2PA/742/3-93/002
N1STIR 6120
Environmental Management Systems
Voluntary Project Evaluation Guidance
/
\
Multi-State Working Group on
Environmental Management Systems
U.S. DEPARTMENT OF COMMERCE
National Institute of Standards
and Technology
Gaithersburg, MD 20899-0001
(MIST
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NISTIR 6120
Environmental Management Systems
Voluntary Project Evaluation Guidance
MSWG
Multi-State Working Group on ' .
Environmental Management Systems
U.S. DEPARTMENT OF COMMERCE
National Institute of Standards '
and Technology
Gaithersburg, MD 20899-0001
February 13, 1998
U.S. DEPARTMENT- OF COMMERCE
William M. Daley, Secretary ' .
TECHNOLOGY ADMINISTRATION
Gary R. Bachula, Acting Under Secretary
for Technology- ,
NATIONAL INSTITUTE OF STANDARDS
AND TECHNOLOGY
Raymond G. Kammer, Director
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Col/EPA
Department of
Toxic Substances
Control
400 P Street,
4th Floor
P.O. Box 806
Sacramento, CA
958124806
February 13, 1998,
Dear Reader:
Pete Wilson
Governor
Peter- M. "R-bbney
Secretary for
Environmental
Protection
This document is the product of more than.a year's work by many dedicated
people. In the fall of 1996, a group of statex regulators, with additional participation
from two Environmental Protection Agency (EPA) program offices and the business
', and public interest communities, started discussing the possibility of devising pilot
projects to test"the idea that Environmental Management Systems (EMSs) might play
a beneficial role as .policy tools at the state level. At about the same time, a similar
group within EPA's Office of Enforcement and Compliance Assurance began similar
discussions, with a particular concern for the potential use of EMSs to meet national
compliance and performance goals..
Over time, it became clear that the objectives of the two groups were
virtually identical and that their mutual.goal would be best served by a coordinated
effort.' That goal is to gather credible and compatible information of known quality
that is adequate to address key public policy issues.' On September 22, 1997, the
EPA and Multi-State Working Group on Environmental Management Systems
(MSWG) agreed develop, and maintain a common, national database of information
generated by state and federal EMS pilot projects in the interest of saving resources
arid facilitating-research. .
Although this guidance document originated within the MSWG, it has been
reviewed by the relevant offices within EPA, and both it and the accompanying /
protocols document incorporate substantial input'from personnel within those offices:
The MSWG will continue to play a key role in coordination-of pilot projects.
Together, the MSWG and EPA will work to ensure communication, cooperation and
harmonization between the state and federal .entities. We look forward to the results
of this important experiment in reinvention. On behalf of the MSWG,
Sincerely,
Robert D. Stephens, Ph.D. Chair MSWG
Deputy Director
Science, Pollution Prevention & Technology
Program
in
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Statement of Common Purpose
' " " ' :. - " by '" .' -..'' ; -
The Multi-State Working Group on Environmental Management Systems
and '
the U.S. Environmental Protection Agency
' - : : ' to '.' .'.-.'.''
Evaluate the Effectiveness of Environmental Management Systems
September 22, 1997
Federal and State environmental regulators are working in partnership to explore the
utility of environmental management systems (EMS), especially those based substantially on
ISO 14001, in public policy innovation.
Our. goal is to gather credible and compatible information of known quality adequate to
address key public policy issues. We are interested in the effect of.EMSs on, among other
things, environmental performance, environmental conditions,'compliance with environmental
regulations, stakeholder involvement, pollution prevention activities, and the costs and benefits
of environmental activities. The primary mechanism to generate this information will be pilot
projects. Valid, compatible data from other sources will .also be used whenever possible. To
make efficient use of our resources, and to ensure more robust research, EPA and States will
work together on the creation of a common data base. The data base will be open and usable,
while recognizing the need to insure appropriately the confidentiality of participants.
; ._ - \ .. ', ' '-
In the near term, State and federal regulators will jointly develop protocols for data
collection/and ensure adequate funding for the collection, management and analysis of EMS
data. By November 1, 1997, we will produce a detailed action plan to harmonize EMS,
assessment activities. ',. .
The success Of this endeavor, in all of its aspects, depends upon the active participation
of partners in the government, business, public mterest and other sectors. The regulators will,
therefore, .work with their partners to continuously improve and implement this plan' to the
benefit of all.
Charles Fox
Associate Administrator
Office of Reinvention
U.S. Environmental Protection Agency
Robert D. Stephens, Ph.D., Chair MSWG
Deputy Director
Science, Pollution Prevention & Technology Program
California Environmental Protection Agency
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Statement of Intent
The intent of this document is to provide a framework for the collection of
nformation of value to regulatory agencies and others interested in determining the
mpact in several key areas of environmental management systems based on ISO
14001.
The use of this tool and the participation of states and organizations in pilot projects
based on the ISO 14001 standard is entirely voluntary. If the value of ISO 14001 in
meeting public policy goals can be demonstrated, changes in environmental policies,
regulations, or statutes may be considered. The tool is not intended to encourage
modifications to ISO 14001.
By establishing a framework for gathering of data and asking relevant questions, it is
inevitable that a certain amount of bias will exist However, the data categories
within the framework are consistent with ISO 14001. The categories selected are
critical to public policy development-the overriding concern of the states. This
document represents current thinking and will be improved as the states gain
knowledge and experience. It is not a final document
The data gathered, and the ensuing public dialogue envisioned in the data evaluation
process, will allow regulatory agencies to reach insightful and credible conclusions
that otherwise would be difficult or impossible to achieve.
Environmental Management Systems
Voluntary Project Evaluation Guidance
February 13,1998
VII
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Why This is A Winning Approach
It is said "what gets measured gets managed; and what gets managed gets done." That principle
guided the preparation of this guidance. It is also true that non-quantitative data - words with
meaning - provide insight as to "why" something happened. Non-quantitative data was captured in
categories like pollution prevention and interested parties. The goal is to help you find and
organize information you can use to evaluate ybur ISO 14001/EMS. As Green Bay Packer coach
Vince Lombardi said, "If you don't keep score, it's only practice." this tool should help everyone
keep better "score" than the present system.
