirement for operational
assessments, include the following from DOE O 450.1. The paragraph citations are to the DOE
element requirement and the CRD respectively:
* Incorporate environmentally and economically beneficial landscape practices into all new
landscaping programs and policies [5d(4); 6];
* Ensure implementation of centralized procurement and distribution programs (e.g.,
pharmacy) for purchasing, tracking, distributing, and managing materials with toxic or
hazardous content to reduce chemical use, waste and cost [5d(5); 5];
* Develop and implement a program and procedures to maximize the use of safe
alternatives to ODS (in preparation for December 31, 2010, when procurement of Class I
ODS for all non-excepted is to be discontinued), and ODS removal or reclamation is to
be coordinated with DoD [5d(10); 12]; and
* Consider P2 in the specification and acquisition of Departmental supplies to cost
effectively maximize procurement of environmentally preferable products and services
[5d(11); 8].
CHAPTER 4. P2 IN PHASE III—CHECKING AND CORRECTIVE ACTION
Current Location on the P2-ISMS/EMS Integration Road Map
Phase I
Planning &
Aspects
Identification Phase II Phase III Phase IV
Phase II
Implementation &
Operation
Phase III
Checking &
Corrective Action
Phase IV
Management
Review & System
Maintenance
Step 8—Establish the ISMS/EMS Assessment Program
The assessment step is the third part of the plan-do-check-act ISMS/EMS cycle. Performance
assessment provides the necessary feedback to determine the effectiveness of the plan and do
phases and act on any necessary changes.
For DOE elements, DOE O 450.1 requires
* that site ISMS/EMS include the systematic planning, integrated execution and evaluation
of programs for P2 [4a(1)]; policies and procedures to assess performance and implement
corrective actions, where needed [4a(2)]; and annual review and updating, when
appropriate, of measurable environmental goals, objectives and targets [4a(3)];
* monitoring and reporting on site progress toward meeting requirements to reduce or
eliminate waste, the release of pollutants to the environment, and the use of Class I
ozone-depleting substances [5d(9)]; and
* that operations/field/site office managers ensure that contractor ES&H self assessment
programs are established within the framework of DOE P 450.5 and continue to be
effective [5d(16)].
The CRD for DOE O 450.1 requires contractors to
* ensure that the ISMS/EMS provides for the systematic planning, integrated execution and
evaluation of programs for P2; assessment of corrective actions to manage, control, and
mitigate the effects of activities with significant environmental impacts; and annual
review and updating of measurable environmental goals, objectives, and targets [1]; and
* monitor and report on site progress toward meeting requirements to reduce or eliminate
waste, the release of pollutants to the environment, and the use of Class I ozone-depleting
substances [7].
Progress assessments are easier when objectives are articulated clearly and targets are
measurable. The degree of specificity will vary depending upon the information needed to
assess performance and point to necessary modifications. Targets and objectives can include
* PPOAs conducted;
* P2 opportunities identified, funded, and implemented;
* purchases of environmentally preferable products;
* continued promotion of environmentally preferable procurement;
* amounts of emissions or wastes generation reduced;
* cost savings;
* operational efficiency;
* corrective actions implemented and assessed for adequacy;
* centralized procurement and distribution of chemicals;
* elimination or reduction of purchase of ozone depleting substances;
* enhanced security performance; or
* reduced worker exposure or mission vulnerability
An assessment of how well P2 is integrated into site activities will, by necessity, involve
evaluating the adequacy of EMPs, operational controls, and standard operating procedures in
place to achieve the P2 objectives and targets. Table 5 provides examples of metrics that can
be used in the assessment process.
Table 5: Checking and Corrective Action (Example)
Aspect
Activity
Impact
Significance
Objective/Target
Operational
Controls
Checking/Corrective
Action
Air
Emissions
Fire
extinguishers
using
Class-I
ozone-
depleting
substances
(ODS)
Degrading
effect on
air quality
Significant:
based on
regulatory
score (CAA,
E.O. 13148
and O 450.1
provisions)
Objective: discontinue procurement of Class I
ODS for all but non-excepted uses by
12-31-10.
Target 1: inspect all fire extinguishers for
Class I ODS use in 1st quarter of FY05
Target 2: develop prioritized list of fire
extinguishers using Class I ODS for
replacement by end of 3rd quarter of FY05
Target 3: using list, replace all fire
extinguishers using Class I ODS by end of
FY10
Operational Control
1: replace all fire
extinguishers using
Class I ODS
Operational Control
2: develop
procurement
process to ensure
use of approved fire
extinguishers only
Target 1: percentage of
fire extinguishers inspected
Target 2: percentage of
fire extinguishers replaced
Operational Control 2:
implementation of
procurement process
Hazardous
Waste
Generation
Use of
formamide in
genetic
sequencing
Degrading
effect on
air, soil,
and water;
hazardous
waste
storage and
disposal
Significant:
based on
regulatory and
overall score
Objective: identify possible alternatives to
formamide
Target 1: form P2 opportunity assessment
team in 1st quarter of FY05
Target 2: complete P2 opportunity assessment
by end of 3rd quarter of FY05
Modify standard
operating procedure
for genetic
sequencing to
replace formamide
with a non-toxic
chemical
Target 1 and 2: team
formed and opportunity
assessment completed on
time
Operational control:
standard operating
procedure for genetic
sequencing modified and in
use
CHAPTER 5. P2 IN PHASE IV—MANAGEMENT REVIEW
AND SYSTEM MAINTENANCE
Current Location of the P2-ISMS/EMS Integration Road Map
Phase I
Planning &
Aspects
Identification Phase II Phase III Phase IV
Phase II
Implementation &
Operation
Phase III
Checking &
Corrective Action
Phase IV
Management
Review & System
Maintenance
Step 9—Develop the Management Review Process
Management review is the periodic review of the ISMS/EMS by senior management (i.e.,
managers who have the authority to make decisions for the site or facility.) The goal of this
review is to ensure that the ISMS/EMS continues to be suitable, adequate, and effective for its
intended purposes: that is, the ISMS/EMS is appropriate, adequately supported, and
contributing to achieving site targets and objectives.
