Environmental Compliance Review Closeout Process
BACKGROUND:
The U.S. Postal Service implemented a comprehensive environmental compliance review (ECR) program in fiscal year (FY) 1995 to ensure compliance with environmental mandates. The program provides an internal process for reviewing postal facilities' compliance with applicable environmental laws and regulations, tracking regulatory deficiencies, and taking corrective actions.
Within 90 days of completing an ECR, facility management should close all observations (findings of noncompliance or practices that could lead to noncompliance) by completing and documenting all corrective actions. The ECR includes an escalation process that progressively sends system-generated notifications to higher level management at four intervals beginning 15 days before and ending 61 days after corrective action is due to be completed. Finally, at 181 days, open observations are automatically reported monthly to the Office of Sustainability. Failure to close ECR findings on time could result in fines for noncompliance.
Our objective was to determine whether ECR observations were addressed in an effective and timely manner.
WHAT THE OIG FOUND:
The Office of Sustainability and facility management need to improve the ECR closeout process to ensure ECR observations are addressed effectively and on time. From FYs 2012 through 2013, facility management closed only 71 percent of the observations within 90 days as required. We reviewed 142 observations that were open for more than 181 days and found that management closed 26 (18 percent) during our audit and initiated corrective action on 72 (51 percent). However, facility management did not properly document completed corrective actions for 31 observations (22 percent) and did not take corrective action on 13 (9 percent).
Further, the escalation process did not effectively ensure personnel addressed observations open longer than 181 days. This occurred because ECR instructions did not include controls to ensure Office of Sustainability managers regularly assist with open ECR observations and the escalation process did not continue to provide notifications until observations were closed.
We identified about $2 million in assets at risk as a result of potential fines for noncompliance with environmental laws and regulations.
WHAT THE OIG RECOMMENDED:
We recommended the chief sustainability officer implement formal ECR follow-up procedures to ensure continued escalation and assistance until observations are closed; and coordination with operations management at the headquarters, area, district and facility levels as appropriate.