MSWG Participants Involved in Development of the
Arizona Minnesota
Dave Ronald ; Leroy Paddock
California North Carolina
Bob Stephens, Chair ' Ravila Gupta
Donald Owens ....' Susan Clarke
Jennifer Smith Allen Jernigan
Illinois Oregon
Peter Wise PaulBumet
Massachusetts .'..'..
Bob Bois ' . .. . ,
Coalition on ISO 14000 Implementation
Jim Connaughton
Environmental Law Institute
John Pendergrass ,
Tulane Law School
Jerry Speir
National Institute of Standards and Technology
Krista Johnsen Leuteritz
Guidance Document
Pennsylvania
Meredith Hill
Mary Lou Barton
Stacy Richards
Texas
Andrew Neblett
Wisconsin
JefTSmoller
BrendaHagman
Lynda Wiese
University of North Carolina
Richard Andrews
John Villani
MaryMcKiel,USEPA
Jim Home, US EPA
Environmental Management Systems
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IX
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Environmental Management Systems Voluntary Project Evaluation
Guidance
Table of Contents
I INTRODUCTION
Background x . 3
Purpose and Description ^
EMS Project Evaluation Categories 9
Environmental Performance 9
- Environmental Condition - 9
Environmental Compliance 10 .
' Costs and Benefits H
Pollution Prevention H
Interested Parties 12 ,
Example: How to Use Guidance 13
H. EMS PILOT PROJECT EVALUATION TABLES AND QUESTIONNAIRES
Column Heading for Tables 1,2 and 3 . ', 20
Table 1: Environmental Performance Indicators 22-23
Table 2: Environmental Condition Indicators 24-25
Table 3: Environmental Compliance Indicators 26-28
Exhibit 1: Costs and Benefits 29
Exhibit 2: Pollution Prevention 30
Exhibits: Interested Parties 31
m. ADDITIONAL INFORMATION
Method of Reduction , 34
. ,
Contact Information 36
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I. INTRODUCTION
Background
Purpose and Description
EMS Project Evaluation Categories
Example: How to Use the Guidance
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February 13,1998
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I. INTRODUCTION
Just as the price of freedom is eternal .vigilance, the cost of needed continual environmental
improvement may be the constant need to balance the use of regulations with voluntary
initiatives. State and federal agencies are testing ways to achieve environmental gains through .
more effective, less costly compliance and through promotion of pollution prevention methods
and technologies. There are efforts in all sectors to address both the resource and environmental
performance issues which face regulator and regulated alike.
The ISO 14001 Environmental Management Standards series, developed within the International
Organization for Standardization, may prove helpful for focusing on allocation of resources and
on performance issues. The principal document of this series, ISO 14001, Environmental
Management Systems (EMS), provides a framework for implementing an organization's
environmental policy and meeting its EMS objectives. Compliance and prevention are
specifically mentioned as two required policy elements which the 14001 system must address.
Measuring the impact of an ISO 14001 EMS on the actual environmental performance of an
organization is the subject of pilot projects being conducted by both federal and state agencies.
EPA and a number of states have expressed interest in coordinating the implementation and data
collection/analysis phases of their ISO 14001 pilot projects. Sharing project performance
information and results can substantially increase the value of the projects for all interested
parties.
This group, known by its participants as the Multi-State Working Group (MSWG) on
Environmental Management Systems, includes California, Texas, Oregon, Arizona, Illinois,
Minnesota, Wisconsin, Pennsylvania, Massachusetts, and North Carolina. The Working Group
has prepared this voluntary project design document, known as the Project Evaluation Guidance
(Guidance), which can be used by the states and is consistent with their pilot project
implementation schedules
Other participants were included in the discussions since the innovative approaches represented
by ISO 14001 will require new partnerships and relationships. Representatives of two USEPA
offices, two representatives of the environmental community, one from National Institute of
Standards and Technology (NIST), two from academia and one from the regulated community
also participated in the development of this Guidance. The group also received input from other
EPA offices. ...''.
State regulatory agencies and EPA are experimenting with new models for more effective and
efficient ways to ensure compliance with regulatory requirements and meet environmental,
enforcement, and performance goals. One model is to test the hypothesis that the use of an ISO
14001 environmental management system has a positive effect on environmental performance,
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Including compliance with regulatory requirements. The idea is to encourage a system that will
maintain not only compliance but enhance overall environmental and organizational
performance. ;
Systematic management of environmental responsibilities may prove helpful to an organization
to achieve improved environmental compliance along with additional goals. The ISO 14001
standard is one framework for such a system, but not the only one. ISO 14001 does not set
specific levels of performance. ISO 14001 provides a framework for establishing an
environmental policy, setting performance objectives for the EMS, and continually improving
the system. Analysis of impacts (potential and actual), implementation plans, training, auditing
and management feedback are all elements within the EMS system. Specific goals and
objectives are unique to each organization. The environmental policy uniquely reflects the
character of the organization. ISO 14001 EMS systems can help any organization achieve
multiple and mutually-reinforcing goals to benefit a wide range of interested parties:
management, employees, the community, citizen advocates, customers, and government The
MSWG evaluation format can be used to credibly and uniformly test the system.
