Environmental Management System Training

Environmental Management System Training
United States Forest Service July 6, 2004 Ed Pinero, Acting Federal Environmental Executive

EMS Implementation Workshop
An Overview of Environmental Management Systems (EMS) and the ISO Standard EMS Implementation Workshop

WHAT IS AN ENVIRONMENTAL MANAGEMENT SYSTEM? The ISO 14001 Definition
“The overall management system that includes organizational structure, planning activities, responsibilities, practices, procedures, processes and resources for developing, implementing, achieving, reviewing and maintaining the environmental policy.” This is the definition of an EMS that is found in the ISO EMS Standard - it is complex but is clear that all aspects of an organization or facility are affected by the EMS - also, note that the definition follows the plan do check act paradigm of developing, implementing, achieving, reviewing and maintaining - also note that all of this is to support the environmental policy - think about that as you are begin your EMS by drafting your policy EMS Implementation Workshop

“ems” vs. “EMS” All organizations have some type of environmental management system regardless of what they do For this discussion, the focus is a more formalized, recognized, and structured approach defined in the international EMS standard, ISO 14001 In most cases, additional effort is needed to transition from existing environmental activities to the more formal ISO type EMS EMS Implementation Workshop

An Effective EMS is: Flexible Transparent Useful to the “practitioner” In harmony with mission focus Focused on continual improvement An EMS is a flexible process that thrives on change- because each component responds to changes in another - the EMS can adapt to changes affecting the organization -from changes in regulations to changes in mission An EMS is transparent in several ways - it is based on standard components that are understood by those actively implementing the EMS and the is general awareness within the overall organization. Finally, those outside the organization are provided an opportunity to understand the EMS An EMS benefits each activity of an organization seeking to make each more efficient - an EMS requires that you look at your organizations activities - often when this happens, the practitioner is empowered to make the activity more efficient A well designed EMS reflects the mission and goals of the organization and supports that mission by making the organization more efficient and cognizant of those things that could hamper, or interfere with, the mission An EMS always looks to improve efficiency and effectiveness of the organization - and because an EMS is a process that is designed for long-term review and planning, it allows an organization to address improvement over a manageable timeframe EMS Implementation Workshop

EMS and ISO 14001 14001 is one of the standards in the series Created by International Organization for Standardization (Geneva, Switzerland) Each participating nation has a committee that develops consensus and contributes (one vote each, for US it is ANSI) EMS Implementation Workshop

Important EMS Terms “Shall” “Establish and Maintain” “Responsibility and Authority” EMS Implementation Workshop

Continual Improvement Checking & Corrective Action
Plan Do Check Act 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 Implementation Workshop

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 EMS Implementation Workshop

Environmental Aspects and Impacts-ISO 14001 Definition
Elements of an organization’s activities, products or services which can interact with the environment. (For example: wastewater discharges, air emissions, resource consumption, energy usage, ecosystem alterations, etc.) ENVIRONMENTAL IMPACTS Any change to the environment, whether adverse or beneficial, wholly or partly resulting from an organization’s activities, products, or services (based on the aspects, for example: air emissions impacts the air by degrading the air quality). Efforts and activities related to managing the environmental aspects is how the EMS becomes tangible to the workforce. EMS Implementation Workshop

Implementation and Operation
Capabilities & Organization & Controls Accountability Communications Document Control Training, Awareness and Competence Operational Control Structure and 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 Responsibility Communication Emergency Preparedness and Response EMS Implementation Workshop

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. EMS Implementation Workshop

Management Review 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 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 EMS Implementation Workshop

Keep in mind… 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. EMS Implementation Workshop

Why Implement an Environmental Management System?
EMS Implementation Workshop Why Implement an Environmental Management System?

The Drivers - Why EMS? History/perspective
EMS responded to “root causes” for poor environmental program management and compliance problems EMS has corollary benefits of management systems to mission and environmental stewardship EMS represents the next step in evolution from compliance, to pollution prevention (for compliance), to EMS The EO that calls for EMS implementation - EO was written by a group of federal agency mangers who had seen good and bad environmental programs - the EMS approach represents an effort to identify root causes of poor environmental program management from an agency standpoint - it also responds to EPA knowledge of causes for non-compliance with regulations - finally - it recognizes that the benefits of a well managed environmental program go beyond compliance with regulations but also benefits the mission of the organization and provides a framework for environmental stewardship EMS Implementation Workshop

EO 13148 Establishes EMS as environmental management policy for the Federal government Requires agencies to incorporate EMS into agency environmental directives and policies Requires facilities to develop and implement EMS by December 31, 2005 As a result of these findings, EO establishes the basis for environmental management across the Federal community - by requiring EMS concepts to be integrated into agencies policies and by requiring the Federal agencies ensure their facilities are implementing EMSs at their facilities EMS Implementation Workshop