Paragraph 5d(16) of DOE O 450.1 requires that DOE operations/field/site office managers
ensure that contractor ES&H self-assessment programs are established within the framework of
DOE P 450.5, Line Environment, Safety and Health Oversight, dated 6-26-97, and continue to be
effective.
Paragraph 5d(17) requires that the annual ISMS review process assess contractor ES&H
performance objectives, performance measures, and commitments based on environmental risks,
impacts of site activities, and established P2 goals.
Management review should bring management attention to P2 successes, resource needs, and
additional opportunities; should assess the adequacy of site P2 processes and activities; and
should result in recommendations for necessary changes (e.g., new or modified objectives,
measurable targets, or assessment criteria.)
Step 10 Develop a Plan to Keep the ISMS/EMS Updated
The ISMS/EMS should be modified as site operations and missions change and new
requirements are generated by laws, Executive Orders, or DOE directives.
Regulatory or mission or program changes will require site re-evaluation of environmental
aspects and their significance, which could lead to modification of objectives, targets, and
corresponding EMS operational controls. Successful completion of P2 objectives and targets
also will trigger a revision of the P2 elements in the ISMS/EMS
RESOURCES
The following is a brief listing of the types of available P2 resources. More resources are
available at http://epic.er.doe.gov/epic/ and http://www.eh.doe.gov/p2/
Affirmative Procurement Program for Recycled Content and Biobased Products—Guidance for
Compliance with Section 6002 of the Resource Conservation and Recovery Act and Executive
Order 13101 (http://twilight.saic.com/ap/APPG_2001.htm).
Buying Green Training (http://www.eh.doe.gov/p2/p2train.asp).
DOE Pollution Prevention Program Plan
(http://www.eh.doe.gov/p2/p2integratedhomepage/p2plan.asp).
DOE Sustainable Design Program (http://www.pnl.gov/doesustainabledesign/).
Green Landscaping (www.epa.gov/greenacres/).
Leadership in Energy and Environmental Design
(http://www.usgbc.org/LEED/LEED_main.asp).
P2 in the Environmental Restoration Program (http://www.eh.doe.gov/p2/p2iner/).
Pollution Prevention and Energy Efficiency Leadership (P2/EE) Goals
(http://www.eh.doe.gov/p2/wastemin/P2goals.PDF).
Pollution Prevention Opportunity Assessment training
http://mis.doe.gov/ess/training_catalog_detail.cfm?course_num=000723&skey=none
Responsibilities of DOE site recycling coordinators http://tis.eh.doe.gov/p2/ap/RCduties.doc
Strategic Plan to Implement Executive Order 13101 Greening the Department of Energy through
Waste Prevention, Recycling, and Federal Acquisition
(http://www.eh.doe.gov/p2/ap/StraPlan.pdf).
U.S. Green Building Council (http://www.usgbc.org/).
GLOSSARY
Bio-based Products—commercial or industrial products (other than food or feed) that use
biological products or renewable domestic, agricultural, or forestry materials. (Source:
E.O. 13101)
Environmental Aspect—elements of an organization’s activities, products, or services that can
interact with the environment. (Source: ISO-14001)
Environmental Impact—a change to the environment, whether adverse or beneficial, wholly or
partially resulting from an organization’s activities, products, or services. (Source: ISO-14001)
Environmental Objective—an overall environmental goal, arising from the environmental policy
that an organization sets itself to achieve, and which is quantified where practicable. (Source:
ISO-14001)
Environmentally Preferable—products or services that have a lesser or reduced effect on human
health or the environment when compared with competing products or services that serve the
same purpose. The product or service comparison may consider raw materials acquisition,
production, manufacturing, packaging, distribution, reuse, operation, maintenance, or disposal.
(Source: E.O. 13101)
Environmentally Preferable Purchasing—Procuring products or services that have a lesser or
reduced effect on human health or the environment when compared with competing products or
services that serve the same purpose. (Source: E.O. 13101)
Environmental Target—a detailed performance requirement, quantified where practicable, and
applicable to the organization or parts thereof, which arises from the environmental objectives
and needs to be set and met to achieve those objectives. (Source: ISO-14001)
Life-cycle Assessment—comprehensive examination of a product’s environmental and economic
aspects and potential impacts throughout its lifetime, including raw material extraction,
transportation, manufacturing, use and disposal. (Source: E.O. 13101)
Pollution Prevention—reducing or eliminating the generation of waste, the release of pollutants
to the environment, and the use of Class I ozone-depleting substances (ODS) through source
reduction, reuse, segregation, and recycling and by procuring recycled-content materials and
environmentally preferable products and services. [Source: DOE O 450.1, paragraph 4b(3)]
Recycling—process by which recovered materials are transformed into new products. [Source:
Title 40, Code of Federal Regulations (CFR), section 246.101]
Significant Environmental Aspect—an environmental aspect that has or could have a significant
impact on the environment, the organization, or to the organization’s mission. (Source:
ISO-14001)
Source Reduction—any practice that reduces—
* the amount of any hazardous substance, pollutant, or contaminant entering waste streams
or otherwise released into the environment (including fugitive emissions) before
recycling, treatment, or disposal and
* the hazards to public health and the environment associated with the release of such
substances, pollutants, or contaminants. (Source: Pollution Prevention Act of 1990)
Sustainable Design—encompasses the materials used to build and maintain a facility, the energy
and water needed in its operation, and the ability to provide a healthy and productive
environment for facility users. (Source: Los Alamos National Laboratory Sustainable Design
Guide)
Waste Prevention—any change in the design, manufacturing, purchase, or use of materials or
products (including packaging) to reduce their amount or toxicity before they are discarded; the
reuse of products or materials. (Source: E.O. 13101)
Waste Reduction—preventing or decreasing the amount of waste being generated using waste
prevention, recycling or purchasing recycled and environmentally preferable products. (Source:
E.O. 13101)
APPENDIX A. POLLUTION PREVENTION OPPORTUNITY ASSESSMENT FORMS
Pollution Prevention Opportunity Assessment
Worksheet 1
Team and Activity Description
Date P2OA ID Code Facility
Activity
Team Members (*Leader) Telephone MSIN
Description of Activity to be examined in this P2OA
Pollution Prevention Opportunity Assessment
Worksheet 2
Activity Flow Diagram
Date P2OA ID Code Facility
Activity
Chemical and
Radioactive Inputs
Material Inputs
Energy Inputs
Name
Qty.
