Effective November 28, 2013, the Postal Service™ is revising the Administrative Support Manual (ASM) and the Employee and Labor Relations Manual (ELM). Subchapter 69, Environmental Compliance, has been added to the ASM and Subchapter 890, Environmental Management, has been removed from the ELM (see page 8).
The revisions reflect new roles and responsibilities resulting from an organizational restructure of the environmental function. This restructure moved the environmental function from Employee Resource Management to the Office of Sustainability. In addition, ASM, Subchapter 69, contains new language concerning data management, records management, training, corrective/preventive action, communication/outreach, and budget/resource allocation that better supports the Postal Service’s systems approach to managing environmental compliance. These sections contain general language that reflect existing processes and systems currently in use by the Postal Service to manage compliance, such as the Environmental Toolkit (ETK) for data management and the Environmental Compliance Review (ECR) Program for corrective/preventive action. While these sections do contain new language, they do not reflect new requirements.
In conjunction with the new ASM Subchapter, the Office of Sustainability has deployed digital solutions that better accommodate the dynamic nature of environmental regulations at the federal, state, and local level. The foundation is a robust website at: http://blue.usps.gov/sustainability/environmental.htm, which contains compliance assistance tools, including system and operational-specific Environmental Compliance Bulletins and Best Practices, which better reflect operational needs.
This effort has also entailed retiring several outdated management instructions and handbooks. A list of the directives that have been made obsolete is included at the end of this article.
Administrative Support Manual (ASM)
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[Add new subchapter as follows:]
69 Environmental Compliance
691 Policy
The Postal Service complies with all applicable federal, state, and local environmental laws and regulations, and proactively seeks to develop innovative and cost-effective solutions to provide its customers, employees, suppliers, and communities with a safe and healthy environment through the implementation of a compliance management system.
692 Scope
These policies apply to all Postal Service facilities, managers and employees, programs, projects, operations, products, and services.
693 Regulations and Authority
693.1 General
The Postal Service is subject to numerous federal, state, and local environmental laws and regulations. Certain Executive Orders and Environmental Protection Agency policies are recognized by the Postal Service as guidance.
693.2 Federal Laws and Regulations
Federal environmental laws are codified in Title 40 of the Code of Federal Regulations. The following federal laws apply to the Postal Service:
a. National Environmental Policy Act (NEPA).
b. Toxic Substances Control Act (TSCA).
c. Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).
d. Resource Conservation and Recovery Act (RCRA).
e. Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, also known as Superfund).
f. Clean Air Act (CAA).
g. Clean Water Act (CWA).
h. Emergency Planning and Community Right-to-Know Act (EPCRA).
i. Safe Drinking Water Act (SDWA).
j. Energy Policy Act of 2005.
693.3 State and Local Laws and Regulations
Provisions of certain federal laws may be delegated to the states for compliance, monitoring, and enforcement. In many instances, the regulations so delegated present complex compliance requirements that vary by locality. To add to the complexity, states, cities, municipalities, and counties may enact their own environmental laws and regulations.
694 Environmental Compliance Program
694.1 Description
The Postal Service’s environmental compliance program establishes strategies, evaluates activities, and administers programs and projects to ensure that federal, state, and local environmental considerations are integrated into all Postal Service operations.
694.2 Compliance
694.21 Management System
The Postal Service utilizes an environmental compliance management system for continual improvement that includes systems to manage information, allocate resources, and identify emerging Postal Service and regulatory issues. As part of the management system, the Postal Service identifies environmental aspects, their associated impacts, and determines their significance and risk.
694.22 Review
The Postal Service conducts periodic reviews of its activities and operations to ensure compliance with applicable Postal Service requirements and federal, state, and local environmental laws and regulations.
694.3 Program Evaluation and Management Review
The Postal Service conducts periodic evaluations of environmental compliance policies and programs at all levels of the organization to review the effectiveness of its compliance management system, and national environmental policies and programs, based on established metrics.
694.4 Records Management
The Postal Service maintains standardized retention schedules for required environmental records in the corporate-wide records information management system.