What an EMS is A formal, structured framework of policies, procedures and practices to manage and reduce an organization’s environmental footprint Based on a PLAN-DO-CHECK-ACT framework An approach that reflects the relationship between environmental issues and core mission OK so what is this great thing the EMS? You will hear people refer to an EMS as a framework for addressing the environmental implications of an organization’s (or facilities actions) with policies, objectives and plans, procedures to implement those plans AND check how well those plans are working and change them if necessary. EMS concepts follow accepted business management practices of the plan-do-check-act formula and serve to integrate environmental (and other) issues with core mission - because EMS is flexible and reflects with changing conditions, it is not a one time effort - an because it reflect the full environmental character or footprint of a facility, it goes beyond regulated elements of your facility EMS Implementation Workshop

What an EMS is NOT A one-time project, plan or initiative Focused solely on regulatory compliance An effort solely for the environmental shop EMS Implementation Workshop

Benefits of an EMS Improved environmental awareness, involvement and competency across organization Better communication of environmental issues - internal and external Positive effect on regulatory compliance and environmental performance Some of the benefits of EMS - it improves compliance profile and environmental “footprint” - it improves environmental awareness across the organization (EMS integrates environmental elements at the “practitioner” level) - it improves communication within the organization and outside (about the environmental goals) EMS Implementation Workshop

Benefits of an EMS Improved efficiency, reduced costs, greater consistency in environmental program Flexibility and opportunity to correct imperfections through “continual improvement” Identification of risk and prevention of problems outside of regulatory - e.g., aging infrastructure, known unregulated hazards Because an MES is inherently a business “management system” it improves efficiency and make things work more smoothly at reduced cost and because an EMS is built on the premise that operations change it adapts for change with the premise that we always strive to improve - finally, the EMS identifies operational elements that might otherwise be missed and might become a remediation headache if not addressed EMS Implementation Workshop

Barriers - What stands in the way of EMS?
Organizational change - natural resistance to change in any organization Lack of top management involvement and visibility Organizational issues - “that’s an environmental responsibility” “That’s my responsibility” from the environmental shop OK if EMS is so great what is taking so long?? First, the Federal government, probably more than most organizations is resistant to change - it is a fear that we will invest in change and things will not get better - this is particularly true at top management levels where trying something new can be a career limiting move - people tend to stick with what they have even if it not working as well as you hope - in addition, some see EMS as purely “environmental” and think that the organization can leave the implementation in the hands of the environmental shop - or worse yet, the environmental shop sees EMS as threatening their role and refuses to move forward EMS Implementation Workshop

Potential Barriers small p and BIG P political uncertainty - is EMS here to stay? Perception that EMS already exists - systems exist now, why change? Misunderstanding of relationship to mission “environment only gets in the way of mission” Outside of the organization, you may find that EMS is viewed with suspicion by stakeholders or community members - they may not be as supportive as you would like Also - their may be those in the organization that see this as a “flavor of the month” and think it will go away with change in administration or they will say, an EMS already exists and we really don’t need to go through this exercise - plus, this is just an environmental thing anyway and we really need to focus on our mission right now. We have heard each of these comments and hopefully recognizing these barriers will allow use to deal with them - listen closely this afternoon when those who have implemented EMS speak and you will see why these barriers are not well founded EMS Implementation Workshop

The Three C’s of an Effective EMS
Conformance Meets the requirements (Implements the “shalls”) Consistency Various elements inter-related (i.e., Significant aspects reflected in emergency planning, etc.) Continual improvement Mechanisms are in place to improve the EMS and organizational performance, supported by management commitment and support EMS Implementation Workshop

Keep in mind - AN EMS Is a management system - THAT’S WHAT MAKES IT WORK!! 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! EMS Implementation Workshop

Using Measurement as a Management Tool
Knowing existing conditions allows informed management decisions. An EMS identifies, directs and facilitates relevant measurements. Measurements include environmental conditions, status of programs, compliance, and the EMS itself. Imagine life without measures and parameters to make decisions. Imagine shopping but not knowing prices; trying to manage your health without ever getting a checkup; going to years of school and not getting grades, etc. EMS Implementation Workshop

Examples of Metrics to Measure Benefits
Improves the environmental condition (environmental indicators) Facilitates meeting your mission (how often environmental issues interfere with your mission) Minimizes accidents and problems (incidents, losses) Reduces redundant paperwork (time spent per task) More efficient use of resources (investment per unit activity) Facilitates compliance with requirements (number of non-compliances, penalty costs, missed EO deadlines) Responds to public scrutiny trends (complaints, communications) EMS Implementation Workshop

