Chapter 13 - Environmental Compliance, Stewardship, and Sustainability

1-13.1  INTRODUCTION

1. Purpose.  This issuance establishes the policy, procedures, and responsibilities for managing environmental compliance, stewardship, and sustainability objectives in the Indian Health Service (IHS).
2. Background.  Environmental sustainability efforts support the IHS mission.  Sustainable practices reduce the environmental impact of IHS operations both locally and globally.  High performance facilities use less energy and water and generate less waste.  Investments in sustainable design and operations have relatively short pay back times in health care facilities and significantly reduce operating costs over the life cycle of the facility.  Since IHS operations are highly visible in their local community the IHS can encourage and enhance Tribal community sustainability efforts by demonstrating leadership in this area.

   Executive Order (EO) No. 13514, "Federal Leadership in Environmental, Energy, and Economic Performance," directs Federal Agencies to reduce their greenhouse gas emissions; meet a number of energy, water, and waste reduction targets; and leverage Federal purchasing power to promote environmentally-responsible products and technologies.  Through ongoing utilization of environmental management system (EMS) elements, and implementation of new tools and processes that will improve our environmental performance, the IHS can be a stewardship leader among Department of Health and Human Services (HHS) operating divisions.

3. Goals.
   1. Water Management.  The IHS will act to minimize the impact of water consumption on the environment.  The IHS water management objectives are as follows:
      1. Reduce potable water use intensity by at least 26% by fiscal year (FY) 2020 (2% annually) using FY 2007 consumption data as the baseline.
      2. Reduce non-potable water use (industrial, landscaping, agricultural) by at least 20% by FY 2020 (2% annually) using FY 2010 consumption data as the baseline.
      3. Identify and implement water reuse strategies.
      4. Achieve objectives established by the Environmental Protection Agency (EPA) Storm Water Guidance for Federal Facilities.
   2. Waste Management.  The IHS will manage the consumption of materials to reduce solid waste, increase recycling, and ensure the appropriate reuse of materials.  The IHS waste management objectives are as follows:
      1. Divert at least 50% of non-hazardous solid waste from going to landfills and incinerators by FY 2015.
      2. Divert at least 50% of construction and demolition materials and debris from going to landfills and incinerators by FY 2015.
   3. Greenhouse Gas Emissions Reduction:  Scope 1 and 2.  Through reduction of energy and fuel use, the IHS will reduce greenhouse gas emissions.  The IHS energy use reduction objectives are as follows:
      1. Consider actions associated with reducing energy consumption, increasing the use of renewable energy, and implementing renewable energy generation projects on agency property.
      2. Reduce the consumption of petroleum products in fleet management by 2% annually through the end of FY 2020, using FY 2008 consumption data as the baseline.
      3. As established in the HHS Strategic Sustainability Performance Plan, the IHS will meet all other greenhouse gas and energy-related aspects and goals of EO 13514 to reduce Scope 1 and Scope 2 greenhouse gas emissions by 10.4% by 2020.
   4. Greenhouse Gas Emissions Reduction:  Scope 3.  In accordance with the HHS Strategic Sustainability Performance Plan, the IHS will reduce Greenhouse Gas Scope 3 emissions by 3.3% by 2020 by reducing government-related travel, reducing solid waste contributions to landfills, and through similar initiatives.
   5. High-Performance Sustainable Design/Green Buildings.  The IHS will ensure that sustainable design practices are incorporated into facilities planning and design for new construction and renovation projects.  The Agency's sustainable building objectives are as follows:
      1. Ensure that all new construction, major renovation, or repair and alteration of Federal buildings comply with the Guiding Principles for Federal Leadership in High Performance and Sustainable Buildings Memorandum of Understanding (MOU), January 2006.
      2. Manage existing building systems to reduce energy, water, and materials consumption in a manner that achieves a net reduction in Agency-deferred maintenance costs.  At least 15% of our existing buildings and building leases will meet the Guiding Principles for Federal Leadership in High Performance and Sustainable Buildings MOU, January 2006, mandates by FY 2015.
