r/EPA
United States
Environmental Protection
Agency
Office of Pollution
Prevention and Toxics
(7406)
EPA 744-R-00-012
December 2000
Integrated
Environmental
Management Systems
Company Manual Template
for Small Business
U.S.EPA
Office of
Pollution
Prevention
and Toxics
-------
EPA 744-R-00-012
December 2000
Integrated
Environmental
Management
Systems USERA
A Company Manual Template
for Small Business
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics
-------
Acknowledgments
This document was prepared by Eastern Research Group, Inc. of Lexington, MA, as part of an
effort to show how Design for the Environment (DfE) technical work could be used to support
development of an Integrated Environmental Management System (IEMS). The ERG project
team included David Galbraith, Owen Davis, and Jeff Cantin.
The EPA Project Officer is Karen Chu, with the DfE Program in the Office of Pollution
Prevention and Toxics. Bill Hanson is Director of the DfE Program. Important contributions
were made by Ted Cochin and Jenny Fisher of the DfE Program staff. Additional support was
provided by Abt Associates, Cambridge, MA and from the University of Tennessee, Knoxville
Center for Clean Products and Clean Technologies. The Abt project team included Cheryl
Keenan and Libby Parker. The University of Tennessee project team included Kerry Kelly, Lori
Kincaid and Mary Swanson.
We would also like to acknowledge insights and expertise received from Marci Kinter of the
Screen Printing and Graphic Imaging Association International (SGIA), Fairfax, VA, and from
Foster Knight of The Lexington Group, Lexington, MA.
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Foreword
Why Have an IEMS Manual For Your Company?
For a small or medium-sized company developing an IEMS, the question of how to document
the system itself can be challenging. Many smaller companies lack experience in developing
documentation for their business processes and worry about having to develop extensive
documentation for their IEMS. In the course of a pilot project sponsored by EPA's Design for
the Environment (DfE) Program and a trade association, the small and medium-sized companies
participating in the project requested additional guidance on how to document their lEMSs in a
concise, user-friendly manual. They wanted to achieve the following benefits from effective
documentation:
• Ability to maintain and improve their lEMSs as personnel and responsibilities change (i.e.,
the system is less dependent on a single person).
• Improved system implementation: procedures are clear and easy to follow, and employees
know where to look to find the procedures and records they need.
• Quality improvement and systematization across other company management systems.
To meet this request and to help other small and mid-sized companies document their lEMSs, the
DfE Program has developed the following company manual template. The company manual
template contains procedures and associated formats for an IEMS that is designed according to
the principles set forth in Integrated Environmental Management Systems: Implementation
Guide (EPA 744-R-00-011). This guide is available on DfE's website at http://www.epa.gov/dfe
or through EPA's Pollution Prevention Information Clearinghouse at ppic@epa.gov.
The template itself contains a cover page, table of contents, and complete documentation for the
fictional Smith Corporation's IEMS. As you work through the template you will see instructions
(in italics) on how to tailor each section to the specific requirements of your own small- to
medium-sized company.
Using This Company Manual Template
Please keep the following points in mind as you make use of this company manual template:
• Adapt this manual template to your particular company and its IEMS. The template itself
contains a cover page, table of contents, and complete documentation for the fictional Smith
Corporation's IEMS. As you work through the template you will see instructions (in italics)
on how to tailor each section to the specific requirements of your own small- to medium-
sized company. Bracketed and italic text is also used to refer you to the related section in the
IEMS Implementation Guide (see above). You will probably want to add, eliminate, and/or
modify the procedures and other manual elements to fit your company's IEMS.
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• This manual template contains a good base set of procedures. The IEMS procedures
contained in this template represent the core set of procedures normally documented as part
of an ISO 14001-compliant EMS. You may choose to include all of these procedures
(regardless of whether you eventually will seek certification of your EMS to ISO 14001), or
to add, remove, or modify procedures so that the documentation reflects your organization
and your EMS.
• If it won't be useful, it's not worth your time. As you are adapting this company manual
template, design it so that it will be used (and further adapted) over time. It is much more
important to have a living manual than a perfect manual that just sits on the shelf.
• Pick an appropriate level of detail for your company. In general, the larger a company is, the
more detailed its procedures are—but even this may vary according to your company's
culture.
• If you already have a system for documentation and document control, develop your IEMS
manual to fit that system. There are no specifications or criteria for the system used to
document your IEMS. It makes sense to use whatever system you normally use for
developing and maintaining similar documentation.
• Your manual should reference worksheets, templates, or company records, where applicable.
This manual makes reference to numbered templates that directly follow the corresponding
procedures, as well as to other records maintained elsewhere n the company. (To help locate
these tools within the manual, see the index that follows.) If you use additional formats or
worksheets (i.e., such as the supporting worksheets presented in the IEMS Implementation
Guide), include those as well.
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Integrated Environmental Management System (IEMS)
Manual
Smith Corporation
Prepared by:
January 4, 2001
Revision 1.0
(IEMS Management Representative)
Approved and Authorized by:
(President)
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Smith Corp. - IEMS Manual
Rev. 1.0 (January 4,2001) Pagei
Table of Contents
Table of Contents i
Purpose of This Manual 1
Definitions, Abbreviations, and List of Procedures 2
Company Description: Smith Corporation 4
Smith Corporation's IEMS: Introduction and Scope 5
Environmental Policy 6
IEMS Responsibilities 7
Documentation
RESP-01: IEMS Responsibilities 8
IEMS Components, Procedures, and Documentation 9
Identification of Environmental Aspects (P-EA) 10
Documentation
EA-Ola: Basic and Supporting Operations 11
EA-Olb: Basic and Supporting Operations—Material Flow Diagrams 12
EA-02: Environmental Aspects 13
EA-03: Health, Safety, and Potential Environmental Concerns 14
EA-04: Exposure to Chemicals and Materials 15
Identification of Legal Requirements (P-LR) 16
Documentation
LR-01: Applicable Legal Requirements 17
Identification of Significant Environmental Aspects (P-SEA) 18
Documentation
SEA-01: Determining Significant Environmental Aspects 20
Development of Objectives, Targets, and Action Plans (P-OTP) 21
Documentation
OTP-01: Environmental Objectives 23
OTP-02: Environmental Management Plan 24
Conducting an Alternatives Evaluation (P-AE) 25
Documentation
AE-01: Alternatives Identification 27
AE-02: Evaluation of Alternatives 28
AE-03: Evaluation of Environmental Effects 29
AE-04: Evaluation of Performance 30
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Smith Corp. - IEMS Manual
Rev. 1.0 (January 4,2001) Pagei
AE-05: Evaluation of Regulatory Concerns 31
AE-06: Evaluation of Costs 32
Development of Operational Controls (P-OC) 33
Documentation
OC-01: IEMS Operational Control Procedures 35
Environmental Training (Awareness and Task-Specific) (P-ET) 36
Emergency Preparedness (P-EP) 38
Review of New Purchases, Processes, and Products (P-NPPP) 39
Documentation and Document Control (P-D) 41
Conducting a Compliance Assessment (P-CA) 43
Documentation
CA-01: Compliance Tracking Log 44
Conducting an Internal Assessment (P-IA) 45
Documentation
IA-01: Internal Assessment Checklist 47
IA-02: Internal Assessment Record 48
Taking Corrective Action (P-TCA) 49
Documentation
TCA-01: Corrective Action Form 50
Communication with Stakeholders (P-CS) 51
Documentation
CS-01: Stakeholders and Environmental Issues 53
CS-02: Stakeholder Communication Record 54
Management Review (P-MR) 55
Documentation
MR-01: Management Review Record 57
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Smith Corp. - IEMS Manual
Rev. 1.0 (January 4,2001) Page 1
Purpose of This Manual
[One or more paragraphs describing the purpose of this manual within your company's IEMS.]