Managing Aspects vs. Impacts
It is more prudent and more efficient to manage “how” you interact with the environment than to manage “what” you have done to the environment An EMS is built around identifying, prioritizing, controlling, and improving upon, those elements of the organization that interact with the environment For example; it is is better to know that wastewater discharges may impact the environment, and therefore manage the effluent quality than it is to wait for the fish kill and try to manage the crisis. EMS Implementation Workshop

Fixing the Root Causes An EMS is designed to identify the root causes of non-conformances and initiate corrective and preventive action. This helps minimize the “bandage” syndrome, where the fixes are simply superficial. For example, if drums are not labeled, it is better to find out why they are not, and fix that problem, rather than constantly going around and labeling the drums. EMS Implementation Workshop

Achieving and Maintaining Compliance
There is “compliance management system” embedded within the broader “environmental management system” First- the theme of compliance is seen throughout the plan-do-check-act elements Second, there are specific compliance-related requirements in an EMS (such as periodic compliance audits) that help address compliance issues before they occur. EMS Implementation Workshop

Supporting Mission An EMS identifies and addresses environmental issues that can hamper mission through emergencies or non-compliance The EMS perspective identifies opportunities that ultimately support mission through increased efficiency EMS Implementation Workshop

Connecting the Environment and the Process Owners
An EMS helps each member of the organization understand their role in the environment, and to see how their role at the facility impacts the environment An EMS provides for responsibility, ownership, and accountability of actions and related impacts Results? People that are more aware, better trained, more motivated, and more enthusiastic The greatest benefit of implementing an EMS is the change in behavior in attitudes about the environment. No matter how good the environmental manager of the facility is they can’t do as good of a job as everyone taking responsibility. Most auditors find that it isn’t that people ignore environmental requirements, it is that they are ignorant of their impact on the environment. An EMS is a systematic way to ensure everyone knows about the environmental aspects of their job. An EMS requires that you look at your processes. Often when this happens people find ways to make the process more efficient. EMS Implementation Workshop

Connecting the Organization With the Public
An EMS allows an organization to identify issues which may become a concern to the public An EMS indicates to the public that an organization is aware and responding to environmental issues An EMS provides a forum for discussion and reaction to environmental interests of the public EMS Implementation Workshop

Selecting and Preparing the EMS Team
EMS Implementation Workshop Selecting and Preparing the EMS Team

Function of the Team Conduct the gap analysis Gather and analyze existing data Identify needs Develop implementation plan Initiate early stages of EMS Policy, Aspects/Impacts, Objectives/Targets Environmental Management Program Monitor implementation of EMS EMS Implementation Workshop

Responsibilities of the Team
Collect input and information from employees and Management Educate members of the organization or facility on the EMS Awareness training Activity specific training Brief and advise Management Interact with local community EMS Implementation Workshop

Knowledge and Skills All EMS knowledge and understanding Enthusiasm and energy Organizational / (p)olitical savvy Specialists Communication skills Project management skills EMS Implementation Workshop

The Team Members Keep numbers manageable Strong leadership Known ability to communicate with management Good people skills Best leadership may be outside of environmental shop EMS Implementation Workshop

Team Members Broad base - Include resource (budget) personnel, facilities, representative process owners, on- site contractors, management representative EMS Implementation Workshop

Process Get commitment and authority to act Find appropriate members Provide initial background information of EMS Get commitment from Team Get fully trained Consider consultants help Keep management apprised of progress EMS Implementation Workshop

Level of Effort Leverage existing resources - budget/ planning cycles etc. Depend on Team champions Don’t underestimate effort needed and ensure commitment is there EMS Implementation Workshop

Defining Your Fenceline: What is the scope of an EMS?
EMS Implementation Workshop Defining Your Fenceline: What is the scope of an EMS?

EMS Fenceline Link to aspects - “can control” or are “expected to have an influence” Define the scope of your EMS -alternatives Use physical boundaries of facility Reflect existing management systems Reflect organizational structure 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. EMS Implementation Workshop

EMS “Boundaries” Geographic fenceline or boundary Consider where activities primarily occur Reflect of top management control Management boundaries previously established Existing management plans or systems Corporate boundaries Reflect existing management structure EMS Implementation Workshop

Don’t forget to consider!
Non mission activities Visitor and personnel support, housing, food service, recreation Contractors and services Geographically separate areas Local governments and neighbors EMS Implementation Workshop

Use caution: Don’t artificially exclude processes that you clearly control but are “unmanageable” Don’t artificially exclude something because you believe you can’t control it organizationally Contracted processes are still within your control - they can’t be excluded EMS Implementation Workshop

Questions to ask Are all organizations associated with activities, products, and services included? Will the boundary include process owners and those with authority to improve processes? Is there management control available for the selected boundary? Is primary mission covered? The following groups may be involved with computers: Data systems group – defines specifications, acceptable models, manufacturers, software Purchasing Receiving and burn-in Property management Computer support Property/DRMO – for computer recycling or disposal Budget and planning – for funding for proper recycling, disposal or reuse EMS Implementation Workshop

