Environmental Management An Overview of Environmental Management Systems Wayne E. Bates, PhD, PE

"Problems cannot be solved at the same level of awareness that created them." A thought to consider...

Agenda Compliance Auditing What is an EMS? Developing an EMS Conducting a Gap Analysis Unique Challenges

Compliance Auditing An audit is a snapshot in time used to measure environmental compliance.

Compliance Auditing Facility activities material use and storage hazardous waste generation and disposal emissions Permits Historical releases

Compliance Auditing An auditor may see compliance one day... …and something different the next.

Compliance Auditing Kodak - Example 1987 Organic solvent piping functioning 1988 Pipe breaks - 25,000 gallon release of organic solvent

Compliance Auditing Limitations Multiple snapshots on separate occasions with different outcomes

Compliance Auditing Kodak - Example Systemic issues not reviewed... known antiquated piping network constantly repairing pipe sections leaks observed in various sections maintenance personnel dedicated to repairs

Compliance Auditing Unless systematic issues are reviewed... You won’t get consistent results!

Agenda Compliance Auditing What is an EMS? Developing an EMS Conducting a Gap Analysis Unique Challenges

What is an EMS? A way to identify root causes What are your procedures? How often is training provided? Who is responsible? review them Talk to them review records and talk to staff

What is an EMS? A way to identify root causes Violation Root Causes

What is an EMS? Proactive management tool Organized approach Business-based Clearly defined Prevention vs. treatment Best management practices

What is an EMS? The Improvement Cycle Check Plan DoAct

What is an EMS? Major ISO Components Policy Planning Implementation Corrective Action Management Review

What is an EMS? Major Components + Improvement Cycle Planning Management Review Policy Implementation Corrective Action Start Continuous Improvement

Agenda Compliance Auditing What is an EMS? Developing an EMS Conducting a Gap Analysis Unique Challenges

Environmental Policy Improvement Prevention Compliance Developing an EMS Environmental Policy

Developing an EMS Planning Consider Aspects and impacts –products, activities, and services Legal requirements Objectives and targets Existing SOPs, Policies, Programs

Aspect and Impact Kodak - Example Aspect –piping of organic solvents Impact –potential release to the environment –exposure could cause injury/death

Objective and Targets Vehicle Storage - Example Objective –prevent release Targets –institute inspection program –use inspection to identify repairs –develop procedure to prioritize repairs 0

Developing an EMS Implementation With objectives and targets set let the implementation begin!

Developing an EMS Implementation Roles and responsibilities Training, awareness, competence Communication Documentation and control Operational control Emergency preparedness

Developing an EMS Implementation Roles and responsibilities define, document, communicate Provide training Operational controls define, document, communicate Emergency preparedness

Developing an EMS Implementation Roles and responsibilities Who is responsible? Communicate Document

Developing an EMS Checking/Corrective Action Monitoring and measurement Corrective and preventive action Recordkeeping Auditing

Monitoring and Measurement You can’t manage what you can’t measure Enables you to gauge performance analyze root causes identify corrective actions improve performance

Developing an EMS Management Review Periodic review of results Scheduled review

Agenda Compliance Auditing What is an EMS? Developing an EMS Conducting a Gap Analysis Unique Challenges

Conducting a Gap Analysis So, where do you start? 1. Is there a system in-place? 2. Do people follow the system? 3. Is the system is effective?

Gap Analysis Preliminary EMS Review there is a system in-place people follow the system the system is effective The Gap Analysis is a verification that Intent Implementation Effectiveness This indicates that

Gap Analysis Verification that... system is effective there is a system people follow the system

Gap Analysis Stages Pre-Audit Planning Notification Site VisitPost-Audit Initial Meeting Facility Tour Record Review Interviews Exit Briefing EMS Gaps

Agenda Compliance Auditing What is an EMS? Developing an EMS Conducting a Gap Analysis Unique Challenges

Direction Resources Budget Importance Change

Unique Challenges Difficult roadblocks to overcome Blurred lines of… communication responsibilities