The purpose of this manual is to serve as a high-level "road map" to Smith Corporation's IEMS
and to house the procedures which Smith Corporation follows in implementing and maintaining
its IEMS.
This manual, and subsequent revisions, is distributed by the IEMS coordinator to senior plant
management (including the IEMS management representative), and the IEMS committee. It will
be made available to all Smith Corporation employees, especially those involved in performing
work related to the IEMS.
This manual also serves as the basis for Smith Corporation's internal assessment of its IEMS.
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Smith Corp. - IEMS Manual
Rev. 1.0 (January 4,2001) Page 2
Definitions, Abbreviations, and List of Procedures
[List of all abbreviations used in the manual and definitions of relevant terms.]
Definitions
Design for the Environment (DfE): An approach to incorporating opportunities for risk reduction
and wise resource use into business decision-making, developed through partnerships between
the U.S. Environmental Protection Agency and industry, academic, and other stakeholders
Environmental aspect (EA): An element of Smith Corporation's activities, products, or services
that can or does interact with the environment (create an environmental impact)
Environmental impact: Any change to the environment, whether adverse or beneficial, resulting
from Smith Corporation's activities, products, or services
Significant environmental aspect (SEA): An environmental aspect deemed by the Smith
Corporation as having, or potentially having, a significant impact on the environment
Alternatives evaluation: Process by which alternative methods for completing a particular
function are evaluated using business and environmental criteria
Non-conformity: Discrepancy between Smith Corporation's actual IEMS activities and the
procedures laid out in this manual (i.e., where the actual activities do not follow the procedures)
Indicator: A measurable parameter or predictor of performance (in this case, of environmental
performance)
Root cause analysis: Systematic process to uncover underlying causes of a particular issue or
problem
Abbreviations
DfE Design for the Environment
EA Environmental Aspect
EMS Environmental Management System
SEA Significant Environmental Aspect
List of Procedures
(Alphabetical)
P-AE Conducting an Alternatives Evaluation
P-CA Conducting a Compliance Assessment
P-CS Communication with Stakeholders
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Smith Corp. - IEMS Manual
Rev. 1.0 (January 4,2001) Page 3
P-D Documentation and Document Control
P-EA Identification of Environmental Aspects
P-EP Emergency Preparedness
P-ET Environmental Training (Awareness and Task-Specific)
P-IA Conducting an Internal Assessment
P-LR Identification of Legal Requirements
P-MR Management Review
P-NPP Review of New Purchases, Processes, and Products
P-OC Development of Operational Controls
P-OTP Development of Objectives, Targets, and Action Plans
P-SEA Identification of Significant Environmental Aspects
P-TCA Taking Corrective Action
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Smith Corp. - IEMS Manual
Rev. 1.0 (January 4,2001) Page 4
Company Description: Smith Corporation
[Several paragraphs describing the activities of your company, its location(s), and its mission
and/or values.]
Smith Corporation is a medium-sized business dedicated to the manufacture of high quality
widgets for a variety of large industrial customers. Smith Corporation owns and operates two
plants, one in Jonesville, Kentucky, and one in Johnsville, Tennessee.
Smith Corporation was founded in 1956 and has since built and maintained the reputation of
being a responsive supplier of high quality products, a good employer, and a good community
member.
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Smith Corp. - IEMS Manual
Rev. 1.0 (January 4,2001) Page 5
Smith Corporation's IEMS: Introduction and Scope
[Two or three paragraphs that introduce your IEMS and describe its purpose and scope.]
Smith Corporation has developed and is maintaining an IEMS in order to ensure that we
continue to supply a high quality product to our customers while providing a safe, healthy
workplace for our employees and acting as a responsible member of our community. The Smith
Corporation's IEMS is designed to help us understand our environmental impacts and, through
proactive management, reduce the risks that our productive operations pose to our employees
and to the environment. The IEMS is also the means through which we follow through on the
commitments expressed in our environmental policy.
Scope of Smith Corporation's IEMS
Smith Corporation's IEMS presently covers only the Jonesville, KY plant. More specifically,
the IEMS covers all operations occurring on-site at the plant, from the point of entry of raw
materials and energy to the point of exit of finished manufactured products. In addition to
manufacturing processes and activities, all on-site ancillary operations fall within the scope of
the IEMS, including maintenance, groundskeeping, offices, and the activities of on-site
contractors. The IEMS excludes the environmental aspects of products to the extent that Smith
Corporation does not have influence over their design or disposition. The IEMS does take waste
disposal into account in evaluating the environmental impacts of on-site activities, even though
Smith Corporation may not ultimately be the final disposer of its waste.
Smith Corporation plans to extend the IEMS to the Johnsville, TN plant after it has been in place
for several years at the Jonesville plant.
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Smith Corp. - IEMS Manual
Rev. 1.0 (January 4,2001) Page 6
Environmental Policy
[One or two paragraphs about the importance of the environmental policy in your company's
IEMS. See Module 2 in the IEMS Implementation Guide.]