Gap Analysis and Implementation Plans
EMS Implementation Workshop Gap Analysis and Implementation Plans

Gap Analysis A gap analysis is an assessment process used to compare the current state of your facility’s EMS against a standard. It is not an audit; you cannot “fail” a gap analysis Other similar processes are “Initial Environmental Reviews (IERs)” or “Environmental Management Reviews (EMRs).” EMS Implementation Workshop

Purpose of a Gap Analysis
To identify gaps between your current management systems and the EMS standard To identify existing policies, procedures, programs, metrics, and personnel that can be part of the EMS To assist in establishing a list of actions to achieve the desired EMS EMS Implementation Workshop

Conducting a Gap Analysis
Use tool or checklist that identifies requirements Analysts must be familiar with EMS framework and site activities Allow several days to complete data collection Prepare a summary report that explains what the gaps are and what must be done to fill them EMS Implementation Workshop

Steps in a Gap Analysis Facility walk-through Document review Staff interviews Compare with desired EMS elements Identify and document gaps (be specific, yes or no answers are not helpful) EMS Implementation Workshop

Developing the Implementation Plan
Uses the Gap Analysis findings Intended to logically plan for the implementation Requires assessing what needs to be done, and assigning time frames, resource needs, and milestones to do so Provides a tool to ensure management commitment and “staying the course” EMS Implementation Workshop

Planning the Level of Effort
Estimate level of effort based on gap analysis Leverage existing resources Don’t underestimate! Obtain management commitment for implementation early Web site for local govt case study examples of amount of resources needed to develop EMS: Environmental Management System Pilot Program for Local Government Entities EMS Implementation Workshop

EMS Policy

ISO 14001 Policy Statement Requirements
Be appropriate to the nature, scale and environmental impacts of the organization’s activities, products and services Provides framework for setting objectives and targets Be documented, implemented, maintained and communicated to all employees Include a commitment to: Continual improvement Prevention of pollution Compliance with environmental regulations and other requirements to which the organization subscribes Be available to the public Documented Implemented Communicated EMS Implementation Workshop

Policy Statement Importance
Is the foundation of the EMS Demonstrates management commitment Communicates the “environmental culture and commitments” of the organization Gives the entire organization a statement to rally around EMS Implementation Workshop

Timing the Policy Statement
Policy statement may not be first step: Review your agency’s current environmentally-related policy for adaptability Determine level of awareness of EMS with senior managers and level of understanding of importance of the policy Make a case for EMS first Use initial EMS development information to help formulate policy high level of awareness - proceed with policy low level of awareness - brief concept efficiency and cost reduction improved awareness and compliance EMS Implementation Workshop

Writing the EMS Policy Statement
Is a short, concise statement that includes the requirements as well as additional information to meet stakeholder expectations Does not need to summarize or repeat EMS details Signed by senior-most management within the defined EMS scope Is consistent with EMS framework and aspects Needs to be “ memorable” to staff EMS Implementation Workshop

Legal and Other Requirements
EMS Implementation Workshop Legal and Other Requirements

Examples of Legal Requirements
RCRA CAA CWA SDWA CERCLA EPCRA NEPA OSHA Pollution Prevention Act EMS Implementation Workshop

Examples of “Other” Requirements
Unique to Federal Community Executive Orders and Memoranda Parent Agency Policies Voluntary programs Performance Track LEED Certification Energy Star facility EMS Implementation Workshop

Identify - Initial materials should be in place
Identify existing permits, licenses, reports Use compliance programs of parent agency or service Agency general counsel and legal advisors TEAM guide On line tools Compliance assistance materials -documents EMS Implementation Workshop

Providing Access and Maintaining
Ensure easy access Hardcopy, web access, database Identify and support process to receive and include updates Headquarters audit programs and other tools including tools used by other agencies TEAM guide WEB sites and listserves EMS Implementation Workshop

Access Ensures there is a process that keeps regulatory and other information up-to-date Ensures that there is a process to direct any new information to that part of the organization where it is relevant EMS Implementation Workshop

Process - When things change
Remember - when aspects change, legal and other requirements need to be checked! Recognize relationship between aspects, activities and legal or other requirements Recognize relationship between regulated activity process owners and requirements EMS Implementation Workshop

Aspects, Impacts, and Significant Aspects
EMS Implementation Workshop Aspects, Impacts, and Significant Aspects

Specific Benefits Prompts your organization to identify issues not typically managed; particularly non-regulated issues Integrates environmental issues into operations Makes for proactive planning EMS Implementation Workshop

