FAR 52.223-19—Compliance with Environmental Management Systems.
Plain-English Summary
FAR 52.223-19, Compliance with Environmental Management Systems, is a contract clause used when the acquisition involves work that must operate within an agency or facility Environmental Management System (EMS). The clause addresses two core topics: first, the contractor’s duty to follow all applicable operational controls in the relevant EMS; and second, the contractor’s duty to provide monitoring and measurement information so the Government can evaluate environmental performance against EMS goals. In practice, this means the contractor must understand and comply with site-specific environmental procedures, restrictions, and reporting expectations that may apply at a government facility or under an agency program. The clause is important because it ties contract performance to the Government’s environmental management objectives, helping agencies control environmental impacts, maintain compliance, and measure performance consistently. For contractors, it creates an affirmative performance obligation that may affect how work is planned, executed, documented, and reported, especially where operations involve waste handling, emissions, spill prevention, energy use, or other environmentally significant activities.
Key Rules
Follow EMS operational controls
The contractor’s work must conform to all operational controls identified in the applicable agency or facility EMS. These controls are the specific procedures, restrictions, and practices the Government has established to manage environmental impacts at the site or within the program.
Provide monitoring information
The contractor must provide monitoring and measurement information necessary for the Government to assess environmental performance. This includes data or records needed to determine whether EMS goals are being met.
Applies to applicable EMS
The clause is tied to the EMS that applies to the agency or facility involved in the contract. Contractors should expect the exact requirements to depend on the site or agency program rather than on a single universal standard.
Performance obligation, not optional guidance
The clause uses mandatory language, so EMS controls are contract requirements, not best practices. Failure to follow them can become a contract performance issue.
Supports environmental performance management
The purpose of the clause is to help the Government manage and measure environmental performance relative to EMS goals. Contractors therefore may need to support documentation, tracking, and reporting processes beyond ordinary technical performance.
Responsibilities
Contractor
Conform its work to all applicable EMS operational controls and provide the monitoring and measurement information needed for the Government to evaluate environmental performance. The contractor must integrate EMS requirements into day-to-day performance and ensure personnel and subcontractors follow them.
Contracting Officer
Include the clause when prescribed and ensure the contract reflects the applicable EMS requirements. The contracting officer should also help ensure the contractor understands any site-specific EMS obligations that affect performance.
Agency or Facility EMS Owner/Manager
Identify the operational controls and performance measures that apply to the site or agency program and make them available for contract performance. This party typically defines the environmental controls and the information needed for monitoring and measurement.
Government Technical or Environmental Personnel
Monitor contractor performance against EMS-related requirements, collect or review environmental performance information, and use the data to assess compliance with EMS goals. They may also clarify reporting expectations and site procedures.
Practical Implications
Contractors should review the applicable EMS early, because the real requirements are often site-specific and may affect work methods, materials, waste handling, and reporting.
A common pitfall is treating EMS requirements as informal guidance; under this clause, they are contractually binding operational controls.
Contractors may need to collect environmental data during performance, so they should plan for recordkeeping, measurement, and timely reporting from the start.
Subcontractors and on-site personnel must be trained on the EMS controls, since a failure at the field level can create contract noncompliance.
Contracting officers and program staff should make sure the contractor knows which EMS applies and what information must be provided, to avoid disputes over unclear environmental expectations.
Official Regulatory Text
As prescribed in 23.406 (b) , insert the following clause: Compliance with Environmental Management Systems (May 2011) The Contractor’s work under this contract shall conform with all operational controls identified in the applicable agency or facility Environmental Management Systems and provide monitoring and measurement information necessary for the Government to address environmental performance relative to the goals of the Environmental Management Systems. (End of clause)