As the state agencies evaluate EMS performance, they will also need to assess the degree of
meaningful involvement of interested parties in the process, as well as the quality and
transparency of the information produced.. Credibility of the process and the performance data
will be critical to future policy decisions. To the extent that ISO 14001 is used as a tool to
achieve certain regulatory and public policy goals, organizations should realize that there may be
requirements to involve and to report to interested parties that go beyond those specified in the
ISO standard. Making good faith efforts in meeting those requirements/needs should promote a
climate which enhances the regulatory policy review process. Discussions on approaches to
interested party involvement can be found in a recent publication from the Aspen Institute. 1
The MSWG anticipates that, at a minimum., pilot project evaluation will be based upon the
environmental performance, environmental compliance, pollution prevention and interested party
involvement categories included in the Guidance. The MSWG expects that each project manager
will take all reasonable steps to ensure that all the data called for under the environmental
performance and environmental compliance categories in this Guidance are collected in all pilot
projects. Information from other categories such as pollution prevention and interested party
involvement will also be very important in the analysis of pilot projects. However, the needs of
various pilot projects will vary and insight will be gained by looking at the accumulated
information from all pilot projects as well as comparisons between and among pilots. The long
term1 goal is to collect the most complete set of data possible, to ensure unbiased and reliable
analysis. Careful technical review will be needed on how to handle incomplete data sets.
The data categories which appear hi this document were, to the extent possible, developed
around the lands of data that the MSWG believes will or could be generated by ISO 14001. The
EPA and States recognize that a number of groups are working on data collection and will strive
to have comparable data collection efforts.
The Alternative Path, A Cleaner, Cheaper Way to Protect the Environment The Aspen Institute, 1996.
Environmental Management Systems
Voluntary Project Evaluation Guidance
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Purpose and Description
Testing the impact of pilot projects on
, environmental and economic outcomes
isskey to determining public policies
'relative to ISO 14001. It is important
to note what an organization using ISO
14001 considers important may differ
from what regulators or communities
consider important. The Project
Evaluation Guidance designed by the
MSWG identifies important categories
of measurables that are likely to be of
interest to various interested parties,
and provides the opportunity for
standardization of the measurables
among participating programs. The
value of the approach is to generate
multiple data points across a variety of
^ state regulatory schemes and
geographic communities, thus allowing
the evaluation of outcomes in the range
. of pilot designs.
Who Benefits From The Use of the Guidance ?
This Project Evaluation Guidance is designed to produce
performance information of value to three interested
party groups, helping them determine whether an ISO
14001 system meets their individual and consensus
needs better, than the old way of doing things did.
Government. All elected, appointed and hired
officials at local, state or Federal levels who enact
and implement laws, protect the environment,
manage (defense and other) facilities and balance
.competing needs with limited resources
Business: All who are involved in or important to the
efficient and profitable production and sale of goods
and services and environmental protection. This
includes lenders, analysts, shareholders, insurers,
directors, managers, workers, suppliers, customers
and consumers..
Public Interest: All who have an interest in
environmental protection, including neighbors, the
community, and advocates at various levels.
This Project Evaluation Guidance enables pilot project design teams to evaluate the use of ISO
14001 EMS as a tool to improve environmental performance and assure regulatory compliance.
Teams must consider the specific measurable objectives, data and results of the project. The
Guidance lists measurement
indicators, (Figure 1), that are deemed
valuable to understand the key
technical and policy questions arising
out of the use of ISO 14001 and to
address the wide range of needs the
interested parties identify (see Needs
onpg. 29). A wide variety of
organizations and facilities will
participate in pilot projects, and each
project will have unique design aspects including performance measurements. The Guidance is
neither intended as a totally comprehensive listing of all possible relevant indicators to ISO
14001 pilot project nor as a mandatory listing of requirements for all ISO 14001 projects.
Figure 1
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Who Uses The Guidance
Pilot project teams will assign data collection responsibilities based on likely data sources. As
an example, discharge and emission information, EMS design and compliance costs would, in
many pilots, be available from organization records. Information on interested party
involvement, environmental conditions, and agency costs, would likely come from local, state, or
Federal records. Although each pilot project management team will assign responsibilities as
appropriate, these are strongly encouraged to maintain close coordination in all areas. In all
cases the data will need to fit the prescribed protocol to ensure credibility and comparability .
For a copy of the data collection protocols, contact Professor John Villani at 919-962-2789 at
University of North Carolina at Chapel Hill. '-
The MSWG Evaluation Guidance is designed to meet a wide range of pilot project needs. This
Guidance creates a centralized pilot data collection system (using common reporting format)
with decentralized pilot decisions (using the strength of state diversity). The Guidance may be
applied in numerous ways as shown below:
+ Applied to a organization: It can fit an entire site, a single process within a site, or number of
processes or environmental aspects within the site.
4 Applied to a firm: It can fit a company whether it includes one or a number of facilities,
operations, land holdings and employee commuting patterns.
+ Applied to a business sector: It can fit a number of firms or interests (including professional
interests) that are joined by common functions, interests, principles or goals that relate to the
environment
+ Applied to a government/not-for-profit: It can be used by a government," not-for-profit or
public interest organization (that has regulated or unregulated environmental aspects) to
address environmental indicator, cost, benefit, pollution prevention or interested party
involvement goals.
* Applied to a statute: It can be used when statute or science establishes a pollution reduction
or environmental goal that can be better achieved through cooperative action among different
parties, including organizations and individuals.
+ Applied to a substance: It can be used by a single organization or organizations or
jurisdictions to address the environmental aspects of a particular substance such as volatile
organics, lead, mercury, chemicals or nutrients (e.g. to protect groundwater).
* Applied to a geographic area: It can be used by a group of urban or rural organizations
(public or private) to effectively accomplish goals such as improvements clean air,
biodiversity, ecologically managed watershed, brownfield neighborhood redevelopment or
sustainable forestry.
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Some recommended objectives in the Guidance may-be inappropriate for some pilot projects.
The evaluation^ specific objectives and indicators is the responsibility of the project design
team. . ' ' -'"',.' . ' '
What Will Happen In The Future?
Participating states will work with pilot project organizations arid other interested parties to
achieve agreements that acknowledge special pilot project efforts and risks. The data from these
organizations will provide focused insight into the decisions and actions of the organization and
its community. It also will contribute to a larger state and EPA data pool.
The pilot project evaluation process relies on the competency, credibility and independence of
higher educational institutions. The University of North Carolina, hi concert with other
participating academic interests, will maintain the consolidated data base as recommended by the
Environmental Council of States and supported by The Environmental Protection Agency. A
strategy is being developed that will help government, business and other interested parties
effectively use the data. . .