Name
Qty.
Name
Qty.
Activity
Activity
Time Period
Product or Result Output
Hazardous Waste Output
Non-Hazardous Waste Output
Name
Qty.
Name
Qty.
Name
Qty.
Radioactive Waste Output
Mixed Waste Output
Other
Name
Qty.
Name
Qty.
Name
Qty.
Pollution Prevention Opportunity Assessment
Worksheet 3
Pollution Prevention Opportunity Description
Date P2OA ID Code Facility
Activity
P2O No. 1 P2O Title
Current Practice
Proposed Action
Calculation of Waste Reduction and/or Energy Savings
Calculation of Annual Cost Savings
Current Practice Costs
Waste Disposal Costs
Purchasing Costs
Labor Costs
Subtotal of Current Practice Costs = Waste Costs + Purchasing Costs + Labor Costs =
Proposed Action Costs
Waste Disposal Costs
Purchasing Costs
Labor Costs
Subtotal of Current Practice Costs = Waste Costs + Purchasing Costs + Labor Costs =
Annual Cost Savings = Current Practice—Proposed Action =
Calculation of Implementation Cost and Payback
Vendor/Contact Information
Pollution Prevention Opportunity Assessment
Worksheet 3
Pollution Prevention Opportunity Description
Date P2OA ID Code Facility
Activity
P2O No. 2 P2O Title
Current Practice
Proposed Action
Calculation of Waste Reduction and/or Energy Savings
Calculation of Annual Cost Savings
Current Practice Costs
Waste Disposal Costs
Purchasing Costs
Labor Costs
Subtotal of Current Practice Costs = Waste Costs + Purchasing Costs + Labor Costs =
Proposed Action Costs
Waste Disposal Costs
Purchasing Costs
Labor Costs
Subtotal of Current Practice Costs = Waste Costs + Purchasing Costs + Labor Costs =
Annual Cost Savings = Current Practice—Proposed Action =
Calculation of Implementation Cost and Payback
Vendor/Contact Information
Pollution Prevention Opportunity Assessment
Worksheet 3
Pollution Prevention Opportunity Description
Date P2OA ID Code Facility
Activity
P2O No. 3 P2O Title
Current Practice
Proposed Action
Calculation of Waste Reduction and/or Energy Savings
Calculation of Annual Cost Savings
Current Practice Costs
Waste Disposal Costs
Purchasing Costs
Labor Costs
Subtotal of Current Practice Costs = Waste Costs + Purchasing Costs + Labor Costs =
Proposed Action Costs
Waste Disposal Costs
Purchasing Costs
Labor Costs
Subtotal of Current Practice Costs = Waste Costs + Purchasing Costs + Labor Costs =
Annual Cost Savings = Current Practice—Proposed Action =
Calculation of Implementation Cost and Payback
Vendor/Contact Information
Pollution Prevention Opportunity Assessment
Worksheet 4
Pollution Prevention Opportunities Summary
Date P2OA ID Code Facility
Activity
P2O No.
P2O Title
Waste
Class
Reduced
Annual Waste
Reduction or
Energy Savings
Estimated
Annual
Savings
Estimated
Implementation
Cost
Payback
1
0
$
$
years
2
0
$
$
years
3
0
$
$
years
Other Brainstorming Opportunities
Pollution Prevention Opportunity Assessment
Worksheet 5
Final Summary
Date P2OA ID Code Facility
Activity
Proposed Opportunities and Discussion
Recommendations and Schedule for Implementation
APPENDIX B. EXPERIMENT SAFETY REVIEW FORM EXAMPLE
SAMPLE EXPERIMENT SAFETY REVIEW FORM
REVIEW NUMBER (supplied by ERC):
PRINCIPAL INVESTIGATOR: DATE:
DEPARTMENT/DIVISION/GROUP:
EXT: E-MAIL: LIFE NUMBER:
Project Title:
Location(s):
Funding Source/Account Number:
Proposed Start Date and Duration:
SIGNATURES:
Principal Investigator:
Date:
Experiment Review Coordinator:
Date:
Date:
Date:
Date:
Date:
Date:
Approval
Department Chairperson:
Date:
Review/Approval Comments:
Walkthrough Signature:
Date:
Expiration Date (max 1 yr.):
FUA Change Required? 0 Y 0 N
Fire Rescue Run Card Changes Required? 0 Y 0 N
Has a NEPA Review been Performed for this Project? 0 Y 0 N
Project Termination Acceptance Signature:
Date:
Comments:
I. DEFINE THE SCOPE OF WORK
A. Description
Describe the experiment purpose/scope. Identify all apparatus that will be used and associated
requirements. List special equipment (X-ray generators, lasers, etc.) that will be used during the
project. Identify measurement and test equipment, apparatus operating conditions, and
required maintenance procedures as appropriate. Include calibration frequency for formal
calibration requirements. Attach supporting documents such as engineering calculations,
drawings, and specifications.
Indicate if modification of facility is required. Include the setup and decommissioning phases of
the experiment. The Work Permit Process/Form may better address the hazards and controls
of the set-up and/or tear-down phases. Indicate if a Work Permit will be used.
