SENIOR MANAGERS TRAINING FOR USE WITH DOE O 450.1, ENVIRONMENTAL PROTECTION PROGRAM

WHAT IS AN EMS? An EMS is a systematic and structured approach for addressing environmental consequences of an organization’s activities, products and services An EMS is part of DOE’s overall management system which includes an organizational structure, planning, responsibilities, practices and processes for addressing an organization’s environmental impacts. The expectation is that through this systematic approach, environmental consequences will be identified at the earliest opportunity, and mitigated resulting in improved environmental compliance and protection in a cost-effective manner.

PURPOSE Provide Senior Managers with an overview of DOE O 450.1 requirements, including: an understanding of their DOE O 450.1 roles and responsibilities to ensure successful ISMS/EMS implementation guidance on how to implement EMS as part of Integrated Safety Management Systems (ISMS) As with all management systems, management commitment is a key to the success of an environmental management system (EMS). This training module is designed to help improve senior managers understanding of their responsibilities for implementing an EMS and integrating the EMS into existing Integrated Safety Management Systems (ISMS). More detailed information can be found in DOE G 450.1-10, Senior Managers Implementation Guide for Use with DOE O 450.1 Environmental Protection Program, which is available on the EH-4 website at: http://www.eh.doe.gov/oepa

WHY DO I HAVE TO HAVE AN EMS? To improve environmental performance: To meet the requirements of DOE O 450.1, Environmental Protection Program, and Executive Order 13148, Greening the Government Through Leadership in Environmental Management Having an EMS is a good business practice that should improve environmental performance and help achieve mission goals. Many high performing private sector companies have implemented EMSs. A more in-depth discussion of EMS benefits is contained in subsequent slides. It is the policy of the Federal Government to use environmental management systems to implement environmental protection activities and improve environmental performance. E.O. 13148, Greening Government Through Environmental Management, requires appropriate Federal facilities to implement EMSs by December 31, 2005. In furtherance of this goal, the Department issued DOE O 450.1, Environmental Protection Program, in January, 2003, which requires EMS implementation at DOE sites. EH-4 has also issued accompanying guidance documents which are available on our website.

BENEFITS OF AN ISMS/EMS Achieve mission goals, reduce costs, improve business practices Improve environmental compliance performance Address stewardship and legacy management issues systematically Improve credibility with regulators and local community A successful ISMS/EMS will ensure that environmental concerns are considered as a part of the project planning and become part of the critical path to achieving mission goals. This can help avoid environmental issues becoming last minute, costly surprises that can delay a project. The ISMS/EMS creates a culture of environmental awareness at DOE sites which results in improved environmental compliance performance. Organizations with an ISMS/EMS have demonstrated improved environmental compliance performance. Stewardship and legacy management have become a major mission for DOE. The ISMS/EMS approach will help sites proactively identify and address concerns to implement and maintain sound stewardship practices. The ISMS/EMS can help foster a smooth transition of sites from DOE Program Offices to the Office of Legacy Management by providing a common, understandable, reliable transition framework. Regulatory agencies and local communities have recognized an EMS as evidence that a site is effectively managing its environmental liabilities. Regulatory agencies can reward sites with high-quality integrated management systems with relief from certain administrative requirements (e.g., EPA’s National Environmental Performance Track Program.)

HOW IS DOE’s EMS IMPLEMENTATION MONITORED? DOE’s progress toward implementation is reported to the White House Office of the Federal Environmental Executive (OFEE) on an annual basis by the Assistant Secretary for Environment, Safety and Health (EH-1), who also serves as DOE’s Agency Environmental Executive OFEE maintains a “scorecard” to document Agency progress toward implementation of EMSs by the December 31, 2005 deadline. This scorecard, is tied to the Agency’s overall performance as part of the President’s Management Agenda. EH maintains or links to information about the scorecards on the Web at http://www.eh.doe.gov/oepa

WHAT ARE SENIOR MANAGERS’ RESPONSIBILITIES PURSUANT TO DOE O 450.1? Senior managers must: Ensure that all sites under their purview have implemented ISMS/EMS by 12/31/05 Request, through their annual Departmental budgetary process, the funding and resources needed to implement DOE O 450.1 Additional responsibilities also include: Ensure that the sites under their purview include site-specific goals in their ISMS/EMS that contribute to the accomplishment of DOE Pollution Prevention (P2) and Energy Efficiency (P2E2) goals. (P2E2 goals are contained in a memorandum signed by the Secretary on November 12, 1999). Ensure that sites under their purview develop and implement cost-effective P2 programs that use life-cycle assessment concepts and practices in determining program return-on-investment (ROI). Evaluate, on an annual basis, P2 nominations from sites under their purview, select “best in class” nominees, and transmit the nominating information to the Office of Environment, Safety and Health (EH) for submittal to the White House “Closing the Circle Awards” program. Ensure sites under their purview monitor progress toward meeting the P2 requirements of Order 450.1 and make such information available annually to EH.