The Guidance will hopefully result in the design of many projects with many common objectives
and measurables. The Project Evaluation Guidance is a voluntary tool to help the organization's
designing and implementing ISO 14001 EMS pilot projects. As project data is compiled over
time, all interested parties, including the Federal and state executive and legislative branches,
will be able to evaluate the efficacy of environmental management systems in helping the nation
accomplish environmental, social and economic goals.
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EMS Project Evaluation Categories
The Guidance covers six different categories. Each category will help users generate part of the
.information needed to evaluate how organizations set goals and track progress toward those
goals. Each category will provide useful for considering potential public policy changes. Pilot
projects can use benchmarking to answer the basic question: "Are we better off using-the ISO
EMS than not using it ?" For greatest benefit, benchmarking should establish reliable baseline
data and track progress hi specific target areas. s
TABLE 1: ENVIRONMENTAL PERFORMANCE INDICATORS ,
This section seeks information about potential and actual impacts on air, water and land of the
organization .implementing ISO 14001. Indicator data provide the means to understand whether
environmental impacts are greater or lesser under voluntary EMS . ;
This category includes measures of emissions, their relative priority factors, the use of energy
and natural resources, accidents and other impacts, normalized to production.
The basis for this information is assumed to be the significant aspects/impacts inventory required
by ISO 14001. The project teams are encouraged to develop measures for regulated, as well as
non-regulated significant enykonmental aspects. The data source on discharges are assumed to
be a mix of existing monitoring programs, inventory management and documentation, and
project specific measurements. Project teams are encouraged to explore opportunities for non-
conventional performance measures such as continuous real time emission monitoring, and
feedstock-product-emission/discharge/waste .mass balance. Project teams are further encouraged
to develop relative impact weighing schemes for these discharge performance indicators. Such
weighing schemes will allow assessment of changes in overall environmental and public health
risks as a result of the pilot projects. The complete Table 1, Environmental Performance
Indicators is in Section II page Tl-1.
TABLE 2: ENVIRONMENTAL CONDITION INDICATORS
One outcome the of an environmental management systems may be an unproved environment.
Knowledge relating organizational environmental "aspects to resultant environmental conditions
is important in the selection, and prioritization of environmental impacts. The current draft of
ISO 14031 states that environmental condition indicators (ECIs) "provide an organization with
an environmental context to support the identification and control of its significant
environmental aspects". . .
Environmental condition indicators are commonly developed by governments, and research
institutions rather than by individual business organizations. Current research shows both the
difficulty and importance of understanding environmental conditions as well as attributing
specific operations to ambient conditions. Organizations and project teams which identify a
linkage between an environmental aspect and an environmental condition are encouraged to
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develop appropriate performance indicators for both the aspect (i.e. emission, discharge, energy
use) as well as the environmental condition (i.e. air quality, sediment quality, ecosystem health).
The table poses a common series of questions regarding environmental conditions which may be
of importance when evaluating the aspects and/or performance of a facility. The conditions in
column 1 are examples from the draft standard ISO/CD 14031.2. Each of the 56 cells in the
matrix should prompt pilot project managers to examine the environmental consequences of a
facility operation. The list of condition indicators in column 1 is neither exhaustive nor fully,
applicable to all facilities. Each facility and project team should evaluate -which environmental
conditions) is (are) applicable to its operation and location.
The identification of environmental conditions indicators may be especially appropriate for
baseline and goal setting purposes when designing EMS as applied to a statute, substance or
geographic area as defined on page 9.
TABLES: ENVIRONMENTAL COMPLIANCE INDICATORS
An environmental management system is structured to achieve an organization's environmental
policy. The organization's environmental policy provides a framework for setting
organizational environmental targets and objectives. The environmental targets and objectives
lead to detailed, quantified performance requirements. ISO 14001 requires a commitment to ,
environmental compliance as part of an organization's policy statement. State and Federal
regulators are responsible for ensuring compliance, and thus are interested in understanding the
relationship between an ISO 14001 EMS and compliance. There is a debate about what this
commitment means and how it is implemented. Accordingly, this Guidance document, strongly
encourages that the EMS pilots evaluate compliance through indicators specified in Table 3.
Parts 1 and 2 of Table S.can be used to collect information about the impact of the environmental
management system on the organization's compliance with applicable state and federal
environmental laws and other legal requirements. Table 3 also attempts to measure the
organization's compliance performance as it relates to the significant environmental aspects the
organization itself has identified pursuant to its EMS and other voluntary commitments. Finally,
Parts 1 and 2 measures how effectively an organization deals with a regulatory noncompliance
issue after it has been identified.
If an organization has not had a thorough compliance tracking system prior to instituting an
EMS, it is possible that the number of violations may actually increase after an EMS is initiated.
It is important, therefore, hi evaluating the effectiveness of an EMS in increasing compliance
rates, to look at compliance trends over time to see if the number of violations and seriousness of
violations decreases and repeat violations are avoided, as well as to look at the aspects of the
EMS (training, pollution prevention, etc.) that produced the change.
Part 3 of Table 3 measures environmental compliance performance with specific discharge
limits for air and water during time periods when no violation have been identified, against both
specific permits limits and EMS objectives, if the objectives are more ambitious than existing
permit limits. This information can be reported by chemical or as a permit total, i.e. in
compliance with all limits. It should reflect the number of consecutive months in compliance. It
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is recognized that the different issuing dates of the permit could cause differing permit limits for .'
similar facilities. This needs to be considered if comparisons are undertaken.
Part 4 of Table 3" measiires'environmentol compliance' performance unrelated to specific
discharge limits for the five major federal environmental laws and their state counterparts, during
time periods when no violations have been identified.'