The core of Smith Corporation's IEMS is our environmental policy. The environmental policy
states in broad terms the principal environmental commitments of Smith Corporation. It is
signed by our President and has been communicated to all employees. The environmental policy
is posted on bulletin boards throughout the plant and is available on request to the public,
customers, and authorities. The IEMS coordinator is responsible for ensuring that only the most
recent version of the environmental policy is posted and available.
The environmental policy of Smith Corporation is reproduced below.
[Insert environmental policy]
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Smith Corp. - IEMS Manual
Rev. 1.0 (January 4,2001) Page 7
IEMS Responsibilities
[Several paragraphs describing how the overall responsibility for maintaining the IEMS is
distributed within your company. See Module 1 in the IEMS Implementation Guide.]
Smith Corporation has established an IEMS management representative, coordinator, and
committee with the following responsibilities:
• Management representative. The IEMS management representative is the member of Smith
Corporation's top plant management group responsible for the functioning of the IEMS. It is
his or her job to ensure that all tasks relating to the IEMS are identified and completed in a
timely manner. He or she is also responsible for reporting periodically to the top plant
management group on the progress and results of the IEMS.
• Coordinator. The IEMS coordinator's responsibility is to identify, assign, schedule, provide
the necessary support for, and ensure completion of all tasks relating to the IEMS. The
coordinator works closely with the management representative and with the committee. The
IEMS coordinator is also responsible for maintaining this manual, under the leadership of the
management representative. The junctions of coordinator and management representative
may be filled by the same person.
• Committee. The IEMS committee (which also serves as the plant's safety committee) is
comprised of 6-8 supervisors and employees from major groups or areas within the plant.
The committee is responsible for ensuring that IEMS activities in their areas are carried out
and for reporting the results of these activities to the committee as a whole. In addition, the
committee itself undertakes certain IEMS activities such as the selection of significant
environmental aspects. The committee meets to discuss the IEMS on at least a monthly
basis.
Records
The IEMS coordinator maintains an updated list of management representative, coordinator, and
committee members using format RESP-01 (IEMS Responsibilities).
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Smith Corp. - IEMS Manual
Rev. 1.0 (January 4,2001)
Page 8
RESP-01: IEMS Responsibilities
The following table lists the Smith Corporation's IEMS management representative, coordinator,
and committee:
IEMS Function
Management Representative
IEMS Coordinator
IEMS Committee
Name
Regular Position
Contact Person:
Date Completed:
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Smith Corp. - IEMS Manual
Rev. 1.0 (January 4,2001) Page 9
IEMS Components, Procedures, and Documentation
The following pages of this manual present the components of Smith Corporation's IEMS and
procedures by which these components are carried out. The following elements are included for
each component:
• A statement of the purpose of the component—in other words, how the activity fits into the
IEMS.
• Chronologically ordered and numbered steps that make up the procedure for carrying out the
component. These steps describe what actions are taken and who is responsible and make
reference to records or documentation (e.g., formats) where appropriate.
• Mention of the frequency with which the procedure is carried out.
• Summary list of records referenced in the procedure and person(s) responsible for
maintaining them.
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Smith Corp. - IEMS Manual
Rev. 1.0 (January 4,2001) Page 10
Identification of Environmental Aspects (P-EA)
[See Modules 1 and 3 in the IEMS Implementation Guide.]
Purpose
In order to understand and manage its actual and potential environmental impacts, Smith
Corporation identifies the environmental aspects of its activities, products, and services as they
fall within the scope of the IEMS. As a subset of this activity, Smith Corporation identifies the
health and environmental concerns related to particular chemicals used in the plant.
Procedure
1. Using processing mapping (or input/ouput flow charts), the IEMS committee identifies
the basic manufacturing and supporting operations that fall within the scope of the IEMS.
These are recorded using format EA-01, with supporting material flow diagrams and
table using format EA-Olb.
2. The IEMS coordinator arranges for the environmental aspects of these operations to be
identified by a team of several employees from the operation in question, using the
process mapping approach where feasible and under the oversight of the IEMS
coordinator or a committee member where appropriate.
3. Environmental aspects, and their actual or potential impacts (quantified to the extent
possible), are listed by operation using format EA-02 (similar to Worksheet 1-5 in the
IEMS Implementation Guide).
4. If the environmental aspect involves use of a potentially harmful chemical, the IEMS
committee is responsible for researching the known health and environmental concerns
and listing these using format EA-03 (similar to Worksheet 3-1 in the IEMS
Implementation Guide).
Frequency
This procedure is repeated annually to ensure that any new environmental aspects are identified.
Records
Formats EA-01 a and EA-Olb (Basic and Supporting Operations, Flow Diagrams), EA-02
(Environmental Aspects), and EA-03 (Health and Environmental Concerns) are maintained by
the IEMS coordinator.
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Smith Corp. - IEMS Manual
Rev. 1.0 (January 4,2001) Page 11
EA-Ola: Basic and Supporting Operations
The following are the basic (manufacturing) and supporting operations that fall within the scope
of Smith Corporation's IEMS:
1.
2.
3.
7.
10.
Contact Person: Date Completed:
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Smith Corp. - IEMS Manual
Rev. 1.0 (January 4,2001)
Page 12
EA-Olb: Basic and Supporting Operations - Material Flow Diagrams
[Sample diagrams]
Generic Input-Output Diagram for Office Operations
Paper
Energy
Toner
Copying
Printed Documents
~~* Waste Paper
-* Used Toner
-»• Odors
Generic Input/Output Diagram for a Manufacturing Operation
Chemicals >•
Materials •
Manufacturing
Step
> Chemical Waste
> Materials Waste
*• Waste Water
Product for
Next Step
Product or Service
Component Parts
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Smith Corp. - IEMS Manual
Rev. 1.0 (January 4,2001)
Page 13
EA-02: Environmental Aspects
The environmental aspects of the basic and supporting operations identified in format EA-01 are listed in the following table.
