Environmental Management Systems An Overview With Practical Applications

Presentation Outline The EMS Continuum The Link Between Quality Assurance & EMS Program Key Principals Key Elements EMS Benefits & Costs Compliance Focused EMS EMS Future Directions Comm-Trac TM (EMS Management Software)

Where is your organization on the continuum of EMS development? Ask yourself the following questions: Are you looking for ways to improve EH&S performance? Are you looking for ways to improve EH&S performance? Is the state of your EH&S affairs exposing added liability? Is the state of your EH&S affairs exposing added liability? Does a lack of time or resources prevent effective EH&S management? Does a lack of time or resources prevent effective EH&S management? Are your organization’s EH&S goals linked to other corporate goals? Are your organization’s EH&S goals linked to other corporate goals? If you answered YES to one or more of the above questions, enhancing your EMS can help your organization.

Quality Systems vs. EMS Quality Management System Environmental Quality Policy Quality Policy Adequate Resources Adequate Resources Responsibilities and Authorities Responsibilities and Authorities Training Training System Documentation System Documentation Process Controls Process Controls Document Control Document Control System Audits System Audits Management Review Management Review Environmental Policy Environmental Policy Adequate Resources Adequate Resources Responsibilities and Authorities Responsibilities and Authorities Training Training System Documentation System Documentation Operational Controls Operational Controls Document Control Document Control System Audits System Audits Management Review Management Review

EMS - Key Principles Top Management Commitment Top Management Commitment Focus on Continual Improvement Focus on Continual Improvement Flexibility Flexibility Compatibility with Organizational Culture Compatibility with Organizational Culture Employee Awareness and Involvement Employee Awareness and Involvement

EMS - Key Principles Top Management Commitment making the environment an organizational priority: Thinking of effective environmental management as fundamental to the organization's survival making the environment an organizational priority: Thinking of effective environmental management as fundamental to the organization's survival integrating environmental management throughout the organization: Thinking about the environment as part of product/service and process development and delivery, among other activities integrating environmental management throughout the organization: Thinking about the environment as part of product/service and process development and delivery, among other activities looking at problems as opportunities: Identifying problems, determining root causes and preventing problem recurrence looking at problems as opportunities: Identifying problems, determining root causes and preventing problem recurrence

EMS - Key Principles Continued Most EMSs are built on the "Plan, Do, Check, Act" model. This model leads to continual improvement

EMS - Key Principles Continued Flexibility An effective EMS must be dynamic to allow your organization to adapt to a quickly changing environment. For this reason, you should keep your EMS flexible and simple.

EMS - Key Principles Continued Compatibility with Organizational Culture tailoring the EMS to the culture, or tailoring the EMS to the culture, or changing the culture to be compatible with the EMS approach. changing the culture to be compatible with the EMS approach.

EMS - Key Principles Continued Employee Awareness and Involvement Make sure that everyone understands why the organization needs an effective EMS, what their role is, and how an EMS will help to control EH&S impacts in a cost-effective manner. Make sure that everyone understands why the organization needs an effective EMS, what their role is, and how an EMS will help to control EH&S impacts in a cost-effective manner. Employee involvement helps to demonstrate the organization's commitment to EH&S goals and helps to ensure that the EMS is realistic, practical and adds value. Employee involvement helps to demonstrate the organization's commitment to EH&S goals and helps to ensure that the EMS is realistic, practical and adds value.

Key Benefits Improve environmental performance - Enhanced Compliance Improve environmental performance - Enhanced Compliance Prevent pollution and conserve resources Prevent pollution and conserve resources Reduce/mitigate risks Reduce/mitigate risks Increase efficiency Increase efficiency Reduce costs Reduce costs Enhance image with public, regulators, lenders, investors Enhance image with public, regulators, lenders, investors

EMS Costs Time Time Training Training Consulting Assistance, if needed Consulting Assistance, if needed Costs for technical resources & improvements, if needed. Costs for technical resources & improvements, if needed.

Compliance-Focused EMS’s EMS’s as part of settlement agreements:. Compliance investigations conducted by EPA have increasingly involved identifying causes of observed noncompliance.. Causes arise from inadequate environmental management systems.. EPA has developed key elements for a compliance-focused EMS model.. Used as the basis for EMS requirements in several settlement agreements.

An EMS Under settlement agreements Should Contain: Formal review of the firm’s current EMS. Formal review of the firm’s current EMS. Development of a comprehensive, documented, compliance- focused EMS. Development of a comprehensive, documented, compliance- focused EMS. Development of policies, procedures, and standards for 12 key elements listed by EPA. Development of policies, procedures, and standards for 12 key elements listed by EPA. After 2-3 years of implementation and refinement at least one EMS audit, with results reported to the organization and EPA. After 2-3 years of implementation and refinement at least one EMS audit, with results reported to the organization and EPA.

