Checking, Preventive, and Corrective Action

Procedure

Environmental and EMS monitoring and measurement requirements are identified, communicated, and conducted for practices/aspects. Types of monitoring requirements may include tracking data needed to monitor progress towards achieving environmental objectives and targets, or monitoring required by compliance regulations or permit. Sampling and analysis must also be conducted as required. Environmentally-related equipment is calibrated as necessary and calibration is verified before use. Data needed to respond to data calls and compliance reports and information as requested for semi-annual and annual DoD EMS metrics is collected and submitted. Records associated with monitoring and measurement activities are maintained as required by applicable policy and regulations.

Roles and Responsibilities

1. EAD program managers: identify, communicate and conduct environmental and EMS monitoring and measurement requirements for practices/aspects.
2. EMS Program Manager: collects and submits information as requested for semi-annual and annual DoD EMS metrics.
3. Working Group(s): communicate data needed to track progress to practice owners.
4. Practice owners: conduct sampling and analysis as required; notify EAD of changes in operations that may require sampling and analysis; calibrate environmentally-related equipment as necessary and verify equipment calibration before use.
5. EAD program managers: collect data needed to respond to data calls and compliance reports.

Procedure

The installation implements a self-audit plan per USMC policy and conducts annual self-audits of environmental programs as described in the self-audit plan and the Environmental Compliance Evaluation (ECE) program. Approximately every three years, HQMC conducts a benchmark ECE audit. Out-briefings are conducted to present findings and clarify any issues related to the self-audit and/or ECE results. Corrective actions are implemented using Plans of Action and Milestones (POA&Ms) developed under the Problem Solving procedures and progress in achieving POA&Ms is closely monitored.

Roles and Responsibilities

1. ECE Program Manager: develops and implements a self-audit plan; coordinates with HQMC to ensure benchmark ECEs are conducted; conducts out-briefings to present findings and clarify any issues related to the self-audit and/or ECE results.
2. EAD: conducts annual self-audits of environmental programs; monitors progress in achieving POA&Ms.
3. Environmental Discussion Board: supports organizational preparation for annual and Benchmark ECEs; develops recommendations to present to the Commanding Officer to improve MCAS Cherry Point environmental performance.
4. Contractors and vendors: participate in self-audits as allowed for within contract language or memoranda of understanding.

Procedure

Problem solving is the next step following a compliance evaluation, EMS audit, or general observation. Potential deficiencies are identified through internal (self-audits) and external (benchmark ECE) program reviews on an annual and triennial basis, respectively. Following these reviews, a POA&M is developed for every compliance or conformance finding that is appropriate to the magnitude of the problems and potential or actual environmental impacts. Controls are modified, selected, created, and implemented as a result of corrective and preventive actions, if needed. Corrective actions and POA&Ms are routinely monitored until complete, and monitoring is validated on at least an annual basis. Proposed POA&Ms are reviewed to ensure that they do not result in an increase in environmental impacts. Annually, the results of problem-solving activities, including suggested corrective and preventive actions are compiled to support the Management Review. The results of environmental and EMS reviews are analyzed by the installation and corrective actions are developed as necessary.

Roles and Responsibilities

1. ECE Program Manager: identifies potential deficiencies.
2. EMS Program Manager: identifies potential deficiencies; reviews proposed POA&Ms; communicates results to EAO/CO during Management Review.
3. EAD program managers: develop a POA&M for each compliance or conformance finding; review, modify, select, create, and implement controls; monitor corrective actions and POA&Ms until complete; validate monitoring; communicate results to EMS Program Manager.
4. Practice owners (including contractors and vendors): communicate and implement problem-solving activities/solutions as they relate to their practices.
5. EAO: provides management support for prescribed audit programs and communicates findings to the CO during the Management Review.
6. Environmental Discussion Board: analyzes the results of environmental and EMS reviews and develops corrective actions.

Procedure

The two main components of EMS audit are the annual internal EMS audit and the triennial external Benchmark ECE. An annual internal EMS self-audit schedule, scope, and agenda are developed each year. Practice owners are required to participate in the annual EMS audit as requested. Internal auditors that meet the training requirements within MCO 5090.2 conduct the audit, identifying and documenting any findings. Upon audit completion, out-briefings are conducted to present findings and clarify any issues and submit completed internal EMS self-audit checklists. Following each internal or external audit, POA&Ms are developed for each internal EMS self-audit and benchmark ECE discrepancy and progress toward achieving POA&Ms is tracked. The annual EMS Audit and Conformance Summary with auditors’ training certificates is posted to the EM Portal / Environmental Data Repository no later than December 31st of each year. The summary is posted under appropriate cover signed by the active installation CO and containing the required content outlined in USMC policy.

Roles and Responsibilities

1. EMS Program Manager: develops an annual internal EMS self-audit schedule, scope, and agenda; develops POA&Ms; tracks progress toward achieving POA&Ms; posts the annual EMS Audit and Conformance Summary and training certificates.
2. Internal auditors: receive the appropriate training to conduct internal EMS audits; conduct the audit; conduct out-briefings with the ECE and EMS program managers to present findings and clarify any issues; submit completed internal EMS self-audit checklists.
3. Practice owners: participate in the annual EMS audit.
4. ECE Program Manager: coordinates the triennial Benchmark ECE with HQMC; develops POA&Ms; tracks progress toward achieving POA&Ms.
5. Environmental Discussion Board: assists with the development of recommendations to present to the Commanding Officer to improve MCAS Cherry Point environmental performance.