Introduction to Environmental Management Systems Designing Your EMS: A USDA Workshop Introduction to Environmental Management Systems Self assessment was completed, Gap Analysis available at Area website Environment International Ltd. June 14-16, 2005

EMS Requirements in Executive Order 13148 Agency level EMS self assessment by October 2001 Facility pilot EMS by April 2002 EMS at all appropriate facilities by December 2005 Added “appropriate” facilities. Not all facilities have to have them.

Self Declaration Memorandum to Agency Environmental Executives dated January 27, 2004. Final version of protocol dated September 10, 2003. Verify conformance with ISO 14001. www.epa.gov/

What is an Environmental Management System? “The part of the overall management system that includes organizational structure, planning activities, responsibilities, practices, procedures, processes and resources for developing, implementing achieving and reviewing the environmental policy.” ISO 14001

What is an Environmental Management System? An environmental management system brings together the people, policies, plans, review mechanisms, and procedures used to manage environmental issues at a facility or in an organization.

An EMS is Environmental Facilitates environmental compliance Addresses environmental impacts Broadens environmental responsibilities to all whose work can have a significant impact on the environment Environmental office has technical expertise to contribute It has been my experience that the Environmental Manager is too overworked to have time to be the lead in developing an EMS. The whole point of an EMS is to

An EMS is Management Must have commitment of top managers EMS owned by facility manager Must be consistent with other management systems

An EMS is a System Requires awareness of formal structure Addresses policies, procedures, programs Doesn’t specifically address compliance components (drums, labels, etc.) I modified the third bullet, because an EMS does address emergency planning and training.

Continual Improvement Checking & Corrective Action ISO 14001 Components Continual Improvement Management Review Environmental Policy 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

Environmental Policy Issue a policy statement signed by facility manager At a minimum, commit to Continual improvement Pollution prevention Environmental compliance Identifies EMS framework Publicly available Added “At a minimum” to the description of elements of an E policy. Some government agencies are moving toward sustainability.

Planning Identify aspects and impacts from facility activities, products, and services Review legal requirements Set objectives and targets Establish formal EMS program

Implementation & Operation Define roles and responsibilities Provide EMS training Establish internal and external communication mechanisms Establish document control system Establish operational controls Integrate with or establish emergency preparedness procedures

Checking & Corrective Action Conduct periodic monitoring of environmental performance Identify root causes of findings and conduct corrective and preventive actions Maintain environmental records Conduct periodic EMS audit

Management Review Conduct periodic senior management review of EMS Revise parts of the EMS as needed

Benefits of an EMS Help maintain compliance Reduce operating costs Integrate environmental programs into mission Increase employee involvement Reduce environmental impacts Added a bullet on reducing environmental impacts of organization

Getting Your EMS Started: Your EMS Team Designing Your EMS: A USDA Workshop Getting Your EMS Started: Your EMS Team Environment International Ltd. June 14-16, 2005

Functions of the Team Educate all organizations at facility Conduct gap analysis Collect input from employees, management Plan and implement EMS Interact with local community as needed

Knowledge and Skills Needed for Team Enthusiasm and energy Project management skills Patience and persistence Training expertise Excellent communication skills Process/systems knowledge EMS knowledge Political savvy Access to top management Environmental manager has needed expertise for the Team, but may not be the best person to lead the Team. too busy other priorities prevent him/her from focusing on team’s work

Environmental Policy Statement Designing Your EMS: A USDA Workshop Environmental Policy Statement Environment International Ltd.

How not to create your environmental policy…

Policy Statement Importance Demonstrates management commitment Defines framework for EMS Provides framework for setting objectives and targets Must be appropriate to activities at facility

ISO 14001 Requirements In an ISO 14001 conforming EMS, an environmental policy statement must: Be appropriate to the nature, scale and env. impacts of its activities, products or services Be documented, implemented, maintained and communicated to all employees Be available to the public Documented Implemented Communicated

Management Commitment ISO 14001 Requirements I M P R O V E N T C L A Management Commitment Environmental Policy Documented Implemented Communicated

Environment International Ltd. Designing Your EMS: A USDA Workshop Gap Analysis Environment International Ltd.

