v>EPA
United States
Environmental Protection
Agency
Office Of Water
(4204)
EPA 832-B-96-007
November 1996
Environmental Management
Systems
An Implementation Guide For
Small And Medium-Sized
Organizations
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Environmental Management Systems:
An Implementation Guide for
Small and Medium-Sized Organizations
Environmental
Policy
Management
Review
Continual
Improvement!
Checking /
Corrective Action
NSF International
Ann Arbor, Michigan
November 1996
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Environmental Management Systems:
^ \ '
An Implementation Guide for Small and Medium-Sized Organizations
Written by:
Philip J. Stapleton, Principal
Gloyer-Stapleton Associates, Inc.
Anita M. Cooney, Project Manager
NSF International
William M. Hix Jr., Intern
NSF International
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Acknowledgments
This document was prepared with funding through a cooperative agreement with the U.S.
Environmental Protection Agency's Office of Wastewater Management and Office of Compliance.
NSF International gratefully acknowledges the following Steering Committee Members for their
invaluable contributions to the design and content of this Guide:
Jeffrey R. Adrian, The John Roberts Company
Lemuel D. Amen, Washtenaw County Department of Environment & Infrastructure Services
Stephen P. Ashkin, Rochester Midland
Christine A. Branson, industrial Technology Institute
Ken Burzelius, Midwest Assistance Programs, LeSueur County
Marci Carter, Iowa Waste Reduction Center, University of Northern Iowa
John Dombrowski, U. S. Environmental Protection Agency - Office of Compliance
David Fiedler, Michigan Department of Environmental Quality - Environmental Assistance Div..
Jim Home, U. S. Environmental Protection Agency - Office of Wastewater Management
Wendy Miller, U. S. Environmental Protection Agency - Office of Compliance
Charles Tellas, Milan Screw Products
Bryant Winterholer,. K.J. Quinn & Co., Inc.
The authors of this Guide would .like to thank Douglas Baggett of Hach Company, arid Charles Tellas
of Milan Screw Products, Inc., for sharing their experience and insight via case studies of their
respective companies.
The authors of this Guide would also like to thank Craig Diamond and Tom Ambrose of NSF
International for their significant contributions to the development of this Guide. Your suggestions and
assistance were greatly appreciated.
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Environmental Management Systems: An Implementation Guide for Small
and Medium-Sized Organizations
CONTENTS
* ' r ..'.
Introduction : 1
Section 1: Why Your Organization Should Have an EMS 3
Section 2; Key EMS Concepts 6
Sections: Step-by-Step Action Plan 8
Section 4: Key Elements of an EMS ..;..-.' -. --11
Sections: The Registration Process ......56
Section 6: Sources of Assistance 63 '
Appendices
Appendix A - Case Studies
Milan Screw Products 65
Hach Company '......, ...........70
Appendix B - Background on ISO 14000 and Other EMS Standards ,.-75
Appendix C - Sources of Information and Other Contacts ....:..80
Glossary of Acronyms 89
Bibliography - - .........90
Appendix D - Tool Kit
s Sample Environmental Policies. -92
Sample Process Flowchart > 96
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Ill ill ll II
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CONTENTS (cont'd.)
Descriptions of Environmental Aspect Identification Techniques 98
Sample Procedure: Environmental Aspects Identification.. -100
Resources for Tracking Environmental Laws and Regulations .....104
v. .
Sample Procedure: Tracking Environmental Laws and Regulations...............: 106
Worksheet: Setting Objectives and Targets 109
Sample Procedure: Setting Objectives and Targets..... 113
Sample Tool: Environmental Management Program 116
Sample Schedule for EMS Action Plan .-. ...,ป.... > 118
'''" ' '"-:"''- : 19O
Responsibility Matrix........ - '""
Environmental Training Log..... .. 123
Sample Procedure: Internal Communications ............................................125
Sample Procedure: Communications with External Parties 128
Sample Document Index. .'. 131
Outline of Sample EMS Manual, Other Documents 133
Sample Procedure: Document Control.... .......7. ....; 135
Sample Procedure: Corrective Action (Includes Tracking Log). 139
Environmental Records.Organizer 144
Sample Procedure: EMS Audits - 148
Sample Procedure: Management Review....... 154
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Introduction
This Guide is intended to support and facilitate the development of environmental
management systems (EMS) among small and medium-sized organizations. The Guide
explains how you can develop and implement an effective EMS and how it can support your
organization's mission and goals. Development of an EMS is a voluntary .approach to
improving your organization's environmental performance.
The Guide is designed primarily for use by EMS implementers the people within a small
or medium-sized organization that will lead the EMS development effort. The heart of the
Guide is found in Section 4, "Key Elements of an EMS." For each of the recommended EMS
elements, this section discusses the importance of the element, how you can get started, and
some key suggestions for implementation. In addition, examples of how other organizations
have addressed various EMS elements are provided in Section 4.
The Guide uses the ISO 14001 Standard as a model for an EMS. The ISO 14001 Standard
is the widely accepted official international standard for environmental management systems.
This Guide is not intended for use by registrars (or others) for registration purposes, nor is it
intended to provide specific interpretation of the ISO 14001 Standard.
How this Guide is Organized
Section 1
Section 2
Section 3
Section 4
Sections
Section 6
Appendices
Describes the many benefits of an EMS and how it can help your
organization to compete and prosper in today's global marketplace.
Summarizes the overall management systems concepts. This section
explains what a management system is and how it can support your
organization's mission.
Describes the overall process for building an EMS and provides '
recommendations for planning the overall EMS development effort.
Provides detailed guidance on how"your EMS shojjld be designed and
implemented. This section discusses each of the Key elements of an EMS
and how you can put them in place. ,
f ~ " -'''", ' , " - '
Describes the proce'ss for registering an EMS and selecting a registrar.
Discusses other sources of assistance your organization can use to build
and sustain its EMS.
Provide case studies, sample environmental policies, other sources of
information, and information on EMS standards. In addition, the Tool Kit
provides sample EMS procedures and other tools that your organization
can tailor to fit its EMS needs. The sample procedures are adapted from
actual EMS procedures used by other companies that have implemented an
EMS. '
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Introduction (cont'd.)
Use of Icons
A variety of icons are used in this Guide to highlight key concepts and suggestions for the
reader. A few of these icons include:
The light bulb is used to highlight EMS examples and experiences from small and medium-
sized organizations. It is also used to indicate that additional help is provided in the Tool Kit
or available from other sources.
The hand is used to point out key hints for implementing EMS elements.
The speech balloon is used to indicate Quotes from representatives of organizations that have
implemented an EMS (as well as definitions from the ISO 14001 Standard),
2
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Section 1: Why Your Organization Should Have an EMS
This section explains why ah EMS can help your organization
to compete and prosper in today's global market.
A systematic approach to
meeting your
environmental and
business goals
Key EMS Benefits
- improved environmental
performance
- reduced liability
- competitive advantage
- improved compliance
- reduced costs
- fewer accidents
- employee involvement
- improved public image
- enhanced customer trust
better access to capital
' "We view the
establishment of an
EMS as a process
that forces us to
. better organize our
priorities and
projects and to.
identify problems
and exposures
before they occur."
- K.J. Quinn &Co.
(A small specialty
chemical company)
Is your organization required to comply with
environmental laws and regulations?
Are you looking at ways to improve your overall
environmental performance?
Is the state of your organization's environmental
affairs a significant liability?
Does a lack of time or resources prevent your
organization from taking charge of its environmental
obligations?
Does your organization know how its environmental
objectives relate to its business objectives?
If you answered YES to one or more of the above
questions, an environmental management system
(EMS) can help your organization and so will
this Guide!
As one of your organization's leaders, you know that
interest in environmental protection and sustainable
development is growing. Like many others, your
organization may be increasingly challenged to
demonstrate its commitment to the environment.
Implementing an EMS can help in a number of
important ways.
First, an effective EMS makes good business
sense. By helping'you identify the causes of
environmental problems (and then eliminate them),
an EMS can help you save money. Think of it this
way: ,
Is it better to make a product right the first time or
to perform a lot of re-work later?
' Is it cheaper to prevent a spill in the first place or
clean it up afterwards?
Is it more cost-effective to prevent pollution or to
manage it after it has been generated?
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"We found that an
EMS could improve
employee retention,
new hire selection,
working conditions,
and the perceptions
of our customers,
suppliers, lenders,
neighbors, and
regulators."
;',( , !:'i;:;, ,> Milan Screw Products
(A 32-person manufacturer of
precision fittings)
,.:. .. ,',*: ,
Second, an EMS can be an investment in long-
term viability of your organization. An EMS will help
you to be more effective in achieving environmental
goals. And, by helping businesses to keep existing
customers and attract new ones, an EMS adds
value.
Much of what you need for an EMS may already be
in place! The management system framework
described in this Guide contains many elements that
are common to managing other business
processes, such as quality, health & safety, finance,
or human resources. As you review this Guide, you
may find that you already have many EMS
processes in place, but for other purposes (such as
quality). Integrating environmental management with
other key business processes can improve the
organization's financial and environmental
performance.
The key to effective environmental management is
the use of a systematic approach to planning,
controlling, measuring and improving an
organization's environmental efforts. Potentially
significant environmental improvements (and cost
savings) can be achieved by reviewing and
improving your organization's management
processes. Not all environmental problems need to
be solved by installing expensive pollution control
equipment.
Of course, there is some work involved in planning
and implementing an EMS. But many organizations
have found that the development of an EMS can be
a vehicle for positive change. These organizations
believe that the benefits of an EMS far outweigh the
potential costs (see next page). As they say in the
Tptaj Quality Management (TQM) world, "quality is
freeป _ as |Ong as you are willing to make the
investments that will let you reap the rewards. The
same holds true for environmental management:
Want to know more about EMS costs and benefits?
Read on...
4
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Costs and Benefits of Developing and Implementing an EMS
COSTS
Staff / employee time
Possible consulting assistance
Training of personnel
BENEFITS
Improved environmental performance
Improved compliance
New customers /markets
Increased efficiency / reduced costs
Enhanced employee morale
Enhanced image with public
Reduced training effort for new employees
Enhanced image with regulators
If your organization already has or is considering
a quality management system (such as ISO 9000),
;you will find some significant synergy between what
you need for quality management and for
environmental management. ,
Some Common Aspects of Quality and Environmental Management Systems
Quality Policy
Adequate Resources
Responsibilities and Authorities
Training
System Documentation
Process Controls.
Document Control
System Audits .
Management Review
Environmental Policy
Adequate Resources
Responsibilities and Authorities
Training
System Documentation
Operational Controls
Document Control
System Audits .
Management Review
One final note: Small and medium-sized
organizations often have some advantages over
larger organizations in ensuring effective
environmental management. In smaller
organizations, lines of communication are generally
shorter, organizational structures are less complex,
people often perform multiple functions, and access
to management is simpler. All of these can be real
advantages for effective environmental management.
Are you interested in learning more about how an
EMS can help your organization? If so, let's look
at some key management systems concepts and
how they are applied in the environmental area.
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Section 2: Key EMS Concepts
This section explains what a management system is
and how it can help your company.
The focus on
qualify principles
Definition of an EMS:
A continual cycle of planning,
implementing, reviewing and
improving the actions that an
organization takes to meet its
environmental obligations.
^Continual Improvement^
Enhancing your EMS
to better your overall
environmental
performance.
An effective EMS
doesn't fust happen.
An effective'EMS
nsedfs ongoing
"* management support.
You have probably heard of total Quality Management
(TQM). Your organization may apply TQM principles to
some or all of its operations and activities.
An effective EMS is built on TQM concepts. To improve
environmental management, your organization needs to
focus not only on what things happen but also on why
they happen. Over time, this systematic identification
and correction of system deficiencies leads to better
environmental (and overall business) performance.
Most EMS models (including the recently issued ISO
14001 Standard, which will be described later) are built
on the "Plan, Do, Check, Act" model introduced by
Shewart and Deming. this model endorses the concept
of continual improvement.
Figure 1
In the ISO 14001 EMS Standard, these "plan, do, check,
act" steps have been expanded into seventeen EMS
elements. Each element is discussed in Section 4 of
this Guide.
Putting TQM principles into practice in the environmental
area is the job of top management. To build and
sustain, an effective EMS, management must
communicate to all employees the importance of:
making the environment an organizational priority
(thinking of effective environmental management as
fundamental to the organization's survival)
building environmental management in
everywhere
(thinking about the environment as part of product and
process development, among other activities)
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looking at problems as opportunities
(identifying problems, determining root causes and
preventing their recurrence)
Flexible + simple =
adaptable -{understandable
Employee involvement
, is crucial
Regulators have begun to ^
incorporate management
system concepts into
. regulatory programs (for
example, OSHA's Process
Safety Management
Standard and EPA's
Risk Management Program
for Chemical Accidental
Release Prevention ).