B. Materials Used /Waste Generated
List materials to be used and wastes generated. Refer to the site Chemical Management
System for a complete listing of the chemicals in your locations. Include samples, chemicals,
controlled substances, gases, cryogens, radioactive materials, and biological material. You may
use generic chemical class descriptions for commonly used materials (e.g., organic solvents,
acids). List disposal methods.
Denote disposal method using the codes below.
Materials Used & Wastes Generated
Disposal Method
Type
(Code below)
Estimated Quantity
(provide units)
Estimated Annual
Waste Generation
Per Use
Total/Yr
Note: Identify Age Sensitive materials or special handling requirements.
Disposal Method Codes:
Air Emissions
Liquid Effluents
Wastes
P=Point Source
S=Sanitary
H=Hazardous
F=Fugitive
ST=Storm water
I=Industrial (Non-hazardous waste e.g., oils)
O=Other
R=Radioactive
M=Mixed (Radioactive + Hazardous)
RM=Radioactive Medical
MW=Medical
T=Trash
C. Waste Minimization/Pollution Prevention
Describe how you plan to minimize generation of the wastes described above, and identify
pollution prevention opportunities. Consider ordering/using the smallest amount, using recycled
materials, and substituting non-hazardous materials. The Pollution Prevention and Waste
Minimization Subject Area describes how to plan, conduct, and close out work activities to
eliminate or minimize the impact of their activities on the environment.
II. IDENTIFY AND ANALYZE HAZARDS ASSOCIATED WITH THE WORK
In this section, indicate the hazards in each class. Include the setup and decommissioning
phases of the experiment.
Physical Hazards (check all that apply)
0 None
0 Cryogens
0 Oxygen deficient atmosphere
0 Noise > 85 dBA
0 Fall hazards (e.g., ladders, elevated platforms, towers)
0 Material handling equipment (e.g., cranes, hoists, forklifts)
0 Machine shop or nonportable powered tools use
0 Electrical hazards (exposed conductors, large batteries, capacitors, etc)
0 Confined space
0 Trenching/soil excavation
0 Extreme temperatures
0 Remote location
0 Other (specify):
Pressure or Vacuum Systems (check all that apply)
0 None
0 Compressed gases (lecture bottles, cylinders, gas lines)
0 Pressurized vessels or systems
0 Vacuum chambers or systems with >1000 J stored energy
0 Autoclaves
0 Other (specify):
Fire Hazards (check all that apply)
0 None
0 Open flames
0 Welding, Brazing, Silver Soldering
0 Flammable gases/liquids/solids
0 Other spark producing activity
0 Other (specify):
Chemical Hazards (check all that apply)
0 None
0 Carcinogens
0 Highly acute toxins
0 Reproductive toxins
0 Corrosives
0 Flammable liquids
0 Flammable solids
0 Strong oxidizers
0 Oils
0 Explosives
0 Peroxidizables
0 Pyrophoric materials
0 PCBs
0 Asbestos
0 Pesticides/herbicides
0 Controlled substances
0 Highly reactive materials
0 Perchlorates
0 Toxic metals (e.g., As, Ba, Be, Cd, Cr, Hg, Pb, Se, Ag)
0 Other (specify):
Ionizing Radiation (check all that apply)
0 None
0 Sealed radioactive sources
0 Windowless radioactive sources
0 Dispersible radioactive materials
0 Neutron-emitting radioactive sources
0 Non-fissionable radioactive materials
0 Fissionable radionuclides
0 Ionizing radiation-generating devices (x-ray sources, accelerators)
0 Other (specify):
Nonionizing Radiation (check all that apply)
0 None
0 Class II, IIIa, or IIIb (visible <15mW) lasers
0 Class IIIb (nonvisible >15mW) or IV lasers
0 Dynamic magnetic fields >1G at 60 Hz or dynamic electric fields > 1kV/m at 60 Hz
0 Static magnetic fields < 5 G. No Exposure Form is required
0 Static magnetic fields > 5 G and < 600 G
0 Static magnetic fields exposure. Attach Static
Magnetic Fields Exposure Form when required.
0 Static magnetic fields ? 600 G
0 Radio frequency (RF) or Microwave sources exceeding 10 mW radiated output
0 Infrared sources > 10 W
0 Ultraviolet sources > 1 W
0 Extremely low frequency (ELF) radio sources
0 Other (specify):
Biological Hazards (check all that apply)
0 None
0 Regulated etiological agent
0 Recombinant DNA
0 Animals
0 Human blood/components, human tissue/body fluids
0 Human subjects
0 Other (specify):
Offsite Work (check appropriate box)
0 None
0 Reviewed or controlled by ES&H programs
at the offsite location
0 Requires additional controls (include in the next
section)
See “ Identification of Significant Environmental Aspects and Impacts Subject Area” or your ECR if you need
assistance completing the following table.
Significant Environmental Aspects (check all that apply)
0 None
0 Any amount of hazardous waste generation
0 Any amount of radioactive waste generation
0 Any amount of mixed waste generation (radioactive hazardous waste)
0 Any amount of transuranic waste generation
0 Any amount of industrial waste generation (e.g., oils, vacuum pump oil)
0 Any amount of Regulated Medical Waste (including sharps, hypodermic needles, or syringes)
0 Any atmospheric discharges that require engineering controls to reduce hazardous air pollutants or
radioactive emissions, or are identified as a Title V emission unit, or require monitoring under
NESHAP
0 Any liquid discharges that require engineering controls to limit the quantity or concentration of the
pollutant, or include radionuclides detectable at the point of discharge from the facility, or contain any
of the chemicals listed on the site’s SPDES permit
0 Storage or use of any chemicals or radioactive materials that require engineering controls –
see “Storage and Transfer of Hazardous and Nonhazardous Materials Subject Area”
0 On-site or off-site transportation of chemicals or dispersible radioactive materials
0 Any use of once-through cooling water with a flow of 4 gpm—24 hrs/day (10 gpm—8 hrs/day, daily
use of >15 gpm for >60 days) and discharging to the sanitary sewer
0 Soil contamination or activation
0 Any underground pipes/ductwork that contain chemical or radioactive material/contamination
0 Other environmental aspects related to your work (specify):
0 Process Assessment Form required (determined by ECR or other qualified person)
III. DEVELOP AND IMPLEMENT HAZARD CONTROLS
For each hazard identified in the previous section, describe how that hazard is controlled.
