EMS Checklist (ISO 14001 model) EPA Regions 9 & 10 and The Federal Network for Sustainability 2005

Continual Improvement Checking & Corrective Action Plan Do Check Act Continual Improvement Environmental Policy Management Review Checking & Corrective Action Planning This slide shows the components arranged to reflect the EMS cycle and the notion that the cycle supports the continual improvement concept that is the backbone of an effective EMS the next few slides will describe the various components Implementation & Control

4.2 Policy Top management shall define the organizations environmental policy and ensure that it: a) is appropriate to the nature, scale and environmental impacts of its activities, products or services; b) includes a commitment to continual improvement and prevention of pollution; The EMS policy is really the starting point for the EMS although many organization are holding off on their policies until they learn more about the EMS process. The most critical thing to remember about the policy statement is that, under the standard, it must be implemented - policies cannot be just something that hangs on the wall. Things that are included in the policy are a commitment to pollution prevention, a commitment to continual improvement and a commitment to comply with relevant environmental regulations. A copy must be made available to the public.

4.2 Policy c) includes a commitment to comply their relevant environmental legislation and regulations, and with other requirements to which the organization subscribes; d) provides the framework for setting and reviewing environmental objectives and targets; e) is documented, implemented and maintained and communicated to all employees; f) is available to the public.

Planning Determine Identify Environmental Significant Develop Aspects and Impacts Environmental Aspects Identify Establish Environmental Activities, Objectives Products and Management and Targets Services Determine Legal and Other Program Requirements Next is the planning component - some organizations begin here even before they have drafted their policy - it is here where you inventory what you do that affects the environment - identifying what impacts those activities have on the environment - identify legal and other requirements such as Executive Order performance goals - determine which of the impacts are significant to your organization - and considering that information and your legal and other requirements, establish your objectives and the targets where you ultimately want to be - it is recognized in the standard that the objectives and targets should reflect financial and technological limitations - it is also recognized that the objectives and target should reflect the views of interested parties at this point you are ready to develop your environmental management program that identifies planning and logistics for achieving your objectives, including responsibilities, resources planning, timing and milestones - this activity may be addressed by amending existing strategic planning or developing a separate program - it also establishes the metrics that will be used to determine progress in meeting your objectives

4.3 Planning Establish, Maintain, and Document: 4.3.1 - Procedure to identify Environmental Aspects. a) Activities products and services that it “can control and those that it can influence”, “Activities” for Feds include - Mission: what ‘facility/Agency’ is designed to do, Activities that support the mission, Actions that are both regulated and not regulated.

4.3 Planning Establish, Maintain, and Document: b) Those which have or can have significant impacts on the environment. Determined by you. What is important in your situation - Likelihood, severity, frequency, duration, boundaries, stakeholder concerns, Reflects normal, unique, emergency conditions, and environmental impact

4.3 Planning Establish, Maintain, and Document: 4.3.2 - Procedure to identify legal and other requirements. a) Identify and have access to all legal requirements that apply to your facility’s aspects – use audit guides or protocols, b) Identify other requirements to which you “subscribe” e.g., Executive Orders, agency/bureau policies or voluntary practices.

4.3 Planning Establish, Maintain, and Document: 4.3.3 - Environmental objectives and targets. a) Considering: “legal and other requirements”, significant aspects, financial and technical limitations, interested parties input, policy commitment and commitment to pollution prevention, b) Results will guide how you measure progress.