Operation
Input/Output
Environmental Aspect
(quantify if readily possible)
Environmental Impact
Contact Person:
Date Completed:
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Smith Corp. - IEMS Manual
Rev. 1.0 (January 4,2001)
Page 14
EA-03: Health, Safety, and Potential Environmental Concerns
Work Activity/
Chemical
Environmental
Aspect
Information
Source
Regulatory Data
"S
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Smith Corporation IEMS Manual
Re v 1.0 (January 4,2001)
Page 15
EA-04: Exposure to Chemicals and Materials
Operation
Aspect
Quantity
Used per
Time
Period
Exposure Time
Duration
Frequency
Personal
Protective
Equipment
(PPE)
Pathway
Human
(inhalation,
dermal,
oral)
Environ-
mental
(air, water,
land)
Rank Exposed Groups
Workers
Community
Environ-
ment
Contact Person:
Date Completed:
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Smith Corporation IEMS Manual
Re v 1.0 (January 4,2001) Page 16
Identification of Legal Requirements (P-LR)
[See Module 1 in the IEMS Implementation Guide.]
Purpose
Smith Corporation is committed to complying with all applicable environmental regulations.
This procedure describes how Smith Corporation identifies applicable regulations.
Procedure
1. The IEMS management representative is responsible for tracking applicable
environmental laws and regulations and evaluating their potential impact on the
company's operations. He or she employs several techniques to track, identify, and
evaluate applicable laws and regulations. These techniques include commercial
databases, information from the trade association, direct communication with national
and state regulatory agencies, and periodic refresher training on environmental laws.
2. As necessary, the management representative may call upon off-site resources such as
consultants or attorneys.
3. The management representative compiles and maintains updated copies of applicable
environmental laws and regulations.
4. The management representative, working with the IEMS coordinator and committee,
correlate these regulations to the business activities and environmental aspects associated
with them using format LR-01 (similar to Worksheet 1-6 in the IEMS Implementation
Guide).
Frequency
Periodic: depends on information source.
Records
Format LR-01 (Applicable Legal Requirements) is maintained by the IEMS coordinator. The
IEMS management representative maintains copies of the applicable regulations.
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Smith Corporation IEMS Manual
Rev 1.0 (January 4,2001)
Page 17
LR-01: Applicable Legal Requirements
The following table provides a list of environmental regulations that apply to Smith Corporation's activities. The specific operation(s)
to which each regulation applies are also shown. The operations are a subset of those listed on format EA-02.
Regulatory Agency
Regulation and Specific Provision
Operation(s) to which Provision
Applies
Contact Person:
Date Completed:
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Smith Corporation IEMS Manual
Rev 1.0 (January 4,2001) Page 18
Identification of Significant Environmental Aspects (P-SEA)
[See Module 3 in the IEMS Implementation Guide.]
Purpose
Smith Corporation focuses its management efforts on the most significant of its environmental
aspects. To determine its SEAs, Smith Corporation systematically evaluates its environmental
aspects using environmental and business criteria.
Procedure
1. The IEMS coordinator compiles a master list of environmental aspects onto format SEA-
01 based on the lists submitted from each area (which are compiled on format EA-02).
Where appropriate, individual aspects are grouped. (For example, if consumption of
energy is listed as an environmental aspect in several areas, the coordinator could choose
to group these listings such that consumption of energy appears just once on the master
list.)
2. The IEMS committee then rates each aspect according to the following criteria:
• Regulatory concerns
• Pollution
• Risk, including effects of chemicals and materials, impact on workers, impact on the
surrounding community, impact on the environment, safety, and noise
• Natural resource use
3. Using format SEA-01 (similar to Worksheets 3-5a and 3-5b in the IEMS Implementation
Guide), aspects are assigned a relative value of L, M-L, M, M-H, or H in each category,
where L stands for low impact (or risk, or potential for regulatory issues), M for
medium, and H for high. Information recorded on formats EA-03 and LR-01 are used to
assist the committee in rating each aspect in the categories of risk and regulatory
concerns, respectively.
4. A "Total Ranking" is developed for each aspect by adding the scores for each category
using the following values: L = 1; M-L = 2; M = 3; M-H = 4; H = 5.
5. With all but the last column of format SEA-01 complete, the committee makes a final
determination as to which aspects are significant. As a general guide, the aspects that
score the highest number of points are considered significant. The committee, however,
should use its best judgement in determining significance.
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Smith Corporation IEMS Manual
Rev 1.0 (January 4,2001) Page 19
6. Aspects identified as significant are indicated on format SEA-01.
7. At this point, the IEMS committee may take an initial cut at developing indicators for
the SEAs (at least one indicator per SEA). These preliminary indicators, which will be
reviewed later (see the procedure on operational controls, P-OC), can be noted using
format OC-01.
Frequency
This procedure is repeated on an annual basis.
Records
Format SEA-01 (Determining Significant Environmental Aspects) is maintained by the IEMS
coordinator.
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Smith Corporation IEMS Manual
Rev 1.0 (January 4,2001)
Page 20
SEA-01: Determining Significant Environmental Aspects
The following table shows the IEMS committee's evaluation of the Smith Corporation's environmental aspects based on selected
criteria. Those aspects chosen as significant are indicated in the final column.
Operation
Aspect
Regulatory
Concern
Chemical and Material Risk —
Effects and Exposure
Worker
Community
Environmental
Worker Safety
(JUKI
Community
Issues
Natural
Resources
If
> a
O &
Significant?
Contact Person:
Date Completed:
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Smith Corporation IEMS Manual
Rev 1.0 (January 4,2001) Page 21
Development of Objectives, Targets, and Action Plans (P-OTP)
[See Modules 3 and 5 in the IEMS Implementation Guide.]
Purpose
The Smith Corporation sets objectives for environmental improvement and develops targets
and action plans to meet those objectives. These objectives are generally directly related to the
company's significant environmental aspects and follow from its environmental policy
commitments.
Procedure
1. Top plant management sets environmental objectives for the Smith Corporation such
that the plant has one or more environmental objectives at any one time. The current
environmental objectives are recorded using format OTP-01. Where possible,
environmental objectives are quantified and at least one indicator developed.
2. The IEMS committee is responsible for developing and recommending potential new
environmental objectives to top plant management. In identifying potential new
objectives, the committee considers the following:
• Environmental policy
• The SEAs of the company, considering especially those SEAs that pose chemical
risk
• Applicable laws and regulations and potential future laws and regulations
• Practical business criteria, such as the potential costs and benefits of pursuing a
particular environmental objective
• The views of employees and other interested parties
3. Once environmental objectives are established by top plant management, the IEMS
coordinator assigns responsibility (to the manager of the operations in question, where
appropriate) for developing targets and action plans to realize the objectives. The
targets and action plan that correspond to each objective are recorded by the responsible
person using format OTP-02 (similar to Figures 7-a and 7-b of the IEMS
Implementation Guide). Sometimes, this may require an alternatives evaluation as the
first target (or action item). See P-AE, "Conducting an Alternatives Evaluation," for
more detail.