Part'5 of Table 3 collects information regarding the effect of an environmental management
system on the organization's regulatory Compliance state. Achieving greater efficiency in
regulation and less pollution are important measures of the effectiveness of an EMS. So too are
the tracking and monitoring of pollution and regulatory compliance. Collection of this data,
including objectives and targets, not only allows for continuous improvements of the EMS, but it
also gives the interested parties a basis upon which to weigh regulatory changes. The following
example demonstrates the possible changes in regulatory compliance status using an EMS':
Major to synthetic minor air permit; a firm is classified as a major source for hazardous air
pollutants and may emit more than 10 tons ayear. It does not reach that ceiling. The firm then
uses an EMS to eliminate fugitive emissions of the hazardous pollutant It also finds an
acceptable substitute material. As 'a.result, the firm no longer has the potential to emit 10 tons a
year of the hazardous pollutant. This results in the facility being reclassified as a synthetic minor
source, a change in regulatory status.
j ' f
This category of compliance measurement provides the voluntary opportunity for the facility to
use an environmental management system (EMS), in the context of legal environmental
requirements, to demonstrably show improvement in performance by moving from a higher
(more consequential) regulatory status to a lower (less consequential) regulatory status. The
EMS can also link all environmental media to the same criteria for setting goals and establishing
priorities, such as reducing a particular chemical from all waste streams.
EXHIBIT 1: .COSTS AND BENEFITS-RELEVANT QUESTIONS .
Exhibit 1 lists questions designed to help facilities produce relevant and consistent information
about the costs and benefits of utilizing an EMS.' The MSWG hopes to use the answers
document the ways in which costs and benefits associated with developing and implementing an
EMS are determined. The answers will also serve as a frame of reference to compare the costs
and benefits of facilities that do not operate under an -EMS with the costs and benefits of
facilities operating under an EMS. The answers should include as much quantitative and
qualitative detail as possible, and should consider the value of benchmarking. Exhibit 1 is in
Section II
EXHIBIT 2: POLLUTION PREVENTION - RELEVANT QUESTIONS
Exhibit 2 reports pollution prevention performance information. These qualitative indicators
give added detail to the pollution prevention methods and techniques cited hi Section HI, Exhibit
2 is hi Section n.
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EXHIBITS: INTERESTED PARTY INVOLVEMENT-RELEVANT'QUESTIONS
This section seeks qualitative information about interested party involvement. The ISO J4001
standard does address communication with interested parties in two sections without specifying
how this communication is to occur. Section 4.3.3 (Objectives and Targets) requires that the
views of interested parties be considered when an organization's objectives are established.
Section 4.4.3 requires an organization to develop a process for responding to communication
from external interested parties. In assessing the credibility of ISO 14001 EMS as a potential
tool for achieving certain public policy goals, the MSWG is interested in gathering information
about the extent and nature of interested party involvement hi the implementation process. The
MSWG are also interested in the credibility of the jmplementation from the point of view of
external interested parties and employees. ,
The MSWG seeks answers to the questions in Exhibit 3: Interested party involvement. There is
no requirement that every question be answered, but the information would be useful for the
evaluation process. Exhibit 3 is in Section II. ,
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HOW TO USE THE GUIDANCE: EXAMPLE
This section shows a brief example of how the Tables and Exhibits included in the Guidance may
be used NOTE: Project designers should note that in order to effectively gather
information based on the Guidance categories, the use of standardized protocols will be
required. The protocols are available from the University of North Carolina and will
facilitate the use of the Tables and Exhibits. Contact information for the data collection
protocols may be found on page 30. The Guidance is intended to provide the categories of
interest and are not detailed data collection protocols.
Facility XYZ has completed its aspects inventory and has determined that VOC emissions from a
painting operation are significant The VOC emissions are regulated by-a state permit. Assart
of the ISO 14001 EMS, the organization has set an objective and targetto reduce VOC emissions
from the painting operation by 100% in two years. The organization has switched to awater
based system. Prior to the EMS, the organization was emitting 50 tons of VOC per unit of
production.
Table 1 below indicates that the VOC emission from Facility XYZ can be characterized as (1)
significant based on their EMS aspect and impact determination, and (2) subject to a specific
legal environmental discharge because-the emission is regulated by a state permit. Prior to the
adoption of the EMS, XYZ was emitting 5 tons of VOC/ unit. After the EMS was implemented,
XYZ 's emissions.of VOC decreased to 0 tons of VOC/unit. This decrease in emissions was
attributed to a pollution, prevention technique. This technique was solvent substitution and is
found in Table A as option # 20. _ .
This is simply an example to demonstrate the meaning of the data categories in Table 1. It is not
expected that project teams will actually fill out the Table.. Rather, teams will make use of data
collection protocols that are based on the categories of information contained, in Table 1 to
extract the necessary data.
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Table 1: Environmental Performance Indicators
OBJECTIVE
MEDIA
Significant
as
Identified
through
Organiza-
tional EMS
Non-
significant
as
Identified
through
Organiza-
tional EMS
Subject
to
Specific
Legal
Environ-
mental
Discharge
Limits
Subject
to
Other
Legal
. Environ-
mental
Require-
ments
Normalized
to
Production
Levels
Method of \
Reduction
Tech. # Poll.
(Table ' Prev?
pg.22) (Y/N)
ENVIRONMENTAL PERFORMANCE INDICATORS (ISO/CD 14031, SEC 4.1.2, ASPECTS, IMPACTS INVZNIUKYJ
1, Specific pollutant
discharges
VOC emission
2. Aggregated pollutant
discharge (Aggregate
using appropriate
substance or risk
categories)
Air
X
Water
Land
Air
X
,
X
'
Pre EMS:
5
Ions/unit
Post EMS:
0
tons/unit
#20 Y
\'
Table 2: Environmental Condition Indicators
OBJECTIVE
MEDIA
Significant
as
Identified
through
Organiza-
tional EMS
Non-
significant
as
Identified
through
Organiza-
tional EMS
Subject
to
Specific
Legal
Environ-
mental
Discharge
Limits
Subject
to
Other
Legal
Environ-
mental
Require-
ments
NOT
Subject
To
Legal
Environ-
mental
Require-
ments
ENVIRONMENTAL CONDITION INDICATORS (ISO/CD 14031, SEC 4.1.2.3, ANNEX A)
\
1. Ambient air quality
(near organization)
[pollutant levels, odor, .
