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Audit of Environmental Compliance - Management Action Plan
February 2005
Human Resources and Corporate Service |
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| Recommendations | Management Action Plan | Actions Completed | Actions Out-standing | Estimated Completion Date |
|---|---|---|---|---|
| 1) Clear identification of the accountability for environmental compliance at all levels throughout the department is needed. This includes the identification of compliance levels and reporting requirements related to every program and site in the department and which apply to program staff in the conduct of their work both in DFO facilities as well as in the field. | - The Office of Environmental Coordination (OEC) will develop an accountability framework identifying clear roles and responsibilities regarding the achievement and maintenance of environmental compliance (from the ADM to the Director level) in all Sectors and Regions by October 1, 2004.
- This will be presented to the Departmental Management Committee in November 2004 for approval. |
- Completed |
- Scheduled for DMC on March 2, 2005. | |
| - The second component of this accountability framework will identify clear roles and responsibilities regarding the achievement and maintenance of environmental compliance below the Director level in all Sectors and Regions.
- This will be completed by December 1, 2004. |
- Inventory of 300 positions developed. - Drafting of accountabilities underway. Consultation ongoing. |
- To be scheduled for DMC early in 2005-06. | ||
| - An awareness program will be put in place to ensure that all staff are fully aware of their responsibilities by March 31, 2005
- This awareness is maintained as staff and programs change. |
- Pilot awareness program developed. Testing in Pacific Region scheduled Feb, 2005. | - Delivery across Department next fiscal year. | ||
| - Updating of program will be ongoing. | ||||
| 2) A comprehensive risk-based plan is needed to assess and ensure environmental compliance at all sites and in the conduct of all programs. Environmental studies and corrective actions should be implemented based on an explicit integrated risk management framework. | - A comprehensive risk based national action plan is now being developed and will be completed by March 31, 2004. This plan will include an explicit ranking of risks which is approved by the Departmental Management Committee that will direct efforts to the areas of highest priority. | - Completed. | ||
| - The process that is used by the Office of Environmental Coordination to allocate funds to specific environmental priorities is being reviewed and updated to focus on the achievement of environmental compliance. A revised process will be proposed by September 1, 2004. | - Funding criteria and process have been updated and tested with regions. | - Revised process will be in place for 2005-06 OEC allocation. | ||
| - Approaches used outside of DFO, in other departments and agencies, will be assessed to identify best practices that can be used in DFO. | - Completed. | |||
| - Spending will continue to be monitored and results tracked and reported to Senior Management. | - 2003-04 Annual Report for OEC tracked investments and results. | - 2004-05 Annual Report will track investments and results. | ||
| - DFO is building an Environmental Compliance component in the Department’s Real Property Strategy (DRPS) and will be identified in the Long Term Capital Plan (LTCP) renewal exercise and during its annual capital planning priority budget setting exercises. | - Completed | |||
| - The LTCP renewal exercise will be presented to DMC for approval in late fall or early winter 2004 and submitted to TBS by March 31, 2005. | - Will be submitted to TBS by end of March 2005. | |||
| - The Department is working towards a comprehensive risk based strategy that will direct efforts towards out of compliance conditions, addressing the most important problems first. | - Levels of risk are included in NECAP which drive investment decisions and actions and were reflected in LTCP priorities for 2005-06 – 2009-10. | |||
| - This will be accompanied by a series of standard operating procedures for specific classes of activity, for example hazardous materials & fuel storage systems. These procedures were deemed priorities by Regions in their Action Plan submissions. | - SOPs have been drafted for hazardous materials and fuel storage tanks. | - SOPs to be translated and distributed by March 31, 2005. | ||
| - DFO is committed to developing an effective environmental compliance training curriculum in FY 2004-05. This program will initially be focused on hazardous materials management and fuel storage systems management. | - Development of training curriculum for hazardous material and fuel tanks is underway. | - Curriculum to be translated and distributed by March 31, 2005. | ||
| - Prioritized risk-based management plans will be created to address key departmental environmental aspects including hazardous materials, contaminated sites and storage tank systems. | - EMPs have been developed for hazardous materials and fuel storage tanks. | - Will be translated and distributed by March 31, 2005. | ||
| 3) Sent to Science Sector for completion. | ||||
| 4) A comprehensive and effective environmental compliance monitoring and reporting program, which assesses compliance across the Department, is needed to assure compliance is achieved and maintained across the department. This program should provide an annual environmental compliance status report to the Departmental Management Committee. | - OEC, in consultation with the Audit and Evaluation Directorate, operational Sectors and Regions will complete the baseline assessment by March 31, 2004. | - Completed. | ||
| - The baseline assessment will be distributed to DMC by June 30, 2004. | - Completed. | |||
| - The baseline assessment will be updated annually with new audit findings by June of each year. | - Ongoing | |||
| - The Office of Environmental Coordination (OEC) will report to DMC in September 2004 on progress in implementing the Compliance Action Plans in all regions. | - RDGs received compliance action plan updates for their respective region. | |||
| - An annual departmental report will be prepared by the OEC and presented to DMC by June of each year. Not only will the cycle of environmental reporting be regularized over the course of the next year, but also the quality of the reporting will be enhanced. | - 2003-04 Annual Report finalized. | - To be presented at March 2, 2005 DMC. | ||
| - OEC, in consultation with the Audit and Evaluation Directorate, will develop a Compliance Assurance Program for DMC’s consideration. The Program will include independent site audits to provide DMC with assurance on the accuracy of reporting. This will be completed by June 2004. | - A draft Compliance Audit Guide has been prepared. Regional consultation have been initiated. | - The meeting with Audit and Evaluation is to be held prior to presenting Guide to DMC by the end of March 2005. | ||
| 5) An organizational and functional review of the Office of Environmental Coordination, the Regional Environmental Coordinators and the Environmental Services group in the Coast Guard is needed assess the suitability and effectiveness of the current structure of these organizations in the NCR and the regions in achieving and maintaining environmental compliance. | - An organizational and functional review has been launched to evaluate the governance structure, resources, roles and responsibilities of the various environmental coordination functions in the Department. Consultations are currently underway with Sectors and Regions and will be completed by September 2004. | - In the context of the HRCS Stabilization exercise, OEC developed a Service Catalogue.- Roles and responsibilities of OEC positions have been developed in consultation with regions and other sectors.- One day consultation session with all Sectors was held in Janaury to review respective sectoral roles on environmental compliance.- LTCP exercise provided 5 year resource allocation plan (aligning resources to environmental compliance priorities.) | - Develop SLA between Commissioner and ADM HRCS to confirm roles and service offer for 2005-06.- Return to DMC fall 2005. | |
| - This review will recognize and build on the Departmental Alignment and Assessment Program and the new structural arrangements regarding the Coast Guard. | - Draft Environmental Policy Accountability Framework being discussed with CCG in context of SOA. | |||
SCIENCE |
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| 3) A remedy for the specific non compliance that exists regarding the DFO operated chemical control program, directed at the elimination of the sea lamprey in the Great Lakes, should be a priority. | s.21(1)(a)(b) s.23 In the interim, the sea lamprey management program will continue to strictly adhere to the standard operating and reporting protocols1 as referenced by the pesticide label prescribed by Health Canada to regulate the application of pesticides, minimize non-target mortality and ensure maximum benefits to the Great Lakes fishery. These protocols are set down in the document entitled "Standard Operating Procedures for Application of Lampricides in the Great Lakes Fishery Commission Integrated Management of Sea Lamprey Control Program" which is available from the DFO Regional office in Burlington, Ontario. |
s.21(1)(a)(b) s.23 |
s.21(1)(a)(b) |
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