Definition A gap analysis is a process used to assess the current state of your facility’s EMS. Other similar processes are “environmental management system reviews (EMRs).”

Purpose of a Gap Analysis Identify gaps between your current management systems and the EMS standard Collect policies, procedures, programs, metrics, and personnel that support the current EMS Establish a list of actions to achieve conformance with the standard

EMS Fenceline Factors that will define the scope of each NAA location’s EMS Physical size of your location Research mission of your facility Self-supporting location versus tenant of a larger facility having its own EMS State and municipal agencies that have environmental regulatory oversight over your location Entire organization, or specific operating units or activities (14001 Annex A) EPA Region 8 is tackling their internal functions for their EMS pilot. Will incorporate their programmatic functions later. Fort Riley is building EMS around DECAM functions – Directorate of Environmental Compliance and Management.

Steps in a Gap Analysis Facility walk-through (reference fenceline) Document review Staff interviews Identify and document gaps

Facility Walk Through Identify Activities, Products, and Services Main reason for facility’s existence Support activities Develop Comprehensive Picture of Facility Maps Pictures Lists of buildings and organizations

Document Review Examples of relevant documents: Environmental policy statements Other policy statements Mission statements SOPs Position descriptions Environmental plans (HW, P2, INRMP, SPCC, STORMWATER, AS-BUILT, etc) Training materials

Staff Interviews Identify organizational structure Identify requirements to fulfill mission Determine awareness of staff of EMS Awareness of environmental programs and goals

Identify and Document Gaps Compare with EMS elements Make a list of specific actions to close gaps

Environment International Ltd. March 22-23, 2005 Designing Your EMS: A USDA Workshop Identifying Environmental Aspects defined as a part of activity or product that interacts with environment Environment International Ltd. March 22-23, 2005

Aspects and the EMS When first developing your EMS, do a comprehensive aspects review ISO 14001 requires organizations to: develop procedures to identify environmental aspects keep register of aspects up-to-date As you repeat the EMS cycle, you can revisit the aspects and impacts analysis in areas where changes have occurred or where you need a more detailed analysis to help you in your continuous improvement program. Your most significant environmental impacts may be ones you weren’t thinking about initially.

Building an Aspects Register Assemble list of activities, products, and services Characterize activities, products, and services List aspects Organize and rank aspects as appropriate

Characterizing Your Activities, Products, and Services Interviews with research and field staff (what are they doing, are they using hazardous materials, etc.) What are your location’s hazardous material purchases (review inventories) Hazardous waste records Records from emergency planning, accident reports, emergency incidents Water and energy consumption records

Step 1 Look at the Comprehensive Picture of Your Facility Research Activities Facility Operations Activities Construction and Demolition Activities Within Your “Fenceline”, Identify and List Activities Crop research Animal research Use hazardous chemicals Generate hazardous waste

STEP 2 Determine if there are environmental aspects associated with each activity on your list An environmental aspect is the part of an activity, product, or service that interacts with the environment. An aspect can be thought of as the actual or potential “cause” of an environmental impact. Aspects can be regulated or unregulated. Aspects include those for which there is a regulatory threshold. Amounts released below the threshold should also be considered aspects, not just amounts which exceed a threshold. Example: even if you are a conditionally exempt hazardous waste generator, the hazardous waste you do generate is an aspect(s). There may be no specific regulations covering a particular aspect. Non-hazardous solid waste Carbon dioxide releases Water and energy consumption

Environmental Aspects Example 1 Environmental Aspects Depletion of natural resources in the following ways: (a) Energy utilized in chemical manufacturing; and (b) Energy requirements for chemical storage (e.g., use of electricity for low-temperature refrigeration or ventilation Generation of hazardous waste by the following activities: (a) Duplicate purchasing of hazardous chemicals already on location inventory; (b) Large-scale purchasing of unusable quantities of chemical; and, (c) Chemical is not used, resulting in chemical entering hazardous waste stream due to expired use date. Activity, Product, or Service Purchasing Hazardous Chemicals

