Creating an EMS for Fermilab EMS Team Training FN000367/CR

Objectives What is an EMS? What are the models we have to choose from? What do we have to do and when?

What is an EMS (Environmental Management System) That facet of the organization’s overall management structure that addresses the immediate and long-term impact of it’s products, services, and processes on the environment. It is a systematic approach to ensuring that environmental activities are well managed in the organization. An EMS brings together the people, policies, plans, review mechanisms, and procedures used to manage environmental issues.

What is an EMS Provides a predictable structure for managing, assessing, and continuously improving the effectiveness and efficiency of the management of environmental activities. Builds in periodic review by top management. Emphasizes continuous improvement instead of crisis management.

What is an EMS It’s focus is management practices. It’s goal is minimal impact to the environment.

Tangible Returns on an EMS Investment 1.Provides an environmental management framework. 2.Reduces support costs by integrating site contractors and activities. 3.Supports risk management by reducing the risk profile and diminishes liability. 4.Supports performance-based contracting. 5.Helps avoid gaps and overlaps. 6.Shows due diligence (improves relationship with regulators and the public). 7.Integrates related ES&H activities like P2 and worker safety. 8.Improves recognition of P2 opportunities.

Opportunities-Awards National Performance Track EPA voluntary program to reward recognized facilities and organizations with 1.a proven record of regulatory compliance, 2.a demonstrated commitment to continued improvement and outreach to the local community and the public, and 3.an EMS. Others (Env. Leadership Program, Project XL, Env. Management Reviews)

WHY? Executive Order Strengthening Federal Environmental, Energy, and Transportation Management DOE Order Environmental Protection Program

E.O Is incorporated in the FRA contract with DOE. Directs Federal agencies to implement EMS at all appropriate organizational levels to: –ensure the use of EMS as the primary management approach for addressing environmental aspects of internal agency operations and activities, –Establish agency objectives and targets to ensure implementation of the EO, –Collect analyze and report information to measure performance in the implementation of the EO. Sustainable Practices: 1.Energy efficiency 2.Use of renewable energy 3.Reduction of water consumption intensity 4.Sustainable acquisition of recycled content, energy efficient, biobased, and environmentally preferable products and services 5.Pollution prevention, including reduction or eliminatin of the use of toxic and hazardous chemicals and materials 6.Waste prevention and recycling 7.Sustainable design/high performance buildings 8.Vehicle fleet management, including the use of alternative fuel vehicles and alternative fuels and the further reduction of petroleum consumption 9.Electronics stewardship

DOE Order Environmental Protection Program. –Was DOE Order –Significantly modified Not currently incorporated in the FRA contract with DOE. –FAO is not pushing for its incorporation Is performance based and designed to meet the requirements of E.O

DOE Order Contractor Requirements Document (CRD) Requires contractors to integrate numerous environmentally related requirements already placed on it by existing statutes, regulations, and policies through the use of an EMS incorporated into an ISMS. 13 Points (See handout).

CRD Points 1.Integration into ISMS. 2.Integration into ISMS. 3.Integration into ISMS. 4.Waste prevention, recycling and acquisition, energy efficiency, EMS, fleet and transportation efficiency. 5.Procurement and distribution programs for toxic or hazardous materials management. 6.Economically beneficial landscape practices. 7.P2. 8.P2. 9.P2. 10.Monitoring. 11.Analyses to support monitoring. 12.Oxygen Depleting Substances. 13.EPCRA reporting and planning.

EMS Options Models –ISO (certification or not). –CEMP (The Code of Environmental Management Principles). All follow Plan, Do, Check, Act formula.

ISO Established by the International Organization for Standardization (ISO). Part of ISO series that covers environmental managements systems, environmental auditing, environmental performance evaluation, environmental labeling, life-cycle assessment and environmental aspects in product standards. Specifies the framework for the management system that allows the organization to meet its environmental obligations reliably and consistently outside of the “Command and Control” regime. Revised in 2004.

EMS Elements from ISO Scope Normative References Terms and Definitions EMS Requirements –General Requirements –Environmental Policy –Planning –Implementation and Operation –Checking –Management Review

Policy Statement signed by facility manager. Appropriate to the nature, scale and impacts of the organizations activities, products and services. Commit to: –Continual improvement –Pollution prevention –Compliance and other requirements Provides framework for setting and reviewing environmental objectives and targets. Documented, implemented and maintained. Communicated to persons working for or on behalf of the organization. Available to public.