Key Elements of a Compliance-Focused EMS Environmental policy Environmental policy Organization, personnel, and oversight of EMS Organization, personnel, and oversight of EMS Accountability and responsibility Accountability and responsibility Environmental requirements Environmental requirements Assessment, prevention, and control Assessment, prevention, and control Environmental incident and noncompliance investigations Environmental incident and noncompliance investigations Environmental training, awareness, and competence Environmental training, awareness, and competence Environmental planning and decision-making Environmental planning and decision-making Maintenance of records and documentation Maintenance of records and documentation Pollution prevention program Pollution prevention program Continuing program evaluation and improvement Continuing program evaluation and improvement Public involvement / community outreach Public involvement / community outreach

Key Elements of a Compliance-Focused EMS (cont’d) Environmental policy: Management commitment to achieving compliance with applicable federal, state, and local environmental statutes, regulations, enforceable agreements, and permits Management commitment to achieving compliance with applicable federal, state, and local environmental statutes, regulations, enforceable agreements, and permits Management’s commitment to continuous improvement in environmental performance. Management’s commitment to continuous improvement in environmental performance. Management’s intent to provide adequate personnel and other resources for the EMS. Management’s intent to provide adequate personnel and other resources for the EMS.

Key Elements of a Compliance-Focused EMS (cont’d) Organization, personnel, and oversight: EMS Organization including charts that identify units, line management, and other individuals having environmental performance and regulatory compliance responsibilities. EMS Organization including charts that identify units, line management, and other individuals having environmental performance and regulatory compliance responsibilities. duties, roles, responsibilities, and authorities of key environmental program personnel duties, roles, responsibilities, and authorities of key environmental program personnel Ongoing means of communicating environmental issues and information Ongoing means of communicating environmental issues and information

Key Elements of a Compliance-Focused EMS (cont’d) Accountability and responsibility: Responsibilities of management, on-site service providers, and contractors Responsibilities of management, on-site service providers, and contractors required reporting to regulatory agencies, and corrective actions required reporting to regulatory agencies, and corrective actions Incentive programs for managers and employees Incentive programs for managers and employees Potential consequences for departure from specified operating procedures, including liability for civil/administrative penalties imposed as a result of noncompliance. Potential consequences for departure from specified operating procedures, including liability for civil/administrative penalties imposed as a result of noncompliance.

Key Elements of a Compliance-Focused EMS (cont’d) Environmental requirements: Process for identifying, interpreting, and effectively communicating environmental requirements Process for identifying, interpreting, and effectively communicating environmental requirements Procedures for prospectively identifying and obtaining information about changes and proposed changes in environmental requirements, and incorporating those changes into the EMS. Procedures for prospectively identifying and obtaining information about changes and proposed changes in environmental requirements, and incorporating those changes into the EMS. Processes to ensure communication with regulatory agencies regarding environmental requirements and regulatory compliance. Processes to ensure communication with regulatory agencies regarding environmental requirements and regulatory compliance.

Key Elements of a Compliance-Focused EMS (cont’d) Assessment, prevention, and control: Assessment, prevention, and control: Process for assessing operations, for the purposes of preventing and controlling releases, ensuring environmental protection, and maintaining compliance with statutory and regulatory requirements. Process for assessing operations, for the purposes of preventing and controlling releases, ensuring environmental protection, and maintaining compliance with statutory and regulatory requirements. Process for identifying operations and activities where documented standard operating practices (SOPs) are needed to prevent potential violations or pollutant releases, and defines a uniform process for developing, approving, and implementing the SOPs. Process for identifying operations and activities where documented standard operating practices (SOPs) are needed to prevent potential violations or pollutant releases, and defines a uniform process for developing, approving, and implementing the SOPs. System for conducting and documenting routine, objective self-inspections by department supervisors and trained staff, especially at locations identified by the process described above. System for conducting and documenting routine, objective self-inspections by department supervisors and trained staff, especially at locations identified by the process described above. Process for ensuring input of environmental requirements (or concerns) in planning, design, and operation of ongoing, new, and/or changing buildings, processes, maintenance activities, and products. Process for ensuring input of environmental requirements (or concerns) in planning, design, and operation of ongoing, new, and/or changing buildings, processes, maintenance activities, and products.