694.5 Data Management
The Postal Service utilizes a corporate-wide environmental information system to manage and track environmental data. The system also serves as a central repository for required environmental records.
694.6 Training and Awareness
The Postal Service ensures that employees are competent to perform tasks that have or can have significant impact on the environment. This includes providing general awareness and other environmental compliance training required by applicable federal, state, and local environmental laws and regulations, and environmental programs. Environmental compliance training courses are maintained in the corporate-wide learning management information system.
694.7 Preventive and Corrective Action
The Postal Service takes preventive measures and initiates corrective actions for non-conformance and non-compliance identified during the program evaluation and compliance review processes. The Postal Service records the results of preventive and corrective actions taken, and reviews the effectiveness of these actions.
694.8 Communication and Outreach
The Postal Service communicates to employees and customers its environmental policies, and commitment to implementing environmentally responsible business initiatives, and seeks opportunities to partner with public and private organizations to further its environmental objectives.
694.9 Budget and Resource Allocation
The Postal Service establishes a comprehensive fiscal strategy and corresponding annual operating budget to ensure compliance with applicable Postal Service requirements and federal, state, and local environmental laws and regulations. The strategy includes cost-effective compliance solutions that provide a safe and healthy environment for Postal Service employees, customers, and communities. In addition, the Postal Service assigns adequate resources to implement environmental compliance policies, programs, and the compliance management system.
695 Responsibilities
695.1 Headquarters
695.11 Chief Sustainability Officer, Office of Sustainability
The Chief Sustainability Officer (CSO), Office of Sustainability, performs the following environmental compliance program management functions:
a. Serves as the Chief Environmental Officer for the Postal Service.
b. Communicates environmental policies.
c. Allocates budget and resources for the development, implementation, and assessment of environmental compliance policies, programs, and the compliance management system.
d. Serves as chief liaison with the Environmental Protection Agency (EPA).
e. Establishes the strategic direction for the environmental compliance program.
695.12 Office of Sustainability
The Office of Sustainability, under direction of the CSO, performs the following environmental compliance and risk management functions:
a. Develops the Postal Service’s environmental compliance policies, programs, and strategies.
b. Develops and implements the Postal Service’s environmental compliance management system.
c. Identifies environmental aspects and impacts associated with Postal Service operations and determines their significance and risk.
d. Establishes national environmental compliance performance objectives with measurable targets and tracks progress towards established targets.
e. Manages the identification of federal, state, and local environmental laws, regulations, and guidelines, and incorporates them into Postal Service policy and requirements.
f. Develops and conducts periodic program-level environmental management reviews to ensure alignment with organizational objectives and management systems.
g. Develops and conducts periodic environmental compliance reviews that:
1. Assess risks and liabilities;
2. Evaluate facility activities and operations for compliance with federal, state, and local environmental laws and regulations; and
3. Recommends corrective actions, if necessary.
h. Analyzes and reports on corporate-wide environmental compliance performance and risk, trends, management and compliance review results, and emerging issues.
i. Develops and manages the corporate-level environmental compliance budget for the development, implementation, and assessment of environmental compliance policies, programs, and the compliance management system.
j. Establishes and manages the corporate-wide environmental data information system.
k. Coordinates and deploys a national environmental training program based on regulatory and operational requirements.
l. Tracks EPA, state, and local regulatory developments, and comments on proposed regulations.
m. Coordinates with other federal, state, and local agencies, trade associations, and professional stakeholders on matters of environmental management.
n. Provides environmental assistance during the prevention, preparedness, response, and recovery phases of emergencies.
o. Provides direction and assistance to area and district stakeholders to ensure consistent and standardized implementation of the Postal Service’s environmental compliance policies, programs, and management system.
695.13 Vice President, Facilities
The vice president, Facilities, performs the following environmental program management functions:
a. Ensures that environmental policies are incorporated into all aspects of facility management, including real estate transactions and design, construction, alteration, repair, and excessing activities.
b. Directs the Facilities Department to follow Postal Service environmental policies and all applicable federal, state, and local regulations when managing projects.