      3. Beginning in FY 2020, design all new buildings to achieve zero-net energy by FY 2030.
      4. Implementing, managing, and reporting on sustainable building measures, the IHS will utilize the HHS Federal Real Property Asset Management Sustainable Buildings Implementation Plan, Office for Facilities Management and Policy, December 2008.
   6. Sustainable Acquisitions.  Whenever possible, the IHS will acquire environmentally-preferable products and ensure that sustainable practices and language are included in contracts.  The IHS utilizes the HHS Affirmative Procurement Plan Exit Disclaimer: You Are Leaving www.ihs.gov (APP) as a guide for environmentally-preferable purchasing.
      

      The IHS sustainable acquisitions objectives are as follows:

      1. Ensure that 95% of new contract actions, including task and delivery orders for products and services are energy-efficient (Energy Star or Federal Energy Management Program (FEMP)-designated), water-efficient, bio-based, environmentally-preferable, non-ozone depleting, contain recycled-content materials, and/or are non-toxic or less toxic alternatives.
      2. Update Agency affirmative procurement plans, policies, and programs to ensure that Federally-mandated designated products and services are included in all relevant acquisitions.
      3. Environmentally-Preferable Purchasing (EPP) includes a procurement preference for Electronic Product Environmental Assessment Tool (EPEAT) registered or certified electronic products.
   7. Electronics Stewardship and Data Centers.  The IHS will ensure that electronic systems and equipment are utilized in such a manner as to minimize negative impacts on the environment through reductions in energy consumption and the generation of electronics waste.  The IHS electronics stewardship objectives are as follows:
      1. Establish and implement policy and guidance to ensure the use of power management, duplex printing, and other energy-efficient or environmentally-preferable options and features.
      2. Reflect environmentally sound practices for disposition of all agency excess or surplus electronics products.
      3. Ensure implementation of best management practices to ensure the energy-efficient management of servers and Federal data centers.
      4. Adhere to the HHS Electronic Stewardship Plan.
   8. Regional and Local Planning.  The IHS will consider how planning for new facilities impacts regional environmental stewardship concerns.  The IHS regional and local planning objectives are as follows:
      1. Participate in regional transportation planning (recognition and use of existing community transportation infrastructure).
      2. Align IHS policies to increase the effectiveness of local energy planning.
      3. Incorporate sustainable building locations into policy and planning for new Federal facilities and leases.
      4. Update IHS policy and guidance to ensure that all Environmental Impact Statements and Environmental Assessments required under the National Environmental Policy Act (NEPA) for proposed new or expanded Federal facilities identify and analyze impacts associated with energy usage and alternative energy sources.
      5. Update IHS policy and guidance to ensure coordination and, where appropriate, consultation with Federal, State, Tribal and local management authorities regarding impacts to local ecosystems and watersheds.
4. Policy.  It is IHS policy to comply with Federal environmental regulations and directives; and continually improve IHS sustainable practices.
5. Definitions.
   1. Affirmative Procurement Plan.  The HHS' APP, the "green purchasing" plan, provides guidelines for an effective green purchasing program that encompasses the purchasing and use of designated recycled content, Energy Star, EPEAT-registered, energy-efficient, bio-based, and environmentally-preferable products.  The plan ensures that green products will be purchased to the maximum extent practicable.
   2. Agency Property.  All property, whether owned or leased, directly operated by the IHS.
   3. Electronic Assets.  Electronic assets are desktop and laptop computers, workstations, and computer monitors
   4. Electronic Product Environmental Assessment Tool Exit Disclaimer: You Are Leaving www.ihs.gov .  A system that helps purchasers evaluate, compare, and select electronic products based on their environmental attributes.  The system currently covers desktop and laptop computers, workstations, and computer monitors.