Identify the Engineering Controls (e.g., interlocks, shielding), Administrative Controls
(e.g., procedures, RWPs), or Personal Protective Equipment (e.g., respirators, gloves;
see the Personal Protective Equipment Subject Area) that will be employed to reduce
hazards to acceptable levels. .
The Experiment Review Coordinator, along with the Principal Investigator (PI) and Building
Manager, as appropriate, will evaluate this experiment for impacts that will require an update to
the Facility Use Agreement (FUA), and or Fire/Rescue Run Cards.
The PI develops and implements hazard controls in consultation with, and using feedback from,
the personnel who will be performing the work.
A. Physical Hazards/Controls
Hazard
Controls (Administrative, Engineered, Protective Equipment)
Note: Include maintenance, inspection and testing, and formal calibration, including frequency as appropriate.
B. Chemical Hazards/Controls
Hazard
Controls (Administrative, Engineered, Protective Equipment)
Note: Refer to the “Working with Chemicals Subject Area” for requirements regarding particularly hazardous
chemicals such as carcinogens, reproductive toxins, and highly acute toxins, including postings,
decontamination plan, and address above.
C. Environmental Hazards/Controls
Hazard
Controls (Administrative, Engineered, Protective Equipment)
Note: Identify the requirements from applicable waste management subject area (hazardous, radioactive, mixed,
regulated medical). List all applicable environmental permits (Suffolk County Art. XII, Title V Emission
Source, etc.) and the relevant controls required by those permits.
D. Radiation Hazards/Controls
Hazard
Controls (Administrative, Engineered, Protective Equipment)
Note: List sources/materials. Attach or refer to Radiation Work Permits.
E. Biological Hazards/Controls
Hazard
Controls (Administrative, Engineered, Protective Equipment)
Note: List additional approvals/permits/reviews required (e.g., Biosafety Committee approval).
F. Offsite Work Hazards/Controls
Hazard
Controls (Administrative, Engineered, Protective Equipment)
Note: List the location of all off-site work and identify any off-site organization whose ESH requirements will be
followed (e.g., other DOE Labs). Indicate additional controls (not specified above) that are needed.
IV. PERFORM WORK WITHIN CONTROLS
All work shall be performed within the controls identified within this document. It is the PI’s
responsibility to ensure that this document is kept up to date. The PI should consult with the
ERC as appropriate to determine if changes to this document are significant enough to require a
new review/document.
If a hazard assessment may be required for this experiment, the PI should contact the ES&H
Coordinator and/or the ERC for assistance. The PI should document any hazard assessments
performed for this experiment in Section VI.
A. Training
List all project personnel, indicating they are authorized and competent to perform the work
described. List the training required for each individual. Identify any certifications or
experiment-specific training required. Indicate if any project personnel are minors (18 years of
age). Contact your Training Coordinator and ES&H Coordinator as appropriate for assistance.
It is the responsibility of the PI to maintain a complete up-to-date list of personnel and their full
training requirements, and to ensure that training and qualifications are maintained.
Name
Life/Guest #
Required Training (Course or JTA code)
Note: The site Training and Qualifications Web Site contains course offerings and descriptions, required training
checklist, and employee training records.
B. OSHA/DOE Required Medical Surveillance
Indicate if potential exposure is in excess of trigger levels listed. Exposure evaluation and/or
medical surveillance may be required. Additional training may be required for any indicated
agent. See SBMS for additional information and controls on the hazards listed.
Regulated Hazard
Hazard Specific
Training Trigger
Medical Surveillance Exposure Trigger
0 Inorganic Arsenic
Any day above the OSHA
action level (without regard to
respirator use)
30 days/year above the action level
(without regard to respirator use)
0 Biohazards
(CDC/NIH/WHO listed
Agent)
None
See Subject Area for guidance
0 Cadmium
Any day above the OSHA
action level
30 or more days/year at or above the action
level
0 Lasers
Use Class IIIb or Class IV
Lasers
Use Class IIIb or Class IV Lasers
0 Lead
Any day above the OSHA
action level
30 or more days/year at or above the action
level
0 Methylene Chloride
Any day above the OSHA
action level
- 30 days/year at or above the action level
-
- 10 days/year above the 8-hour TWA PEL
or the STEL
-
- Any time above the 8-hour TWA PEL or
STEL for any period of time where an
employee at risk from cardiac disease or
other serious MC-related health condition
and employee requests inclusion in the
program
0 Noise
Any day above the ACGIH TLV
Any time equal or greater then 85 dBA
TWA 8-hour dose
0 OSHA Regulated
Chemicals
Acrylonitrile Benzene
Benzidine 1,3 Butadiene
4-Dimethyl aminoazobenzene
Ethylene oxide Ethyleneimine
Formaldehyde Vinyl Chloride
Any day above the OSHA PEL
- Routinely above the action level (or in the
absence of an action level, the PEL)
-
- Event such as a spill, leak or explosion
results in the likelihood of a hazardous
exposure
0 Static Magnetic Fields
Worker who routinely works in
magnetic field
- Any time at ³ 0.5 mT (5 G) for Medical
Electronic Device wearer
-
- Any day at ³ 60 mT (600 G) to whole
body [8 hour average]
-
- Any day at ³ 600 mT (6000 G) to limbs [8
hour average]
-
- Any Time at ³ 2 mT (20 G) to whole body
[ceiling]
-
- Any time at ³ 5 mT (50 G) to limbs
[ceiling]
C. Emergency Procedures
Identify any emergency actions, procedures, or equipment that must be in place to insure
personnel safety and environmental protection. Include the Building Local Emergency Plan,
location of emergency shutoffs, and spill control materials.