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Smith Corporation IEMS Manual
Rev 1.0 (January 4,2001) Page 22
Frequency
Environmental objectives are reviewed on a yearly basis. The targets and action plans are
developed and revised as needed by the committee.
Records
Environmental objectives are recorded using format OTP-01 (Environmental Objectives), and
the targets and action plans that correspond to each objective are recorded using format OTP-
02 (Action Plan). The IEMS coordinator is responsible for maintaining these records.
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Smith Corporation IEMS Manual
Rev 1.0 (January 4,2001)
Page 23
OTP-01: Environmental Objectives
The following is a list of Smith Corporation's current environmental objectives.
Objective
Related SEA
Related Environmental Policy
Provision
Performance Measurement
Indicator(s)
Contact Person:
Date Completed:
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Smith Corporation IEMS Manual
Rev 1.0 (January 4,2001)
Page 24
OTP-02: Environmental Management Plan
Objective
Indicator(s)
Target # 1
Action Plan
Person(s) responsible:
Budget
Schedule
Review cycle
Target # 2
Action Plan
Person(s) responsible
Budget
Schedule
Review cycle
Target # 3
Action Plan
Person(s) responsible
Budget
Schedule
Review cycle
Contact Person:
Date Completed:
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Smith Corporation IEMS Manual
Rev 1.0 (January 4,2001) Page 25
Conducting an Alternatives Evaluation (P-AE)
[See Module 4 in the IEMS Implementation Guide.]
Purpose
Smith Corporation periodically conducts an alternatives evaluation to identify viable approaches
to reaching an environmental objective. An alternatives evaluation is a tool for identifying
alternative products and/or processes and evaluating them compared to the baseline based on
business and environmental criteria.
Procedure
1. The IEMS coordinator appoints a small group, overseen by a committee member or by
the relevant operations manager, to identify and evaluate alternatives to a particular
activity or process where an alternatives evaluation is required for meeting an
environmental objective.
2. The group first identifies the function that this activity or process performs in Smith
Corporation's operations. The group also characterizes the baseline, or the current
manner in which the function is being carried out.
3. The group then brainstorms alternative ways of accomplishing this function. Potential
alternatives include using a different material or chemical, changing work practices,
and/or changing process technologies. Alternatives are recorded using format AE-01
(similar to Worksheet 4-1 of the IEMS Implementation Guide)., and the most promising
alternatives are assigned to individual members of the group for further research.
4. The group then evaluates the baseline and alternatives based on the following
considerations: operational performance, cost, regulatory implications, and
environmental impact. The group uses formats AE-02 (similar to Worksheet 4-10 of the
IEMS Implementation Guide} to record its findings (and formats AE-03 to AE-06, as
needed).
5. The group makes a recommendation and presents its recommendation to the IEMS
committee and appropriate operations managers.
Frequency
As often as necessary in the context of developing targets and action plans to meet
environmental objectives.
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Smith Corporation IEMS Manual
Rev 1.0 (January 4,2001) Page 26
Records
Formats AE-01 (Alternatives Identification) and AE-02 (Evaluation of Alternatives) are
maintained by the IEMS coordinator, as well as AE-03 to AE-06 to provide, as necessary,
supporting documentation.
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AE-01: Alternatives Identification
Significant Environmental Aspect(s):
Function:
Baseline
Potential Alternatives
Products
Technologies
Work Practices
Recycling/Reuse
Treatment
Disposal
Contact Person:
Date Completed:
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AE-02: Evaluation of Alternatives
Significant Environmental Aspect(s):
Function:
Alternative
Baseline
Performance
Regulatory
Considerations
Cost
Environmental
Effects
Overall Evaluation
Contact Person:
Date Completed:
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AE-03: Evaluation of Environmental Effects
Significant Environmental Aspect(s):
Function:
Alternative
Baseline
Regul
atory
Conce
rn
Chemical and Material Risk —
Effects and Exposure
Workers
Community
Environment
Wor
ker
Safe
ty
Other
Communi
ty
Issues
Natural
Resources
Overall
Ranking
Preferred
Alternative?
(Y/N)
Contact Person:
Date Completed:
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AE-04: Evaluation of Performance
Significant Environmental Aspect(s):
Function:
Alternative
How Well it Works
Time
Ease of Use
Overall Performance
Evaluation
Baseline
Contact Person:
Date Completed:
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AE-05: Evaluation of Regulatory Concerns
Significant Environmental Aspect(s):
Function:
Alternative
Applicable Regulations
Required Controls
Cost of Compliance
Overall Regulatory
Concerns Evaluation
Baseline
Contact Person:
Date Completed:
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AE-06: Evaluation of Costs
Significant Environmental Aspect(s):
Function:
Alternative
Baseline
Raw Material
Labor
Disposal
Total Cost
Savings
Net Cost
Contact Person:
Date Completed:
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Development of Operational Controls (P-OC)
[See Module 6 in IEMS Implementation Guide. Make sure to integrate your process for
developing and documenting operational controls for SEAs into whatever process your
company already has in place for operational controls.]
Purpose
By developing operational control procedures for critical activities (i.e., those activities
associated with SEAs), Smith Corporation intends to mitigate and control, to the extent
possible, the environmental impacts associated with its SEAs.
Procedure
1. The IEMS committee, with additional input from other employees as needed, carries
out a root cause analysis of each SEA to determine the underlying cause(s) of the
environmental impact. As part of the root cause analysis, the committee will
determine the need for (and adequacy of, if already existing) operational control
procedures to control the critical activities related to the SEA in question and record
its findings on format OC-01 (similar to Worksheet 6-1 in the IEMS Implementation
Guide}. The committee, with input from operations managers as needed, will also
select one or more indicators per SEA for purposes of monitoring Smith Corporation's
environmental performance as related to the SEAs.
2. Where there is a need to create or modify an operational control procedure, the IEMS
committee assigns a member of the committee to draft an operational control
procedure, based on consultation with the employees who undertake that procedure.