4.3 Planning 4.3.3 - Program for achieving objectives and targets, a) including responsible individuals (assign responsibility - function and level), and b) time frames (what will be done, when, and how is it measured)

Implementation and Operation Capabilities & Organization & Controls Accountability Communications Document Control Training, Awareness and Competence Operational Control Structure and Responsibility Implementation is the “do” step in an EMS - this is where roles, responsibilities and authorities for EMS implementation are “defined, documented, and communicated” This step is also where training and communication reside- training reflects both skills training for those whose role in the organization involves potential environmental impact as well as general awareness training for all employees - training includes both training in the EMS itself and general environmental awareness, training to ensure competence in one duties where significant environmental impact may occur as a result of an individuals responsibilities, including training that may be required by regulation in addition, an organization must have a process for internal communication regarding the EMS to its employees across the organization - including information transfer up the chain of command - empowering the individual also here is document control - all documents, including EMS documents, can be located, are reviewed and revised as necessary, current documents are available, obsolete ones are identified as such - this is reflective of the quality standard operational controls are procedures to ensure that actions are taken to prevent deviation from the environmental policy and objects and targets - when your out of compliance, your operational controls are not working - these are also SOPs finally this is where emergency situations are covered - identify potential accidents and prevent, mitigate or respond to associated environmental impact Communication Emergency Preparedness and Response

4.4 Implementation and Operation 4.4.1 – a) Resources, roles, responsibility and authority defined, documented, communicated, b) Management provides resources for implementation of the system, c) Management identifies Management Representative who is responsible for and has authority for: 1. Managing EMS implementation, 2. Reporting to top management on EMS progress.

4.4 Implementation and Operation 4.4.2 - Identification of training needs, and procedures for training, awareness and competence. a) Establish and maintain a procedure for training relevant to: 1) EMS - awareness including policy, 2) Relationship between employee activities and environmental impacts. b) Ensure competence training to: 1) Regulatory requirements, 2) Standard operating procedures.

4.4 Implementation and Operation 4.4.3 Procedures for communications. Establish and maintain a procedure a) For internal communication between levels and functions in both directions, b) For addressing external communications

4.4 Implementation and Operation 4.4.4 EMS documentation. a) Describes core elements of management system and interaction, b) Provides direction to related documentation. 4.4.5 Procedures for Document Control. Establish and maintain procedures for controlling system documents a) Can be located - are legible, dated and maintained, b) Reviewed and revised as necessary and approved, c) Current versions are available to practitioner, d) Obsolete documents are removed from use, and e) Obsolete documents may be retained for legal or knowledge purposes if necessary.

4.4 Implementation and Operation 4.4.6 Operational Control – identification and control of procedures associated with policy, aspects, objectives and targets. a) Identify operations and activities associated with significant environmental aspects, b) Establish and maintain procedures for addressing activities that affect significant aspects to avoid deviations from policy and objectives and targets, c) Considering goods and services, communicate procedures to suppliers and contractors 4.4.7 Procedures related with Emergency Preparedness Response. Establish and maintain procedures to a) Identify potential for emergencies, b) Address accidents and emergencies, c) Prevent, respond to and mitigate environmental impacts, d) Review and revise procedures after emergency or accident, e) Test where appropriate.

Checking and Corrective Action Non-conformance, Monitoring and Corrective and Measuring Preventive Action Records Periodic Internal EMS Audits This component of the EMS process is the “check” stage of the plan-do-check-act paradigm. There are really four categories under this component. Monitoring and measurement covers those activities that can have a significant impact on the environment including those associated with operational controls and objectives and targets - this is to determine whether your are achieving your policy goals and the actions of the environmental program- this includes compliance monitoring programs The second part of this component is nonconformance and corrective and preventive action- this is where an organization addresses nonconformance to policy goals by mitigating impacts that may have occurred, correcting the circumstance that allowed it to occur and preventing further nonconformance - these actions are documented - it should be noted that this goes beyond regulatory issues to all aspects of the standard - this is also where root cause analysis comes into play by addressing the cause of the nonconformance not just the event Also in this component is the requirement for EMS audits - this is to see whether or not the EMS itself is working as identified in the ISO standard and as defined in the EMS planning process including whether is is being properly implemented and maintained - the standard calls for the results of these audits to be provided to management for their review Finally, throughout the process of the EMS implementation, records must be maintained that reflect the actions taken.