D. Transportation
Identify materials, hazards, and controls for any on-site and off-site transportation of hazardous
and/or radioactive materials. See relevant SBMS Subject Areas.
E. Notifications
The PI or designee should notify building occupants of any activities that might impact them or
their work, and document this here. List external personnel/organizations that require
notification related to experimental activities and/or to be notified of changes (e.g., a Site
Committee for review/approval, Occupational Medicine Clinic, or Fire/Rescue).
F. Termination/Decontamination
Describe any decommissioning plan, including decontamination of the area at termination of the
experiment. Identify any hazards and controls, special precautions, or procedures. Include
chemical and waste reconciliation. Indicate if a walk-down or an ERE will be scheduled to
ensure the area is suitable for future projects. Indicate if Work Permit Form/Procedure will be
used.
G. Community Involvement Issues
Identify issues that may require community involvement (see the Community Involvement in
Laboratory Decision-making Subject Area) and describe the plan that addresses these issues.
Attach the Community Involvement Checklist.
V. PROVIDE FEEDBACK ON ADEQUACY OF CONTROLS AND CONTINUE
TO IMPROVE SAFETY MANAGEMENT
Provide comments on the review process, including the review form and communication.
Identify any lessons learned or worker feedback contributing to modifications/improvements to
the controls or process.
VI. ATTACHMENTS
Use this section to include any hyperlinks and/or additional documents, hazard assessments,
figures, and tables that could not be entered into the previous sections of the form.
Attachment 1. Sample Signature Sheet
The PI is responsible for communicating the requirements in this Experiment Safety Review
(ESR) to the project workers. One way to accomplish this is to have each worker read the ESR
and sign an agreement form, such as the one below. This sheet is not submitted as part of the
review process.
I have read this Experimental Safety Review document and understand the
hazards associated with my work activities and the controls in place to mitigate
those hazards. I understand the environmental aspects of my work activities and
will continually work to minimize waste generated and look for areas of
improvement. I am aware of the training requirements and will maintain my
qualifications.
Signature
Print Name
BNL #
Signature
Date
APPENDIX C. WORK PERMIT APPROVAL FORM EXAMPLE
Work Permit #
Work Order #
Job# Activity#
1. Work requester fills out this section.
Requester:
Date:
Ext.:
Dept/Div/Group:
Other Contact person (if different from requester):
Ext.:
Work Control Coordinator:
Start Date:
Est. End Date:
Brief Description of Work:
Building:
Room:
Equipment:
Service Provider :
2. WCC, Requester/Designee, Service Provider, and ES&H (as necessary) fill out this section or attach analysis
ES&H ANALYSIS
Radiation
Concerns
0 None
0 Activation
0 Airborne
0 Contamination
0 Radiation
0 Other
0 Special nuclear materials involved, notify Isotope Special Materials Group
0 Fissionable materials involved, notify Laboratory Criticality
Officer
Safety Concerns
0 None
0 Ergonomics
0 Transport of Haz/Rad Material
0 Adding/Removing
Walls or Roofs
0 Confined Space*
0 Explosives
0 Lead*
0 Penetrating Fire Walls
0 Corrosive
0 Flammable
0 Magnetic Field*
0 Pressurized Systems
0 Asbestos*
0 Cryogenic
0 Fumes/Mist/Dust*
0 Material Handling
0 Rigging/Critical Lift
0 Beryllium*
0 Electrical
0 Heat/Cold Stress
0 Noise*
0 Toxic Materials*
0 Biohazard*
0 Elevated Work*
0 Hydraulic
0 Non-ionizing Radiation*
0 Vacuum
0 Chemicals*
0 Excavation
0 Lasers*
0 Oxygen Deficiency*
0 Other
* Does this work require medical clearance or surveillance from the Occupational Medicine Clinic? 0 Yes 0 No
Environmental Concerns
0 None
0 Work impacts Environmental Permit No.
0 Atmospheric Discharges (rad/non-rad)
0 Land Use
0 Soil
activation/contamination
0 Waste-Mixed
0 Chemical or Rad Material Storage or Use
0 Liquid Discharges
0 Waste-Clean
0 Waste-Radioactive
0 Cesspools (UIC)
0 Oil/PCB Management
0 Waste-Hazardous
0 Waste-Regulated Medical
0 High water/power consumption
0 Spill potential
0 Waste-Industrial
0 Underground Duct/Piping
Waste disposition by:
0 Other
Pollution Prevention (P2)/Waste Minimization
Opportunity:
0 None 0 Yes
FACILITYCONCERNS
0 None
0 Access/Egress
Limitations
0 Electrical Noise
0 Potential to Cause a False Alarm
0 Vibrations
0 Impacts Facility Use Agreement
0 Temperature Change
0 Other
0 Configuration Control
0 Maintenance Work on Ventilation Systems
0 Utility Interruptions
WORK CONTROLS
Work Practices
0 None
0 Exhaust Ventilation
0 Lockout/Tagout
0 Spill Containment
0 Security (see Instruction Sheet)
0 Back-up Person/Watch
0 HP Coverage
0 Posting/Warning Signs
0 Time Limitation
0 Other
0 Barricades
0 IH Survey
0 Scaffolding-requires
inspection
0 Warning Alarm (i.e. “high level”)
Protective Equipment
0 None
0 Ear Plugs
0 Gloves
0 Lab Coat
0 Safety Glasses
0 Coveralls
0 Ear Muffs
0 Goggles
0 Respirator
0 Safety Harness
0 Disposable Clothing
0 Face Shield
0 Hard Hat
0 Shoe Covers
0 Safety Shoes
0 Other
Permits Required (Permits must be valid when job is scheduled.)