In many cases, a separate operational control procedure may not be required, rather
the integration of environmental control procedures into an existing procedure. The
operational control procedure should take the form of a "Work Instruction," namely a
summary list of required steps or measures. In addition to describing the steps
necessary to carry out the particular activity in an environmentally sound manner, the
work instruction should also include steps to conduct monitoring, where applicable.
3. After the operational control procedure has been developed and implemented, its
status is recorded as such on format OC-01. The procedure itself enters into the
relevant Smith Corporation operator's handbook and/or is posted at the site of the
activity in question.
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Frequency
As new SEAs are identified. For existing SEAs, a review of the associated root cause
analysis and operational control procedures is conducted yearly.
Records
Format OC-01 (IEMS Operational Control Procedures) is maintained by the IEMS
coordinator. The procedures themselves are maintained in the relevant Smith Corporation
operator's handbook and/or posted at the site of the activity in question.
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OC-01: IEMS Operational Control Procedures
SEA
Indicator(s)
Associated Job
Functions
Existing Operational
Control Procedures
Operational Control
Procedures Development/
Modification Needed
Responsible/
Status
Location
Posted
Contact Person:
Date Completed
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Environmental Training (Awareness and Task-Specific) (P-ET)
[See Modules 6 and 8 in the IEMS Implementation Guide; Module 8 offers a sample format for
tracking training in case your HR staff does not do this already.]
Purpose
To ensure that its employees carry out their duties in as environmentally responsible a manner as
possible, Smith Corporation provides all employees with environmental awareness training on
environmental issues and provides task-specific training to those employees whose jobs are
associated with significant environmental aspects.
Procedure
Awareness Training
1. All new employees receive a 15-minute introduction to the Smith Corporation's IEMS,
specifically its environmental policy, significant environmental aspects, and
environmental objectives. This introduction, which includes an opportunity for the new
employees to ask questions about the IEMS, is given by the human resources (HR)
manager as part of his general orientation for new employees. Records of employees
who have received this introduction are maintained by the HR department.
2. Each year employees are invited to a company picnic. One of the scheduled events for
this picnic is a 15 minute talk by a member of Smith Corporation's IEMS implementation
committee. This person speaks about the environmental accomplishments of the Smith
Corporation, the state of its IEMS, and the goals for the coming year. These remarks
provide an update to the initial IEMS awareness training received by employees.
Task-Specific Training
3. Using the root cause analysis as a tool (see P-OC and format OC-01), the IEMS
committee, working in coordination with the appropriate operations managers, identifies
the job functions that are associated significantly with each SEA.
4. The IEMS committee, in conjunction with the relevant operations manager, then
determines what training employees performing each of these job functions should
receive in order to control actual environmental impacts to the greatest possible extent.
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5. Operations managers are responsible for ensuring that their employees receive the
appropriate task-specific environmental training. Where possible, environmental training
is integrated with other types of training (e.g., operational) that employees are receiving.
The HR manager keeps records of the training received by each employee.
Frequency
Awareness training is given to new employees during their first week at Smith Corporation.
Task-specific training is given to relevant employees as they take on a new function that is
associated with a SEA. Task-specific training is updated, as necessary.
Records
Records of the awareness and task-specific training received by each employee are kept by the
HR manager. The job functions associated with environmentally critical activities (i.e., those
functions that should receive task-specific training) are listed on format OC-01.
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Emergency Preparedness (P-EP)
[Note: this procedure assumes that your company has a general emergency response plan in
place, into which environmental considerations can be integrated.]
Purpose
As part of its IEMS, Smith Corporation strives to ensure that the environmental impacts
associated with any emergency situations are minimized to the greatest extent possible.
Procedure
1. Smith Corporation has an Emergency Response Committee charged with identifying
potential emergency scenarios and developing and ensuring the implementation of
appropriate procedures, should an emergency situation develop.
2. With the assistance of the IEMS coordinator, the Emergency Response Committee a)
identifies the potential negative significant environmental impacts associated with
potential emergency scenarios, b) incorporates measures to minimize these impacts into
emergency response procedures, and c) ensures that adequate training (including
simulations) is provided to appropriate Smith Corporation staff to implement these
procedures.
3. The Emergency Response Committee maintains records of the potential emergency
scenarios it is prepared for, the potential environmental impacts associated with each
scenario, and the procedures established to minimize these impacts. The HR manager
keeps records of training received by staff on implementation of emergency response
procedures.
Frequency
The Emergency Response Committee meets quarterly to review the status of its work.
Records
Records of emergency scenarios, associated potential environmental impacts, and procedures to
mitigate these impacts are kept by the Emergency Response Committee. Training records are
kept by the HR manager.
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Review of New Purchases, Processes, and Products (P-NPPP)
[Note: This procedure will almost certainly need to be substantially modified in order to fit the
situation of your company. Smaller companies may not have a formal new product design or
facilities engineering group, for example. The key is to find a way (that can be documented and
verified, if possible) of ensuring that when new chemicals are being purchased, when new
products are being developed, or when a facility is being substantially modified, environmental
considerations are taken into account. See Module 7, Worksheet 7-1 in the IEMS Implementation
Guide.]
Purpose
When purchasing new chemical supplies, modifying its processes, and making new products,
Smith Corporation strives to ensure that environmental considerations, particularly those related
to SEAs, are taken into account.
Procedure
1. When processing an order for a new chemical or other potentially harmful input, the
purchasing manager clears the purchase with a member of the IEMS committee. The
IEMS committee member initials the box marked "environmental approval" in the New
Purchase Approval Form to signify his or her approval of the purchase.
2. Smith Corporation has a product development group and facilities engineering group.
The product development group develops potential new products that Smith Corporation
could offer (sometimes these are identified by the sales and marketing group, sometimes
they are identified internally). The facilities engineering group is responsible for
reconfiguring (or, in some cases, expanding) the facility's production lines to produce
new products.
3. The product development group notifies a member of the IEMS committee before final
approval of a new product design. The IEMS committee member reviews the design in
light of the facility's SEAs and environmental objectives and targets. When the
committee member is satisfied that the new design is in accordance with the plant's
environmental goals, he initials the appropriate box in the Design Approval Form that is
sent to the president for approval.