The concept of continual improvement recognizes that
problems will occur. But a committed organization
learns from its mistakes and prevents similar
problems from occurring in the future.
An effective EMS must be dynamic to allow your
organization to adapt to a quickly changing business
environment. For this reason, you should keep your
EMS flexible and simple. This also helps make your
EMS understandable for the people who must
implement it you and your organization's
employees.
As you build and implement an EMS, some
roadblocks may be encountered. Some people in the
organization may view an EMS as bureaucracy or
extra expense an "add-on" to what you do now.
There may be resistance to change or fear of new
responsibilities. To overcome these potential
roadblocks, make sure that everyone understands
why the organization needs an effective EMS and.
how an EMS will help you control environmental
impacts in a cost-effective manner. Getting people
involved in designing and implementing the EMS will
demonstrate the organization's commitment to the
environment and help to ensure that the EMS is
realistic, practical and adds value.
Building or improving your EMS (with the help of this
Guide) is a great opportunity to assess how your
organization manages environmental obligations and
to find better (and more cost-effective) solutions.
While you will probably identify some areas where
your current EMS can be improved, this does not
mean that you should change things that are working
well ! By reviewing what your organization does and
how well it works, you can ensure that your EMS will
be viable and effective, both now and in the future.
Don't get discouraged if your system has some bugs
at first this is to be expected. Remember, the focus
is on continual improvement \
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Section3: Step-by-Step Action Plan
This section explains the process of building an EMS.
Putting the theory of
EMS into practice
JxSt
teps to Consider
Gain management
commitment
Choose a champion
Prepare budget and
schedule
Build cross-functional
team
Involve employees
Conduct preliminary
review
Modify plan
Prepare procedures /
other documents
Plan for change
Train employees
Assess performance
Milan Screw Products
found that the use of a
cross-functional group
(the environmental task
group) was the key to
progress in evaluating
and implementing their
EMS. Participation of
shop floor employees is
essential in successfully
implementing an EMS.
K.J. Quinn & Company
found that it could perform
a initial seltessessment of
its environmental programs
In 20-25 hours.
Building an EMS might sound like an overwhelming task
for a small organization, but it need not be. Time and
other resources are limited in any small organization, so it
is important that your resources are Used wisely. One
way to do this is by following a simple, effective plan.
Fortunately, you can build on the experiences of other
organizations who have already implemented an EMS.
Examples are provided throughout this Guide.
Figure 2 illustrates some key steps in the EMS building
process. The importance of careful planning cannot be
overemphasized. Taking the time to figure out what you
need to do, how you will do it, and which people must be
involved will pay big dividends down the road.
Using a team approach for buildingjfour EMS is a good
way to improve commitment ana ensure that the
objectives, procedures and other system elements are
realistic, achievable, and cost-effective. Ideas for using
your team and involving employees are discussed on the
following pages.
A few hints to keep in mind as you build your EMS:
. Help is available don't hesitate to use it.
(See Section 6 of this Guide for more on resources.)
Consultants can provide help in evaluating your EMS
and suggesting approaches used successfully
elsewhere. Look for ways to hold consulting costs
down. For example, you may be able to join forces
with other small businesses in your area to hire a
consultant.
Some Thoughts on the Use of Consultants
Assess your own in-house resources first.
Make sure both parties understand the scope of
work.
Get references and check them. Look for
consultants with experience in small business and
your specific industry.
Use consultants to gain insights on approaches used
by other companies.
An EMS developed by consultants "in isolation will
not work. Your own people need to be involved in
the process.
Look at your existing environmental compliance plans
and programs to assess how effective they have
been and how they might be improved.
8
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Figure 2
(i) Obtain
Management
Commitment
2) Choose
a Champion
Creating Your Own EMS: Key Steps
The first step in the EMS-building process is gaining
top management's commitment to supporting the EMS.
Management must understand the benefits of an EMS
and what it will take to put an EMS in place.
Management commitment and vision should be clear
and communicated across the organization.
Not all small or medium-size organizations have the
luxury of choosing among multiple candidates, but your
choice of project champion is critical. The champion
should have the necessary authority, an understanding
of the organization, and project management skills.
The champion should be a "systems thinker" (some
ISO 9000 experience would be a plus, but is not
necessary) and must have the time to commit to the
EMS-building process. ..'-,'
^3) Prepare
Budget and
Schedule
Build
Project
Team
The project champion should prepare a preliminary
budget and schedule for developing the EMS. Costs
will likely include staff and employee time, training,
Some consulting assistance, materials, and possibly
some equipment (such as a computer or word
processor). The schedule should consider the various
tasks described below, among others.
A team with representation from key management
functions and production or service areas can identify
and assess issues, opportunities, and existing
processes. You may want to consider including
contractors, suppliers, and other external parties to be
part of the project team where appropriate. This team
will need to meet frequently, especially in the early
stages of the project. The cross-functional team can
help to ensure that procedures are reasonable and wi|l
build commitment to the EMS.
Employees are a great source of knowledge on
environmental and health & safety issues related to
their areas as well as on the effectiveness of current
processes and procedures. They can help the project
team in drafting procedures. Employee ownership of
the EMS will be greatly enhanced by meaningful
employee involvement in the EMS development
process,
more
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Figure 2 (cont'd.)
(j) Conduct
Preliminary
Review
2) Modify
Plan
(7) Prepare
Procedure &
Documents
(9) Plan for
Change
(M) Assess
EMS
Performance
Creating Your Own EMS (cont'd.)
The next step is to conduct a preliminary review of
your current environmental programs and system and
compare these against the criteria for your EMS (such
as ISO 14001). Evaluate your organization's structure
and its procedures, policies, environmental impacts,
training programs, and other factors. Determine which
elements of your current system are in good shape and
which need additional work.
The project plan might need to be modified based on
the results of the preliminary review. The modified
plan should describe in detail the key actions needed,
who will be responsible, what resources are needed,
and when the work will be completed.
At this point, you are ready to develop procedures
and other system documents. In some cases, this
might involve modifying existing environmental
procedures or adapting other business procedures
(such as quality or health & safety management
procedures) for EMS purposes. In some cases, you
might need to develop new procedures. Get help from
employees and the cross-functional team, as
discussed above.
In building your EMS, make sure that the system is
sufficiently flexible. While you will likely need to
modify your EMS over time, try to avoid making your
EMS so rigid that you must change it frequently to
reflect the realities of your operation.
Once the procedures and other documents have been
prepared, you are ready to implement the EMS. As a
first step, train your employees on the EMS, especially
with regard to the environmental impacts of their
activities, any new / modified procedures, and any new
responsibilities.
After the EMS is up and running, be sure to assess
system performance. This will be accomplished
through periodic EMS audits and ongoing monitoring
and measurement. Assessment of EMS performance
provides the opportunity to improve the system and
your environmental performance over time.
10
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Section 4: Key Elements of an EMS
This section provides guidance on how to build and implement an EMS.
As mentioned earlier, your EMS should be built on the "Plan, Do, Check, Act" model to ensure that
environmental issues are systematically identified, controlled, and monitored. Using this approach
will help to ensure that performance of your EMS improves over time.
This section describes seventeen EMS elements included in the ISO 14001 Standard. While there are
several good EMS models available, this Guide uses the ISO 14001 Standard as a starting point for
describing EMS elements for several reasons:
ISO 14001 is a widely accepted international Standard for EMS;
ซ Companies may be asked to demonstrate conformance with ISO 14001 as a
condition of doing business in some markets; and
The Standard is consistent with the key elements found in most EMS models.
Management
Review
Environmental
Policy
Checking /
Corrective Action
Monitoring and Measurement
Nonconformance and Corrective
and Preventive Action
Records
EMS Audits
Continual
Improvement'
Planning
Environmental Aspects
Legal/ Other Requirements
Objectives and Targets
Environmental
Management Program
Implementation
Structure and Responsibility
Training, Awareness, Competence^
Communication
EMS Documentation
Document Control
ป Operational Control
> Emergency Preparedness^
/ Response
11
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Elements of an ISO 14001 EMS: A Snapshot
Environmental policy Develop a statement of your organization's commitment
to the environment. Use this policy as a framework for planning and action.
Environmental aspects Identify environmental attributes of your products,
activities and services. Determine those that could have significant impacts on the
environment.
Legal and other requirements Identify and ensure access to relevant laws
and regulations (and other requirements to which your organization adheres).
Objectives and targets Establish environmental goals for your organization, in
line with your policy, environmental impacts, views of interested parties and other
factors.
Environmental management program Plan actions to achieve objectives and
targets.
Structure and responsibility Establish roles and responsibilities and provide
resources.
Training, awareness and competence Ensure that your employees are
trained and capable of carrying out their environmental responsibilities.
Communication Establish processes for internal and external communications on
environmental management issues.
EMS documentation Maintain information on your EMS and related documents.
Document control Ensure effective management of procedures and other
system documents. ,
Operational control Identify, plan and manage your operations arid activities in
line with your policy, objectives and targets.
Emergency preparedness and response Identify potential emergencies and
develop procedures for preventing and responding to them.
Monitoring and measurement Monitor key activities and track performance.
Nonconformance and corrective and preventive action Identify and
correct problems and prevent recurrences.
Records Keep adequate records of EMS performance.
EMS audit Periodically verify that your EMS is operating as intended.
Management review Periodically review your EMS with an eye to continual
improvement.
12
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How Does the ISO 14001 Standard Support Environmental Compliance?
ISO 14001 requires an organization to:
develop an environmental'policy with a commitment to compliance;
have a procedure for identifying and having access to environmental laws and
regulations;
set objectives and targets that are in line with its environmental policy (which includes a
commitment to compliance);
establish operational control procedures; .
ซ establish procedures for emergency preparedness and response;
establish a procedure for periodically evaluating compliance ...
/ \
While these requirements relate directly to an organization's compliance management, each
of the seventeen elements of the ISO 14001 Standard can contribute to enhanced
compliance (e.g., communication, training, documentation, records, nonconformance and
corrective / preventive action, EMS audits, management review, etc.). An EMS based on the
ISO 14001 Standard can complement and improve your organization's compliance
management and help your organization to meet objectives and .targets that go "beyond
compliance." An EMS based on the ISO 14001 Standard can also help your organization to
meet objectives and targets that address issues that are not subject to regulation.
If you would like to order a copy of the actual ISO 14001 Standard, please contact one of
the authorized sources (see Annex C - page 88 for additional information).
The following is a overview of each of the 17 elements of the ISO 14001 Standard in
greater detail...
13
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Environmental Policy
Why do we need an environmental policy?
What is my
organization's
commitment to the
environment?
Continual
Improvement:
"Process of enhancing
the environmental
management system to
achieve Improvements in
overall environmental
performance In line
with the organization's
environmental policy"
- ISO 14001
An environmental policy is your management's
declaration of commitment to the environment. The
policy should serve as the foundation for your EMS
and provide, a unifying vision of environmental
concern by the entire organization.
Your policy should be more than just flowery prose.
Since it serves as the. framework for setting
environmental objectives and targets, the policy should
be brought to life in your plans and deeds.
Everyone in the organization should understand the
environmental policy and what is expected of them in
order to achieve the organization's objectives and
targets.
Your policy should contain three key commitments (see
box, below), including a commitment to continual
improvement. This doesn't mean that you must
improve in all areas at once, but that the policy should
drive your overall efforts to continually improve your
organization's environmental management.
Sample environmentalpolicies (which contain the three
key policy commitments) are provided in the Tool Kit
(see page 92).
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Key Policy
Commitments
- Continual improvement
- Pollution prevention
- Compliance with relevant
laws and regulations
Hints:
Your organization probably has an environmental
policy now, even if it's not written. For example, your
; organization is probably committed to complying with
the law and avoiding major environmental problems,
at a minimum. Document your existing commitments
as a starting point.
Your policy should be related to your products and
services, as well as supporting activities. Consider
the results of your preliminary review before
finalizing the policy. Also, make sure the policy
reflects the environmental aspects of your products,
services and activities (as described in the next
section).
Keep your policy simple and understandable. Ask
yourself: What are we trying to achieve? How can I
best communicate this to the rest of the
organization? Will we do what we said we would?
Keep in mind that your policy should be explicit
enough to be auditable.
14
-------
Review: Have we ...
developed a written
policy?
considered our key
products, activities,
and services?
addressed the three
key commitments?
effectively
communicated the
policy?