opacity, noise,
temperature]
2. Ambient water quality
(near organization)
[contaminant levels, grd &
surface, D.O., turbidity,
temperature]
3. Land quality [ambient
contaminant, nutrient,
erosion]
_.,
Air
Water
Performance
Relative To
Legal
Environ-
mental
Require-
ments
J
~~1
\
Environmental Management Systems
Voluntary Project Evaluation Guidance
February 13,1998
14
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How to Use The Guidance Example: As a result of the implementation of the EMS, the
organization-lias uncovered a violation of a state air permit that is considered to be serious and a
significant aspect. The organization has promptly corrected the situation and has placed a
corrective action procedure in place. ' . ,
Table 3: Environmental Compliance Indicators
OBJECTIVE
MEDIA
,
Significant
as
Identified
through
Organiza-
tional EMS
Non-
significant
as
Identified
through
Organiza-
tional EMS
Subject
to
Specific
Legal
Environ-
mental
Discharge
Limits
Subject
to
Other
Legal
Environ-
mental
Require-
ments
NOT
Subject
to
Legal
Environ-
mental ^
Require-
ments
Performance
Relative To \
Legal \
Environ- I
. mental \
Require- \
ments )
/
ENVIRONMENTAL COMPLIANCE INDICATORS (ISO/CD 14031, SEC 4.1.2.3, ANNEX A) /
''.' ' ' -, , , : , - (
Y
Serious violations/x
' Non-serious violations
Prompt discovery of
violations
air
-
X
X
-
V /
How to Use the Guidance Example: As a result of switching to a water based system, Facility
XYZ experienced a reduction in air emissions. Since a pollution prevention alternative was
chosen for the Method of Reduction column, the Pollution Prevention Exhibit was answered as
follows. , ' - '
Exhibit 1: Pollution Prevention
Interested parties Input
Government
Public Interest
OBJECTIVE
To what degree was
emphasis in policy
statement on pollution
prevention
Yes, not
-reqd by
state law
Pollution prevention plan
developed. If yes, required
by state law?
Environmental Management Systems
Voluntary Project Evaluation Guidance
February 13, 1998,
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16
-------
This section examines to what extent the implementation of an EMS results in an increase of the
use pollution prevention methods and technologies within the organization. Itwill workin
conjunction with the Performance Indicators in that any reduction or increase of emissions within
the Performance Indicators section,will be examined to determine what specific technologies
(Pollution Prevention or control techniques) were employed to achieve the reduction.
Environmental Management Systems
Voluntary Project Evaluation Guio'ance
February 13,1998
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18
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II. EMS PILOT PROJECT EVALUATION TABLES AND
EXHIBITS
Table 1: Environmental Performance Indicator;?
Table 2: Environmental Condition Indicators
Table 3: Environmental Compliance Indicators
Exhibit 1: Costs and Benefits
Exhibit 2: Pollution Prevention
Exhibits: Interested party involvement
- 19
Envirqnmental Management Systems , ,
Voluntary Project Evaluation Guidance
February 13,1998 , ' .
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Column Headings for Tables 1,2, and 3.
1. Media: Environmental media into which pollutant is discharged
2. Significant as identified through organizational EMS: Significant environmental aspects as
per ISO 14001 and the aspect identification process.
3. Non-significant as identified through organizational EMS: Non-significant environmental
aspect as per ISO 14001 and the aspect identification process.
4. Subject to specific legal environment discharge litnits: Legally required discharge, emission,
waste management, or other performance limits.
5. Subject to other legal environmental requirements: Subject to management, reporting,
monitoring or other administrative, non-quantitative requirements
6. Not subject to legal environmental requirements: Not subject to mandatory regulation under
local, state, or Federal laws.
7. Subject to other voluntary requirements: Subject to voluntary industry standards, i.e.
Responsible Care, ICC Charter, Great Printers Project, etc.
8. Performance relative to legal environmental requirements: The degree to which
performance exceeds or falls short of regulatory standards (as quantitative as feasible).
9. Normalized to production levels: Normalize performance measures to account for changes in
organization activity
10. Source of data: Description of data sources
11. Quality of data: Assessment of confidence in data, statistical limits of quantitative data
where possible, description of confidence in qualitative data/information
12. Relative value: A statement, or a ranking of the value or importance of a specific
performance measure in assessing overall performance of organization
13. Comments: Any supplemental information which will aid in the understanding of
performance data/information
14. F/o/a/fo7i5." Environmental violations are violations of federal, state or local or
environmental statutes, regulations, rules, permits, decrees, orders or agreements.
Environmental Management Systems
Voluntary Project Evaluation Guidance
February 13,1998
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15. Serious Violations: Serious violation is as defined by EPA penalty policies, major, .
significant minor or state policies if state violations only. ,,
16. Non-Serious Violations: Non-serious violation is as defined by EPA penalty policies,
' major, significant minor or state policies of state violations only.
17. Repeat Violations: Repeat violation is as defined under the EPA Audit/Self-Policing Policy:
\ an environmental violation (or closely related environmental violation) that has occurred
previously within the past three years at the same facility, or is part of a pattern of federal,
state or local violations by the facility's parent organization (if any), which have occurred
within the past five years. ,
'..-,-. - ' ' . -. "\
18. RCRA: 42 U.S.C.A Section 6901 et. seq.
19. TSCA: 15 U.S.C.A. Section 2601 et. seq.
20. FIFRA 7U.S.C.A. Section 136 et.seq. , .
21. Clean Air Act: 42 U.S.C.A. Section 7401 et. seq.
22. Clean Water Act: 33 U.S.C.A. Section 1251 et seq.
23. Regulatory Status: Benchmark is the existing regulatory condition for each of the
environmental media based on a hierarchy of legal requirement beginning with the greatest
liability. Goal refers to the EMS goal established for each media for reducing legal
liabilities.