Environmental Aspects and Impacts-ISO 14001 Definition
Elements of an organization’s activities, products or services which can interact with the environment. (For example: wastewater discharges, air emissions, resource consumption, energy usage, ecosystem alterations, etc.) ENVIRONMENTAL IMPACTS Any change to the environment, whether adverse or beneficial, wholly or partly resulting from an organization’s activities, products, or services (based on the aspects, for example: air emissions impacts the air by degrading the air quality). Efforts and activities related to managing the environmental aspects is how the EMS becomes tangible to the workforce. EMS Implementation Workshop

ISO 14001 requires organizations to:
Develop procedures to identify environmental aspects in order to determine those which have or can have significant impact on the environment Keep aspects information up-to-date (regularly, and whenever changes occur), not once and done. Necessary records will include aspects lists, and significant aspects list EMS Implementation Workshop

Role of Aspects in the EMS
Significant aspects drive the EMS and are a subset of the full list of aspects EMS is designed to identify, control, manage, and improve upon the significant aspects Compliance with Legal and Other Requirements is a part of the system that does relate to the aspects Elements such as operational control (procedures and work instructions), training, monitoring and measurement, emergency planning, and setting objectives all depend on significant aspects. EMS Implementation Workshop

More on Environmental Aspects
Aspects are “cause”, impact is the “effect” Control and influence of aspects is a factor Aspects can be: direct or indirect normal, abnormal, or emergency past, present, or future Aspects address not only waste stream, but resource consumption, energy, and other “non-traditional” factors (noise, odor, visual) EMS Implementation Workshop

Going About the Aspects Process
Identify who and how this will be done (aspects procedure) List and characterize activities, products services Identify aspects and impacts for each A/P/S -Tap into your knowledge base! Determine significance Maintain records EMS Implementation Workshop

Activities, Products and Services
This is where you describe what you do at your facility – mostly “activities” for Feds Consider mission – what ‘facility’ is designed to do - e.g. visitor center Consider activities that support the mission – e.g. vehicle maintenance Consider actions that are both regulated and not regulated e.g. commuting to work EMS Implementation Workshop

Aspect Analysis - Examples of Activities
Mission related operations Maintenance Motor vehicle fleet operations Wastewater treatment Solid waste handling and disposal Raw material and chemical handling Bulk storage of fuels Administrative and employee activities Engineering Purchasing EMS Implementation Workshop

List Aspects Can sort and organize aspects, for example: Releases to air Water consumption, pollution Land contamination Use of raw materials, natural resources Other local environmental, community issues Will be able to “re-sort” later to better manage the aspects EMS Implementation Workshop

Examples of Aspects Not an aspect: Improve air quality – this is an objective P2 – this is an objective Vehicle maintenance – this is an activity Water pollution – this is an impact Aspect: Waste generation Material usage Fuel usage Air emissions Chemical consumption Energy consumption EMS Implementation Workshop

Examples Activity, Product, or Service Aircraft operations Bus transportation and maintenance Environmental Aspect Jet fuel consumption Jet fuel releases (potential) Noise generation Gasoline consumption Electricity consumption Solid waste generation Water consumption Waste water generation EMS Implementation Workshop

Examples 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 EMS Implementation Workshop

Examples Activity, Product, or Service Store Cafeteria
Environmental Aspect Raw material consumption Fuel consumption for transport Solid waste generation Food waste generation Electricity consumption Water consumption Waste water generation Release of ammonia from refrigeration equipment (potential)

Examples Activity, Product, or Service Office work Environmental Aspect Electricity consumption Water consumption Waste water generation Release of ozone depleting substances in air cooling units (potential) Solid waste generation Heavy metals “use” in computers EMS Implementation Workshop

Examples Activity, Product, or Service Cleaning offices Playing field upkeep (golf course, softball field, parade ground) Environmental Aspect Hazardous material release Electricity consumption Solid waste generation Waste water generation Water consumption Runoff from pesticide usage Gasoline consumption Grass clipping generation EMS Implementation Workshop

Identify the Impacts of Aspects
Once the aspects are identified, you must identify the impact(s) associated with each one. This can be done using the same process you used for aspects, except there might be more involvement of environmental staff to assess impacts List impacts along with aspects Example of impact not typically part of an environmental program – paper consumption EMS Implementation Workshop

Examples of Aspects & Impacts
Air emissions (exhaust) Water consumption Fuel release (accidental spills) Noise generation Energy consumption (lights left on) Paper recycled Air quality degraded Water resource depleted Storm water contaminated Soil contaminated Area nuisance Increased CO2 from coal-fired power plant emissions Landfill space conserved, raw materials conserved 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 Implementation Workshop

Determine Significant Aspects
A significant aspect is one that has or can have a significant impact on the environment (you define) Site selects the criteria for significance rating and cutoff value Significance can be determined by numeric cutoff value or subjective assessment based on yes/no answers Significance could be tied to: environmental degradation concerns, natural resource concerns, regulatory or legal exposure, concerns of interested parties EMS Implementation Workshop