Activity, Product, or Service Environmental Aspects Example 2 Activity, Product, or Service Facility Maintenance Environmental Aspects Hazardous waste generation (spent fluorescent lamps, PCB containing lamp ballasts, spent solvents, paints) Generation of asbestos-containing waste Generation of universal waste (used oils, mercury-containing equipment) Ozone depletion (repair of older refrigeration equipment containing ozone depleting refrigerants) Generation of solid waste (excess furniture and equipment) Release of volatiles

Activity, Product, or Service Example 3 Activity, Product, or Service Vehicle maintenance Environmental Aspect Hazardous waste generation Gasoline consumption Noise generation Electricity consumption Solid waste generation Water consumption Waste water generation Release of volatiles

Example 4 Environmental Aspect Activity, Product, or Service Electricity consumption Water consumption Waste water generation Release of ozone depleting substances in air cooling units Solid waste generation Disposal of toxics from computer toner, etc. Activity, Product, or Service Office work

Step 3 A significant environmental aspect is an environmental aspect that has or can have a significant environmental impact. Significance could be tied to: Environmental concerns Natural resource concerns Regulatory or legal exposure Business or mission concerns Concerns of interested parties

Factors That May Play a Role in Managing Aspects Size, severity and duration of environmental impact Ease of improvement Regulatory or Executive Order requirement Cost Mission impact Community impact Sustainability

From Aspects to Impacts Designing Your EMS: A USDA Workshop From Aspects to Impacts Environment International Ltd. March 22-23, 2005

Definition An environmental impact is a change to the environment, either adverse or beneficial, wholly or partially resulting from an organization’s activities, products, or services.

Potential Aspect Impact Cause Effect Process Outcome Verb Noun

Examples of Aspects & Impacts Vehicles emit exhaust Water leaks Fuel spills occur Spills happen from containers Lights, computers are left on when not in use Paper is bleached w/Cl2 Bicycles used, not cars Air pollution Water resource depleted Stormwater contaminated Chemical contamination of soil, water Air pollution and use of resources Dioxins in wastewater Less air pollution Examples of regulated, unregulated impacts Example of natural resource impact Examples of actual and potential impacts Example of human impacts Example of offsite impacts due to products used Example of positive environmental impact

EMS and Impacts Use the aspects register to identify impacts EMS addresses significant aspects Document your process for identifying aspects and impacts Add impacts to the aspects register

Exercise: Aspects & Impacts Activities, products, services Aspect Impact Transportation Fuel use Air pollution Natural resource depletion

Legal and Other Requirements Designing Your EMS: A USDA Workshop Legal and Other Requirements Environment International Ltd.

Potential Environmental Legal Requirements RCRA CAA CWA SDWA CERCLA ESA Natural and Cultural Resource regulations EOs NEPA EPCRA OSHA Pollution Prevention Act OPA Energy Policy Act Historical Preservation regulations FIFRA TSCA

EMS and Environmental Compliance Commitment to compliance is a key part of an EMS Achieve compliance through application of source reduction techniques Use EMS to direct resources to source reduction projects that address compliance issues

Updating Legal Requirements Required by ISO 14001 Regular review of regulations Distribution to appropriate personnel ISO 14001 requires facilities to establish a procedure to identify and make accessible legal and other requirements

Information Sources Code of Federal Regulations web site http://www.gpo.gov/nara/cfr/index.html Federal Register web site http://www.gpo.gov/su_docs/aces/aces140.html U.S. Code web site http://www4.law.cornell.edu/uscode/ EPA web site

Determining the Significant Aspects Designing Your EMS: A USDA Workshop Determining the Significant Aspects Environment International Ltd.

Definition A significant environmental aspect is an environmental aspect that has or can have a significant environmental impact. Significance could be tied to: Environmental concerns Natural resource concerns Regulatory or legal exposure Business or mission concerns Concerns of interested parties

EMS Requirements ISO 14001 uses “significant” aspects and impacts as the basis for developing objectives and preparing programs The facility determines which aspects and impacts are “significant” The EMS must address all significant aspects

Significance Considerations Size, severity and duration of environmental impact Ease of improvement Regulatory or Executive Order requirement Cost Mission impact Community impact Sustainability

Exercise: Determining significant Aspects Use reproducible methodology; e.g., rank using a formula containing factors the organization considers important Potential factors severity probability/frequency risk (environmental/ health/financial) Mission impact external concerns ability to control/ improve duration regulatory concern