24. Discharge Category:. For each media, the current legal requirements representing the most
substantial or potential discharge activity is identified and benchmarked. An EMS goal can
be set, in the context of legal environmental requirements, to demonstrably show
improvement hi performance by moving from a higher (more consequential) category to a
lower (less consequential) category.
25. Distinquisher: Each environmental media has unique criteria for differentiating between
the levels of regulatory requirements or types of facilities. This is the unique identifier for
the specific media category of legal requirements.
26 Pollutant:A pollutant is any hazardous substance, hazardous waste, solid waste, effluent, runoff, emission or
other material that is regulated under environmental statutes or any material containing a hazardous substance
that is emitted or discharged to air, surface water, groundwater, or placed on the land..
27. Cost of Compliance: Expenditures necessary to maintain compliance with legal
- requirements including, for example, record keeping, reporting, sampling, permit fees or
pollutant generation fees are calculated for both the existing state and when the new
regulatory status is achieved. -
. ' ' - . ." ' %. 21
Environmental Management Systems , _
Voluntary Project Evaluation Guidance .
February 13, 1998
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EXHIBIT 1: COSTS AND BENEFITS OF EMS DEVELOPMENT AND
:. IMPLEMENTATION
QUESTIONS FOR FACILITY
1. What have been the direct or indirect costs and benefits (either real or projected) for
developing, implementing and maintaining your EMS and what units of measurement were
used? If possible, please break out both costs and benefits by category (e.g. development,
, implementation and maintenance) and type (e.g. materials, equipment, labor, fees,'
consultants, other).
2. At what pouit did you begin measuring costs and/or what baseline(s) was chosen by the
facility to track progress? Did you calculate the cost of compliance systems?
3. Were you able to use your existing methodologies for tracking;costs and benefits or did a
new methodology need to be developed? Describe the methodology used..
4. Were there any particular barriers or problems you encountered when tracking costs and
benefits? If so, briefly describe them. ,
5. What: costs have been incurred and benefits realized specifically from pollution prevention
initiatives, training programs and interested party involvement activities that may have been
undertaken as a part of your EMS? Please cite direct and indirect costs and benefits -
including those relative to overhead costs such as legal, public relations, and administrative.
6 What have been the changes hi costs for activities such as obtaining permits, maintaining
records, and compliance monitoring? Were these cost changes associated with going from a
"higher" to a "lower" permit? (see Compliance Section)
7. Is your firm tracking other potential benefits of implementing an EMS such as change in the
firm's market share, access to new markets, insurance rates, bond ratings, stock prices, and
costs of capital? Please share specifics if possible.
8. Do you currently have a quality management system in place? How did this impact the
costs/benefits of developing, implementing and maintaining your EMS? Please share details
as available.
9. Generally, were the costs incurred and benefits realized generally higher or lower than
originally expected? Explain.
QUESTIONS FOR STATE AGENCY
1. What were the changes in costs, if any, associated with time spent for permitting, inspecting
and monitoring the facility? How~does this compare with facilities without ah EMS?
2; What other costs and benefits did the agency realize by undertaking the pilot project?
EnvironmentalManagement Systems 29
Voluntary Project Evaluation Guidance
February 13,1998
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EXHIBIT 2: POLLUTION PREVENTION
OBJECTIVE
To what degree was '
emphasis in policy
statement on pollution
prevention
Pollution prevention plan
developed. If yes, required
by state law?
Appropriate pollution
prevention training given
to all employees
Pollution prevention teams
formed
Pollution prevention
involves suppliers
Pollution prevention
involves customers
Pollution prevention urall
business plans
Pollution prevention
ehavior rewarded
Design for Environment
practices followed
What pollution prevention
objectives and targets were
set?
Information
Location
Policy
statement
Training
records
Company
information /
team reports
Mgmt
Framework
Marketing Plan
Mgmt
Framework
Personnel Plan
Mgmt
Framework
Company
information
Interested Party Input
Employees
Public Interest
Government
Environmental Management Systems
Voluntary Project Evaluation Guidance
February 13, 1998
30'
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EXHIBIT 3: INTERESTED PARTY INVOLVEMENT
NOTE: ISO 14001 defines "interested party" as an "individual or group concerned with or
affected by the environmental performance of an organization.
It should be self-evident that any regulatory response to the .implementation of an EMS will
require a high degree of public credibility of the process that generated and manages the EMS.
Obviously, one can seek.to assess that credibility either qualitatively or quantitatively, and
discussion of that choice occupied considerable time in the development of this document
Ultimately, as the following questions indicate, the decision of the group was to focus on the
qualitative. .
That is not meant to discourage pilots from seeking to assess the before-and-after public
perception of a facility's performance in some quantitative manner. As some would argue, only
what gets measured gets managed, and there may well be important data to be gathered
quantitatively. Generally, we are concerned about the cost of developing such data and about its
reliability. Still, we do not discourage attempts to develop pre-and post EMS measures of public
satisfaction with a facility's operation in some .numerical, or other research validated, way -
whether via surveys, focus groups, or similar methods. Some systems for measuring satisfaction
may already be in place at a facility, such as internal employee surveys, and these may be
adaptable to provide information about individuals' assessment of the EMS. It is obvious that
there are many possible ways to compile responses to the qualitative questions raised in this
section of the document. For example, they might simply be answered by a company manager,
the regulatory agency might do its own independent assessment; or each person involved in the
interested party process may be asked to provide his or her individual answers to the questions.
Whatever the process, the method should be documented so that relative comparisons can be
made between pilots.
Questions:
1. Were interested parties involved in the development and implementation of the
organization's EMS ?
2. If. so, what was the composition of the interested party group and how were its members
chosen?
3. How and at what point(s) were interested parties involved or consulted hi the planning of the
EMS, in such areas as: identification of environmental aspects and impacts and selection of
objectives and targets , .
4. How and at what point(s) were they involved in the implementation and oversight of the.
. EMS? : ". : . ''" '.':'. ' '
! > - ± . t '-.''',"
5. Did the environmental aspects identified and the objectives and targets chosen for the EMS
address those issues that were important to the interested parties?