   5. Electronics Stewardship Plan.  An HHS plan used to implement strategies to improve the life cycle environmental management of electronic assets.  These guidelines cover acquisition, operations and maintenance, and end-of-life management.
      Electronic Stewardship Plan For the U.S. Department of Health and Human Services, Office of the Secretary, May 2007.Exit Disclaimer: You Are Leaving www.ihs.gov .
   6. Energy Star Exit Disclaimer: You Are Leaving www.ihs.gov .  Energy Star is a joint program of the EPA and the Department of Energy.  The goal of the program is to help the nation save money and protect the environment through energy-efficient products and practices.
   7. Environmental Audit.  An environmental audit process using the OEHE Environmental Audit Protocol methods to ensure that IHS operated programs are in compliance with Federal EPA regulations.  All IHS operated facilities will be audited every five years.
   8. Environmental Compliance.  Actions taken to ensure that an organization meets the minimal requirements of applicable environmental regulations and pertinent EOs.
   9. Environmental Stewardship.  The responsibility for environmental quality shared by those whose actions affect the environment.
   10. Environmentally-Preferable.  Products or services that have a lesser or reduced effect on human health and the environment when compared with competing products or services that serve the same purpose.  This comparison applies to raw materials, manufacturing, packaging, distribution, use, reuse, operation, maintenance, and disposal.
   11. Executive Order.  An order issued by the President of the United States of America to manage operations of the Federal Government.  Executive Orders have the force of law.  (See Executive Orders Exit Disclaimer: You Are Leaving www.ihs.gov  to view the environmental EOs.)
   12. External Audit.  An audit conducted by a party not involved in the planning or implementation of a process.
   13. Federal Energy Management Program Exit Disclaimer: You Are Leaving www.ihs.gov .  This program facilitates the Federal government's implementation of sound, cost-effective energy management, and investment practices to enhance the nation's energy security and environmental stewardship.
   14. Greenhouse Gas.  Gases that trap heat in the Earth's atmosphere.  Greenhouse gases include water vapor, carbon dioxide, methane, nitrous oxide, fluorinated gases, and ozone.
   15. Greenhouse Gas Protocol Initiative.  The Greenhouse Gas Protocol Initiative Exit Disclaimer: You Are Leaving www.ihs.gov  defines three scopes of greenhouse gas emissions.
       1. Scope 1:  Emissions directly emanating from stationary buildings and vehicles.
       2. Scope 2:  Emissions from the generation of electricity purchased and consumed by the IHS for Agency operations.
       3. Scope 3:  Emissions that are a consequence of activities including, but not limited to, employee travel, transportation of goods to facilities, and disposal of solid waste in landfills.
   16. Sustainability.  In the context of environmental stewardship, sustainability refers to the long-term management of our facilities and operations in a manner which ensures that the IHS practices, planning, and operations reduce our impact on the environment.  Sustainable practices ensure that the actions of the present generation do not compromise the environment for future generations.
   17. Zero Net Energy.  A general term applied to a building's use with zero net energy consumption and zero greenhouse gas emissions annually.
6. Authorities.
   1. Executive Order No. 13423Exit Disclaimer: You Are Leaving www.ihs.gov , "Strengthening Federal Environmental, Energy and Transportation Management," Federal Register (FR) Vol. 72, No. 17, Friday, January 26, 2007.

      Codified into law by Omnibus Appropriations Act of 2009, Public Law. 111-8, 123 Stat. 524 (2009).

   2. Executive Order No.13514Exit Disclaimer: You Are Leaving www.ihs.gov , "Federal Leadership in Environmental, Energy, and Economic Performance," FR Vol. 74, No. 194, Thursday, October 8, 2009.
   3. Department of Health and Human Services Strategic Sustainability Performance PlanExit Disclaimer: You Are Leaving www.ihs.gov 
   4. Department of Health and Human Services Strategic Sustainable Buildings Implementation PlanExit Disclaimer: You Are Leaving www.ihs.gov , December 31, 2008 or current version.