Regulatory Importance Ranking Aspects to Determine Those That Should Be Managed Under My Location’s EMS Severity 5 Catastrophic 4 High 3 Moderate 2 Low 1 Slight 0 Positive Impact Regulatory Importance 5 Current violation 4 Non-compliance, past 3 yrs 3 Non-compliance, past 5 yrs 2 In compliance 1 Below regulatory cut-off 0 Unregulated

Example of Rating Scheme Significance = (Severity + RI + Prob)*Ease of Improvement **For few aspects or small locations the team can

Setting Objectives and Targets Designing Your EMS: A USDA Workshop Setting Objectives and Targets Environment International Ltd. June 2005

Definitions An EMS objective is an overall goal arising from the environmental policy statement set by the organization. An EMS target is a detailed measurable performance requirement related to the objective.

Organizations Shall Consider: Legal and other requirements Significant environmental aspects Technological options Financial, operational and business requirements Views of interested parties

Examples Objective: Reduce energy consumption by 30% by the year 2010 based on a 2004 calendar year baseline. Target: Immediately implement policy of turning off computers when not in use. Replace all lighting with energy efficient bulbs/fixtures by Dec 2005. Install motion detectors on light switches by June 2006.

Examples Objective: Reduce transportation congestion by 20% by December 2006. Targets: Increase the number of employee-days of mass transit use by 50% by the year 2006 based on a 2004 calendar year baseline. Purchase 25 bicycles for use within the facility by December 2005.

Setting Objectives and Targets Start with Planning data Options for identifying objectives: Goal setting workshop EMS Coordinator recommendations EMS Team recommendations Management Priorities

Exercise: Setting Objectives & Targets Aspect Impact Indicator (measure) Objective Target Fossil fuel consumption Use of non-renewable resource Gas bills, electric car purchases Purchase electric cars Lower bills, # cars bought

Linking Objectives to Programs Designing Your EMS: A USDA Workshop Linking Objectives to Programs Environment International Ltd. March 22-23, 2005

Definition An environmental management program is a formal set of procedures or activities designed to assign responsibility for and measure performance in achieving its environmental objectives and targets. Includes the means and timeframe by which the objectives and targets will be achieved.

Environmental Management Programs An environmental management program should define: responsibilities resources objectives documentation schedules Should be effectively aligned with existing management system elements Consistent with Budget and Planning Resource Allocation Systems Information and Support Systems Organizational Accountability Structure Reward and Appraisal Systems Measuring and Monitoring Systems Communication and Reporting Systems

EMS Document Structure Policy Aspects Register Objectives and Targets Environmental Management Plans Training Needs Surveys Organizational Charts Environmental Management Programs Standard Operating Procedures Training Records Hazardous Waste Manifests Energy Bills Day-to-Day Operations

Linking Objectives to Programs Start with EMS objectives Match programs to objectives Review current programs for non-conformance Correct non-conformance in programs Initiate new programs for objectives without existing programs

Summary of the EMS Planning Process Designing Your EMS: A USDA Workshop Summary of the EMS Planning Process Environment International Ltd.

Continual Improvement Checking & Corrective Action ISO 14001 Components Continual Improvement Management Review Environmental Policy 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

EMS Planning Steps Identify EMS Team Identify/Write/Modify Environmental Policy Identify Current Programs and Perform Gap Analysis Define Fenceline Identify Aspects and Impacts Create Program to Achieve Objectives and Targets Develop Objectives and Targets Prioritize/ Determine Significance

Where you should be at the end of the planning process: Prepared a policy statement Put together an EMS team Defined your fenceline Conducted a gap analysis Created an aspects register Reviewed legal requirements Determined the significant impacts Set objectives and targets Created environmental management programs

EMS Implementation and Operation Designing Your EMS: A USDA Workshop EMS Implementation and Operation Environment International Ltd. June 2005

EMS Implementation Translate all your planning into action Where performance is improved Next step is to roll out: training procedures documentation new job assignments

ISO 14001 Elements Implementation and operation involves Structure and Responsibility Training, Awareness & Competence Communication EMS Documentation Document Control Operational Control Emergency Preparedness and Response

Structure & Responsibility ISO 14001 requires facilities to define, document, and communicate organizational roles and responsibilities in an EMS, including an EMS management representative management to provide appropriate human, physical and financial resources to implement and maintain the EMS OMB Circular A-11 reinforces the requirement to budget for implementation of the EMS Organizations encouraged, under ISO14004, to show costs and benefits of environmentally related activities.