EMS Requirements ISO uses “significant” aspects and impacts as the basis for developing objectives and preparing programs. The organization chooses which aspects are “significant,” based on applying their own criteria, to the related impacts. However, once significant, the EMS must address the aspect. Process and criteria for significance described in procedure. EMS Implementation Workshop

Many Methods for Determining Significance Criteria
Staff judgment Risk Assessment Organizationally-derived criteria and/or hybrid approaches based on staff judgment and risk assessment Key is to be consistent, and in line with “reality check” – are you capturing what makes sense? Criteria must relate to environmental impact EMS Implementation Workshop

Examples of Significance Criteria
Magnitude - How big of a problem is it? Global, regional, local? Severity - How bad will it get? Probability - How likely is it to occur? Daily, weekly, monthly, annually, in emergencies, only when a certain event happens, when a new project starts? Regulated? Of concern to interested parties? EMS Implementation Workshop

Applying the Criteria Each aspect must be evaluated in terms of the criteria Significant ones listed Each time a new aspect enters the system for whatever reason, it must be evaluated for significance ALL significant aspects must be carried forward into the system EMS Implementation Workshop

Identify Aspects Significant? no Remains on aspect list yes Significant aspect No, or yes but want to do more? Objectives and targets Under Control? Operation controls yes Address now? No (still must have controls) Yes EMPs, and Operational Control Deployed in EMS

Setting Objectives and Targets
EMS Implementation Workshop Setting Objectives and Targets EMS Implementation Workshop

Definition An EMS objective is an overall goal that reflects the environmental policy statement set by the organization. An EMS target is a detailed, measurable performance metric related to the objective. EMS Implementation Workshop

Examples Objective: Reduce use of hazardous chemicals Target: Reduce use of EPA listed Toxic Release Inventory chemicals by 5% annually based on calendar year 2001 use figures EMS Implementation Workshop

Examples Objective: Reduce energy consumption Target: Reduce energy consumption by 25% by the year 2005 based on a 2000 calendar year baseline. EMS Implementation Workshop

Examples Objective: Improve environmental compliance Target: Reduce the number of internal environmental compliance audit findings by 50% on an audit-to-audit basis. EMS Implementation Workshop

Examples Objective: Reduce transportation congestion Target: Increase the number of employee-days of mass transit use by 50% by the year 2006 based on a 2002 calendar year baseline. Target: Purchase 25 bicycles for use within the facility by the year 2004. EMS Implementation Workshop

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

Begins with initial planning data Policy Legal and other requirements Significant environmental aspects Consider Technological options Financial, operational and business requirements Views of interested parties EMS Implementation Workshop

Other drivers for consideration Agency mission Agency / management priorities This is where you can reflect “reality” What can be done You will do this again EMS Implementation Workshop

Some organizations set compliance as an objective to help remind them that the remainder of the system reflects that commitment Significant aspects can be deferred if they are controlled and get no worse because of their deferral EMS Implementation Workshop

Targets - How aggressive?
It depends: Stretch targets - you may not meet them but trying may get you further Minimal targets - you will get there - likely to only maintain status quo - little improvement Be Realistic: you may need additional info to address ability to measure success towards objective EMS Implementation Workshop

REMEMBER Setting objectives and targets must be true to policy statement commitments - pollution prevention, continual improvement and particularly compliance with regulations, are not negotiable considerations Objectives and targets drive your management plan You will do this exercise again and again ... EMS Implementation Workshop

Setting objectives and targets; the process
Prepare summary of issues to be considered community concerns agency/ management priorities cost data future missions of facility or agency Provide information to decision makers EMS Implementation Workshop

Considerations Use what will work best but keep in mind: You will need buy-in from management AND the organization The objectives and targets selected will be the basis for the environmental management program for this cycle EMS Implementation Workshop

Closing the Loop Objectives and Targets must ultimately be established at each relevant function and level of the organization Targets identify how progress will be measured EMS Implementation Workshop

The Environmental Management Program
EMS Implementation Workshop The Environmental Management Program EMS Implementation Workshop

Environmental Management Program
The Management Program defines how the Objectives and Targets are to be achieved - including: Assignment of responsibility at each relevant function and level - the who Description of means - the how and what Identification of time frame - the when EMS Implementation Workshop

Assignment of Responsibility:
Function Reflects relationship between activity and impact - ensures that impact is addressed where it occurs Reflects support structure to ensure program is enabled - procurement, budget, training EMS Implementation Workshop

Assignment of Responsibility:
Level Ensures that program reflects and recognizes hierarchy and structure of the organization Reflects necessity of accountability - Organizational levels above direct process are generally supervisory and management and must be engaged EMS Implementation Workshop

