Environmental Management

An Overview of Environmental Management Systems

Wayne E. Bates, PhD, PE

"Problems cannot be

solved at the same level of

awareness that created

them."

A thought to consider...

Agenda

Compliance Auditing

What is an EMS?

Developing an EMS

Conducting a Gap Analysis

Unique Challenges

Compliance Auditing

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

Compliance Auditing

Facility activities• material use and storage• hazardous waste generation and disposal• emissions

Permits

Historical releases

Compliance Auditing

An auditor may see compliance one day...

…and something different the next.

Compliance AuditingKodak - Example

1987Organic solvent piping functioning

1988Pipe breaks - 25,000 gallon release of organic solvent

Compliance AuditingLimitations

Multiple snapshots

on separate occasions

with different outcomes

Compliance AuditingKodak - Example

Systemic issues not reviewed...

• known antiquated piping network• constantly repairing pipe sections• leaks observed in various sections• maintenance personnel dedicated to repairs

Compliance AuditingUnless systematic issues are reviewed...

You won’t get consistent results!

Agenda

Compliance Auditing

What is an EMS?

Developing an EMS

Conducting a Gap Analysis

Unique Challenges

What is an EMS?A way to identify root causes

What are your procedures?

How often is training provided?

Who is responsible?

review them

Talk to them

review records and talk to staff

What is an EMS?A way to identify root causes

Violation

Root Causes

What is an EMS?

Proactive management toolOrganized approachBusiness-basedClearly definedPrevention vs. treatmentBest management practices

What is an EMS? The Improvement Cycle

Check

Plan

DoAct

What is an EMS?Major ISO 14001 Components

Policy

Planning

Implementation

Corrective Action

Management Review

What is an EMS?Major Components + Improvement Cycle

Planning

ManagementReview

Policy

Implementation

CorrectiveAction

Start

ContinuousImprovement

Agenda

Compliance Auditing

What is an EMS?

Developing an EMS

Conducting a Gap Analysis

Unique Challenges

EnvironmentalPolicyIm

prov

emen

t Prevention

Compliance

Developing an EMSEnvironmental Policy

Developing an EMSPlanning

Consider• Aspects and impacts – products, activities, and services

• Legal requirements• Objectives and targets• Existing SOPs, Policies, Programs

Aspect and ImpactKodak - Example

Aspect– piping of organic solvents

Impact– potential release to the environment– exposure could cause injury/death

Objective and TargetsVehicle Storage - Example

Objective– prevent release

Targets– institute inspection program– use inspection to identify repairs– develop procedure to prioritize repairs

• 0

Developing an EMSImplementation

With objectives and targets set

let the implementation begin!

Developing an EMSImplementation

Roles and responsibilities

Training, awareness, competence

Communication

Documentation and control

Operational control

Emergency preparedness

Developing an EMSImplementation

Roles and responsibilities

define, document, communicate

Provide training

Operational controls

define, document, communicate

Emergency preparedness

Developing an EMSImplementation

Roles and responsibilities

Who is responsible?

Communicate Document

Developing an EMSChecking/Corrective Action

Monitoring and measurement

Corrective and preventive action

Recordkeeping

Auditing

Monitoring and MeasurementYou can’t manage what you can’t measure

Enables you to • gauge performance• analyze root causes• identify corrective actions• improve performance

Developing an EMSManagement Review

Periodic review of results

Scheduled review

Agenda

Compliance Auditing

What is an EMS?

Developing an EMS

Conducting a Gap Analysis

Unique Challenges

Conducting a Gap AnalysisSo, where do you start?

1. Is there a system in-place?2. Do people follow the system?3. Is the system is effective?

Gap AnalysisPreliminary EMS Review

there is a system in-place

people follow the system

the system is effective

The Gap Analysis is a verification that

Intent

Implementation

Effectiveness

This indicates that

Gap AnalysisVerification that...

system is effective

there is a system

people follow the system

Gap Analysis Stages

Pre-Audit

PlanningNotification

Site Visit Post-Audit

Initial MeetingFacility TourRecord ReviewInterviewsExit Briefing

EMS Gaps

Agenda

Compliance Auditing

What is an EMS?

Developing an EMS

Conducting a Gap Analysis

Unique Challenges

Unique Challenges

Direction

Resources

Budget

Importance

Change

Unique ChallengesDifficult roadblocks to overcome

Blurred lines of…• communication• responsibilities