Incorporate EMS into Organizational Structure Revise organizational charts to reflect EMS Modify position descriptions to include EMS responsibilities Measure EMS performance in performance reviews Reassign personnel to EMS if necessary Allocate training and financial resources to EMS

EMS Roles & Responsibilities EMS Coordinator EMS Team Senior manager Line managers Personnel specialists Information management staff Functional experts Engineers Contracting officials Purchasing officials Energy managers Technical experts NEPA Contractors, concessionaires The knowledge and skills necessary to achieve environmental objectives should be identified. These should be considered in personnel selection, recruitment, training, development of skills and ongoing education. (ISO14004) Motivation to continually improve can be enhanced when employees are recognized for achieving environmental objectives and targets and encouraged to make suggestions that can lead to improved environmental performance. (ISO14004)

EMS Coordinator Management representative with defined roles and responsibilities: ensuring EMS requirements are met report on performance of the EMS to top management for review and as a basis for improvement

Performance Reviews Require accountability for appropriate personnel Measure individual performance as it contributes to EMS objectives Include EMS in EMS Coordinator’s and EMS Team’s reviews (HRD ) Operational managers should be responsible and accountable for effective implementation of EMS and environmental performance. Employees at all levels should be accountable, within the scope of their responsibilities, for environmental performance in support of the overall environmental management system.

Resource Allocation Management must provide sufficient resources to implement the EMS including: Personnel Physical resources Equipment Training Financial resources (HWC)

Training is essential to an effective EMS! Training Steps Determine audiences for general and specific training Identify trainer Develop and implement training schedule Keep accurate and complete records Training is essential to an effective EMS!

ISO 14001 Training Requirements EMS Awareness level in addition to functional areas Personnel performing tasks that can cause significant environmental impacts shall be competent based on education, training, and/or experience. (USTs, WWTRs) Management shall provide resources essential to the implementation and control of the environmental management system. Resources include human resources and specialized skills, technology and financial resources.

ISO 14001 Training Requirements (cont.) Conformance with environmental policy and EMS Significant environmental aspects of work activities Roles and responsibilities in EMS Emergency preparedness and response Potential consequences of departure from specified operating procedures (SOPs)

Audience and Needs EMS Coordinator- thorough knowledge of EMS framework EMS Team- working knowledge of EMS framework Senior managers- knowledge of purpose and management role in EMS Employees with significant aspects– role in EMS and responsibilities All employees- basic environmental and EMS awareness

Training Timeline General EMS Training (Dec 2005): First group - EMS coordinator, EMS team Second group - Facility manager, senior managers Third group - All employees Specific Training on SOPs: Supervisors and responsible employees

Training Records Legible, identifiable and readily retrievable Protected against damage, deterioration or loss Retained and available to verify conformance Current system is acceptable

Communication Why is it important? Convey management commitment to EMS Raise awareness of organization’s environmental policies, objectives, targets and programs Generate suggestions for improvement Address concerns and questions Inform interested parties about the EMS and environmental performance Address emergency planning and other relevant issues

Internal Communication “Vertical” communication within the organization Senior manager to/from line managers Line managers to/from staff EMS team to/from senior manager, line managers, staff “Horizontal” communication Between offices Within an office or shop Results from EMS monitoring, audit and management review should be communicated to those within the organization who are responsible for performance.