   5. Department of Health and Human Services Strategic Electronics Stewardship PlanExit Disclaimer: You Are Leaving www.ihs.gov , May 2007 or the current version.
   6. Affirmative Procurement Plan:  Purchasing Environmentally Preferable Products and ServicesExit Disclaimer: You Are Leaving www.ihs.gov  at the U.S. Department of Health and Human Services, issued by the Office of the Secretary, Office of the Assistant Secretary for Administration and Management, Office of Acquisition Management and Policy, April 2009.
   7. The Greenhouse Gas Protocol Exit Disclaimer: You Are Leaving www.ihs.gov  for the U.S. Public Sector, Interpreting the Corporate Standard for U.S. Public Sector Organizations, World Resources Institute and Logistics Management Institute (LMI), October 2010.
   8. United States Environmental Protection Agency, Technical Guidance on Implementing the Stormwater Runoff Requirements for the Federal Projects under Section 438 Exit Disclaimer: You Are Leaving www.ihs.gov  of the Energy Independence and Security Act.  EPA 841-B-09-001, December 2009.
   9. Guiding PrinciplesExit Disclaimer: You Are Leaving www.ihs.gov  for Federal Leadership in High Performance and Sustainable Buildings, January 2006.
   10. Indian Health Service Environmental Compliance Awareness Guide, Office of Environmental Health and Engineering (OEHE), December 2007.
   11. OEHE Technical Handbook - Volume View:
       1. Volume III, Part 23-1 Environmental Reviews (NEPA)
       2. Volume III, Part 21, Chapter 21-17.2   Sustainability Guidelines for New Facility Construction, Build-To-Lease and Major Renovations
       3. Volume VI, Part 72-2:  Energy Management Program
       4. Volume VI, Part 72-4:  Water Management.
       5. Volume VI, Part 75-1:  Environmental Audit Process
       6. Volume IX, Part 120:  Administration and Management
   12. Affirmative Procurement Plan:  Purchasing Environmentally Preferable Products and Services at the U.S. Department of Health and Human Services, Office of the Secretary, Office of the Assistant Secretary for Administration and Management, Office of Acquisition Management and Policy, October 2010.

1-13.2  ENVIRONMENTAL STEWARDSHIP COMPONENTS

1. Compliance.  The IHS will comply with:
   1. all EO No. 13514 and EO No. 13423 applicable requirements.
   2. all applicable Federal, State, Tribal, and local environmental laws.  The IHS Environmental Compliance Awareness Guide provides an overview of most applicable environmental regulations.
   3. all IHS construction and renovation projects will adhere to NEPA planning requirements.  See the Environmental Review Manual
2. Environmental Management System.  An EMS is a quality assurance tool used to identify environmental impacts, develop objectives and targets, prioritize actions to reduce or eliminate negative impacts, monitor progress, and develop management reports.  The IHS will use EMS principlesExit Disclaimer: You Are Leaving www.ihs.gov  in planning and implementing sustainability efforts.
3. Audits.
   1. General.  All IHS facilities will participate and respond to general audit requests in a timely manner.  Environmental EOs and HHS implementation guidance policy contain requirements for periodically assessing environmental stewardship progress, gaps, and successes.
   2. Environmental Audit.  To evaluate compliance with environmental regulations, all IHS facilities are subject to regulatory compliance audits.  The IHS Environmental Audit Protocol will be used for this internal evaluation.
   3. Sustainable Building Audits.  All IHS-operated facilities are subject to Sustainable Building Audits to ensure that IHS operations are conducted in a sustainable manner.  (See the Sustainability chapters in the OEHE Technical Handbook.)
4. Reports.  The Office of Management and Budget (OMB), HHS, and the IHS may impose data calls or other reporting requirements to collect information on the implementation of the environmental EOs.