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4. The facilities engineering group is responsible for notifying a member of the IEMS
committee before final approval of any Facility Modification or Expansion Plan. (The
Facility Modification or Expansion Plan is required for any facilities engineering job that
costs more than $20,000.) The IEMS committee member reviews the plan in light of the
facility's SEAs and environmental objectives and targets. When the committee member
is satisfied that the new design is in accordance with the plant's environmental
management goals, he initials the appropriate box in the Facility Modification or
Expansion Plan form that is sent to the operations manager for ultimate approval.
Frequency
As new chemicals are purchased, new products are developed, and/or production lines are
modified.
Records
The New Purchase Approval Forms are maintained by the purchasing manager. The Design
Approval Forms are maintained by the product development group. The Facility Modification or
Expansion Plans are maintained by the facilities engineering group.
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Documentation and Document Control (P-D)
[See Module 8 in the IEMS Implementation Guide.]
Purpose
To ensure effective operation of the IEMS, Smith Corporation documents the procedures of its
IEMS and keeps records of the outcomes of IEMS processes, and of the important environmental
issues facing the plant. This IEMS manual comprises this documentation. Documentation is kept
up-to-date.
Procedure
1. The IEMS coordinator documents the procedures that define Smith Corporation's IEMS
in this manual. The IEMS committee formally reviews and, if necessary, revises this
manual on an annual basis. Revised manuals are assigned a new revision number (a
minor set of revisions would change the number from, say, 1.1 to 1.2; a major revision
would change the number from, say, 1.1 to 2.0). Finally, the IEMS coordinator ensures
that no employees or managers use outdated revisions of this manual.
2. The IEMS coordinator maintains updated records of the following outcomes, or results,
of the functioning of the IEMS:
• Environmental policy
• Environmental aspects (EA-01, EA-02, EA-03)
• Applicability of legal requirements to EAs (LR-01); note that copies of the
regulations themselves are maintained by the IEMS management representative
• Significant environmental aspects (SEA-01)
• Objectives, targets, and action plans for environmental management programs (OTP-
01, OTP-02)
• Results of alternatives evaluations (AE-01, AE-02, AE-03 - AE-06)
• List of operational control procedures related to SEAs (OC-01)
• Results of internal assessments (IA-01 and IA-02)
• Corrective actions taken (TCA-01)
• Management reviews (MR-01)
These items are described in more detail in the relevant procedures in this manual.
3. The IEMS coordinator is not responsible for maintaining records of environmental
training and emergency response preparations; the operational control procedures
themselves; or the New Purchase Approval Forms, the Design Approval Forms, or the
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4. Facility Expansion or Modification Plans. These records are maintained by the
appropriate person or group, as specified in the relevant procedures of this manual.
Frequency
Manual review and revision on an annual basis.
Records
Maintained as outlined in the procedure.
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Conducting a Compliance Assessment (P-CA)
[See Module 7 in the IEMS Implementation Guide.]
Purpose
Smith Corporation conducts a periodic compliance assessment to ensure that it complies
with all applicable local, state, and federal environmental regulations.
Procedure
1. The IEMS management representative maintains copies of applicable legal
regulations, which are summarized on format LR-01. Based on these regulations, the
IEMS management representative and coordinator compile a list of questions as an
compliance assessment protocol. These questions are intended to be sufficient to the
compliance status of Smith Corporation with respect to applicable environmental
regulations (both the paperwork and the performance-related components).
2. The IEMS coordinator and another operations manager carry out the assessment by
determining and recording the answers to the compliance assessment protocol.
When they are done with the compliance assessment, they note any actual or
potential compliance issues on format CA-01 (Compliance Tracking Log). Each
actual and potential compliance issue is immediately referred to corrective action
(see the Taking Corrective Action procedure, P-TCA).
Frequency
Monthly.
Records
Compliance assessment results are recorded by the internal assessment team using the
compliance assessment protocol and using format CA-01. Records are maintained by the
IEMS coordinator.
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CA-01: Compliance Tracking Log
Person
Responsible
Regulation
Root Cause
Compliance
Check Date
Results
Corrective
Action/Date
(see: TCA-01)
Compliance
Verified/Date
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Conducting an Internal Assessment (P-IA)
[See Module 9 in the IEMS Implementation Guide.]
Purpose
Smith Corporation conducts periodic internal assessments of its IEMS to ensure that it is being
implemented and operated according to the procedures laid out in this manual.
Procedure
1. At intervals, a team of two or three operations managers or employees, who are not on
the IEMS committee, conducts an internal assessment of Smith Corporation's IEMS.
The assessment team uses this manual as the basis for its assessment. In particular, the
assessment team checks to make sure that:
• Each procedure is being carried out as stated in this manual
• Smith Corporation's environmental policy is being upheld
• Progress is being made in meeting the environmental objectives
The assessment team bases its evaluation on objective evidence, including documentation
and records (e.g., those cited in this manual), interviews with key employees, and
observations. Note that this is not a compliance audited
2. The assessment team completes the checklist on format IA-01 and writes up its findings
using format IA-02. A "major non-conformity" occurs when an IEMS procedure is
clearly not being implemented, when one of the commitments in the policy is not being
upheld, or when no progress is being made in achieving an environmental objective; a
"minor nonconformity" occurs when a procedure is being implemented inconsistently,
yet without causing major failings in the IEMS as a whole.
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3. Each non-conformity is immediately referred to corrective action (see the Taking
Corrective Action procedure, P-TCA).
4. Records of each assessment (i.e., formats IA-01 and IA-02) are maintained by the IEMS
coordinator.
Frequency
At least two times per year.
Records
Assessment results are recorded by the internal assessment team using formats IA-01 and IA-02
(Internal Assessment Checklist and Internal Assessment Record). Records are maintained by the
IEMS coordinator.
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IA-01: Internal Assessment Checklist
Internal Assessment Team:
Date of Internal Assessment:
Signed:
IEMS Procedures:
Check each item assessed (includes auditing of records, where applicable):
Environmental policy (adherence to policy commitments)
Environmental objectives (progress; implementation of action plans)
IEMS responsibilities (RESP-01)
Identification of Environmental Aspects (P-EA)
Identification of Legal Requirements (P-LR)
Identification of Significant Environmental Aspects (P-SEA)
Development of Objectives, Targets, and Action Plans (P-OTP)
Conducting an Alternatives Evaluation (P-AE)
Development of Operational Controls (P-OC)
Environmental Training (Awareness and Task-Specific) (P-ET)
Emergency Preparedness (P-EP)
Review of New Products and Processes (P-NPP)
Documentation (P-D)
Conducting a Compliance Assessment (P-CA)
Conducting an Internal Assessment (P-IA)
_ Taking Corrective Action (P-TCA)
Management Review (P-MR)
IEMS Performance
Achieved objective #1
Achieved objective #2
Achieved objective #3
Contact Person: Date Completed
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IA-02: Internal Assessment Record
Internal Assessment Team
Date of Internal Assessment
Signed
Major Non-Conformities Observed
1.