0 None
0 Cutting/Welding
0 Impair Fire Protection Systems
0 Concrete/Masonry
Penetration
0 Digging/Core Drilling
0 Rad Work Permit-RWP No
0 Confined Space Entry
0 Electrical Working
Hot
0 Other
Dosimetry/Monitoring
0 None
0 Heat Stress Monitor
0 Real Time Monitor
0 TLD
0 Air Effluent
0 Noise
Survey/Dosimeter
0 Self-reading Pencil
Dosimeter
0 Waste Characterization
0 Ground Water
0 O2/Combustible
Gas
0 Self-reading Digital
Dosimeter
0 Other
0 Liquid Effluent
0 Passive Vapor
Monitor
0 Sorbent Tube/Filter
Pump
Training Requirements (List below specific training requirements)
Based on analysis above, the Walkdown Team determines the risk,
complexity, and coordination ratings below:
If using the permit when all hazard ratings are low, only the
following need to sign: ( Although allowed, there is no need to
use back of form)
ES&H Risk Level:
0 Low 0 Moderate 0 High
WCC: Date:
Complexity Level:
0 Low 0 Moderate 0 High
Service Provider: Date:
Work Coordination:
0 Low 0 Moderate 0 High
Authorization to start Date:
(Departmental Sup/WCC/Designee)
3. Both work requester and service provider contribute to work plan (use attachments for detailed plans)
Work Plan (procedures, timing, equipment, and personnel availability need to be addressed):
Special Working Conditions Required:
Operational Limits Imposed:
Post Work Testing Required:
Job Safety Analysis Required: 0 Yes 0 No
Walkdown Required: 0 Yes 0 No
Reviewed by: Primary Reviewer will determine the size of the review team and the other signatures required based on hazards and job complexity.
Primary Reviewer signature means that the hazards and risks that could impact ES&H have been identified and will be controlled according to site
requirements.
Title
Name (print)
Signature
Life #
Date
Primary Reviewer
ES&H Professional
Other
Other
Work Control Coordinator
Service Provider
Review Done: 0 in
series
0 team
4. Job site personnel fill out this section.
Note: Signature indicates personnel performing work have read and understand the hazards and permit requirements (including any attachments).
Job Supervisor:
Contractor Supervisor:
Workers:
Life#:
Workers :
Life#:
Workers are encouraged to provide feedback on ES&H concerns or on ideas for improved job work flow. Use feedback form or space below.
5. Departmental Job Supervisor, Work Control Coordinator/Designee
Conditions are appropriate to start work: (Permit has been reviewed, work controls are in place and site is ready for job.)
Name:
Signature:
Life#:
Date:
6. Departmental Job Supervisor, Work Requester/Designee determines if Post Job Review is required. 0 Yes 0 No
Post Job Review (Fill in names of reviewers)
Name:
Signature:
Life#:
Date:
Name:
Signature:
Life#:
Date:
7. Worker provides feedback.
Worker Feedback (use attached sheets as necessary).
a) WCM/WCC: Is any feedback required? 0 Yes 0 No
b) Workers: Are there better methods or safer ways to perform this job in the future? 0 Yes 0 No.
8. Closeout: Work Control Coordinator (authorizing dept.) checks quality of completed permit and ensures the work site is left in an acceptable
condition. (WCC can delegate clean up of work area to work supervisor)
Name:
Signature:
Life#:
Date:
Comments:
INSTRUCTIONS FOR FILLING OUT THE WORK PERMIT
Header Information
The “Work Permit #” line shall be filled in by whatever numbering sequence a given department
or group wants to use. The Work Control Coordinator maintains a logbook or spreadsheet of
work permit numbers issued. The other three number lines are provided for tracking purposes
and are filled in as appropriate. The “Standing Work Permit” box is checked if the permit is
being used as such.
Section 1—Work Request
The work requester fills out the required information in this section. The name in the “Work
Control Coordinator” line is the requester’s WCC. The “Service Provider” line is the department
doing the work.
Section 2—Hazard Analysis
The work requester initially fills out this section identifying the location hazards, facility concerns,
work controls, and specific training needs. The requester provides the work information to the
service provider and schedules a walkdown of the job site. A Walkdown Team composed of the
requester, service provider, and ES&H support personnel (as needed) may provide further input
for Section #2. The service provider predominantly identifies the task hazards and appropriate
controls.
Notes:
-For each subsection, a “NONE” or a hazard or work control box must be checked.
-The “Safety Concerns” items with an asterisk indicate work activities that may require Industrial
Hygiene to investigate, and may then require OMC medical surveillance. If the workers are
already on the protocol list for the activity or hazard, then OMC surveillance would not be
needed and the “No” box would be checked. If not sure of the worker’s medical status or the
particular work activity, mark “Yes” and contact Industrial Hygiene to evaluate.
-When a job involves a significant change to the amount of chemicals or radioactive materials in
a facility, the Building Manager must be notified to determine if the Facility Hazard Category has
been affected as per the Facility Use Agreement.
-For guidance in determining if security concerns are applicable see “Security Checklist.”
-Table 1 and 2 in the screening guidelines attachment provide additional definition to the ES&H
issues.
Section 2—Low, Moderate and High Hazard Determination
The bottom part of Section 2 is used by the WCC or Walkdown Team to make a final
determination as to the rating levels (low, moderate, or high) for ES&H risk, complexity, and
work coordination. A given task may be a skill of the worker job, but the complexity of the
system or the work coordination involved can dictate a higher level of planning.
If the WCC or Walkdown Team decides that ES&H risk, complexity, and work coordination are
all low, then the job is categorized as a low hazard and the work permit process can be
terminated at this point. If a permit will be used for low hazard work, the Work Control
Coordinator, the service provider (supervisor, craft, or technician), and an individual authorizing
work must sign in the lower right hand corner of the front side.
If any of the ES&H risk, complexity, or work coordination rating levels are checked off as
moderate or high, then the rest of the work permit form must be processed.