INTEGRATING EMS INTO ISMS DOE O 450.1 requires DOE elements to ensure that site ISMSs include an EMS An EMS is that part of ISMS which addresses the environmental consequences of an organization’s products, services and activities In those instances where ISMS is not required for a site, DOE elements must develop and implement a stand-alone EMS Integration of an EMS into an ISMS (ISMS/EMS) provides a unified framework for the management of resources, the control and attenuation of risks, and the establishment and achievement of the organization’s environmental and safety goals. The ISMS/EMS should be viewed as an enhancement of ISMS that adds those EMS elements not previously included in the ISMS.

EMS FRAMEWORKS Several EMS frameworks exist, including ISO 14001, which is the most popular DOE O 450.1 does not require DOE organizations to use ISO 14001 or any specific framework The ISO 14001 framework involves an independent third-party certification DOE O 450.1 allows for EMS self-certification by Program Offices DOE O 450.1 does not require DOE elements to implement any specific brand name EMS. But, the Order does identify specific EMS elements that are required to be included in an ISMS/EMS. DOE managers have the option to use different frameworks to implement the ISMS/EMS at their sites as long as the site can demonstrate it has an ISMS/EMS that meets the requirements of DOE O 450.1. Senior Managers (including DOE Operations/Field/Site Office managers) need to consider the attributes of the particular frameworks in deciding which will be best for their site. For example: Frameworks like ISO 14001 include certification based on an audit by an independent third party registrar. The certification lasts for three years. During this period, the registrar will conduct periodic verification audits. Renewal after three years is based on the assessment by the registrar. Such frameworks offer the potential to increase credibility of the sites EMS with external groups including regulators; however, they may be more costly to maintain than a self-certified EMS. Where environmental aspects for the operation are complex, the third party review can provide fresh insights to what an EMS needs to cover. Self-certification or self-declaration means that a site determines, through its own internal evaluation, that it fully conforms to the requirements of DOE O 450.1 and makes an affirmative declaration that it conforms to the Order. This declaration should be made public and periodic DOE verification audits should be performed. Self-certification frameworks may be less costly and may be more easily tailored for DOE needs and concerns than the more structured externally certified frameworks; however, they may require more public involvement to achieve the same level of external credibility. Guidance documents and tools are available at http://www.eh.doe.gov/oepa along with information or links to information gained from applying EMS to various DOE sites. Regardless which framework is chosen, the EMS elements must be compatible with, and integrated into, the site ISMS. When a site does not have an ISMS, DOE elements must still ensure the implementation of an EMS per requirements of DOE O 450.1.

IMPLEMENTATION OF ISMS/EMS AT CLOSURE SITES Closure sites are sites that have ceased operations or have identified near-term closure dates Closure sites are required to implement ISMS/EMS Closure sites can use a graded approach to supplement their existing ISMSs to meet the requirements of DOE O 450.1 ISMS/EMSs at Closure sites can serve as the framework for their transition to the Office of Legacy Management and/or for long-term stewardship. Sites conducting closure activities may have most of the elements of an ISMS/EMS in place. Existing environmental documents such as National Environmental Policy Act (NEPA) Environmental Impact Statements (EIS), Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) documents or legal agreements with the Environmental Protection Agency (EPA) and/or state agencies can be used to meet the requirements of Order 450.1. For example, significant environmental aspects and impacts may have been identified in the Remedial Investigation/Feasibility Study (RI/FS) process under CERCLA. CERCLA also has numerous procedural requirements which could be considered for the EMS. Sites are encouraged to tailor (using a graded approach) their EMSs to the nature and extent of the environmental impacts.

HOW CAN I ENSURE SUCCESSFUL IMPLEMENTATION OF EMS AS PART OF ISMS? Communicate your support the ISMS/EMS Provide oversight and training Engage stakeholders Senior management should make it clear to everyone that they fully support the implementation of the ISMS/EMS. One way this can be done is through endorsing and communicating an environmental policy. A strong, clear environmental policy statement, emphasizing principles such as regulatory compliance, pollution prevention, and continual improvement in environmental performance, is evidence that senior management supports the ISMS/EMS and expects all employees to do the same. Management should provide a combination of general awareness training for all employees, as well as more detailed training for employees whose jobs have environmental consequences. Management may wish to consider developing a number of courses tailored to the nature of the work done by different people at different levels of the organization Senior manager oversight and guidance are essential for maintaining momentum over the course of the ISMS/EMS implementation process. Periodically, senior managers should take the time to review how well the ISMS/EMS is being implemented. When senior management maintains interest, members of the staff also stay focused. Senior managers must be personally involved in ISMS/EMS management reviews and issue specific direction as needed. DOE-specific guidance, training and tools are available at http://www.eh.doe.gov/oepa. Senior managers frequently interact with the local community and other stakeholders. Implementation of the ISMS/EMS initiative can provide these groups with a positive message regarding a site’s commitment to environmental protection and stewardship.

CONCLUSIONS ISMS/EMS provides an environmental protection program that ensures early detection of and systematic management of environmental problems Managers can integrate environmental considerations into everyday business processes and mission activities Effective ISMS/EMS implementation can create an organizational culture of superior environmental performance through increased environmental awareness and life cycle accountability for everyone working at DOE sites