The policy can be a stand-alone document or it can be
integrated with your health & safety, quality, or other.
organizational policies.
Consider who should be involved in developing
the policy and the best process for writing it. Input
from a range of people in your organization should
increase commitment and ownership.
Make sure that your employees understand the
policy. Options for communicating your policy
internally include posting it around the site (e.g., in the
lunch room), paycheck stuffers, incorporating the
policy into training classes and materials, and
references to the policy at staff or all-hands meetings.
Test awareness from time to time by asking
employees what the policy means to them.
The'policy should also be communicated externally.
Options for external communication include business
cards, newspaper advertisements and annual reports,
among other options. You can choose to
communicate the policy proactively or in response to
external requests.
Environmenta
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Three Pillars
of an
Environmental
Policy
15
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Identifying Environmental Aspects
How does my organization interface with the environment?
/Environmental Aspect:
"Element of an
organization's
activities, products, or
services that can
interact with the
environment"
ISO 14001
/^Environmental Impact:
'Any change to the
environment, whether
adverse or beneficial,
wholly or partially
resulting from an
organization's activities,
products, or services."
)efine
environmental
aspects
Decide if under
your control andL
influence
dentify related^
environmental
Decide if the
impacts are
significant
To plan for and control its significant environmental
impacts, an organization must first know what these
impacts are. But knowing what the impacts are is only
part of the challenge you also should* know where
these impacts come from.
If your organization has undertaken pollution prevention
projects, you are probably familiar with this concept
you must know how a waste is generated in order to
minimize or eliminate ft. As with pollution prevention, the
identification and management of environmental aspects
can (1) have positive impacts on the bottom line and (2)
provide significant environmental improvements.
Your EMS should include a procedure to identify the
environmental aspects that your organization:
can control, and
over which it can have an influence.
The relationship between aspects and impacts is one
of cause and effect. The term "aspects" is neutral, so
keep in mind that your environmental aspects could be
either positive (such as making a product out of
recycled materials) or negative (such as discharge of
toxic materials to a stream).
Your organization is not expected to manage issues
outside its sphere of influence. For example, while your
organization probably has control over how much
electricity it uses, it likely does not-control the way in
which the electricity is generated.
Once you have identified the environmental aspects of
your products, activities, and services, you should
determine which aspects, could have significant impacts
on the environment. These environmental aspects
should be considered when you set your'environmental
objectives and define your operational controls (as
discussed later).
A multi-step process (see figure at left) can be used to
make this evaluation. Keep the resulting information up-
to-date, so that potential aspects of new products,
services, and activities are factored into your objectives
and controls.
-------
Service Organizations Can
Benefit from an EMS
The US Postal Service examined
environmental aspects related to the
vehicles it operates, the chemicals it
uses to maintain equipment, the
solid wastes it generates, and the
products (stamps) that it sells.
Key Hints:
Look beyond
regulations and
at non-regulated
activities
Prioritize in
setting objectives
Consider services
& contractors
Warner-Lambert Company developed
process flow sheets, to identify & 'Visualize"
all waste streams from operations, and to
determine how much they were costing the
company. It also examined the packaging
of products and waste.
Factors to Consider:
ecological effects
human health impacts
catastrophic effects
resource, depletion .
scale, severity &
duration of impacts
probability of occurrence
cost of changing
other business effects
Hints:
In identifying aspects and impacts, you should also
look at activities not controlled by applicable laws
and regulations. But because many of your
aspects/impacts may be addressed by legal
requirements, your compliance program might yield
some valuable information. Permits, audit reports,
and other such documents can serve as useful inputs.
Beyond regulations, look at issues such as land,
energy, and other natural resource use.
* Once you have identified environmental aspects and
related significant impacts, use this information in
setting your objectives and targets. This does not
mean that you need to address all of your impacts
at once. There may be good reasons (such as cost,
availability of technology, and scientific uncertainty) for
addressing some impacts now and deferring action on
others. Keep in mind that managing environmental
aspects could have positive business impacts.
Remember to look at services as well as products.
While the need to examine your on-site operations
might be obvious, you should 'also consider the
potential impacts of what you do off-site (such as
servicing equipment at customer sites). Similarly, the
environmental aspects of the products, vendors, and
contractors you use may be less obvious, but should
still be considered.
Identifying significant environmental aspects is one of
the most critical elements of the E_MS and can be
one of the most challenging. Decisions you make in
this task can affect many other system elements (such
as, setting objectives and targets, establishing
operational controls, and defining monitoring needs).
Careful planning and conduct of this activity will pay
dividends in later steps.
Getting Started
To understand your environmental aspects, it helps to
understand the processes by which you generate
products and services. A flow chart of your major
processes might help you understand the inputs and
outputs of your processes and how materials are used.
A sample flow chart is provided in-the Tool Kit (see
page 96). You may also want to consider the views of
interested parties some organizations have found
external parties to be a good resource to help you
identify your organization's environmental aspects.
There are many readily-available sources of
information to help you perform your -assessment. For
starters, look at your permits, various regulations that
apply to your operations, audit reports, .EPCRA reports,
17 ' ,
-------
Review: Have we ...
D evaluated our products,
activities, and
services?
O determined which
aspects have
significant impacts?
O documented a
procedure?
and monitoring records. Trade associations, regulatory
agencies, your customers and suppliers also might
provide useful information to support your assessment.
Various techniques exist for evaluating environmental
v impacts. Find one that can be readily adapted for your
use in identifying environmental aspects and significant
impacts. Consider techniques used for compliance
with the OSHA Process Safety Management Standard,
environmental impact assessments, and life cycle
analysis. More information on these techniques can be
found in the Tool Kit (see page 98).
Once you've found a process that works for your
organization, describe the process in a written
procedure. A sample procedure for performing the
'::.' assessment is provided in the Tool Kit (see page 100).
' . -You can start out with a simple process for identifying
aspects and then refine the process over time as
needed. You also can address the more obvious
impacts or "low hanging fruit" first, then tackle the more
. complex issues later.
The Link Between Aspects and Impacts - Some Examples from a Real Company
Aspects
Emissions of volatile organic
compounds
Discharges to stream -
Spills and leaks
Electricity use
Use of recycled paper
Potential Impacts
Increase in ground level ozone
Degradation of aquatic habitat and drinking water
supply
Soil and groundwater contamination
Air pollution, qlobal warming
Conservation of natural resources
Things to Consider in Evaluating Environmental Aspects:
O Water Effluents
O Land Use
D Raw Material and Resource Use
O Normal and Abnormal Conditions
D .Air Emissions
D Solid and Hazardous Wastes
O Contamination of Land
O Local Issues
(e.g. concerns raised by the community such
as: noise, odor, dust, traffic, appearance, .etc.)
(e.g., start-up, shutdown, emergencies)
18
-------
Legal and Other Requirements
What standards affect the organization?
Setting the legal
framework for
your EMS
Legal requirements include:
Federal requirements
* State or local requirements
Permit conditions
Other requirements might
include (for example):
Company-specific codes
Standards in locations where
you sell products
International Chamber of
Commerce (ICC) Charter
for Sustainable
Development
Chemical Manufacturers
Association's (CMA)
Responsible Careฎ
American Petroleum
Institute's Strategies for
Today's Environmental
Partnership (API STEP)
Other industry codes or
programs to which your
organization voluntarily
subscribes.
Key Steps
- Identify
Requirements
- Analyze Impacts
- Communicate
- Act
To be in compliance with the laws and regulations that
apply to your organization, you must first know what the
rules are and how they affect what you do. As
discussed earlier, compliance with legal requirements is
one of the "three pillars" upon which your environmental
policy should be based. Costs of non-compliance (in.
terms of dollars, public image and possible damage to
the environment) can be very high.
, An effective EMS will include a process for:
ฐ identifying applicable legal and other requirements,
and; ,
ensuring that these requirements are factored into
the organization's efforts.
Changing legal requirements might require that you
modify your environmental objectives or other elements
of your EMS. By anticipating new requirements and
making changes to your operations, you can avoid some
future compliance obligations and their associated costs.
Getting Started
Your EMS should include a procedure for identifying
and having access to the legal and other requirements
that apply to your organization. These "other
requirements" might include industry codes, the CERES
Principles, or similar requirements to which your
organization may subscribe.
The process of identifying applicable regulations,
interpreting them, and determining their impacts on your
operations can be a time-consuming task. Fortunately,
there are many ways in which your organization can
obtain information about applicable laws or regulations.
These include:
commercial services (offered on-line, on computer
disk, and on paper);
regulatory agencies (federal, state and local);
tradegroups / associations;
public libraries; , .
seminars and courses;
newsletters / magazines; , .
consultants and lawyers;
the Internet; and
customers, vendors and other companies.
Small business assistance programs exist in every state.
Under the Clean Air Amendments of 1990, each state
environmental regulatory agency must establish a
19 ' ' ' ' .'.'
-------
Get information
on federal
environmental rules
on the Internet at
http://www.epa.gov
Review: Have we...
a identified applicable rules
and other requirements
and determined their
impacts?
O established and
documented a process for
keeping up-to-date?
D communicated to the
right people?^.
technical and compliance assistance program to help
companies comply with air quality rules. These
programs are being expanded into other environmental
"media" -(e.g., water, waste management) as well. In
addition, National Compliance Assistance Centers can
provide compliance assistance for certain industry
sectors (see Section 6 & Annex C for more information).
Once the applicable legal and other requirements have
been identified and analyzed for their impacts, you
should communicate these requirements (and plans for
complying with them) to the appropriate people within
the organization. Communicating the "other
requirements" that apply to your organization (as well as
their impacts) is an important and often overlooked
step.
A list of some resources you can use to identify and
track environmental laws and regulations is provided in
the Tool Kit (see page 104). Annex C also contains
additional sources of information about environmental
laws and regulations. The Tool Kit contains a sample
procedure for tracking environmental laws and
regulations (see page 106),
Commonly Applicable Federal Environmental Laws in the US
Clean Air Act (CAA)
[40 CFR Parts 50-99]
Clean Water Act (CWA)
[40 CFR Parts 100-145, 220-232, 410-471]
Federal Insecticide, Fungicide and
Rodenticide Act (FIFRA)
f40 CFR Parts 150-1 89]
Resource Conservation and Recovery
Act (RCRA)
[40 CFR Parts 240-299]
Toxic Substances Control Act (TSCA)
[40 CFR Parts 700-799]
Comprehensive Environmental
Response, Compensation and Liability
Act (CERCLA, also known as "Superfund")
[40 CFR Parts 300-311]
Emergency Planning and Community
Right-To-Know Act (EPCRA)
[40 CFR Parts 350-374]
Hazardous Materials Transportation Act
(HMTA)
[49 CFR Parts 100-1 80]
Establishes ambient and source emission standards and permit
requirements for conventional and hazardous air pollutants.
Establishes ambient and point source effluent standards and permit
requirements for water pollutants, including those discharged
directly to a waterbody and to a public sewer.
Establishes a program for the review of, registration, and control of
pesticides.
Establishes regulations and permit requirements for hazardous
waste management. Also, creates standards for underground
storage tanks holding oil or hazardous substances.
Regulates the use, development, manufacture, distribution and
disposal of chemicals. Certain chemicals (such as PCB's) targeted
for specific management standards.
Establishes program for cleaning up contaminated sites and
establishes liability for clean-up costs. Also, provides reporting
requirements for releases of hazardous substances.
Establishes a program to inform the public about the hazardous
and toxic chemicals used by industries. Reporting requirements
apply to companies using, processing, or storing specific chemicals
over specified quantities.
Establishes standards for the safe transportation of hazardous
materials. '
20
-------
Objectives and Targets
How will objectives and targets help my organization?
What does my
organization do to
achieve its policy?
Environmental Objective:
"Overall environmental
goal, arising from the
environmental policy, that
an organization sets itself
to achieve, and which is
quantified where ,
practicable."
- ISO 14001
' Environmental Target:
"Detailed performance
requirement, quantified
where practicable,
applicable to the
organization or parts
thereof, that arises from
the environmental
objectives and that needs
to be set and met in order to\
achieve those objectives."/
Objectives and targets help you translate purpose into
action they should be factored into your strategic plan
and can facilitate the integration . of environmental
management with other business management
processes.
You determine what objectives and targets are
appropriate for your organization. These goals can be
organization-wide or applied to individual units or
activities. In setting objectives, keep in mind your
environmental policy, including its three "pillars." You
should also consider your significant environmental
aspects, applicable legal and other requirements, the
views of interested parties, your technological
options, and financial, operational, and other
business requirements.