1-13.3  RESPONSIBILITIES

1. Director, IHS.  The Director, IHS:
   1. ensures administrative compliance with all environmental regulations, environmental-related EOs, and HHS sustainability requirements.
   2. appoints an Agency sustainability workgroup representative to serve as the Sustainability Outreach/Communications Manager.
2. Office Directors and Division Directors.  All IHS Office Directors and Division Directors are responsible for promoting and integrating environmental stewardship and sustainable principles into their work practices.
3. Chief Sustainability Officer.  The Director, IHS, will appoint the Chief Sustainability Officer (CSO).  The CSO will be supported by a Sustainability Advisory Board.  (See IHS Circular No. 2013-03, "Sustainability Advisory Board - Charter.")  The Sustainability Advisory Board will assist the CSO in providing guidance to the IHS Director on issues pertaining to environmental stewardship and sustainability.  The primary functions of the CSO are:
   1. Facilitate and direct cooperation among the various program managers to achieve the EO goals and EMS implementation.
   2. Communicate sustainability initiatives to IHS leadership.
   3. Coordinate accurate and timely feedback to relevant HHS data calls.
   4. Actively participate in HHS sustainability efforts and workgroups as appropriate.
   5. Serve as the central point of contact for all sustainability issues or questions, including official HHS sustainability data calls.
   6. Appoints the Sustainability Outreach/Communications Manager.
4. Director, Office of Information Technology.  The Director, Office of Information Technology, is responsible for ensuring that electronics stewardship and data center energy usage concerns are addressed across the IHS.  Responsibilities include the following:
   1. Appoint an Agency Sustainability Workgroup Representative to serve as the Electronic Stewardship and Data Consolidation Manager.
   2. Coordinating and communicating electronics stewardship issues, initiatives, and goals to IHS personnel in Information Technology programs, acquisitions, and contracts management, biomedical engineering, and other key technology positions at all levels of the organization.
   3. Technical consultation on electronics stewardship initiatives.
   4. Developing programs to address electronic stewardship issues.
   5. Responding to HHS data requests related to the EOs.
5. Director, Office of Management Services.  The Director, Office of Management Services, is responsible to ensure that provisions are in place to address sustainable acquisitions, reduction of greenhouse gas emissions, and reduction of fuel use pertaining to fleet operation.  Responsibilities include:
   1. Coordinating and communicating stewardship issues, initiatives, and goals specifically related to functions of property and supply programs, acquisition policy, fleet management, and human resource areas, such as telework.
   2. Responding to HHS data requests related to the functional areas listed in E(1) above.
6. Director, Office of Environmental Health and Engineering.  The Director, OEHE, is responsible for ensuring that provisions are in place to address high-performance sustainable design, reduction of energy and water consumption, reduction of greenhouse gas emissions pertaining to fixed facilities across the IHS, and waste management.  Responsibilities include the following:
   1. Coordinating and communicating facility design and facility operations stewardship issues, initiatives, and goals to all levels of the organization.
   2. Providing technical consultation on facility design and facility operations stewardship initiatives.
   3. Developing programs to address facility design and facility operations environmental issues.
   4. Appointing Agency Sustainability Workgroup Representatives to serve as the Environmental Manager, Pollution Prevention/Waste Manager, Energy/Water Manager, and Sustainable Green Buildings Manager.
   5. Responding to HHS data requests related to EOs.
7. The Sustainability Outreach and Communications Manager.  The Sustainability Outreach and Communications Manager is responsible for:
   1. Overall internal and external sustainability communications.
   2. Coordinating activities with and supporting the HHS Sustainability Outreach and Communications Manager.
   3. Advising senior leadership on sustainability outreach and communication issues.
   4. Assisting in preparing and disseminating outreach materials and promoting outreach events.
8. Environmental Manager.  The Environmental Manager is responsible for:
   1. Assisting organizational personnel and operations in achieving and maintaining compliance with applicable environmental regulations.