Environmental Management Systems
Voluntary Project Evaluation Guidance
February 13, 1998 '
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6. Does the EMS address other socioeconomic needs of the interested parties such as jobs and
economic and environmental sustainability?
7. What changes would you recommend in the way the .interested party process was
undertaken?
8. What processes did you develop for receiving, documenting, and responding to relevant
communication from external interested parties?
9. What processes for external communication on significant environmental aspects did you
consider?
10. How were decisions reached within the interested party group? (consensus, vote, etc.) What
weight was given to the group's decisions? Was any technical or financial support provided
to the group?
Environmental Management Systems
Voluntary Project Evaluation Guidance
February 13,1998
32
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III. ADDITIONAL INFORMATION
Method of Reduction
Needs
Contact Information
Environmental Management Systems
Voluntary Project Evaluation Guidance
February 13, 1998 =.'..
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III. ADDITIONAL INFORMATION
Method of Reduction
If the data presented in the column Normalized Production Levels in Table 1: Environmental
Performance Indicators indicates a reduction in pollution discharges, this list may identify the
method of reduction implemented. Table A presents a list of pollution prevention options, but is
hi no way exhaustive. The use of this list will help to determine if pollution prevention was the
primary means of reduction. Indicate the appropriate number from Table A, in the Method of
Reduction column hi Table 1. Pollution Prevention is defined as both reduction at the source and
recycling.
Table A
POLLUTION PREVENTION OPTIONS
OPERATING PRACTICES
1. Segregate hazardous waste to make more
amenable to recycling
2. Segregate hazardous waste from non-hazardous
waste
3. Improved maintenance scheduling, recordkeeping,
or procedures
4. Changed production schedule to minimize
equipment and feedstock changeovers
5. Other changes in operating practices (Specify)
INVENTORY CONTROL:
6. Instituted procedures to ensure that materials do
not stay in inventory beyond shelf-life.
7. Began to test outdated material continue to use
if still effective -
8. Eliminated shelf life requirements for stable
materials
9. Instituted better labeling procedures
10. Instituted clearinghouse to exchange materials
that would otherwise be discarded
11. Other (specify)
SPELL AND LEAK PREVENTION
12. Improved storage or stacking procedures
13. Improved transfer for loading, unloading, and
transfer operations
14. Installed overflow alarms or automatic shutoff
valves
15. Installed secondary containment
16. Installed vapor recovery
17. Implemented inspection or monitoring program
of potential spill or leak sources
18. Other (specify)
RAW MATERIAL MODIFICATIONS
19. Increased purity of raw materials
20. Substituted raw materials
21. Other (Specify)
PROCESS MODIFICATIONS
22. Instituted closed-loop recycling
23. Modified equipment, layout, or piping
24. Instituted better controls on operating conditions
(flow rate, temperature, pressure, residence
time)
25. Other (specify)
PRODUCT MODIFICATIONS
26. Changed product specifications
27. Modified design or composition
28. Modified packaging
29. Other (specify)
OTHER POLLUTION PREVENTION
ACTIVITY
30. Specify
TECHNOLOGY
31. Specify
RECYCLING
32. Specify
Environmental Management Systems
Voluntary Project Evaluation Guidance
February 13,1998
34
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NEEDS-
In October, 1996, representatives of business, government regulators and public interest,
groups met in Madison, Wisconsin as part of an ISO 14001 Roundtable process sponsored by the
states of Wisconsin, Pennsylvania and the University of Pennsylvania's Wharton School of,
Business and University of Wisconsin-Madison's La Follette Institute of Public Affairs. The
interested parties were asked to identify their "needs" from ISO 14001 pilot projects planned hi
both states. It was stated that all the goals may not be met but that the pilots should be selected
and designed to meet as many goals and needs as possible. This is their unedited list that is
offered to prompt thinking: , ,
'" " .*
Government Regulators
Enhanced environmental performance, objectively demonstrated; :.
reduced transaction costs for government; increased community involvement;
transferability to other groups; high level of credibility and acceptability of the
pilot process and its results; identification of areas of regulatory flexibility
needed to achieve beyond compliance; market driven.
Public Interests
Meaningful public involvement to include not only the neighbors but
customers (process and outcome); test me quality, accuracy and nature of the
information disseminated; test the quality of the discussion that occurs based
' . on the input and the information; development of a set of environmental
indicators that are measurable and can be tested as a part of the pilot;
credibility; clear articulation of the limits of the pilot results; defining very clearly
the parameters and the boundaries of the pilot; to learn from the experience
and to act on what we have learned, e.g. take enforcement action,if major -
violations are found mat meet EPA criteria for enforcement under the audit
policy; a mechanism to aid in conflict resolution.
Business
Credibility, mechanism to resolve conflict clearly defined set or
parameters when go into the pilot; complementary to existing regulatory system,
one does not supplant the othei;; allows of self declaration of certification; ,
positive environmental outcomes; positive economic outcomes; reduce
transaction costs for business; creation of a forum composed of all interest
groups to discuss issues of regulatory flexibility within the pilot study; sound
credible scientific information; company EMS information system that is accept
by me regulators ~ one set of books and data; look at the low cost thkd party
certification; no certification; provide a test of the benefits of ISO to businesses
of all sizes.
Environmental Management Systems _ -
Voluntary Project Evaluation Guidance ' , '
February 13,1998
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CONTACT INFORMATION;
For additional information on the Guidance Document please contact:
Ravila Gupta NC Department of Environment and Natural Resources Phone:
919-715-6507 .
\
Bob Stephens CA Environmental Protection Agency, Phone: 510-540-3003
JeffSmoller WI Department of Natural Resources, Phone: 608-266-2747
For information on the data collection protocols, please contact:
John Villani, University of North Carolina, Chapel Hill, Phone: 919-962-2789
36
Environmental Management Systems
Voluntary Project Evaluation Guidance
February 13,1998
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