695.14 Facilities Department
When managing projects, the Facilities Department performs the following environmental program management functions:
a. Maintains the reports and records required by environmental regulations.
b. Ensures that such reports and records are distributed to the appropriate installation heads, and that copies are retained in the Facilities Department’s project records.
c. Obtains necessary permits and approvals required by environmental regulations.
695.15 Other Headquarters Functions
All Headquarters functions (especially Engineering, Delivery and Post Office Operations, Network Operations, Information Technology, National Preparedness, New Products and Innovation, and Supply Management) must ensure that environmental policies are incorporated into policies, programs, and projects under their control.
695.2 Area Offices
695.21 Vice Presidents, Area Operations
The vice presidents for Area Operations perform the following environmental compliance program management functions:
a. Ensure adequate resources to support area activities that directly align with national environmental policies and programs.
b. Support the efforts of the Office of Sustainability, area managers of Operations Support, the district managers, and installation heads to ensure that facilities are in compliance with environmental laws and regulations.
c. Provide the support and resources necessary to implement environmental reviews of facility activities and operations, and to see any necessary corrective actions to successful completion.
695.22 Area Managers, Operations Support
The area managers of Operations Support coordinate with the Office of Sustainability to:
a. Identify resource requirements to support area activities that directly align with national environmental policies and programs, and facilitate compliance with environmental laws and regulations.
b. Provide the support and resources necessary to implement environmental reviews of facility activities and operations, and to see any necessary corrective actions to successful completion.
695.3 Performance Clusters
695.31 District Managers
The district managers:
a. Provide the support and resources necessary for facilities under their jurisdiction to comply with federal, state, and local environmental laws and regulations, and Postal Service environmental policies and programs.
b. Ensure the timely completion of environmental corrective actions within their management control.
c. Ensure that installation heads retain environmental records required by Postal Service policy, and federal, state, and local environmental laws and regulations.
695.32 Installation Heads
The installation heads:
a. Ensure their facility’s compliance with federal, state, and local environmental laws and regulations, and Postal Service environmental policies and programs.
b. Ensure that facility personnel are properly trained, as applicable, and that such training is documented.
c. Ensure that only trained personnel manage tasks that trigger Postal Service policy, and federal, state, and local environmental laws and regulations.
d. Maintain complete and up-to-date records pursuant to Postal Service policy, and federal, state, and local environmental laws and regulations. Such records include operating permits, asbestos surveys, hazardous waste manifests, training certifications, and records of inspections.
e. Perform related tasks necessary to comply with applicable federal, state, and local environmental laws and regulations.
f. Report visits and site inspections by federal, state, and local environmental regulatory agencies, and any environmental Notice of Violation or similarly entitled notification of non-compliance to the Office of Sustainability.
695.33 Middle–Level Managers and Supervisors
Middle-level managers and supervisors ensure compliance with Postal Service policy and applicable environmental laws and regulations within their respective areas of responsibility.
695.4 All Employees
All employees must follow Postal Service policy and applicable federal, state, and local environmental laws and regulations in the conduct of their duties for the Postal Service.
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As a result of this revision, the following directives have been made obsolete:
a. Management Instruction EL-890-2007-1, Air Quality Management.
b. Management Instruction EL-890-2007-6, Water Quality Management.
c. Management Instruction EL-890-2008-2, National Storage Tank Program.
d. Handbook AS-551, Clean Air Act Compliance Guide.
e. Handbook AS-554, Water Reference Guide.
f. Handbook AS-554-A, Water Management Guide for Facility Managers.
g. Handbook AS-554-B, Water Conservation Guide.
h. Handbook AS-554-C, Vehicle Washing Technologies.
i. Handbook AS-554-D, Water Permitting Guide.
j. Handbook AS-555, Environmental Compliance Quality Assurance Review Guide.
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We will incorporate these revisions into the online update of the ASM, available on the Postal Service PolicyNet website:
n Go to http://blue.usps.gov.
n In the left-hand column under “Essential Links”, click PolicyNet.
n Click Manuals.
(The direct URL for the Postal Service PolicyNet website is http://blue.usps.gov/cpim.)
— Environmental Compliance and Risk Management,
Corporate Sustainability Office, 11-28-13