   2. Participating in the HHS Environmental Manager Workgroup by attending periodic meetings and providing review and technical comments.
   3. Providing accurate and timely feedback to environmental data-calls.
   4. Reviewing and providing comments to proposed HHS environmental goals, policies, and guidance documents.
   5. Developing an environmental management implementation strategy.
9. Pollution Prevention and Waste Manager.  The Pollution Prevention and Waste Manager is responsible for:
   1. Assisting organizational personnel and operations in achieving and maintaining compliance with applicable environmental regulations.
   2. Participating in the HHS Sustainability Pollution Prevention Workgroup.
   3. Providing accurate and timely feedback to waste management data-calls.
   4. Reviewing and providing comments to proposed HHS waste management goals, policies, and guidance documents.
10. Green Procurement Manager.  The Green Procurement Manager is responsible for:
    1. Serving as the organizational coordinator on green procurement requirements and procedures.
    2. Informing organizational personnel of their responsibilities under the HHS' APP.
    3. Promoting staff awareness of the environmental issues affecting procurement and ensuring procurement personnel receive appropriate training regarding APP products and services.
    4. Actively participating in the HHS Sustainability Green Procurement Workgroup.
    5. Reviewing and providing comments to proposed updates to HHS APP.
    6. Providing timely and accurate information for data calls to the HHS Green Procurement Manager.
    7. Providing contract standard language and ensure that contracts include requirements for environmentally-preferred products and services.
11. Energy and Water Manager.  The Energy and Water Manager is responsible for:
    1. Serving as the organizational coordinator on overall compliance with energy and water laws, regulations, and EOs.
    2. Establishing procedures and awareness programs to ensure organizational personnel and operations comply with applicable energy and water requirements.
    3. Participating in the HHS Sustainability Greenhouse Gas Scope 1 & 2 Workgroup.
    4. Providing timely and accurate information for data calls.
    5. Reviewing and providing comments to proposed HHS energy and water goals, policies, and other guidance documents.
12. Greenhouse Gas Scope 3 Manager.  The Greenhouse Gas Scope 3 Manager (Telework/Travel/Commuting) is responsible for:
    1. Serving as the organizational coordinator on HHS Greenhouse Gas Scope 3 mandates.
    2. Establishing procedures and awareness programs to ensure organizational personnel and operations comply with the applicable HHS Greenhouse Gas Scope 3 goals.
    3. Coordinating activities with the Environmental Manager.
    4. Advising senior leadership on telework or transportation issues.
    5. Supporting HHS Greenhouse Gas Scope 3 initiatives.
13. Fleet Manager.  The Fleet Manager is responsible for:
    1. Serving as the organizational coordinator on overall compliance with fleet management laws, regulations, and EOs.
    2. Establishing procedures and awareness programs as required to ensure organizational personnel and operations comply with applicable fleet management requirements.
    3. Actively participating in the HHS Sustainability Greenhouse Gas Scope 1 and Scope 2 Workgroup.
    4. Providing timely and accurate information for data calls to the HHS Fleet Manager.
14. Electronic Stewardship and Data Consolidation Manager.  The Electronic Stewardship and Data Consolidation Manager is responsible for:
    1. Serving as the IHS coordinator on electronics stewardship management.
    2. Encouraging IHS employees to purchase greener electronic products, reduce impacts of electronic products during use, and manage obsolete electronics in an environmentally safe way.
    3. Actively participating in the HHS Sustainability Electronic Stewardship Workgroup.
    4. Adapting the HHS Electronics Stewardship Plan to fit the IHS mission.
    5. Using EPEAT registered products.
    6. Activating Energy Star power settings.
    7. Ensuring policies and programs are in place to extend the useful lifetime of IT equipment.
    8. Ensuring environmentally sound end-of-life management practices.
    9. Providing timely and accurate information for data calls to the HHS Electronic Stewardship Manager.
15. Sustainable Green Buildings Manager.  The Sustainable Green Buildings Manager is responsible for:
    1. Serving as the organizational coordinator on sustainable green building design, construction, operations, and maintenance.
