Randy said:
From what I've heard the RAB folks have positive feelings ragarding the EPA'a position...they've been getting more business. The EPA is actively seeking registration services for its facilities and other government agencies are following suit. I've had a couple of dozen EPA and other government folks in a variety of ISO 14001 related training sessions.
We won't see a tidal wave here, but the beach will get wet.
I recently taught my second annual ISO 14000 Lead Auditor course for Government at the U.S. Department of Energy's (DOE) Strategic Petroleum Reserve Project Management Office (my former office). I'll be teaching the same course for the U.S. Army in Maryland in a couple of weeks. Some government facilities have been ISO 14001 (and a few ISO 9001) certified for many years.
The only surprise with the EPA Position Paper is that it took so long in coming. It might have had more of an impact had it come while Federal agencies were still trying to decide how to approach the mandatory Executive Order requirement to have an EMS in place prior to the first of 2006 (although certification was not required). Some agencies like DOE, U.S. Army bases, and the Veteran's Administration Hospitals have been fairly proactive in implementing EMS's.
EPA has been involved with EMSs for over 10 years, playing a part in the development of ISO 14001, serving on interagency task forces, conducting voluntary Environmental Reviews/EMS audits of other Federal agencies, managing the Performance Track Program, advising the states, developing EMS for their labs and/or Regional offices, etc. As a DOE employee, I was involved with EPA in leading some of their Environmental Reviews and in Performance Track/State meetings.