Policy
\
Environmental
Aspects
Legal / Other
Requirements
I Views of
Interested Parties
*
r
[Technology| J
Finance
Environmental
Program
Objectives
and
Targets
There are no "standard" environmental objectives that fit
all organizations. Your objectives and targets should
reflect what your organization does and what it wants to
achieve.
21
-------
Factors to consider
in setting objectives
and targets:
ability to control
ability to track /
measure
cost to track /
measure
progress reporting
links to policy
commitments
A sample
worksheet and
procedure for
setting objectives
and targets are
included in the
Tool Kit (see
pages 109&i13).
Hints:
Objectives and targets should be set by the people in the
functional area involved they will be best positioned to
n establish, plan for, and achieve these goals.
Involving people in the area will help to build commitment.
Objectives should be consistent with your overall business
mission and plan and the key commitments established in your
policy (pollution prevention, continual improvement, and
compliance).
Be flexible in your objectives. Define a desired result and let
the people responsible determine how to achieve the result.
Keep your objectives simple initially, gain some early
successes, and then build on them. '
* Communicate objectives and targets (as well as your progress
in achieving them) across the organization. Consider a regular
report on progress at staff meetings.
To obtain the views of interested parties, consider holding an
open house or establishing -a focus group with people in the
community. These activities can have other payoffs as we'll. .
Make sure your objectives and targets are realistic. Determine
how you will measure progress towards achieving them.
Keep in mind that your suppliers (service or materials) can
help you in meeting your, objectives and targets (e.g., by
providing more environmentally friendly products).
POLLUTION
PREVENTION SS
The most significant savings from Pacific Gas & Electric's EMS have
come from reductions in hazardous waste generation and disposal.
Ten years ago the hazardous waste generated by operations
exceeded 90,000 tons per year now that number is below 10,000
tons per year and is still falling.
22
-------
Comparing Objectives and Targets - Some Examples
Objectives
Reduce energy use
Reduce usage of hazardous chemicals
Reduce hazardous waste generation
improve employee awareness of
environmental issues
Improve compliance with wastewater
discharge permit limits ,
Targets
Reduce electricity use by 10% in 1996
Reduce natural gas use by 1 5% in 1 996
Eliminate use of CFC's by 1 997
Reduce use of high-VOC paints by 25%
Reduce chrome wastes in plating area by
50% in 1997 . -
ซ Hold monthly awareness training courses
Train 100% of employees by end of year
Zero permit limit violations by the end of
1997 .
POLLUTION
PREVENTION &&
Warner-Lambert Company used a "holistic" approach to identify its waste streams. The
company looked beyond emissions from its property and considered all of the
ramifications of its activities ...
By replacing chillers and redesigning the chilling system to be more efficient, the
company has realized $250,000 in energy savings. Because the company is more
energy efficient, it has reduced emissions at the local power plant!
By redesigning and revising dust collection, the company now uses 40 hp instead of
100 hp (without compromising the effectiveness of the dust collection system), has
lowered its operating costs, (and, reduced emissions at the local power plant).
Review: Have we...
documented objectives and targets at relevant
functions and levels within the organization?
O ensured that our objectives and targets are
consistent with the environmental policy (including
commitments to pollution prevention, continual
improvement, and compliance)?
CJ ensured consistency with our business plan /
mission?
O established a process for tracking and reporting
progress? '___
23
-------
Environmental Management Prograrn(s)
Why do we need an environmental management program?
A road map for
achieving your
environmental goals
Objectives and
Targets
Established
T
Environmental
Management
Program Defined
T
Monitoring and
Measurement
So far, this Guide has focused on the foundations of your
EMS (the planning elements) and on defining what your
organization intends to achieve in the environmental area.
To ensure that objectives and targets are achieved, you
need an action plan.
The environmental management program should be linked
directly to your objectives and targets that is, the
program should describe how the organization will translate
its goals into concrete actions so that environmental
objectives and targets will be achieved.
To ensure its effectiveness, your environmental
management program should:
designate responsibilities for achieving goals, and
define the means and time frame for achieving those
goals.
Keep in mind that your program should be a dynamic one.
Consider modifying the program when:
objectives and targets are revised or added;
progress in achieving your objectives and targets is
made or not made; or
products, processes, or facilities change or other factors
arise.
Your action plan need not be compiled into a single
document, A "road map" to several plans is an acceptable
alternative, as long as the key responsibilities, tactical steps
and schedules are adequately defined in these other
documents.
Keep in mind that this program should not be developed in a
vacuum it should be coordinated or integrated with
other business plans, strategies, and budgets. For
example, if you are planning changes to a manufacturing
process (say, for quality or production purposes), then it
makes sense to look at the possible environmental issues
associated with this process change at the same time.
Hints:
Involve your employees early in establishing and carrying
put the program.
Clearly communicate the expectations and responsibilities
laid out in the program to those who need to know.
Build on the plans and programs you have now for
environmental compliance, health &,safety, and/or quality
management purposes.
24
-------
Key Hints
involve employees
Communicate
expectations ;
Build on existing
programs
Keepprogram simple
Look for opportunities
POLLUTION
PREVENTION &0t
In an effort to reduce VOC
emissions, Aeroquip
Corporation has successfully
replaced a high-solids paint
with a water-based paint.
Solvent use has decreased
significantly because the
dilution solvent for the paint is
now deionized water.
Re-evaluate your action plan when you are considering
significant changes to your products, processes, facilities
or materials. Make this re-evaluation part of your change
management process. ,
Keep it simple (see sample tool, below) and focus on
continual improvement of the program over time.
Thought to Keep in Mind: There may be real
opportunities here!! Coordinating your environmental
program with your overall business plans and strategies may
position your organization to exploit some significant cost-
saving opportunities.
Review: Have we...
O prepared an action plan on how the organization
will meet its objectives and targets?
O included responsibilities, means and time
frames?
D incorporated environmental concerns in our
change management process?
O communicated the plan and tracked progress
Internally? ,
Environmental Management Program ~ Sample Tool
Objective / Tan
Action
Items
,
Priority
Respon-
sibilities
aet#1:
Schedule
Resources
Needed
Comments
(Note: A full-size copy of this tool is provided in the Tool Kit see page 116.)
A Sample Schedule for an EMS Action Plan is provided in the Tool Kit (see page 118).
*
25
-------
Structure and Responsibility
How does our organizational structure affect environmental management?
Aligning your
resources
to succeed
"Resources include
human resources
and specialized skills,
technology, and
financial resources."
- ISO 14001
Characteristics of a
good management
representative:
Knowledgeable
Assertive
Independent
More organizational
advantages of small
business:
shorter lines of
communication
less complex
organization
limited delegation
simpler access to
management
For your EMS to be effective, roles and responsibilities
must be clearly defined and communicated. In a small
organization, the commitment of all employees is
needed. ,
Top management plays a key role by providing the
resources needed to ensure that the EMS is
implemented effectively. Ensuring this capability is one
of the most important jobs of top -management (see
"Finding Resources" on next page).
Any effective management system needs an advocate.
Top management should appoint a management
representative. This representative (1) ensures that the
EMS is established and implemented; (2) reports on its
performance over time; and (3) works with others to
modify the EMS when necessary. The management
representative could be the same person who serves as
the project champion (as discussed in Section 3), but
this is not mandatory. Management can use information
on EMS performance to improve the system over time.
(A business owner, plant or shop manager, or any
number of other people might serve as an effective
management representative.)
Small and medium-sized businesses may have an
advantage over larger businesses in structuring their
organizations .for environmental management.
Because personnel and other resources are generally
more limited in small businesses, people often "wear
more than one hat" and are experienced in performing
multiple functions. In some cases, the individual
responsible for environmental management in a small
firm is also responsible for quality, health & safety,
facilities, or other related functions. For this reason,
integrating environmental responsibilities with other
functions can be greatly simplified.
Getting Started:
The following questions can help you determine the right
organizational structure for environmental management:
Look at the scope of your environmental
management program: What capabilities do we
need? Who needs to be involved to make the system
effective? What training or other resources will they
need?
Look at your significant environmental impacts:
What operations / activities need to be controlled?
Who needs to be involved to ensure that controls are
implemented?
26
-------
'Getting Started
Look At:
* Program scope
Environmental
aspects
Previous audits
Other systems
Look at the results of previous audits or other
assessments: What does this information tell us
about the effectiveness of our organizational
structure? How could it be improved?
Look at the current responsibilities for
environmental management How can we
enhance ownership of environmental management
across the organization? How can other business
functions support the EMS? (See next page.)
Look at your quality management and / or other
existing management systems: What roles and
responsibilities exist in these management
systems? Where are the opportunities .for
integration?
Consider flow charting your organization's
activities relating to environmental management.
This can help you understand how processes work
and the final product can be a great communication
and training tool. Flow charts might be useful to
look at processes such as chemical purchasing and
distribution, employee training, and preventive
maintenance, among others.
Consider integrating
EMS wjth your existing:
information systems
purchasing controls
quality procedures
work instructions
training programs
communication efforts
reporting systems
recruitment, appraisal and
disciplinary processes
More information on
resources is found in
Section 6. of this Guide
Hints:
Build flexibility into your organization's
Recognize that environmental (and
management needs will change over time.
EMS.
other)
Be sure to communicate to people what their roles
are (as well as the roles of others). One tool for
communicating these responsibilities is a
responsibility matrix (an example of which is
provided in the Tool Kit see page 120).-
Finding Resources
In most cases, developing and maintaining an EMS
will not require large capital outlays. What an EMS
will require is time. Many small organizations have
found that they can make effective use of interns or
temporary employees to perform potentially time-
consuming EMS development tasks (such as
collecting data, drafting and typing procedures,
etc.). This approach allows in-house personnel to
focus on more complex EMS development tasks.
Also, exploit the links between environmental
management and other aspects of your
organization. Look for areas where environmental
management can support other business functions
(and vice-versa see next page). .
.27
-------
How Various Functions Can Support Your EMS
Functions
Purchasing
Human Resources
Maintenance
Finance
Engineering
Top Management
Line Workers
How They Can Help (Possible Roles)
Develop and implement controls for chemical / other material
purchases
Define competency, requirements and job descriptions for vanous
EMS roles
Integrate environmental management into reward, discipline and
appraisal systems .
\ ,
Implement preventive maintenance program for key equipment
Track data on environmental management costs
Prepare budgets for environmental management program
Evaluate economic feasibility of environmental projects
Consider environmental impacts of new or modified products and
processes
Identify pollution prevention opportunities
Communicate importance of EMS throughout organization
Provide necessary resources
Track and review EMS performance
Provide first-hand knowledge of environmental aspects of their
operations
Support training for new employees
Review: Have we....
O defined roles for environmental management?
a communicated those roles internally?
D assessed resource needs?
P designated a management representative?
O integrated environmental management with other
business functions wherever possible and practical?
28
-------
Training, Awareness and Competency
Why is training important to the success of our EMS?
Building internal
capabilities
Implementing an EMS
involves everyone
Reasons for
' Training
motivation
awareness
commitment
skills/ capability
compliance
performance
An example of a
provided in the Tool
Kit (see page 123).
There are two excellent reasons for training employees
about environmental management and your EMS:
Every employee can have an impact on the
environment.
Any employee can have good ideas about how to
improve environmental management efforts.
Each person and function within your organization can
play a role in environmental management. For this
reason, your training program should cast a wide net.
Everyone in the organization should be trained on the
environmental policy, significant environmental impacts
of their work activities, key EMS roles and
.responsibilities, procedures that apply to their activities,
and the importance of conformance with EMS
requirements.
Air personnel should receive appropriate training.
However, training is just one element of establishing
competence, which is typically based on a combination
of education,'training, and experience. For certain key
roles (including tasks which can cause significant
environmental impacts), you should establish criteria for
measuring the competence of individuals performing
those tasks. .
Getting Started:
'.- A critical first step in developing your training
program is assessing your training and skill
needs. In assessing these needs, you should
consider both general and specific aspects (e.g.,
"What EMS procedures affect Joe's daily work and
what happens if they aren't followed?" "What
environmental impacts might Joe's work cause?"
"What broader understanding of environmental
issues and our EMS does Joe need?")
Look at the training you conduct already, for
compliance with environmental and health and
safety regulations and other purposes. You may
find that your existing training efforts go a long way
towards satisfying the requirements for the EMS.
29
-------
Milan Screw Products found that
it could provide a great deal of
its EMS training during "brown
bag" lunches, during which
employees bring their lunches,
participate in a training session,
and remain "on the clock" for the
lunch period.