External Communication The organization must Review, document and respond to relevant external communication ARS communicates through several channels, both regulatory and research, NEPA

Examples of External Communication Public Involvement Earth Day Open Houses Web Sites Traditional Media Newspapers TV and radio Regulatory submissions Facility newsletters EPCRA reporting NEPA scoping, public involvement Citizens’ advisory committees Two way communication is encouraged! Communications should be understandable and adequately explained – Plain English Information should be verifiable. Organization should present an accurate picture of its performance. Information should be presented in a consistent form (for example in similar units of measurement for easy comparison)

EMS Documentation Describes main elements of EMS Provides directions to related documents Supports employee awareness Facilitates implementation and evaluation of the system and environmental performance

Examples of EMS documents Policy statement Information on significant aspects Procedures Process information Organizational charts Internal and external standards Site emergency plans Records

Document Control Documents can be located by people who need them (ADM or CDSO) All documents are reviewed, revised and approved for adequacy Current versions are identified/available Documents of external origin important for the EMS are identified as such Obsolete versions are promptly eliminated

EMS Requirements for Operational Controls Establish and maintain procedures for activities associated with significant aspects Most facilities have existing operational controls (Facility, lab protocols) Stipulate operating criteria in procedures Communicate procedures to appropriate parties (suppliers, contractors, etc.) Communicate relevant procedures and requirements to suppliers and contractors

Examples of Operational Controls Standard Operating Procedures Contract language Labeling of materials Signage Log books Check lists Measuring equipment Energy meters Tank volume meters Overflow devices and check valves Air flow indicators Preventive maintenance

Emergency Preparedness / Response – EMS Requirements Establish and maintain procedures to identify and respond to accidents and emergencies (Safety, OEP plans) Address potential environmental effects Review and revise procedures as necessary after accidents (accident investigation) Conduct periodic tests of procedures (drills) Most federal facilities have mature programs in place

Environment International Ltd. Designing Your EMS: A USDA Workshop Checking Environment International Ltd. Seattle, WA (206) 525-3362 • www.eiltd.net

Checking Conduct periodic monitoring of environmental performance Identify root causes of findings and conduct corrective and preventive actions Maintain environmental records Conduct periodic EMS audit

Checking Procedures shall be established for monitoring the EMS and correcting deviations. Requirements for procedures cover: Monitoring and measurement Evaluation of compliance Nonconformance and corrective and preventive action Control of records EMS audits

Monitoring and Measurement Develop procedures to regularly monitor and measure key operations and activities with significant environmental impacts Record information tracking performance, relevant operational controls and conformance with the organization’s objectives and targets Calibrate and maintain monitoring equipment and retain associated records

Evaluation of Compliance Establish procedures to periodically evaluate compliance with relevant environmental legal and other requirements Keep records of the results

Nonconformance and Corrective and Preventive Actions Establish and maintain procedures for handling and investigating nonconformance taking action to mitigate impacts initiating and completing appropriate corrective and preventive actions

Nonconformance and Corrective and Preventive Actions (cont.) Record any changes resulting from corrective actions Review the effectiveness of actions taken

Reasons for a Nonconformance Implementation differs from documentation System is not working Requirement is not addressed

Records – a special type of document Provide verification of things that have happened Individual records are not updated (new records are created) Slide to be used during brainstorming session to make an electronic statement???

Records Procedures must be maintained for the identification, storage, protection, retrieval, retention and disposal of environmental records. Records must be maintained to demonstrate conformance to EMS requirements and the results achieved.

Records Properly maintained records will be legible identifiable traceable to the activity, services or product involved

Scope of Records Records should cover: Legal compliance Process monitoring Environmental aspects and their impacts Environmental training Inspection, calibration and maintenance activity Continued…

Scope of Records (cont.) Environmental communications Details of non-conformance: incidents, complaints and follow-up action Tests for emergency preparedness Environmental performance information Pertinent supplier and contractor information Environmental audits and management reviews Environmental meetings

Environment International Ltd. Designing Your EMS: A USDA Workshop EMS Audits Environment International Ltd. Seattle, WA (206) 525-3362 • www.eiltd.net

Environment International Ltd. March 22-23, 2005 Designing Your EMS: A USDA Workshop Management Review Environment International Ltd. March 22-23, 2005

Management Review Conduct periodic senior management review of EMS Revise parts of the EMS as needed

Continual Improvement Management must regularly review the EMS and audit results to ensure sustained improvement in environmental performance and compliance with changing regulations. An organization must be committed to continual improvement of environmental performance so that its EMS continues to be effective and environmental aspects are always factored into business decisions.

Post - Test Any questions about: EMS Checking and Corrective Action EMS Auditing Management Review Other