Planning Identify aspects and impacts from activities, products, and services. –Determine significance –Document and keep up-to-date –Are taken into account in establishing, implementing and maintaining the EMS Review legal and other requirements. –Identify and have access to –Determine how they apply to aspects –Are taken into account in establishing, implementing and maintaining the EMS Set objectives, targets and programs. –Document at relevant functions and levels –Measurable –Take into account legal and other requirements when establishing –Program for achievement Designation of responsibility Means and time-frame to achieve

Planning Important Questions: 1.How do activities interact with the environment? 2.Do they produce waste? 3.Are hazardous materials involved? 4.Are operations located in ecologically sensitive areas? 5.How much water and energy are used? 6.How are significant impacts currently identified? 7.What effect could an accident have on the environment? 8.How are laws and regulations tracked? 9.Have commitments beyond compliance been made? 10.Are there ways to support other initiatives, such as NEPA? 11.How can it be integrated with safety?

Identifying Environmental Aspects An aspect is an element of an activity, product, or service that interacts with the environment. –Can be thought of as the actual or potential “cause” of an environmental impact. –Can be regulated or unregulated. –Can be negative or positive. –Begin by looking backward and then forward.

Examples Vehicles emit exhaust Water leaks from distribution system Fueling spills occur Volatiles from open containers Noise from equipment Unnecessary energy use from lights and computers left on Use of paper bleached with chlorine Bicycles don’t emit exhaust

Activity, Product, or ServiceEnvironmental Aspect Vehicle usage Fuel consumption Fuel exhaust Noise generation Visitor Services Fuel consumption Electricity consumption Solid waste generation Water consumption Waste water generation

Activity, Product, or ServiceEnvironmental Aspect Vehicle Maintenance Hazardous waste generation Gasoline consumption Noise generation Electricity consumption Solid waste generation Water consumption Waste water generation Release of volatiles

Activity, Product, or ServiceEnvironmental Aspect Cafeteria food serviceFood waste generation Electricity consumption Water consumption Waste water generation Use of ammonia in refrigeration equipment Office WorkElectricity consumption Water consumption Release of ozone depleting substances in air cooling units Solid waste generation Disposal of toxics from computer toner, etc Waste water generation

Aspects and the EMS A comprehensive aspects analysis was done during development of the EMS. –Begins with development of a procedure to identify aspects. –Maintain register of aspects up-to-date.

Building an Aspects Register Assemble list of activities, products, and services. Characterize activities, products, and services. List aspects. Quantify aspects if possible. –Helps in prioritization and ranking for improvement.

Planning Objectives and Targets: Objectives describe the goals for environmental performance. Examples: emissions goals, pollution prevention, use of raw materials, or incidence of non-compliance. Targets are specific and measurable intermediate steps that can be measured in terms of obtaining the objectives. Examples: achieving a 50% reduction in releases of certain toxic substances within two years. Performance Indicators can give a sharper focus to goal-setting. Developing them allows managers to assess compliance status, manage environmental liability, evaluate risk, track progress and meet the challenge of continuous improvement.

Implementation and Operation Resources, roles, responsibility and authority. Competence, training and awareness. Communication. Documentation. Control of documents. Operational control. Emergency preparedness and response.

Resources, roles, responsibility and authority Management shall ensure the availability of resources essential to establish, implement, maintain and improve the EMS –Human resources and specialized skills –Organizational infrastructure –Technology –Financial Shall be defined, documented and communicated Appoint management representative –Ensure the EMS is established, implemented and maintained –Report to top management on the performance of the EMS for review, including recommendations for improvement

Competence, training and awareness Ensure persons performing tasks for it or on its behalf (contractors should be included) that have the potential to cause a significant environmental impact be competent on the basis of appropriate education, training or experience, and shall retain records. Identify training needs associated with the environmental aspects and the EMS and provide training or take other action to meet these needs and retain associated records. Establish, implement and maintain a procedure to make persons working for or on the Labs behalf (contractors) aware of: 1.The importance of conformity with the Labs policy and procedures and with the requirements of the EMS 2.The significant aspects and related actual or potential impacts associated with their work, and the environmental benefits of improved personal performance 3.Their roles and responsibilities in achieving conformity with the requirements of the EMS, and 4.The potential consequences of departure from specified procedures.

Communication and Reporting Establish, implement and maintain a procedure, with regard to environmental aspects and the EMS, for: –Internal communication with various levels and functions –Receiving, documenting and responding to relevant communication from external interested parties Decide whether to communicate externally about significant environmental aspects, and if so, document the decision and method for accomplishment

Communication and Reporting Necessary to motivate and direct employees, and build confidence and acceptance with the public and regulators. Important Questions: What is the process for communicating the policy? Do they work well and run smoothly or are they in “crisis” mode? Are the right audiences being reached? Is dialogue two-way? How is feedback managed? Are corrective action results communicated effectively? How can continual improvement be effectively communicated? Communication Techniques: Examples: written directives, e-messages, regular employee mtgs., public meetings, press releases, periodic rpts., newsletters, etc.