Key Steps in Developing a Training Program
Step 1: Assess training needs & requirements
Step 2: Define training objectives
Step 3: Select suitable programs and methods
Step 4: Prepare training plan (who, what, when,
where, how)
Step 5: Implement training program
Step & Track training (and maintain records)
Step 7: Evaluate training effectiveness
Step 8: Improve training program (as needed)
'Training Resources:
internal trainers /
experts
consultants
community colleges
vendors / suppliers
customers
technical / trade /
business associations
self-study or
study groups
training consortia
, (teaming with other
local companies)
computer-based
training
Hints:
Because of the level of effort involved in a training
program, this is one EMS area where you don't want
to start from scratch. Many employees may already
be qualified on the basis of their experience and
previous training. (Keep in mind that all training
should be documented.) Since some employees may
require training on how to run a process safely, on-
the-job training certainly plays a role.
Plan and schedule training opportunities carefully.
While finding enough time for training can be a
challenge, there may be creative ways to make "more
time" (see box above left). Use venues like safety
meetings, staff meetings, and tool box meetings to
provide "training" and reinforce key messages.
New employees can pose a significant training
challenge. Consider developing an EMS training
package for new employee orientation. Even better,
videotape one of your current EMS training courses to
show new employees.
In reviewing training needs, don't forget to consider
the qualifications and training needs of your
environmental manager and your trainers.
Professional certification programs may be
appropriate for certain functions.
Factor your EMS skills requirements into your
recruiting, selection, and new employee orientation
efforts (as noted above).
30
-------
When Training Might
Be Needed
New employee is hired
Employee is transferred
to new job
> Individual doesn't follow
procedure / instruction
Procedures are changed
'New process, material, or
or equipment is introduced
1 Company changes objectives
and / or targets
1 New regulation affects
company activities
1 Job performance is not
acceptable
Establishing competency for various tasks can be a
challenge. Competency criteria for jobs that can cause
significant environmental, impacts should be as
objective as possible.
One informal method for assessing competency is to
question employees in critical functions as to how they
perform various aspects of their jobs (e.g., "Show me
how you ."). Use responses to determine whether
they have the requisite skills and understanding to do
the job safely. This will help you gauge whether
additional training may be needed.
Consider "job aids" to supplement training or help
establish competence. Examples of job aids include
written or pictorial job procedures, decision .tables or
flow charts,
Review: Have we ...
O identified training
needs?
D developed a training
plan? .
n provjded the required
training at all levels?
D communicated training
responsibilities?
O tracked and
documented training?
A Few Thoughts about Adult
Learning
Adults need the opportunity to integrate
new ideas with what they already know.
Information that conflicts sharply with
existing beliefs or has little conceptual
overlap with what is already known is
acquired more slowly.
Adults prefer self-directed learning and
want to have a hand in shaping the
training program.
Adults have expectations. It is important
to clarify these up-front.
Adults prefer active participation to
straight lecture.
Adapted from "30 Things We Know for
Sure About Adults Learning"
(Training Magazine, July 1988)
31
-------
Communications
How are communications critical to the success of our EMS?
Opening the
information
lines
Consider
communication
strategies for:
neighbors
community groups
other interest groups
local officials
' regulatory agencies
emergency responders.
External Outreach
Warner-Lambert Company
has hosted local community
leaders, state agencies, and
federal agencies, to share
its environmental activities
and programs and to obtain
feedback.
''Milan Screw Products'
staff interviewed
neighbors, customers,
suppliers, and
employees' family
members to obtain the
views of external
V parties. J
The importance of employee involvement in developing
and implementing your EMS has been discussed earlier.
Effective environmental management requires effective
communications.
Communications will help you:
motivate the workforce;
explain the environmental policy (both internally and
externally) and how it relates to the overall business
vision / strategy;
ensure understanding of roles and expectations;
demonstrate management commitment;
monitor performance; and,
identify potential system improvements.
Effective internal communications require mechanisms
for information to flow top-down and bottom-up. Since
employees are on the "front Jines," they are often an
excellent source of information, issues and ideas.
Communicating with external parties is also important for
effective environmental management. Obtaining the
views of neighbors, community groups, and customers,
.(among others), will help you understand how your
organization is perceived by others. Information from
external sources can be critical in setting environmental
and other business goals.
An effective EMS should include procedures for:
communicating internally (between levels and
functions), and
soliciting, receiving, documenting and responding to
external communications.
Getting Started:
The first step in designing a communications program is
determining your audiences. Make a list of internal and
external audiences.
Once you identify the audiences, you should then
determine what you need to communicate with them.
(What do they need to know about your products or
operations? What are their concerns?)
Next, decide how you can best reach them. Appropriate
communication methods might vary from audience to
audience. Start by looking at your existing methods for
communicating, both internally and externally. These
might include:
32
-------
Sample procedures
for internal and external
communications are
provided in the Tool
Kit (see pages 125 & 128). :
POLLUTION
PREVENTION &fr
and
Communication
Rochester Midland
Corporation developed a
program to improve indoor
environmental quality in
buildings where its cleaning
products are used. This
model program uses
cleaning procedures that
reduce emissions, products
that are less hazardous, and
engineering controls for
consistent quality.
Rochester Midland placed
postcards on building
tenants' desks that informed
them of the program &
solicited feedback for
continual improvement of
the program.
internal Methods
newsletters
staff meetings
employee meetings
bulletin boards
brown bag lunches
External Methods
open houses
focus groups
press releases
annual reports
advertising
Hints:
/ i
Determine how proactive your external
communications strategy will.be. Select an approach
that fits your organization's culture and strategy. For
example, will reporting on environmental performance
and progress give you an edge over the competition?
While a proactive external communications program
may require more resources, some organizations have
found that a proactive strategy can be quite beneficial.
Weigh the costs and benefits for yourself, but keep in
mind that there might be many interested audiences.
In communicating with employees, it is helpful to explain
not only what they need to do but why they need to do
it. For example, when describing a requirement based
on a regulation, simply saying "the regulations require it"
is not sufficient explanation. Try to explain the purpose
behind the rule and why it is important. Also make a
clear connection between the requirement and how it
applies to each person's job. . ' > '
Keep the message simple all communications
should be clear, concise, and accurate.
Managing responses to external inquiries does not have
to be a burdensome task. Use a simple method, such
as stapling an inquiry to its written response and then
filing them together. The key is to be able to
demonstrate that the organization has a system for
responding to external inquiries.
Review: Have.we ...
P established procedures for internal and external
communication?
O determined who is responsible for responding to external
inquiries?
a identified target audiences?
D determined the proper communications methods for each
audience? :
33
-------
EMS Documentation
Why do we need documentation of our EMS?
Describing your EMS
and how the pieces
fit together
Bute of thumb; ^
Try to keep the I
description to no I
mom than one page I
per EMS element I
V J
Easier to read and
understand =
easier to follow
To ensure that your EMS is well understood and
operating as designed, you need to get information to the
people doing the work. In addition, there are external
parties that might need to understand how your EMS
operates, such as customers, registrars, regulators,
lending institutions, and the public. A "road map" of your
EMS explaining how the pieces fit together can be a very
useful tool.
EMS documentation can be viewed as a series of
explanations or statements of how EMS criteria (such as
ISO 14001) apply to your organization. While you don't
need to, maintain a single "manual", you should maintain
EMS information in a form that:
describes the core elements of your EMS (and how
these elements relate to each other), and
provides direction to related documentation.
You can maintain this documentation either on paper or
electronically. There may be some advantages to
maintaining documents electronically, such as easier
updating, access control, and ensuring that the most up-
to-date version of a document is used by all readers.
EMS documentation is related to (but not the same as)
EMS records. EMS documentation describes what
your system consists of (i.e., what you do), while EMS
records demonstrate that you are doing what you said
you would do. EMS records are described later in this
Guide.
Hierarchy of EMS
Documentation
Forms, Drawings, etc.
One way to think about your EMS documentation is to
use the figure shown above, which also applies to ISO
9000 documents.
34
!i'l lll'li!,! ', ' 'I I'
-------
Use flowcharts
or other graphics
where they help
explain the
system and its
linkages
Hints:
Keep your EMS documentation simple and choose a
format that works best for your organization. The
documentation does not need to describe every detail
of your EMS or how your organization conforms to the
ISO 14001 Standard (or other EMS criteria). Instead,
consider providing references to other documents or
procedures.
Use the results of your preliminary assessment to
prepare your EMS documentation. In the course of
conducting the preliminary assessment, you should
have collected or prepared useful material on how your
organization satisfies the EMS criteria.
ซ The usefulness of your EMS documentation can be
improved by including the organization's mission
statement, vision, guiding principles, and annual
objectives (if these exist). These will help readers
understand the organizational context and how the
EMS supports overall business goals.-
ซ An EMS manual can be a useful tool for explaining your
EMS to new employees, customers, or others. A
sample outline for an EMS manual is provided in the
Tool Kit (see page 133).
ซ EMS documentation should be updated as needed,
based on any system improvements you put in place.
However, if you put too much detail in an EMS
manual, you may have to update the manual frequently
(see first hint, above). .-.,,-.
Review: Have we...
O documented the
environmental
policy, organization,
key procedures, and
other system
elements?
a described where
people can find the
documents listed
above and related
documents?
ID explained the
linkages among
system elements?
What Constitutes EMS Documentation?
Consider including the following:
your environmental policy
your organizational structure and key responsibilities
descriptions of how your company meets ISO 14001
requirements (e.g., "How do we identify
environmental aspects?". "How do we control
documents?" How do we conduct EMS audits?")
references to key procedures /controls
direction to other related documents (such as
emergency response plans, training plans, etc.)
35
-------
Document Control
How do we ensure everyone is working with the right information?
Getting everyone
on the same page
Suggested elements
of document control;
issue / revision date
effective date
approval
(i.e., signature)
revision number
document number
(or other identifier)
copy number
cross-references
Key Question;
Is everyone working
with the same set of
documents?
Start with a few
copies, then add
more if the need
is shown.
People in your organization probably use various
documents (drawings, work instructions and the like) as
they perform their duties. To ensure that your personnel
are consistently doing the job right, the organization
must provide them with the right tools. In this case, the
tools needed are the correct and up-to-date procedures,
drawings and other documents. Without a mechanism to
control EMS documents, the organization has no way of
knowing (or verifying) that people are working with the
right tools.
To ensure that everyone is working with the proper EMS
documents, your organization should have a procedure
that describes how documents are controlled.
Implementation of this procedure should ensure that:
EMS documents can be located,
they are periodically reviewed,
current versions are available where needed, and
obsolete documents are removed.
Your document control procedure should designate
responsibility and authority for preparing documents,
making changes to them and keeping them up-to-date. In
other words, you need to make it clear who can actually
change documents and what the change process is.
Getting Started:
EMS document control requirements are almost a mirror
image of the ISO 9000 requirements. Organizations that
have or are developing an ISO 9000 management system
cap enjoy some advantages here.
Even if your organization doesn't have an ISO 9000
system, you might be better off than you think. Your
organization probably has document controls in place for
other business purposes (such as finance, human
resources or purchasing). Assess how well these controls
work and if they can be adapted for your EMS.
36
-------
Documents that
should be controlled:
."*-:
policy
manual
procedures
work instructions
forms & drawings
Hints:
" Don't make your procedure more complicated than it
needs to be. While larger organizations often have
complex processes for document control, smaller
organizations can use simpler systems.
Limiting distribution makes the job easier. Does
everyone have access to one or a few copies?
Determine how many copies you really need and
where they should be located for ease of access.
If the people that need access to documents are
connected to a local area network, consider using a
paperless system. This can facilitate control and
revision of documents considerably.
Prepare a document control index that shows all of
your EMS documents and the history of their revisi9n.
Put this index in your manual. Also, if multiple copies
of documents are available at the facility, prepare a
distribution list, showing who has each copy and
where the copies are located.
As your procedures or other documents are revised,
highlight the changes (by underlining, boldface, etc.).
This will make it easier for the reader to find the
changes.
The Tool Kit contains a sample' document control
procedure (see page 135) and a sample index of EMS-
controlled documents (see page 131).
Review: Have we...
O developed a procedure
to control EMS
documents?
O determined the number
of copies of documents
we need?
a established
responsibilities and
authorities for
document preparation,
revision, management,
and disposition?
/^ \
/ Document
Requirements
O=MS '
Documentation
Procedures
Policy
Others...
Document
Control
Requirements
^ Records
\ Requirements
Preparation
Issuance
Revision
Disposition
identification
Retention
Storage
Disposition
\
/
Linkages among EMS documentation, document
control and records
37
-------
Operational Control
What operations and activities must be controlled for environmental management?