Key Elements of a Compliance-Focused EMS (cont’d) Environmental investigations: Standard procedures and requirements for internal and external reporting of potential violations and release incidents. Standard procedures and requirements for internal and external reporting of potential violations and release incidents. Procedures for investigation, and prompt and appropriate correction of potential violations. The investigation process includes root-cause analysis of identified problems to aid in developing the corrective actions. Procedures for investigation, and prompt and appropriate correction of potential violations. The investigation process includes root-cause analysis of identified problems to aid in developing the corrective actions. System for development, tracking, and effectiveness verification of corrective and preventive actions. System for development, tracking, and effectiveness verification of corrective and preventive actions.

Key Elements of a Compliance-Focused EMS (cont’d) Training, awareness, & competence: Specific education and training required for organization personnel, as well as process for documenting training provided. Specific education and training required for organization personnel, as well as process for documenting training provided. Program to ensure that organization employees are aware of its environmental policies and procedures, environmental requirements, and their roles and responsibilities within the environmental management system. Program to ensure that organization employees are aware of its environmental policies and procedures, environmental requirements, and their roles and responsibilities within the environmental management system. Program for ensuring that personnel responsible for meeting and maintaining compliance with environmental requirements are competent on the basis of appropriate education, training, and/or experience. Program for ensuring that personnel responsible for meeting and maintaining compliance with environmental requirements are competent on the basis of appropriate education, training, and/or experience.

Key Elements of a Compliance-Focused EMS (cont’d) Planning and decision-making: Process to integrate environmental planning into organizational decision making Process to integrate environmental planning into organizational decision making Established written targets, objectives, and action plans by at least each operating organizational subunit with environmental responsibilities, as appropriate, including those for contractor operations conducted at the facility, and how specified actions will be tracked and progress reported. Established written targets, objectives, and action plans by at least each operating organizational subunit with environmental responsibilities, as appropriate, including those for contractor operations conducted at the facility, and how specified actions will be tracked and progress reported. Targets and objectives must include achieving and maintaining compliance with all environmental requirements. Targets and objectives must include achieving and maintaining compliance with all environmental requirements.

Key Elements of a Compliance-Focused EMS (cont’d) Maintenance of records & documentation: Types of records developed in support of the EMS (including audits and reviews), who maintains them and where, and protocols for responding to inquiries and requests for release of information. Types of records developed in support of the EMS (including audits and reviews), who maintains them and where, and protocols for responding to inquiries and requests for release of information. Data management systems for any internal waste tracking, environmental data, and hazardous waste determinations. Data management systems for any internal waste tracking, environmental data, and hazardous waste determinations.

Key Elements of a Compliance-Focused EMS (cont’d) Pollution prevention program: Internal program for preventing, reducing, recycling, reusing, and minimizing waste and emissions, including procedures to encourage material substitutions. Internal program for preventing, reducing, recycling, reusing, and minimizing waste and emissions, including procedures to encourage material substitutions. Mechanisms for identifying candidate materials to be addressed by program and tracking progress. Mechanisms for identifying candidate materials to be addressed by program and tracking progress.

Key Elements of a Compliance-Focused EMS (cont’d) Evaluation and improvement: Evaluation and improvement: Program for periodic (at least annually) evaluation of the EMS Program for periodic (at least annually) evaluation of the EMS Program for ongoing evaluation of facility compliance with environmental requirements, including periodic compliance audits by an independent auditor(s). Program for ongoing evaluation of facility compliance with environmental requirements, including periodic compliance audits by an independent auditor(s). Audit results are reported to upper management, and potential violations are addressed through the process described under Environmental Incident and Noncompliance Investigations above. Audit results are reported to upper management, and potential violations are addressed through the process described under Environmental Incident and Noncompliance Investigations above.

Key Elements of a Compliance-Focused EMS (cont’d) Public involvement & community outreach: Program for ongoing community education and involvement in the environmental aspects of the organization's operations and general environmental awareness.

EMS - Future Directions Increasing regulatory focus… Compliance Focused EMS Moving From Certifying EH&S Performance By Periodic Inspections To Continuous Demonstration Stronger Focus On Managing Costs, Optimizing Business Processes & Quality Systems Real Time EH&S Decision Making Governmental Organizations - Compliance With Executive Order 13148: Greening the Government Through Leadership in Environmental Management ( December 31, 2005)Executive Order 13148: Greening the Government Through Leadership in Environmental Management

EMS Compliance-Focused Tools A complete EMS utilizes reliable software tools supported by systems, procedures, and people. A complete EMS utilizes reliable software tools supported by systems, procedures, and people.

Summary The EMS Continuum The Link Between Quality Assurance & EMS Program Key Principals Key Elements EMS Benefits & Costs Compliance Focused EMS EMS Future Directions Comm-Trac TM (EMS Management Software)

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