Introduction to Environmental Management

Systems

Environment International Ltd.

June 14-16, 2005

Designing Your EMS: A USDA Workshop

2

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

3

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/

4

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

6

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

7

An EMS is Management

• Must have commitment of top managers

• EMS owned by facility manager

• Must be consistent with other management systems

8

An EMS is a System

• Requires awareness of formal structure

• Addresses policies, procedures, programs

• Doesn’t specifically address compliance components (drums, labels, etc.)

9

ISO 14001 Components

Environmental

Policy

Continual Improvement

Planning

Implementation &

Control

Checking & Corrective Action

Management

Review

10

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

11

Planning

• Identify aspects and impacts from facility activities, products, and services

• Review legal requirements

• Set objectives and targets

• Establish formal EMS program

12

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

13

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

14

Management Review

• Conduct periodic senior management review of EMS

• Revise parts of the EMS as needed

15

Benefits of an EMS

• Help maintain compliance

• Reduce operating costs

• Integrate environmental programs into mission

• Increase employee involvement

• Reduce environmental impacts

Getting Your EMS Started:Your EMS Team

Environment International Ltd.

June 14-16, 2005

Designing Your EMS: A USDA Workshop

17

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

18

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 Policy Statement

Environment International Ltd.

Designing Your EMS: A USDA Workshop

20

How not to create your environmental policy…

21

Policy Statement Importance

• Demonstrates management commitment

• Defines framework for EMS

• Provides framework for setting objectives and targets

• Must be appropriate to activities at facility

23

ISO 14001 Requirements

IMPROVEMENT

COMPLIANCE

PREVENTION

Management Commitment

EnvironmentalPolicy

Gap Analysis

Environment International Ltd.

Designing Your EMS: A USDA Workshop

25

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).”

26

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

27

EMS FencelineEMS 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

28

Steps in a Gap Analysis

• Facility walk-through (reference fenceline)

• Document review

• Staff interviews

• Identify and document gaps

29

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

30

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

31

Staff Interviews

• Identify organizational structure

• Identify requirements to fulfill mission

• Determine awareness of staff of EMS

• Awareness of environmental programs and goals

32

Identify and Document Gaps

• Compare with EMS elements

• Make a list of specific actions to close gaps

Identifying Environmental Aspects

defined as a part of activity or product that interacts with environment

Environment International Ltd.

March 22-23, 2005

Designing Your EMS: A USDA Workshop

34

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

35

Building an Aspects Register

• Assemble list of activities, products, and services

• Characterize activities, products, and services

• List aspects

• Organize and rank aspects as appropriate

36

Characterizing Your Activities, Characterizing Your Activities, Products, and ServicesProducts, 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

37

Step 1 Step 1 • Look at the Comprehensive Picture of Your FacilityLook at the Comprehensive Picture of Your Facility

– Research Activities– Facility Operations Activities – Construction and Demolition Activities

• Within Your “Fenceline”, Identify and List ActivitiesWithin Your “Fenceline”, Identify and List Activities– Crop research– Animal research– Use hazardous chemicals– Generate hazardous waste

38

STEP 2STEP 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.

39

Example 1Example 1 Activity, Product,

or Service

• Purchasing Hazardous Chemicals

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.

40

Example 2Example 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

41

Example 3Example 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

42

Example 4Example 4

Activity, Product, or Service

• Office work

Environmental Aspect

• 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.

43

Step 3Step 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

44

Factors That May Play a RoleFactors That May Play a Rolein Managing Aspectsin 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

Environment International Ltd.

March 22-23, 2005

Designing Your EMS: A USDA Workshop

46

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.

47

Potential

Aspect Impact

Cause Effect Process OutcomeVerb Noun

48

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

ASPECTS IMPACTS

49

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

Legal and Other Requirements

Environment International Ltd.

Designing Your EMS: A USDA Workshop

52

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

53

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

54

Updating Legal Requirements

• Required by ISO 14001

• Regular review of regulations

• Distribution to appropriate personnel

55

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

Environment International Ltd.

Designing Your EMS: A USDA Workshop

57

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

58

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

59

Significance Considerations• Size, severity and duration of environmental

impact

• Ease of improvement

• Regulatory or Executive Order requirement

• Cost

• Mission impact

• Community impact

• Sustainability

60

Exercise: Determining significant Aspects

Potential factors– severity

– probability/frequency

– risk (environmental/

health/financial)

– Mission impact

– external concerns

– ability to control/

improve

– duration

– regulatory concern

Use reproducible methodology; e.g., rank using a formula containing factors the organization considers important

Setting Objectives and Targets

Environment International Ltd.