Building in performance
Identification
of Significant
Operational
Controls
To ensure that your environmental policy is followed and
that your objectives are achieved, certain operations and
activities must be controlled. Where an operation or
activity is complex and/or the potential environmental
impacts are significant, these controls should take the
form of documented procedures. Procedures can help
your organization to ensure regulatory compliance and
consistent environmental performance. Procedures can
also play a key role in employee training.
Documented procedures should cover those situations
where the absence of procedures could lead to
deviations from the environmental policy or your
objectives and targets. Determining which operations
should be covered by documented procedures and how
those operations should be controlled is a critical aspect
of developing an effective EMS.
In deciding which activities need to be controlled, look
beyond routine production .on the shop floor. Activities
such as maintenance, management of on-site
contractors, and relationships with suppliers or
vendors could affect your organization's environmental
performance significantly.
Examples of Activities
and Operations that
Might Require
Operational Controls:
management /
disposal of wastes
approval of new
chemicals
* storage & handling of
raw materials and
chemicals
wastewater treatment
operation of paint line
operation of plating
system
management of
Getting Started:
Start by looking at the environmental aspects and
potentially significant impacts which you identified
earlier. Identify. the processes from which these
significant impacts arise, and consider what types of
controls might be needed to prevent or manage these
impacts. If you have flow charts of these processes,
identify the points in each process where some type of
control may be appropriate.
Prepare draft procedures and review them with the
people who will need to implement them. This will.help
to ensure that the procedures are accurate and realistic.
-------
Hints:
Look at procedures you already have in place to
comply with environmental and health & safety
regulations. Some of these may be adequate to
control significant impacts (or could be modified to do
so). Develop a chart to keep track of what is needed:
Procedure
needed
(none exists)
ซ
ซ '
ป
ซ
I''-'''"
Procedure
exists, but is not
documented
-.
Procedure exists
. and
is documented
No procedure
needed
Factors That Could
Affect the Need for
Documented Procedures:
risk of activity
complexity of activity /
methods
degree of supervision
skills / training of
workforce
Rules of Thumb: the more highly skilled and trained
your employees are, the less critical procedures will be.
The more complex the work or the greater the potential
impact on the environment,, the more important these
procedures will be.
Once you have identified operations-that require control,
consider what kinds of maintenance and calibration may
be appropriate. However, the need for maintenance on
equipment that could have significant environmental
impacts should be obvious, and the need to plan and
control such maintenance should not be overlooked.
This does not mean that an elaborate preventive or
predictive maintenance program is needed in all cases.
Assess your existing maintenance program and its
effectiveness before.making significant changes.
39
-------
POLLUTION
PREVENTION ft&
Rochester Midland
Corporation, a manufacturer of
cleaning and other chemical
products, formed a partnership
with a cleaning contractor that
uses Rochester Midland's
products, the owners of a
building where the products are
used, and building tenants, to
lessen the risks associated with
cleaning products. The partners
began by developing'common
goals, identifying alternative
cleaning products and
processes, and identifying
opportunities to reduce risks to
building occupants and cleaning
staff. Over a two-month period,
they were able to: reduce
chemical exposures; improve
tenant satisfaction; improve
communication, awareness, and
training; achieve a 50%
reduction in cleaning products;
and achieve .measurable cost
savings.
Hints on Writing Procedures
Understand the existing process (start with a flow
chart, if one is available). Build on informal
procedures where possible.
Focus on steps needed for consistent
implementation.
Use a consistent format and approach.
Review draft procedures with employees that will
have to implement them. (Better yet, enlist
employees to help write them.) .
Keep procedures simple and concise. Excessive
detail doesn't provide more control and is not
needed.
Some of your identified environmental aspects may be
related to.the chemicals, raw materials, or other goods
and services you obtain from vendors/suppliers.
Likewise, the activities of your contractors can affect
your environmental performance. Communicate your
expectations (including any relevant procedures) to
these business partners.
While the development of procedures can be time-
consuming, some organizations have come up with
creative ways to reduce the data collection burden.
Consider having a college intern or temporary
employee interview your employees "on the line" to
collect information on what employees do and how
they do it.
If your organization uses a "work team" concept, ask
the work teams to draft procedures for their areas (or
to modify existing procedures for EMS purposes).
Review: Have we...
O developed procedures to control key
operations / activities?
O trained employees on these procedures?
n covered normal operations, abnormal
operations, emergencies?
40
-------
Emergency Preparedness and Response
How should we be prepared for accidents and emergencies?
Minimizing the impacts
of uncontrolled events
Don't think only about
response-focusion
how to prevent accidents
inihetfirstplacel.
Review prior accidents
and incidents as one
guide to where future
incidents may occur.
Despite an organization's best efforts, the possibility of
accidents and other emergency situations still exits.
Effective planning and preparation can reduce^ injuries,
protect employees and neighbors, reduce asset losses and
minimize production downtime.
An effective emergency preparedness and response
program shou|d include provisions for:
assessing the potential for accidents and
emergencies;
preventing incidents
environmental impacts;
and their associated
plans / procedures for responding to incidents;
periodic testing of emergency plans /procedures; and,
mitigating impacts associated with these incidents:
Consistent with your organization's focus on continual
improvement, it also is a good idea to review emergency
response performance after an incident has occurred.
This review can help determine if more training, is needed
or if emergency plans / procedures should be revised.
Useful Information:
Material safety data sheets
Plant drawings
Process flow diagrams
Piping and instrumentation
diagrams .
Design codes and
standards
Specifications on safety
systems (alarms,
sprinklers, etc.)
Getting Started:
This is another area where you should not have to start
from scratch. Several environmental and health and
safety regulatory programs require emergency plans
and/or procedures. Look at what you have in place
now and assess how well it satisfies the items
discussed above.
One area where additional work is often needed is on
identifying the potential for accidents and
emergencies. A team of site personnel (from
engineering, maintenance and Environmental Health &
Safety, for example) can identify most potential
emergencies by asking a series of "what if" questions
related to hazardous materials, activities, and
processes employed at the site. In addition to normal
operations, the team should consider start-up and
shutdown of process equipment, and other abnormal
operating conditions.
41
-------
Ask yourself: Does everyone (including new
employees) know what to do in an emergency? How
would contractors or site visitors know what to do in an
emergency situation?
Communicate with local officials (fire department,
hospital, etc.) about potential emergencies at your site
and how they can support your response efforts.
Hints:
Mock drills can be an excellent way to reinforce
training and get feedback on the effectiveness of your
plans / procedures.
Post copies of the plan (or at least critical contact
names and phone numbers) around the site and
especially in areas where high hazards exist. Include
phone numbers for your on-site emergency
coordinator, local fire department, local police, hospital,
rescue squad, and others as appropriate.
Review: Have we...
D reviewed operations for
potential emergency
situations?
O developed plans /
procedures for managing
these situations?
O trained personnel and
obtained any necessary
emergency equipment?
D established a feedback
loop so we can leam
from our experiences?
Checklist for Emergency Preparedness
and Response Plan
Does your plan describe the following:
potential emergency situations {such as fires,
explosions, spills or releases of hazardous materials,
and natural disasters)? ,
hazardous materials used on-site (and their
locations)?
key organizational responsibilities (including
emergency coordinator)?
arrangements with local emergency support
providers?
emergency response procedures, including
emergency communication procedures?
locations and types of emergency response
equipment?
maintenance of emergency response equipment?
training / testing of personnel, including the on-site
emergency response team (if applicable)?
testing of alarm / public address systems?
evacuation routes and exits (map), and assembly
points?
42
-------
Assessing how
well the system
is working
'If you can't measure it,
you can't manage H.
- Peter Drucker
Which operations and
activities can have
significant .environmental
impacts?
f What are the key
(- characteristics of
V these operations and
X. activities?
Monitoring and Measurement
How do we know how we are doing?
An EMS without an effective monitoring and measurement
program is like driving at night without the headlights on *
you know that you are moving but you can't tell where you
are going! Monitoring and measurement enables you to:
gauge your environmental performance;
analyze root causes of problems;
ป identify areas where corrective action is needed; and,
improve performance / increase efficiency.
In short, monitoring helps you manage your business
better. Pollution prevention and other strategic business
opportunities are identified more readily when current and
reliable data is available.
Your organization should develop procedures to:
ฐ monitor key characteristics of operations and
activities that can have significant environmental
impacts; ,
track performance (including how well you meet your
objectives and targets);
calibrate and maintain monitoring equipment; and,
through internal audits, periodically evaluate your
compliance with applicable laws and regulations.
How do we measure
these characteristics?
Attributes of an Effective
Measurement Program
simple
flexible
consistent
ongoing
results communicated
reliable data produced
Getting Started:
* Monitoring and measuring can be resource-intensive.
One of the most important steps you can take is to
clearly define your needs. While collecting information
is clearly important, 'resist the urge to collect data "for
data's sake."
* l
Review the kinds of monitoring you-do now for
regulatory compliance and other purposes (such as
quality or health and safety management). How well
does this serve your EMS purposes? What additional
monitoring or measuring might be needed?
You can start with a relatively simple monitoring and
measurement system, then build on it as you gain
experience.
43
-------
Hints:
Environmental
performance
evaluation is an
ongoing process
Regulators may provide
incentives for effective
compliance management
programs, including sett-reporting
(see the ERA'S Final Policy
Statement - "Incentives for Self-
Policing: Discovery, Disclosure,
Correction and Prevention of
Violations "'- December22, 1995
Federal Register, Vol. 60, No. 246).
Employees should have
a mechanism to report
regulatory violations (or
other EMS issues) without fear of
retaliation by their employer.
> Monitoring key process characteristics: Many management
theorists endorse the concept of the "vital few" that is, that a
limited number of factors can be measured to determine the
outcome of a process. The key is to figure out what those factors
are and how to measure them. Root cause analysis is one way
to identify what those factors might be.
' Most effective environmental measurement systems use a
combination of process and outcome measures. Outcome
measures look at results of a process or activity (such as the
amount of waste generated or the number of spills that took
place). Process measures, on the other hand, look at "upstream"
factors, such as the amount of paint used per unit of product or
the number of employees trained. A combination of process and
outcome measures may be right for your organization.
' Equipment calibration: Identify process equipment and
activities that truly affect your environmental performance. As a
starting point, look at the key process characteristics you
identified earlier. Some companies choose to put key monitoring
equipment under a special calibration and preventive
maintenance program. This can help to ensure accurate
monitoring and lets employees know which instruments are most
critical for environmental monitoring purposes. In some cases, it
may be more cost-effective to subcontract calibration and
maintenance of monitoring equipment than to perform these
functions internally.
> Assessing regulatory compliance: Determining your
compliance status on a regular basis is very important. You-
should have a process to systematically identify, correct, and
prevent violations. Performance of the compliance management
program should be considered during EMS management review
(see page 54). The box below describes some of the
characteristics of a good compliance management program.
Compliance Management Program Elements
Organization policies and standards that describe how
employees are to meet the regulations
Assignment of responsibility for compliance oversight
Processes to systematically ensure that policies and standards
are carried out (e.g., monitoring and auditing)
Appropriate incentives and disciplinary procedures
Prompt disclosure of findings
Prompt and appropriate correction of problems
(adapted from EPA's final policy statement on self-auditing;
December 22, 1995)
44
-------
Leading vs. Lagging
Indicators
Number of people
trained in spill
prevention (Leading)
VS.
Number of spills that
took place (Lagging)
Evaluating environmental performance: Go back and look
at your significant environmental aspects and the
objectives and, targets associated with those significant
aspects/What information will you need to determine if the
company is achieving its objectives and targets?
Focus on things that you can do something about!
Start by selecting a few performance indicators that are:
- simple and understandable
- objective .
- verifiable
- relevant to what your organization does (i.e., its activities,
products, and services)
Make sure you can commit the necessary resources to track
this information over time. It is OK to start small and build
overtime as your company gains experience in evaluating its
performance. Keep in mind that no single measurement will
tell your organization how it is doing in the environmental
area. . ;
People respond best to information that is meaningful to "their
world." Putting environmental information in a form that is
relevant to their function increases the likelihood they, will
act on the information. Be sure' to link your measurement
program with your communications program and other
elements of the EMS (such as management reviews, as
discussed later).
The distinction between audits and environmental
performance evaluation can be confusing. The figure below
is intended to explain the two concepts. Both are important
to your EMS.