Identification of Means
The “how” an organization intends to achieve a given objective and target Will reflect the activity(ies) that has prompted the “significance” and Objective and Target determination Will define what is to be done to manage and improve processes to address the ongoing or potential impact of the activity EMS Implementation Workshop

Definition of Time-frame
Simply the schedule for addressing the objective and target Should reflect temporal nature of activities prompting target - how soon can things be altered Recognize the ability to address both short and long-term issues as well as ongoing responsibilities EMS Implementation Workshop

Example Objective: Increase solid waste diversion Target: Increase to a 60% diversion rate for all solid waste by the year 2005 based on a 40% diversion rate in 1996. EMS Implementation Workshop

EMP - Example EMP - Increase recycling at cafeteria Function - Cafeteria tray handlers, cafeteria purchasing agent, facility solid waste handler Level - In addition to above - cafeteria line supervisor and manager, budget officer, and facilities manager EMS Implementation Workshop

EMP - Example Means - Purchase more recyclable containers, post signs and improve disposal behavior - separate and recycle more cans and bottles Time-frame - Starting next purchasing cycle and targeting to reach 10% annual reduction EMS Implementation Workshop

EMP - the Process Begin with Objective and Target and activities list that drives significance determination Determine necessary changes to activity to address impact and draft a means to achieve Determine who is directly and indirectly linked to the impact - who are the process owners? EMS Implementation Workshop

EMP - the Process Determine others that affect or enable the process or activity - identify their roles and how the organizational structure provides accountability Determine factors affecting time-frame for the activity or process and factors that may control changes EMS Implementation Workshop

EMP - the Process Develop metrics that reflect target to allow “checking” Develop program ensuring that individuals critical to implementing change are included Review information to identify gaps - ensure connections between means, responsibilities and schedule are each identified and addressed EMS Implementation Workshop

New Developments The EMP must be established and maintained. Changes in activities or other new developments that affect Objective and Targets must be reflected in the EMP Since aspects must be kept up-to-date - changes will flow to EMP EMS Implementation Workshop

EMP Implementation EMP may be stand alone or integrated into existing planning processes Important to ensure that wherever it lands it will be effective Important that those responsible for implementation are aware of ensuing change Ensure that Management embraces the EMP! EMS Implementation Workshop

Initial Awareness Training
EMS Implementation Workshop Initial Awareness Training

Why EMS Awareness Training
The initial stages of the EMS depend on individuals within the organization The EMS Team will include a range of representatives from within the organization Information gathering will depend in part on contributions from across the organization Something new - people need to know Knowledge and understanding build ownership EMS Implementation Workshop

Why Employee Awareness?
The EMS is deployed by the practitioners Practitioners are more aware of the day-to-day impacts of their activities than anyone Practitioners know the best improvements Ultimately, the Standard requires awareness of the impacts of the organization’s activities Start the process EMS Implementation Workshop

Awareness Training Process
Process similar to obtaining management support Recognize issues important to all entities within the organization Mission Improved health, safety and security Improved efficiency Improved environmental footprint Don’t overwhelm EMS Implementation Workshop

Timing - Early enough to facilitate gap analysis and other early stages of EMS Support - Ensure adequate management support - authority and responsibility Message - Like Management, reflect issues of importance to audience Presenter(s) - Ensure adequate knowledge of EMS elements EMS Implementation Workshop

Keep it simple Goals is to inform and solicit assistance Use familiar tools Cafeteria notices Managers briefings Remember - this is the initial effort EMS Implementation Workshop

EMS Conformance Audit

Environmental Management System Audit
A systematic and documented verification process of objectively obtaining and evaluating evidence to determine whether an organization’s environmental management system conforms to the environmental management system audit criteria set by the organization, and for communication of the results of this process to management. EMS Implementation Workshop

EMS Audits Purpose of an EMS Audit Does the system conform to set criteria? Has EMS been properly implemented, maintained? Provide information to management and organization to allow continual improvement Addresses all of EMS (documentation and implementation) Not a performance audit or a compliance audit EMS Implementation Workshop

Purpose of an EMS Audit Evaluates conformance of EMS to framework, policy commitments Addresses management components Doesn’t explicitly address compliance Includes all personnel and activities associated with significant impacts EMS Implementation Workshop

What do you need to do? Develop audit procedure(s) and programs that describe the “when, how, who, and where” of how the EMS auditing will be done Conduct audits Keep proper records Feed audit information into rest of EMS EMS Implementation Workshop

Audit Outcomes Assessment tool to provide for corrective action and continual improvement of system- which leads to improved performance Report to management EMS Implementation Workshop