June 2005

Designing Your EMS: A USDA Workshop

64

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.

65

Organizations Shall Consider:

• Legal and other requirements

• Significant environmental aspects

• Technological options

• Financial, operational and business requirements

• Views of interested parties

66

ExamplesObjective: 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.

67

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.

68

Setting Objectives and Targets

• Start with Planning data

• Options for identifying objectives:

Goal setting workshop

EMS Coordinator recommendations

EMS Team recommendations

Management Priorities

69

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

Environment International Ltd.

March 22-23, 2005

Designing Your EMS: A USDA Workshop

71

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.

72

Environmental Management Programs

An environmental management program should define:

– responsibilities– resources– objectives– documentation– schedules

Should be effectively aligned with existing management system elements

73

EMS Document Structure

PolicyAspects Register

Objectives and Targets

Environmental Management Plans Training Needs Surveys Organizational Charts

Standard Operating Procedures Training Records Hazardous Waste Manifests Energy Bills

EMS

EnvironmentalManagementPrograms

Day-to-DayOperations

74

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

Environment International Ltd.

Designing Your EMS: A USDA Workshop

76

ISO 14001 Components

Environmental

Policy

Continual Improvement

Planning

Implementation &

Control

Checking & Corrective Action

Management

Review

77

EMS Planning Steps

Identify EMS Team

Identify/Write/Modify

Environmental Policy

Identify Current Programs and Perform Gap

Analysis

Identify Aspects

and Impacts

Prioritize/ Determine

Significance

Develop Objectives

and Targets

Create Program to Achieve

Objectives and Targets

Define Fenceline

78

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

Environment International Ltd.

June 2005

Designing Your EMS: A USDA Workshop

80

EMS Implementation

• Translate all your planning into action

• Where performance is improved

• Next step is to roll out:– training– procedures– documentation– new job assignments

81

ISO 14001 Elements

Implementation and operation involves

• Structure and Responsibility

• Training, Awareness & Competence

• Communication

• EMS Documentation

• Document Control

• Operational Control

• Emergency Preparedness and Response

82

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

83

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

84

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

85

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

86

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 )

87

Resource Allocation

– Personnel– Physical resources– Equipment– Training– Financial resources (HWC)

Management must provide sufficient resources to implement the EMS including:

88

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!

89

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)

90

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)

ISO 14001 Training Requirements (cont.)

91

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

92

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

95

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

96

External Communication

The organization must

• Review, document and respond to relevant external communication

• ARS communicates through several channels, both regulatory and research, NEPA

97

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

98

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

99

Examples of EMS documents• Policy statement

• Information on significant aspects

• Procedures

• Process information

• Organizational charts

• Internal and external standards

• Site emergency plans

• Records

101

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.)

102

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

103

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

Checking

Environment International Ltd.Seattle, WA

(206) 525-3362 • www.eiltd.net

Designing Your EMS: A USDA Workshop

105

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

106

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

107

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

108

Evaluation of Compliance

Establish procedures to periodically evaluate compliance with relevant environmental legal and other requirements

Keep records of the results

109

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

110

Nonconformance and Corrective and Preventive Actions (cont.)

Record any changes resulting from corrective actions

Review the effectiveness of actions taken

111

Reasons for a Nonconformance

Implementation differs from documentation

System is not working Requirement is not addressed

112

RecordsRecords – a special type of document

– Provide verification of things that have happened

– Individual records are not updated (new records are created)

113

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.

114

Records

Properly maintained records will belegible identifiabletraceable to the activity, services or

product involved

115

Scope of Records

Legal compliance

Process monitoring

Environmental aspects and their impacts

Environmental training

Inspection, calibration and maintenance activity

Records should cover:

Continued…

116

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

Scope of Records (cont.)

Management Review

Environment International Ltd.March 22-23, 2005

Designing Your EMS: A USDA Workshop

119

Management Review

• Conduct periodic senior management review of EMS

• Revise parts of the EMS as needed

120

Continual ImprovementManagement 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.

121

Post - Test

Any questions about:• EMS Checking and

Corrective Action

• EMS Auditing

• Management Review

• Other