Distinguishing Auditing from Environmental
Performance Evaluation
Audits
periodic
sample of data
independent
verifies conformance
EPE
ongoing
frequent
line function
* assesses performance
45
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Example EMS Performance Indicators
Pounds of VOC emitted per unit of production
Pounds of hazardous waste generated per year
Percentage of employees completing environmental
training
Average time for resolving nonconformities
Energy use per unit of production
Percentage of solid waste recycled / reused
Review: Have we ...
D identified key process characteristics and how to measure /
monitor them?
D set up a process to regularly evaluate (through internal audits)
compliance with laws and regulations?
O determined how to measure performance against our
objectives and targets?
D established procedures to maintain and calibrate key
monitoring equipment?
46
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Nonconformance and Corrective / Preventive Action
What do we do when we find a problem?
Fixing EMS problems
and avoiding them
in the future
Nonconformance
means......
system does not
meet the EMS criteria
(such as ISO 14001)
or-;
implementation is not
consistent with the
S description
Recurring problems
are expensive I
No EMS is perfect. You will probabjy find problems with your
system, especially in the beginning (through audits,
measurement, or other activities). Your EMS will also need to
change as your organization changes and grows. When
system deficiencies are encountered, your organization will
need a process to ensure that:
problems (including nonconformities) are investigated;
root causes are identified;
corrective actions are identified and implemented; and,
corrective actions are tracked and documented.
EMS nonconformities and other system deficiencies should be
analyzed to detect patterns or trends. Identifying these trends
will allow you to anticipate and prevent future problems.
Focus on correcting and preventing problems. Preventing
problems is generally cheaper than fixing them after they
occur (or after they reoccur). This approach is consistent with
the continual improvement philosophy.
= System Improvement
Hints:
If your organization has an ISO 9000 management system,
you should already have a corrective / preventive action
process for quality purposes. You can use this as a model
(or integrate with it) for EMS purposes.
Small companies might find they can combine their
management review and corrective action processes,
especially if the same people are involved in both. At the
very least, a strong link should exist between the two
processes.
The amount of planning and documentation needed for
corrective / preventive actions can vary with the severity of
the problem (and its potential environmental impacts).
Don't go overboard'with bureaucracy simple methods
often work best.
47
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Why do EMS
problems occur?
Typical causes include:
poor communication
faulty or missing
procedures
equipment malfunction
(or lack of maintenance)
lack of training
lack of understanding (of
requirements)
failure to enforce rules
Once you document a problem, the organization must be
committed to resolving it. Corrective actions should be
implemented as quickly as possible. Be sure that your
corrective / preventive action process specifies
responsibilities and schedules. Review your progress
regularly and follow up on any deficiencies.
Make sure you collect the right data / information to make
good decisions. While many corrective actions may be
"common sense," you need to look below the surface to
determine why a problem has occurred.
Initially, most EMS problems may be identified by your
auditors. However, over the long run, most problems and
good ideas may come from the people in the shop doing the
work. This should be encouraged. Find ways to get
employees involved in the system improvement process (for
example, via suggestion boxes, contests and incentive
programs).
/^Key Steps: ^
identify the problem
identify the cause
(investigate)
come up with solution
implement solution
document solution
ป communicate solution
People doing the work
are often in the best
position to see
problems and suggest
solutions.
The Tool Kit contains
a sample corrective
action procedure
and tracking log
(see page 139).
Sources
of change
Investigate and
recommend
solutions
Institutionalize
Change .
Corrective
Action
Process
Management
i, Review
Review: Have we ...
a developed procedures for investigating, correcting,
and preventing system deficiencies?
D set up a process for assigning responsibilities for
and tracking completion of corrective actions?
O set up a process to revise procedures or other EMS
documents based on corrective / preventive
actions?
48
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Evidence that the
EMS is working
properly
Records
How do we prove that our EMS is working?
The value of records management is fairly simple you
should be able to prove that your organization is actually
implementing trie EMS as designed. While records have value
internally, over time you may need to provide evidence of EMS
implementation to external parties (such as customers, ,a
registrar, or the public). Records management is often viewed
as bureaucratic, but it is hard to imagine a process or system
operating consistently without keeping accurate records.
Records should be
important to the operation
of the EMS, including your
regulatory compliance efforts.
Key Questions:
what records are kept?
who keeps them?
where are they kept?
how are they kept?
how long are they kept?
how are they accessed?
how are they disposed?
Basic records management is straightforward you need to
decide what records you will keep, how you will keep them
and for how long. You should also think about how you will
dispose of records once you no longer need them.
If your organization has an ISO 9000 management system,
you should have a system for managing quality records.
Hints:
Focus on records that add value avoid bureaucracy.
If records have no value, then don't collect them. The
records you choose to keep should be accurate and
complete.
You may need to generate certain .forms as you develop
your EMS. These forms should be simple and
understandable. ' , '
Consider combining your records management processes
for environmental and health & safety records.
Establish a records retention policy and stick to it. Make
sure that your policy takes into account records retention
requirements, specified in applicable environmental
regulations. : .
In designing your records management system, be sure to
consider:
- who needs access?
- to what records?
- in what circumstances?
If your organization uses computers extensively, consider
using an electronic EMS records management system.
Maintaining records electronically can provide an excellent
means for rapid retrieval of records as well as controlling
access to sensitive records.
Think about which records might require additional security.
Do you need to restrict access to certain records? Should a
back-up copy of critical records be maintained at another
location? . '
49
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The Tool Kit contains
a tool for organizing your
filing system (see page
144). Copy the pages, cut out the
tabs, and use them to set up
your fifes.
Types of Records You Might Maintain (Examples):
legal, regulatory and other code requirements
results of environmental aspects identification
reports of progress towards meeting objectives and targets
permits, licenses and other approvals ,
training records
EMS audit and regulatory compliance audit reports
reports of identified nonconformities, corrective action plans
and corrective action tracking data
hazardous material spill / other incident reports
communications with customers, suppliers, contractors and
other external parties
results of management reviews
sampling and monitoring data
maintenance records
equipment calibration records
* ISO 14001 requires that organizations have procedures for
training records and the results of audits and reviews *
Review: Have we ...
O identified records to be maintained?
D. determined their retention times?
D set up a good storage, and retrieval system?
50
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Objective evidence of
conformance with
EMS requirements
Audits are vital
to continual
improvement
' EMS Audit:
"A systematic and
documented verification
process of objectively
obtaining and evaluating
evidence to determine
whether an organization's
environmental management
system conforms to the,
environmental management
system audit criteria
set by the organization,
and for communication
of the results of this
^ process to management."
EMS Auditing
Are we doing what we said we would do?
. ** - ป,..-.
Once your organization has established its EMS, verifying the
implementation of the system will be critical. To identify and
resolve EMS deficiencies you must actively seek them out.
In a small organization, audits are particularly relevant since
managers are often so close to the work that they may not see
problems or bad habits that have developed. Periodic EMS
audits will establish whether or not all of the requirements of
the EMS are being carried out in the specified manner.
For your EMS audit program to be effective, you should:
develop audit procedures and protocols;
establish an appropriate audit frequency;
train your auditors; and, ,
maintain audit records.
The results of your EMS audits should be linked to the
corrective action system (as described earlier).
While they can be time-consuming, EMS audits are critical to
EMS effectiveness. Systematic identification and reporting of
EMS deficiencies to management provides a great opportunity
to:
maintain management focus on the environment,
ซ improve the EMS, and
ensure its cost-effectiveness.
Getting Started:
How frequently do we need to audit? In determining the
frequency of your EMS audits, some issues to consider are:
-the nature of your operations,
- the significant environmental aspects / impacts (which
you identified earlier), \
- the results of your monitoring program, and .
- the results of previous audits.
As a rule of thumb, all parts of the EMS should be audited at
least annually. You can audit the entire EMS at one time or
break it down into discrete elements for more frequent
audits. (There may be advantages to more frequent audits,
but the decision is up to you).
- IS014001
5,1
-------
Audit procedures should
describe;. t
audit scope (areas and
activities covered)
audit frequency
audit methods
key responsibilities
reporting mechanisms
Traits of a
good auditor:
Independent (of the
activity being audited)
Objective
Impartial
Tactful
Attentive to detail
Who will perform the audits? You will need trained EMS
auditors. Auditor training should be both initial and
ongoing. Commercial EMS auditor training is available, but
it might be more cost-effective to link up with businesses and
other organizations in your area (perhaps through a trade.
association) to sponsor an auditor training course. A local
community college might also provide auditor training.
EMS auditors should be trained in auditing techniques and
management system concepts. Familiarity with
environmental regulations, facility operations, and
environmental science is a big plus, and in some cases may
be essential to adequately assess the EMS. Some auditor
training can be obtained on-the-job. Your organization's
first few EMS audits can be considered part of your auditor
training program (but make sure that an experienced
auditor takes part in those "training" audits).
If your company is registered under ISO 9000, consider
using your internal ISO 9000 auditors as EMS auditors.
Although some additional training, might be needed, many of
the required skills are the same for both types of audits.
1 How should management use audit results?
Management can use EMS audit results to identify trends
or patterns in EMS deficiencies. The organization must
also make sure that any identified system gaps / deficiencies
are corrected in a timely fashion and that the corrective
actions are documented.
Sources of Evidence:
interviews
* document review
observation of
work practices
I
Hints:
Your EMS audits- should focus on objective evidence of
conformance. (If you cannot tell whether or not a particular
procedure has been followed, then you should consider
revising the procedure). During the actual audit, auditors
should resist the temptation to evaluate why a procedure
was not followed that step comes later.
During the course of the audit, auditors should discuss
identified deficiencies with the people who work in the
area. This will help the auditors verify that their
understanding is correct. It can also serve as refresher
training (on EMS requirements) for employees.
If possible, train at least two people as internal auditors.
This allows your auditors to work as a team. It also allows
audits to take place when one auditor has a schedule conflict
(which is unavoidable in a small organization!).
-------
ISO has finalized three
guidance standards for
environmental auditing
ISO 14010, ISO 14011, and
ISO 14012. These
guidelines may help your
organization to develop its
EMS auditing program (see
Annex B for additional
information);
Results of
regulatory
compliance
audits are often
good indicators
of EMS
deficiencies.
Use compliance
audit tidings to
guide your EMS
audit efforts.
Even if you have
an effective
\ internal audit
program,
consider periodic
external audits to
ensure
objectivity.
Some Options for Auditing
Barter for audit services with other small companies
Use external auditors
Have office personnel audit production areas (and vice-
versa) .. .
' Before you start an audit, be sure to communicate the audit
scope, schedule, and other pertinent information with the
people in the affected area(s). This will help avoid confusion
and will facilitate the audit process.
Consider linking your EMS audit program to your regulatory
compliance audit process. But keep in mind that these audit
programs have different purposes, and while you might want
to communicate the results of EMS audits widely within your
organization, the results of compliance audits might need to
be communicated in a more limited fashion (in order to
maintain attorney-client or attorney work product privilege,
for example).
The Tool Kit includes a sample EMS audit procedure (see
page 148).
Periodic
EMS Audits
EMS
Established
Corrective Actior
Process
Management
Reviews
Linkages among EMS audits, corrective action and
management reviews
Review: Have we ...
O developed an audit program?
D determined an appropriate audit frequency?
D selected and trained EMS auditors?
a conducted EMS audits as described in the program?
n developed a process to keep records of these audits?
53
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Management Review
How do we ensure that our EMS will remain viable?
Closing the continual
improvement loop
Management reviews can
be used to demonstrate
top management's ongoing
support for the environment
.Just as a person should have periodic physical exams,
your EMS must be reviewed by management from time to
time to stay "healthy." Management reviews are the key
to continual improvement and to ensuring that the EMS
will continue to meet your organization's needs over time.
Management reviews also offer a great opportunity to keep
your EMS efficient and cost-effective. For example,
some organizations have found that certain procedures
and processes initially put in place were not needed to
achieve their environmental objectives or control key
processes. If EMS procedures and other activities don't
add value, eliminate them.
The key question that a management review seeks to
answer is:
"Is the system working?" (i.e., is the EMS suitable.
adequate and effective, given our needs?)
Hold
management
reviews "after
hours" so that
production will
not be affected.
The Tool Kit
contains a sample
Management
Review procedure
(seepage 154).
Hints:
There are two kinds of people who should be involved in
the management review process:
-people who have the right information / knowledge
people who can make decisions
Determine the frequency for management reviews that
will, work best for your organization. Some
organizations combine these reviews with other
meetings (such as director meetings) while other
organizations hold "stand-alone" reviews. For ISO 9000
purposes, management reviews are typically held once
or twice per year.
Regardless of what approach your organization takes,
make sure that someone takes notes on what issues
were discussed, what decisions were arrived at, and
what action items were selected. Management reviews
should be documented.
