Sustainability

Standardized Reporting Requirements for Environmental Notices of Violation

The U.S. Postal Service® makes every effort to comply with all applicable local, state, and federal environmental regulations. A Notice of Violation (NOV), or similarly entitled action such as a warning letter or a notice of noncompli­ance, is issued to the Postal Service™ for the violation of an environmental regulation. Local, state, or federal agen­cies issue these actions.

Examples of noncompliance actions include, but are not limited to, the following:

n The issuance of an NOV from a state environmental protection agency for a vehicle maintenance facility’s noncompliance with the state’s underground storage tank regulations.

n The issuance of a notice of noncompliance from a state environmental agency for the improper disposal of haz­ardous waste generated by a Postal Service worker or contractor working at a Postal Service facility.

n A warning letter issued by a state department of envi­ronmental protection for storm water violations.

Unlike Safety’s nationwide tracking of Occupational Safety and Health Administration (OSHA) violations, the national environmental compliance program has, until recently, been primarily an area function. As such, individ­ual areas have established NOV tracking capabilities but might not be reporting NOVs to the Headquarters’ office of Environmental Compliance and Risk Management. The office of Environmental Compliance and Risk Manage­ment, now within the office of Sustainability, is standardiz­ing the tracking and reporting of all NOVs.

By tracking NOVs, the Postal Service will ensure that timely and necessary actions are taken to respond to NOVs and that certain critical NOVs are referred to the Law Department. In addition, the tracking of NOVS will assist with performing trend analysis to determine needed com­pliance-focused activities.

When an installation head, or a facility department project manager, becomes aware of an NOV or a similarly entitled action issued by a local, state, or federal agency, he or she must send an electronic copy of the NOV to the east or west manager, Regional Sustainability Initiatives, within 5 days of receipt of the NOV.

For NOVs generated in the Northeast, Eastern, Capital Metro Areas, and Headquarters-related facilities, send an electronic copy to Nick DeCarlo, eastern manager, Regional Sustainability Initiatives at Nicholas.Decarlo@usps.gov.

For NOVs generated in the Great Lakes, Western, Southwest, and Pacific Areas, send an electronic copy to Larry Hanna, western manager, Regional Sustainability Ini­tiatives at Larry.J.Hanna@usps.gov.