2.
3.
Minor Non-Conformities Observed
1.
2.
3.
Is Smith Corporation making progress in meeting its IEMS objectives?
Is Smith Corporation adhering to the commitments in its environmental policy?
Suggestions for Improving the IEMS
Contact Person: Date Completed:
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Taking Corrective Action (P-TCA)
[See Module 9 in the IEMS Implementation Guide.]
Purpose
Smith Corporation uses a formal corrective action process to ensure that actual or potential
compliance issues and IEMS non-conformities are addressed quickly and effectively.
Procedure
1. The management representative assigns responsibility for taking action to correct each
actual or potential compliance issue or non-conformity identified in a compliance
assessment or an internal assessment (see P-CA and P-IA, respectively) to an appropriate
manager or employee. Together they fill out the "Statement of the Problem" part of the
Corrective Action Notice (format TCA-01; similar to Worksheet 7-7 in the IEMS
Implementation Guide).
2. The person responsible then undertakes the corrective action required, calling upon the
management representative, the IEMS committee, and others for assistance as necessary.
3. The responsible person and the management representative fill out the "Completion of
Corrective Action" part of the Corrective Action Notice when corrective action is
complete.
Frequency
Whenever significant problems in the functioning of the IEMS are identified, primarily through
the internal assessment process.
Records
Corrective action is recorded using format TCA-01; records are maintained by the IEMS
coordinator.
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TCA-01: Corrective Action Form
Statement of the Problem
Date
Description of non-conformity or actual or potential compliance issue
Description of potential solution
Person responsible for corrective action
Deadline for completion of corrective action
Completion of Corrective Action
Actions taken
Results
Date
Signed:
Management Representative Person Responsible
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Communication with Stakeholders (P-CS)
[See Module 8 in IEMS Implementation Guide.]
Purpose
To ensure that interested external stakeholders receive appropriate information about the
company's environmental activities, Smith Corporation has developed a company policy for
considering and, where appropriate, responding to queries, comments, or complaints from
stakeholders.
Procedure
1. The IEMS committee identifies stakeholders and their potential interests in the
environmental performance of Smith Corporation using format CS-01, Stakeholders and
Environmental Issues. If the committee decides that proactive communication on
environmental issues is necessary with any group, that decision is recorded on CS-01 and
responsibility is designated.
2. When any form of communication is received regarding Smith Corporation's
environmental performance or management from a stakeholder, that communication is
immediately forwarded to the IEMS management representative.
3. The IEMS management representative considers the nature of the communication and
makes a decision on whether and how to respond to it based on the guidance below and
on the more specific guidance in CS-01. The IEMS management representative is
responsible for maintaining records of each such communication and response using
format CS-02, Stakeholder Communication Record. Where internal actions are necessary
to address the communication, this is noted on CS-02 and a Corrective Action Form
(TCA-01) is initiated.
Guidance for Communicating with Stakeholders on Environmental Issues: Smith
Corporation's environmental policy is available to all stakeholders upon request. Smith
Corporation will do its best, however, to respond in kind to all good-faith
communications from stakeholders about environmental issues, including complaints,
comments, and information requests. However, Smith Corporation may not choose to
respond in all cases, particularly if the request is made in bad faith or if sensitive
information is requested.
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Frequency
As per environmental communication.
Records
Records of environmental communications from stakeholders and Smith Corporation's responses
are kept by the IEMS management representative and are tracked using format CS-02. An
updated version of CS-01, Stakeholders and Environmental Issues, is kept in this manual.
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CS-01: Stakeholders and Environmental Issues
Stakeholder
Potential Environmental Interest
Proactive Communication Plan
(if desired)
Person
Responsible
Contact Person:
Date Completed:
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CS-02: Stakeholder Communication Record
Date Communication Received
Type of Communication
Received From
Address/Telephone Number/
E-Mail
Content of Communication (attach copy if possible)
Will Smith Corporation Respond?
Date of Response
Person Responding
Position
YES NO
Nature of Response (attach copy if possible)
Are Internal Actions Necessary? (If Yes, fill out a Corrective Action Form.)
Contact Person:
Date Completed:
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Management Review (P-MR)
[See Module 9 in the IEMS Implementation Guide.]
Purpose
To ensure the effectiveness of the IEMS and its continual improvement, Smith Corporation top
management periodically reviews the important elements and outcomes of the IEMS.
Procedure
1. In preparation for the management review, the IEMS management representative gathers
the following information and makes it available to top plant management, including the
owner and President of Smith Corporation and the plant manager:
• Environmental policy
• List of IEMS committee and others responsible for major parts of the IEMS (RESP-
01)
• List of significant environmental aspects and criteria of significance (SEA-01)
• Update on compliance status of the plant and on any potential upcoming regulations
that might require an advance strategy
• List of environmental objectives and targets (OTP-01 and OTP-02)
• Environmental performance results (from monitoring and measuring SEA indicators
and indicators of progress toward environmental objectives and targets)
• Bullet-point description of other accomplishments of the IEMS (e.g., number of
people trained, etc.)
• Results of most recent IEMS internal assessment (IA-02), compliance assessment
(CA-01), and corrective actions taken
• Description and documentation of feedback from stakeholders (if received)
• Analysis of the costs and benefits of the IEMS (as quantitative as possible)
2. Top plant management meets to review and discuss the information presented. The IEMS
management representative and coordinator will also be present. Depending on its
review, top management may direct specific and/or significant changes in the scale and
direction of the IEMS in order to improve its effectiveness and business value. The
conclusions and directives that result from the management review are recorded using
format MR-01 and kept by the IEMS coordinator.
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Frequency
Quarterly.
Records
Results of management reviews are recorded using format MR-01. Records are kept by the
IEMS coordinator.
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MR-01: Management Review Record
Date of review meeting
Persons present at meeting
Name
Position
Conclusions
Actions to be taken
Person(s) responsible
Signed:
Management Representative
Plant Manager
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