Documentation Must include: 1.The environmental policy, objectives, and targets 2.Description of the scope of the EMS 3.Description of the main elements of the EMS and their interaction, and reference to related documents 4.Documents, including records, required by the standard 5.Documents, including records, determined by the Lab to be necessary to ensure the effective planning, operation and control of processes that relate to the EMS

Control of documents Documents required by the EMS and by the standard shall be controlled, including records A procedure must be established, implemented and maintained to: 1.Approve documents for adequacy prior to use 2.Review and update as necessary and re-approve documents 3.Ensure that changes and the current revision status of documents are identified 4.Ensure that relevant versions of applicable documents are available at points of use 5.Ensure that documents remain legible and readily identifiable 6.Ensure that documents of external origin determined by the Lab to be necessary for the planning and operation of the EMS are identified and their distribution controlled, and 7.Prevent the unintended use of obsolete documents and apply suitable identification to them if they are retained for any purpose

Operational Control Identify and plan those operations that are associated with the identified significant environmental aspects consistent with the environmental policy, objectives and targets, in order to ensure that they are carried out under specified conditions, by 1.Establishing, implementing and maintaining a documented procedure to control situations where their absence could lead to deviation from the environmental policy, objectives and targets 2.Stipulating the operating criteria in the procedure 3.Establish, implement and maintain procedure related to the identified significant environmental aspects of goods and services used by the Lab and communicating applicable procedures and requirements to suppliers, including contractors

Emergency Preparedness and Response Establish, implement and maintain a procedure to identify potential emergency situations and potential accidents that can have an impact on the environment and how it will respond to them Respond to actual emergency situations and accidents and prevent or mitigate associated adverse environmental impacts Periodically review and, where necessary, revise the emergency preparedness and response procedures, in particular, after the occurrence of accidents or emergency situations Periodically test such procedures where practicable

Checking Monitoring and measurement Evaluation of compliance Nonconformity, corrective action and preventive action Control of records Internal audit

Monitoring and Measurement Establish, implement and maintain a procedure(s) to monitor and measure, on a regular basis, the key characteristics of operations that can have a significant environmental impact. –Must include the documenting of information to monitor performance, applicable operational controls and conformity with the objectives and targets. Ensure the calibrated or verified monitoring and measurement equipment is used and maintained and shall retain associated records.

Evaluation of Compliance Periodically evaluate compliance with applicable legal requirements. Keep records of results. Evaluate compliance with other requirements. Keep records of results.

Nonconformity, Corrective Action and Preventive Action Procedure to deal with actual and potential nonconformity(ies) and for taking corrective action and preventive action. It shall define requirements for: –Identifying and correcting nonconformities and taking actions to mitigate their impacts. –Investigating nonconformities, determining their causes and taking actions in order to avoid their recurrence. –Evaluating the need for actions to prevent nonconformities and implementing appropriate actions designed to avoid their occurrence. –Recording the results of corrective actions and preventive actions taken, and –Reviewing the effectiveness of corrective actions and preventive actions taken. Actions taken shall be appropriate to the magnitude of the problems and impacts encountered. Ensure that any necessary changes are made to the EMS documentation.

Control of Records Establish and maintain records as necessary to demonstrate conformity to the requirements of the EMS, the standard, and the results achieved. Procedure for the identification, storage, protection, retrieval, retention and disposal of records. Records shall be and remain legible, identifiable and traceable.

Internal Audit Ensure that internal audits of the EMS are conducted at planned intervals to: –Determine whether the EMS Conforms to planned arrangements of environmental management including the requirements of the standard. Has been properly implemented and is maintained, and –Provide information on the results of audits to management. Audit programs shall be planned, established, implemented and maintained that address: –The responsibilities and requirements for planning and conducting audits, reporting results and retaining associated records, –The determination of audit criteria, scope, frequency and methods. Selection of auditors and conduct of audits shall ensure objectivity and impartiality of the audit process.

Management Review Conduct periodic senior management review of EMS as a whole. –Ensure its continuing suitability, adequacy and effectiveness. –Include assessing opportunities for improvement and the need for changes to the EMS, including the policy and objectives and targets. –Retain records of the reviews.

Management Review Input to review: –The results of internal audits and evaluations of compliance with legal requirements and with other requirements. –Communications from external interested parties, including complaints. –Environmental performance. –The extent to which objectives and targets have been met. –Status of corrective and preventive actions. –Follow-up actions from previous management reviews. –Changing circumstances, including developments in legal and other requirements related to environmental aspects. –Recommendations for improvement. Output to review –Any decisions and actions related to possible changes to the policy, objectives, and other elements of the EMS consistent with the commitment to continual improvement.

