DCAMM did not ensure that all solid waste recycling requirements in state-owned buildings were met.
The Division of Capital Asset Management and Maintenance’s (DCAMM’s) facility managers at state-owned and state-occupied buildings did not ensure that occupants of those buildings adhered to established solid waste recycling requirements. By not ensuring that occupants in state-owned buildings fully comply with these requirements, DCAMM creates a higher-than-acceptable risk of building occupants improperly handling their solid waste and losing the opportunity to obtain revenue (recycling credits for the value of recycled materials) that would reduce the Commonwealth’s costs for waste disposal.
By not ensuring that occupants in state-owned buildings fully comply with these requirements, DCAMM creates a higher-than-acceptable risk of building occupants improperly handling their solid waste and losing the opportunity to obtain revenue...that would reduce the Commonwealth’s costs for waste disposal.
We visited 10 state buildings, spoke with the DCAMM onsite facility managers at each building, and determined that none of the facility managers performed solid waste stream audits;1 had written waste management plans or recycling/waste management policies or procedures; monitored or maintained records of solid waste trash removal and recycling activities at their buildings; or received waste hauler reports2 regularly and used the information on such reports to determine the right service level, identify inefficiencies, and track recycling progress. Six of the buildings we visited used single-stream3 recycling, and others were partially recycling (they recycled paper, but not bottles or cans). Further, none of the facility managers had inquired about any possible credits available for recycled materials.
Authoritative Guidance
According to Section 7C of Executive Order 515,
Agencies shall ensure that they integrate increased recycling practices in the disposal of their own waste materials, including but not limited to paper, glass, cans, plastic bottles, containers, and electronic equipment. This effort shall include the positioning of recycling bins in their offices and the contracting for recycling services to pick up and recycle these materials. [Emphasis added.]
As the state agency responsible for facilities management at all state-owned and state-occupied facilities, DCAMM is responsible for ensuring that occupants at these facilities comply with the solid waste recycling requirements of Section 7C of Executive Order 515.
According to DCAMM's Facilities Management & Maintenance Standard 04, a solid waste stream audit is necessary for all buildings owned and managed by the Commonwealth. The standard also states that facility managers should collect monthly hauler reports in order to calculate waste diversion and waste removal costs.
The standard also includes the following:
1.0 Roles and Responsibilities
1.1 The OFMM Director of Operations and Maintenance or an appointed designee, shall ensure implementation of this Standard and its requirements at all Commonwealth facilities. . . .
1.4 Facility Managers
a. Work with DCAMM and the building occupants to develop a solid waste management policy that establishes hierarchy for management of waste within the facility.
b. Work with DCAMM and building occupants to identify a solid waste management plan that outlines service levels, locations, equipment and staff responsibility....
h. Ensure that banned materials collected do not go for disposal at landfills, municipal waste combustion facilities, or transfer stations. Implement recycling collection programs with haulers that ensure collection and management of all restricted materials in a way that prevents disposal....
2.0 Implementation. . . .
2.4 Facility Managers shall ask contractors to provide credits for recyclable materials that are uncontaminated and have a market value. . . .
7.0 Recordskeeping
7.1 A solid waste/trash stream audit is necessary for all buildings owned and managed by the Commonwealth to identify the following solid waste related issues for the facility. . . .
e. Disposal Records: Indicate receipt and acceptance of waste by landfills, municipal waste combustion facilities, and transfer stations licensed to accept waste materials. Include manifests, weight tickets, receipts, and invoices.
Reasons for Noncompliance
DCAMM does not have any monitoring controls in place to ensure that its onsite facility managers properly implement, and ensure adherence to, the established solid waste recycling requirements. In addition, according to DCAMM officials, facility managers are “occupant focused” and spend the majority of their time working on occupant issues, leaving little time to collect and review monthly hauler reports or perform solid waste stream audits.
DCAMM did not monitor compliance with recycling provisions of state agency leases
DCAMM’s administration did not ensure that property owners adhered to contractually agreed-upon recycling requirements. DCAMM’s lack of monitoring for compliance with the recycling provisions of leases could have an adverse environmental effect.
We surveyed 50 state agencies that were leasing properties through DCAMM and received responses from 39. Our survey revealed the following:
- 21 (54%) of the agencies were not aware of DCAMM’s recycling policies and procedures.
- 19 (49%) of the agencies were not aware the leases contained recycling language.
- 19 (49%) of the agencies performed partial recycling.
- 14 (36%) of the agencies performed full (single-stream) recycling.
- 6 (15%) of the agencies did no recycling.
Authoritative Guidance
According to Section 7C of Executive Order 515,
Agencies shall ensure that they integrate increased recycling practices in the disposal of their own waste materials, including but not limited to paper, glass, cans, plastic bottles, containers, and electronic equipment. This effort shall include the positioning of recycling bins in their offices and the contracting for recycling services to pick up and recycle these materials.
The requirements of this order are explicitly incorporated into the standard lease executed between DCAMM and owners of properties leased to state agencies.
Reasons for Noncompliance
DCAMM has not established controls to monitor building owners’ compliance with lease provisions regarding recycling. Rather, according to DCAMM officials, after leased space is occupied, DCAMM relies on the tenants to inform it of any concerns or noncompliance with the leases on the part of the building owners.
Recommendations
- DCAMM should develop administrative policies and procedures that provide for oversight of facility managers’ activities. These policies should require regular performance of solid waste stream audits, written waste management plans, documented recycling/waste management policies and procedures, monthly collection and analysis of hauler reports, and maintenance of written records to document the monitoring process.
- Facility managers should investigate the availability of credits to offset the cost of recycling.
- DCAMM should establish administrative policies and procedures that require monitoring of compliance with the recycling provisions of leases and should communicate these requirements to state agencies occupying leased space.
Auditee's Response
DCAMM is committed to improving our facility management systems to ensure that solid-waste stream audits are conducted periodically and that written waste management plans, policies and procedures are in place at all state-owned buildings. DCAMM will create written guidance for facility managers informing them how to collect and analyze monthly hauler reports and manifests and how to monitor and enforce contract requirements. Further, DCAMM will investigate the possibility of receiving credits to offset solid-waste hauling charges, and we will work with the Operational Services Division to ensure that our contractors meet the state contract specifications relative to securing credits as available. . . .
DCAMM acknowledges that we can do more to provide for monitoring compliance with the recycling provisions in leases
DCAMM acknowledges that we can do more to provide for monitoring compliance with the recycling provisions in leases. As a result of this audit, DCAMM’s Office of Leasing is updating its communication protocol whereby user agencies will be advised of the services that the lease requires of the landlord including, but not limited to, recycling.
| Date published: | April 27, 2018 |
|---|