Section 3—Work Plan
The work plan section is filled out predominantly by the work requester with input from the
service provider and ES&H personnel as needed. The job site should be visited by the
Walkdown Team. A written description shall detail the job and any precautions that need to be
taken. Use attachments for detailed plans (i.e., drawings) and longer narrative if needed.
If the ES&H risk level is rated high, then a Job Safety Analysis, JSA, must be written and
attached to the work permit.
Section 3—Primary Reviewer
It is encouraged to review work permits in a team setting as opposed to circulating the permit for
review and signoff in series. The team environment has proven to be more effective in achieving
good ES&H reviews and in coordinating the required resources.
The primary reviewer is responsible for assembling ES&H and subject matter experts as
needed for the review based on the ESH risks, job complexities, and overall coordination. If the
Primary reviewer is a member of the Walkdown Team, then the team signoff in the “Reviewed
By” section can occur following the walkdown if desired. Following review and approval, the
work permit is returned to the work requester for scheduling with the work provider.
Section 4—Supervisor and Worker Signoffs
A pre-job briefing with the crew to review job hazards, permits, and coordination requirements.
(Required for moderate and high hazards)
The supervisor and the workers sign the form (or an attachment) to indicate that they
understand the hazards, the controls and the permit requirements.
Note: The workers must sign for themselves; it is not permissible for the supervisor to write
their worker’s names on the work permit.
Section 5—Conditions Appropriate to Start Work
The affected department usually authorizes the start of the job. Without this section, the
workers could start any time without a final check with the department. The person signing this
section verifies that the requirements designated on that permit (work controls, etc.) have been
met, and that the job may proceed.
Section 6—Post Job Review
The job supervisor or work requester determines whether a post job review is needed. In some
cases, the review team may decide that a post job analysis would be beneficial for lessons
learned and will request the review. If a review is requested, print the name of the reviewer(s)
on the line and check off the “Yes” block. If no review is needed, check off the “No” block.
Section 7—Worker Feedback
This section is provided for the workers to feedback comments on ES&H issues from the job or
on how to improve the work efficiency. The WCM/WCC may request worker feedback by
answering yes to Section 7(a); if 7(a) is marked yes, then it is up to the WCM/WCC /Supervisor
to solicit (and document on the WP or attached sheet) feedback from the workers. Regardless
of the answer to 7(a) workers are encouraged to answer Section 7(b).
Section 8—Closeout
The original copy of the work permit is returned to the Work Control Coordinator who originated
it initially. The Work Control Coordinator reviews the permit for consistency, signs off to close it
out, and files it. The WCC provides feedback to appropriate personnel if any permit
discrepancies occur.
APPENDIX D. METAL SHOP ELECTRICAL DISCHARGE MACHINE PROCESS MAP
APPENDIX E. DEPARTMENT OF ENERGY POLLUTION PREVENTION AND
ENERGY EFFICIENCY LEADERSHIP GOALS*
DOE will strive to minimize waste and maximize energy efficiency as measured by continuous,
cost-effective improvements in the use of materials and energy, with the years 2005 and 2010 as
interim measurement points.
A. Reducing Waste and Recycling.
* Reduce waste from routine operations by 2005, using a 1993 baseline, for these waste
types:
o Hazardous 90 percent
o Low Level Radioactive 80 percent
o Low Level-Mixed Radioactive 80 percent
o Transuranic (TRU) 80 percent.
* Reduce releases of toxic chemicals subject to Toxic Chemical Release Inventory
reporting by 90 percent by 2005, using a 1993 baseline.
* Reduce sanitary waste from routine by 75 percent by 2005, and 80 percent by 2010, using
a 1993 baseline.
* Recycle 45 percent of sanitary wastes from all operations by 2005 and 50 percent by
2010.
* Reduce waste resulting from cleanup, stabilization, and decommissioning activities by 10
percent on an annual basis.
B. Buying Items with Recycled Content.
Increase purchases of EPA-designated items with recycled content to 100 percent, except when
not available competitively at reasonable price or that do not meet performance standards.
C. Improving Energy Usage.
* Reduce energy consumption through life-cycle cost effective measures by 40 percent by
2005 and 45 percent by 2010 per gross square foot for buildings, using a 1985 baseline
20 percent by 2005 and 30 percent by 2010 per gross square foot, or per other unit as
applicable, for laboratory and industrial facilities, using a 1990 baseline.
* Increase the purchase of electricity from clean energy sources:
o Increase purchase of electricity from renewable energy sources by including
provisions for such purchase as a component of our request for bids in 100 percent of
all future DOE competitive solicitations for electricity.
o Increase the purchase of electricity from less greenhouse gas-intensive sources,
including, but not limited to, new advanced technology fossil energy systems, and
other highly efficient generating technologies.
D. Reducing Ozone Depleting Substances and Greenhouse Gases.
* Retrofit or replace 100 percent of chillers greater than 150 tons of cooling capacity and
manufactured before 1984 that use class I refrigerants by 2005.
* Eliminate use of class I ozone depleting substances by 2010, to the extent economically
practicable, and to the extent that safe alternative chemicals are available for DOE class I
applications.
* Reduce greenhouse gas emissions attributed to facility energy use through life-cycle cost
effective measures by 25 percent by 2005 and 30 percent by 2010, using 1990 as a
baseline.
E. Increasing Vehicle Fleet Efficiency and Use of Alternative Fuels.
* Reduce our entire fleet's annual petroleum consumption by at least 20 percent by 2005 in
comparison to 1999, including improving the fuel economy of new light duty vehicle
acquisitions and by other means.
* Acquire each year at least 75 percent of light duty vehicles as alternative fuel vehicles, in
accordance with the requirements of the Energy Policy Act of 1992.
* Increase usage rate of alternative fuel in departmental alternative fuel vehicles to 75
percent by 2005 and 90 percent by 2010 in areas where alternative fuel infrastructure is
available.