Management Review

Management Review Specific requirement of ISO 14001; to occur periodically and must include top management Distinct from checking or EMS audit Designed to ensure ongoing and practical involvement by top management Essential part of management commitment and continual improvement Management review should be broad enough in scope to address the environmental dimensions of all activities, products and services of the organization, including their impact on financial performance and possibly competitive position. EMS Implementation Workshop

Management Review Components
Full system overview Status of objectives and targets EMS Performance Audit findings Evaluation of environmental policy Is E. policy still suitable in light of changing legislation changing expectations and requirements of interested parties changes in the products and activities of the organization advances in science and technology lessons learned from environmental incidents market preferences reporting and communication EMS Implementation Workshop

Towards Continual Improvement
Identify areas for improvement of EMS Review and approve corrective or preventive action plan Verify effectiveness of action plans Make changes to procedures Add or adjust Objectives and Targets Revise Environmental Policy Provide support and resources EMS Implementation Workshop

Ensuring Effective Management Reviews
Develop a procedure and schedule; with set agenda, sign in process, minutes, and follow up action items Make sure top management attends Keep good records Ensure you follow up!!!!!! EMS Implementation Workshop

Synchronizing Planning with the Other Elements
EMS Implementation Workshop Synchronizing Planning with the Other Elements Deploying the EMS

Capabilities & Organization & Controls Accountability Communications Document Control Training, Awareness and Competence Operational Control Structure and 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 Responsibility Communication Emergency Preparedness and Response EMS Implementation Workshop

Structure and responsibility - define general responsibility Training, awareness and competence - train to policy, environmental impacts Communication - inform relative to aspects and the EMS EMS Documentation - develop, maintain and provide access to core directions EMS Implementation Workshop

Operational control - provide standard direction to address impacts and goals Emergency preparedness and response -provide direction to address extraordinary situations EMS Implementation Workshop

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. EMS Implementation Workshop

Monitoring and measurement - determine if the EMS is working, goals are being met and compliance is assured Non-conformance - define responsibility for addressing issues raised from monitoring and measurement Records - develop and maintain body of knowledge from EMS EMS Implementation Workshop

EMS audit - determine if EMS is properly developed and deployed EMS Implementation Workshop

Management Review 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 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 EMS Implementation Workshop

EMS Conformance Auditing
EMS Implementation Workshop EMS Conformance Auditing

Environmental Management System
The part of the overall management system that includes organizational structure, planning activities, responsibilities, practices, procedure, processes and resources for developing, implementing, achieving, reviewing and maintaining the environmental policy. EMS Implementation Workshop

Environmental Management System Audit
A systematic and documented verification process of objectively obtaining and evaluating evidence to determine whether an organization’s environmental management system conforms to the environmental management system audit criteria set by the organization, and for communication of the results of this process to management. EMS Implementation Workshop

EMS Audit Not a compliance audit Done by those with EMS auditing training/experience Periodic “snap-shot” assessment to verify system EMS Implementation Workshop

Internal vs. External Audits
Internal audits (First Party audits) are those done by participants of the EMS being audited (can be employees, or consultants as agents of the organization) Second party audits are those done by auditors from outside the EMS in question (but could be from same organization) Third party audits are done by independent, registrars In all cases, audit should cover same elements!!!! EMS Implementation Workshop

Certification vs. Self Declaration
In both cases, a representation is made to outside parties of conformance to EMS criteria. Certification is done by accredited, third party registrars Self-Declaration is any other claim of conformance other than certification Self-Declaration should be more than internal EMS audit EMS Implementation Workshop

EMS Auditing and ISO ISO created companion auditing guidance standards (14010, 14011, (soon to be 19011), but these are not required for certification Registrars must adhere to these at a minimum ISO issues guidance to certification and accreditation bodies (but can be used to guide self declaration programs) US accrediting body is ANSI-RAB EMS Implementation Workshop

EMS vs. Compliance vs. EMR Auditing
Different criteria- EMS looks at system, compliance looks at regulatory requirements EMS audit is a system, or process audit, a compliance audit looks at compliance performance (compliance status), EMR looks at pieces of the system or a very broad perspective EMS Implementation Workshop

Self Declaration and EO 13148
Protocol developed by EO Workgroup EMS verification procedures will rest with each Agency/Bureau Procedures due by December 31, 2004 Updated at least every five years Procedures will require an independent basis Facilities may self declare prior to procedures using protocol guidance EMS Implementation Workshop

Agency Self Declaration Procedures
Will include Selection and direction for use of evaluation guide Frequency of internal evaluations Requirement for management declaration Frequency of independent review Makeup of review team including qualifications of independent reviewers EMS Implementation Workshop

Resources - EMS section - slides, presentations, briefing papers Exceptional EMS tools - including roadmap and decision assistance General tools - Federal facility site being upgraded EMS Implementation Workshop

Environmental Management System Training

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