    2. Advising senior leadership on sustainable issues and participating in the development of HHS policies related to sustainability requirements.
    3. Actively participating in the HHS Sustainable Buildings Workgroup.
    4. Providing feedback on sustainability data calls.
    5. Monitoring organizational progress in incorporating the Guiding Principles from the Memorandum of Understanding for Leadership in High Performance and Sustainable Buildings.
16. Area Director.  The Area Director will:
    1. Prioritize and address environmental stewardship and sustainability issues, ensure that IHS facilities utilize a quality improvement structure (plan, do, check, and act).
    2. Use existing safety or environment of care committee to identify, prioritize, monitor, and improve deficiencies recommended as a method of assuring that environmental stewardship and sustainability issues are addressed.
    3. Adhere to internal IHS environmental policies, guidelines and initiatives.  Examples include following regulatory and sustainability audit practices, using EMS principles, disposing of IHS generated waste in EPA compliant landfills, and following internal guidance on property demolition and disposal.
    4. Ensure that Area operations meet or exceed all Federal, State, Tribal, and local environmental regulations and policy requirements.
    5. Participate in environmental audits of the Area Office.
    6. Address EO 13423 and EO 13514 requirements and establish priorities for implementation.
    7. Provide specific environmental training as needed.
    8. Provide timely information for environmental stewardship and sustainability reports as requested by the OMB, the HHS, and the IHS.
    9. Appoint a primary contact for environmental stewardship and sustainability at each Service Unit.  It is recommended that the primary contact be in a position of higher-level authority because the aspects of environmental stewardship and sustainability involve many organizational functions including property and supply, information technology, finance, facilities management, safety, and environmental health.
    10. Establish Chief Executive Officer (CEO) performance elements that incorporate environmental stewardship and sustainability goals and responsibilities set forth in this policy.
17. Chief Executive Officer.  The CEO is responsible for ensuring that all aspects of environmental stewardship and sustainability are implemented in their Service Unit as follows:
    1. Use the existing safety or environment of care committee to identify, prioritize, monitor, and improve deficiencies recommended as a method of en suring that environmental stewardship and sustainability issues are addressed.
    2. Adhere to internal IHS environmental policies, guidelines and initiatives.  Examples include following regulatory and sustainability audit practices, using EMS principles, disposing of IHS generated waste in EPA compliant landfills, and following internal guidance on property demolition and disposal.
    3. Ensure that Service Unit operations meet or exceed all Federal, State, Tribal, and local environmental regulations and policy requirements.
    4. Participate in environmental stewardship and sustainability audits.
    5. Address the requirements of EO 13423 and EO 13514 and establish priorities for implementation.
    6. Prioritize and address environmental stewardship and sustainability issues.
    7. Utilize a quality improvement structure (plan, do, check, and act).
    8. Provide for specific environmental training when needed.
    9. Provide timely information for environmental stewardship and sustainability reports as requested by OMB, HHS, and the IHS.
18. Supervisors.  Supervisors encourage employees to use public transportation, bicycle, car-pooling, and telework programs that help to reduce greenhouse gas emissions.
19. Employees.  All IHS employees are responsible for incorporating stewardship decisions into their daily job functions including, at a minimum, the following measures:
    1. Conserving power by turning off lights and electrical equipment when not in use.
    2. Always considering environmentally-preferable products, including reduced-packaging products that limit waste and are composed of materials that can be reused or recycled, when making purchasing decisions.
    3. Utilizing recycling programs when available and dispose of all waste appropriately.
    4. Using duplex copying or printing when possible to reduce paper consumption.
    5. Minimizing work travel and considering whether teleconferencing or web conferencing or other methods may be used in lieu of travel.