4.5 Checking and Corrective Action 4.5.1 Establish and maintain documented procedures to Monitor and Measure operations and activities related to related to significant environmental aspects. a) Formally track performance, and operational control, b) Reflect objectives and targets, c) Maintain and calibrate monitoring equipment 4.5.2 Establish and maintain a procedure to periodically assess compliance with environmental regulations and other requirements 4.5.3 Establish and maintain procedures to address Non-Conformance and Corrective and Preventive Action, defining responsibility and authority to address non-conformance a) Mitigate impacts, b) Identify cause, c) Develop corrective action and implement it, d) Modify procedures if necessary to prevent recurrence.

4.5 Checking and Corrective Action 4.5.4 Establish and maintain procedures for identification, storage, protection, retrieval, retention and disposal of Environmental Records. a) Must be legible, identifiable and traceable to the activity, product or service involved, b) Demonstrate conformance to Standard 4.5.5 Establish and maintain a program and procedure for periodic Environmental Management System Audit to determine if the EMS a) Is being properly implemented and maintained, b) Conforms to the standard, and c) Audit information provided to management.

Management Review To Assess the suitability, Take account of: audit findings progress records on objectives changes to facilities changes in activities, products or services changes in technology concerns of interested parties other relevant information To Assess the suitability, adequacy, and effectiveness of the EMS In order to determine the need for change and improvement to: the environmental policy the objectives and targets other elements of the EMS The next step in the EMS process is management review. Note that this is not the “final step.” This is where management, those with the responsibility and authority to alter facility policies and activities, review the EMS and determine what- if any- changes to make. The EMS is reviewed for “continuing suitability, adequacy and effectiveness.” From the review can come changes to the policy, objectives and targets and the EMS program. Remember one of the goals of the EMS is continual improvement - according top SIO 14001 that is “enhancing the EMS to achieve improvements in overall performance in line with the organization’s environmental policy.” That’s in large part what this step is all about

4.6 Management Review 4.6 Top Management shall, at determined intervals a) Review EMS to ensure suitability, adequacy and effectiveness, b) Ensure necessary information is collected, c) Review is documented, d) Review shall address the possible need for changes.

Continual Improvement Checking & Corrective Action Plan Do Check Act Continual Improvement Environmental Policy Management Review Checking & Corrective Action Planning This slide shows the components arranged to reflect the EMS cycle and the notion that the cycle supports the continual improvement concept that is the backbone of an effective EMS the next few slides will describe the various components Implementation & Control

An Effective EMS 1. Meets the requirements (conformance with the “shalls”) 2. Consistency with the various elements inter-related (i.e., Significant aspects reflected in emergency planning, etc.) 3. Mechanisms are in place for continual improvement. To improve the EMS and organizational performance supported by management commitment and support.

Remember… The EMS and related measurement tools are just that, tools. Alone, they will not guarantee success. The organization must use the tools, not just have them. An effective EMS is “alive”; constantly measuring performance, making adjustments, and looking for opportunities for continual improvement, Accountability is critical. It is important to remember - EMS is a tool - it only works as well as those using it - it requires a commitment on the part of the organization and each member of that organization from top management down. And, an EMS must be a living effort - it is a fine tool for enhancing performance and making an organization more effective in all aspects of its mission, not just environmental.

An EMS... Is a management system. Is more than compliance - includes safety, energy, water etc. and non-regulated impacts. Supports mission! Takes time - it is a process, not an event. Requires the environmental people to get out of their box. EMS requires commitment - its not a part-time job. In closing - remember EMS is a recognized business management tool employed to help respond to your environmental issues while supporting your mission - it goes beyond regulatory compliance and identifies a range of issues related to organizational management such as security, energy and health and safety - and it supports you mission by making you organization more efficient across the board But remember - it take time to properly implement an EMS and it takes commitment - we have seen that the Federal government can be a leader in a number of fronts and this is an opportunity that we cannot miss!