Self-Declaration Federal facilities implementing ISO EMS standard can “self declare” when they reach full implementation of the standard. Focus should be on implementation unless there is a compelling reason to register.

EMS Document Structure EMS –Policy –Aspects Register –Objectives and Targets

EMS Document Structure Environmental Management Programs –Environmental Management Plan –Training needs –Organization Chart

EMS Document Structure Day-to-Day Operations –SOP’s –Training –Hazwast Manifests –Energy Bills

Ownership of Parts ManagementProvide review and direction. Environmental OfficeProvide technical expertise. Line managersProvide knowledge. ProcurementPurchasing knowledge; contractors. Maintenance or EngineeringFacilities management. Other support groupsKnowledge of facility systems.

Coordinate the System Cross reference parts to office. Identify parts that aren’t clearly assigned. EMS coordinators must demonstrate the linkage between the part and the office. The success of the EMS depends on integration into day-to- day activities with ownership as the key to success.

The EMS Teams 1.The Working Level Team 2.The Senior Management Team

The Working Level Team (You and Me) Educate all organizations at the lab. Conduct internal assessments and audits. Collect input from employees and management. Plan and implement EMS (develop EMPs). Interact with local community as needed.

The Senior Management Team (Advisory) LSC Brought in at decision making time. Approve EMPs.

Level of Effort Estimated based on gap analysis. Leverage existing resources. Shouldn’t be underestimated. Obtain management commitment for policy and implementation.

Performance Measures Translate organization goals and targets into operational terms. Not easy for environmental performance. Pitfalls: –Overreaching (trying to measure everything) –Focusing on activities that are easy to quantify rather than on desired results directly keyed to organization goals. EMS performance: –Use environmental attributes –Gauge how well the EMS is functioning –Benchmarking against the performance of others

Performance Measures Measuring Environmental Attributes –Quantitative measures of regulated pollutants. –Help identify when certain regulatory thresholds have been met or track activities that can have direct impacts on the environment. –Can translate directly into environmental performance. –Example (emissions control).

Performance Measures Measuring EMS Performance –Can be challenging. –How does the system respond to changing conditions? –Example: Regulatory Change Determination of regulation’s applicability Incorporated into training Communicated throughout organization Incorporated into operating procedures Incorporated into self-assessment protocols Use for P2 and continuous improvement and compliance Use to adjust objectives and targets

Performance Measures Benchmarking A comparison of programs. Allows for benefit from experience of peak performers. Requires establishment of baseline to measure progress.

Performance Measures Measures Elements tracked as a trend over time. Examples: Volume of a key hazardous material purchased. BTUs of energy consumed. Concentration of a residual in wastewater discharged. Outcomes Levels wanting to be achieved. Examples: 5% reduction in volume of hazardous material purchased. Installation of high- efficiency lighting in 50% of office space. 0 discharge of process wastewater.

Pollution Prevention P2 benefits can be significantly enhanced through the EMS framework. –Ensure broader awareness of P2 issues. –Enhance relevant training and communication. –Strengthen ability to recognize and capitalize on P2 opportunities.

NEPA Already a set of tools to identify the environmental impacts, to consider the impacts fully in decision-making, and to reduce the impacts. –Addresses new but not ongoing activities. Development of the EMS allows an opportunity to build on the strengths and address the shortcomings.

NEPA Integrating existing NEPA activities into the EMS. –Use existing staff expertise. Educate differences. –Use existing procedures. Identification of impacts and identification and analysis of alternatives. –Incorporate public involvement activities.

NEPA Building on Past NEPA Analyses. –Identify Impacts A good head start of sources for identifying aspects and impacts. –Use Existing Impact Assessment Tools Build on skills and methodologies to establish relationships between actions and potential effects. –“Significant” Caution Significant Impacts NEPA = EISEMS = threshold set by us Common: Direct and indirect impacts, cumulative impacts, and P2.

Integrated ESH Management System (IESHMS) Provides a formal, organized process to plan, perform, assess, and improve the safe conduct of work in the DOE.

Hazard Analysis FESHM Chapter 2060 –Hazard analysis is a process by which personnel can plan work as well as identify and mitigate the environmental, safety and health hazards involved in any work activity. –Example in table 1: Potential Hazards Guideline. Hazardous substances and regulated pollutants Chemical usage When have environmental aspects been documented in a HA?

Hazard Analysis Expand to include what should also be there. –the environmental impacts.

What is Expected of Us DOE Status Reporting. DOE Order 450.1? NSF Annual Audit. Tripartite Assessments. Effective Use of EP Subcommittee.