The management review should assess how changing
circumstances might influence the suitability,
effectiveness or adequacy of your EMS. Changing
circumstances may be internal to your organization
(i.e., new facilities, new materials, changes in products
or services, new customers, etc.) or may be external
54
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Information sources
to consider:
audit results . ,
internal suggestions
external communications
progress on objectives
and targets
other environmental
performance measures
reports of emergencies,
spills, other incidents
new or modified legislation
and regulations
new scientific/ technical data
on materials and processes
used by the organization
The Internet is a
good way to
stay on top of
changing laws,
regulations,
technologies,
and other
environmental
information.
"Many of the benefits
of an EMS cannot be
anticipated beforehand.
You will have to discover
them as pleasant
surprises at some point
after implementation.
They will be there."
factors (such as new laws, hew scientific information, or
changes in adjacent land use).
Once you have documented the action items arising
from your management review, be sure that someone
follows-up. Progress on these items should be
tracked.
As you evaluate potential changes to your EMS, be sure
to consider your other organizational plans and
goals. Environmental decision-making should be
integrated into your overall management and strategy.
Questions to Ponder During Management Reviews
Did we achieve our objectives and targets? (if not, why
not?) Should we modify our objectives?
Is our environmental policy still relevant to what we do?
Are roles and responsibilities clear and do they make
sense?
Are we applying resources appropriately?
Are the procedures clear and adequate? Do we need
others? Should we eliminate some?
Are we monitoring our EMS (e.g., via system audits)?
What do the results of those audits tell us?
What effects have changes in materials, products, or
services had on our EMS and its effectiveness?
Do changes in laws or regulations require us to change
some of our approaches?
What stakeholder concerns have been raised since our
last review?
Is there a better way? What else can we do to
improve? ' '.
Review: Have we ...
n established a process for periodic reviews of our
EMS?
a documented the results of such reviews?
CD followed-up on action items to ensure closure?
- Milan Screw Products
CONGRATULATIONS !! YOU NOW HAVE ALL
OF THE ELEMENTS OF AN EFFECTIVE EMS !!
55
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Section 5 : The Registration Process
7/7/s section describes the registration process, and will help you to decide
if your organization should pursue registration.
1st Party Audit
internal Audit
2nd Party Audit
Customer audit of a
supplier
3rd Party Audit
Audit by another party
independent of a supplier
and its customer
"Registration"
vs.
"Certification"
Both terms can be used to
describe the third-party
process, in the U.S., the
term "registration" is
generally used for
management systems,
while the term
"certification" is generally
used for products.
Environmental management system registration is the
process whereby a non-biased "third-party" . attests that an
organization's EMS conforms with the requirements of an
EMS standard, such as ISO 14001. The third-party
organization that performs the registration services is called
a "registrar," and is selected by the organization that desires
registration services. The type of registration services that
will be offered for ISO 14001 will be similar to those offered
for the ISO 9000 series of quality management system
standards. In North America, over 13,000 companies have
been registered to ISO 9000.
A registrar can be "accredited" by a third-party accreditation
body that is independent of the registrar. Accreditation is
the process in which a registrar's competence is evaluated
by a third-party accreditation body with national or
governmental recognition. Accreditation greatly enhances a
registrar's credibility.
ISO 14001 does not require that an organization implement
the Standard at the corporate level. For example, one
organization may choose to implement the Standard
throughout the entire organization, while another may
implement the Standard in one particular facility. An
organization can elect to register the entire organization, a
division(s), selected facilities, a particular facility, or selected
operations within a facility. The key factor in choosing the
organizational unit for registration purposes is that it has its
own functions and administration.
Registrars may have different registration processes and
may offer different types of services. The following is a
description of a fairly typical registration program which is
provided for illustrative purposes:
The Registration Process
Step 1: Application for Registration
The organization seeking EMS registration submits an
application indicating the activities . and facilities of the
organization or site to be registered.
56
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Overview of
the Typical
EMS Registration
Process:
1. Application
2. EMS Documentation
Review - Desk Audit
3. On-siteEMS
Readiness Review
4. Registration Audit
5. Registration
Determination
6. Surveillance
The ISO 14001 Standard
does not require third-
party registration, but
market forces and
regulatory incentives
may provide strong
encouragement for
registration.
Step 2: Review of EMS Documentation /Desk Audit
The organization submits documentation of its EMS, which
includes its" environmental policy and documentation
indicating how. it meets each clause in the ISO 14001
Standard. The documentation is reviewed by a designated
lead auditor. The auditor generates a written report which
indicates conformance or nonconformance of the
documented EMS to each clause of the Standard.
Step 3: On-site EMS Readiness Review
The lead auditor conducts an on-site visit in order to resolve
any EMS documentation nonconformities and to verify that
the facility is prepared for a full registration audit. The on-site
visit is also used to assess the resources and logistics
necessary for the full registration audit.
Step 4: Registration Audit
An audit team conducts an on-site audit to evaluate and'
verify .through objective evidence (interviews, procedures,
records, etc.) that the EMS conforms to the requirements in
the ISO 14001 Standard, is effectively implemented, and has
sufficient provisions to be maintained.
Step 5: Registration Determination
A final report containing the results of the registration audit is
submitted to the organization. To receive a Certificate of
Registration, an organization must successfully meet the
requirements of the ISO 14001 Standard, as well as the
registration policies of the registrar.
'. . ' . ' ' ? '
Step 6: Surveillance
Surveillance audits are typically performed semi-annually to
verify continued conformance with the ISO 14001 Standard.
During the surveillance audits, the audit team may only audit
certain elements of the EMS. Over a three year period,
however, all of the elements of the EMS must be reviewed to
ensure continued conformance to the requirements of the
ISO 14001 Standard.
Possible Registration Audit Results
There are three possible results from a registration or
surveillance audit. The registrar can determine that the
applicant is:
-------
Recommended for registration
There are no major nonconformities.
-or-
Classification
of
Audit Findings:
Major Nonconformity
Absence or complete
breakdown of an EMS
element A large
number of minor
nonconformities for one
element may be
considered a major
nonconformity.
Minor Nonconformity
A single observed
nonconformity.
Registration -> Credibility
Recommended for registration following verification of
corrective action
There are one or more major nonconformities which can.
be corrected and verified without a full re-audit.
-or-
Recommended for an on-site reassessment
There are several major nonconformities which indicate a
breakdown of the EMS. Another full on-site audit is
required.
Should Your Organization Pursue Registration?
There are numerous benefits associated with implementing
an EMS; some of those benefits can be the result of external
recognition. An organization that voluntarily implements an
EMS standard, such as ISO 14001, may be able to
demonstrate externally that it has made a commitment to
environmental protection.
The ISO 14001 Standard does not require registration. An
.organization can demonstrate its commitment to proactive
environmental management to its stakeholders and other
interested parties in two ways:
An organization can have its EMS audited and
registered by an independent 3rd party, i.e. registrar;
or ;
An organization can make a self-determination and
self-declaration of conformance to an EMS standard.
' '
An organization should carefully consider several factors in
order to determine which approach is best. An organization's
reputation and relationship with its stakeholders and other
interested parties may play a significant role in helping it to
determine which option is most desirable. An organization
that, is weighing the pros and cons of self-declaration vs.
registration should also consider the following factors:
58
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"We conducted that
eventually Quinn
would have to be
IS014001 certified to
compete internationally."
-. K.J. Quinn
Hach Company will
"wait and see" if market
forces and potential
regulatory incentives
provide sufficient
benefits to offset the
costs of registration.
Hach Company
"... as is the case with
ISO 9000, some early
indications are that
IS014001 registration
will be a prerequisite for
doing business
internationally, especially
in Europe."
Globe Metallurgical Inc.
Strategic goals;
Maintenance of current market position;
Opportunities for a competitive .advantage;
Investor criteria for access to capital;
Possible regulatory incentives; and
The credibility of self-declaration.
In certain cases, EMS registration may be required by
customers or may be necessary to fulfill a contract
requirement. Organizations that sell their goods or services
internationally may find that EMS registration is a strong
selling point in the global marketplace and may enable them
to obtain preferred supplier status. For certain organizations,
registration to the ISO 9000 series of quality management
system standards has become a prerequisite for doing
business domestically and internationally. EMS registration
may be pursued by a wide variety of organizations, including
those that have obtained quality management system
registration. EMS registration may result in a competitive
advantage for organizations that have achieved it.
An organization may pursue registration as a means to
demonstrate to its shareholders that its EMS conforms to
the requirements in an international EMS standard.
Organizations that are striving for good community
relations may use registration as a vehicle to improve or
maintain their public image. Some lenders and insurers
have indicated that organizations that have obtained EMS
registration may be given preferential treatment because
they are perceived to be a lower risk.
Regulators, both at the state and federal level, have
indicated that they may provide incentives, in the future, for
organizations that successfully implement an effective EMS.
Regulatory agencies are currently evaluating the
effectiveness of EMS implementation but have not committed
to what types of regulatory incentives may be available.
Examples of regulatory incentives could include streamlined
permitting processes and reduced fines. Organizations that
provide goods or services to government agencies may be
granted preferred supplier status if they implement an
effective EMS. .
69
-------
An organization evaluating whether or not registration is an
appropriate goal should consider the following questions:
Should Your
Organization Pursue
EMS Registration ?
Consider:
/ Strategic goals
/ Customers
/ Competitors
/ Shareholders
/" Local community
/ Lenders/Insurers
/ Regulatory agencies
The Organization
1) What is your organization's motivation for implementing
ISO 14001?
2) Is your organization's senior management committed to
ISO 14001 implementation?
3) How does environmental management fit into your
organization's operating and strategic goals?
Customers
4) Have your customers indicated that they will require ISO
14001 registration? -
5) Do your customers give preferential treatment to
environmentally responsible suppliers?
6) Does your organization sell its products or services
internationally (particularly in Europe or Japan)?
7) Are your competitors pursuing ISO 14001 registration?
Shareholders
8) Are your shareholders concerned about your
environmental management practices?
9) Have your shareholders considered using your proactive
environmental practices as a marketing tool?
Local Community
1O) Has your local community raised concerns about your
environmental practices?
11) Has your organization been looking for a means to
demonstrate your proactive environmental management
practices to your local community?
60
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Lenders/Insurers
12) Will your lenders or insurers offer your organization
better rates if it has a registered EMS?
Regulatory Agencies
13) Are your organization's activities highly regulated?
(Wou(d any potential regulatory relief provide motivation
for registration?)
The benefits of EMS registration may vary significantly
among organizations. In addition, the costs associated with
the registration process will vary significantly among
organizations, depending on the size of the organization and
the number of facilities/divisions they choose to register. A
cost-benefit analysis may help your organization to weigh the
costs associated with EMS registration with the benefits your
organization can expect to achieve. Your organization
should determine if registration will add value to your
business. *
Choosing a Registrar
If your organization chooses to pursue EMS registration, you
may want to consider the following factors when choosing a
registrar: .
1) Are they accredited? Major accreditation bodies
include: the American National Standards Institute
(ANSI); the Registrar Accreditation Board (RAB); and
the Raad voor Accreditatie (RvA) (the Dutch Council for
Accreditation).
2) How many years have they been in business?
* -
3) ,4 Do they provide registration services for quality
management systems (ISO 9000)? (May be helpful if
your organization is pursuing registration to both ISO
9000 and ISO 14001.)
4) What is the experience base of the auditors? Do they
have experience in quality management systems and
environmental management? Do they have experience
in your particular industry?
61
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5) How many clients do they have? Can they provide you
with a list of customers/references?
6) Are they accredited in your Standard Industrial
Classification (SIC) Code?
7) Do they have experience working with small and
medium-sized organizations?
8) Are they geographically convenient to your operations?
Can they provide you with a lead auditor who is located
close to your organization? (Geographic proximity can
' reduce travel expenses.)
9) Is registration "continuous" or does it expire? (Is a full
registration audit required again after a period of time?)
10) What are their costs over a four-year period?
62
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Section 6: Sources of Assistance
This section describes where your organization can find additional help.
There are many free or inexpensive resources available to help your organization develop and
"implement an EMS. The following is a description of some of these resources. A list of
contacts is included in Annex C of this Guide.
, . - ^ . ,,
Federal Government Agencies
The U.S. Environmental Protection Agency (USEPA): provides information on a number of
tqpics that can be useful in the development and implementation of an EMS. Some of these
resources include: assistance with interpretation of environmental laws and regulations-
information on pollution prevention technologies; case studies; fact sheets; and hotlines to
answer questions about environmental issues.
The USEPA's Office of Compliance has established telecommunications-based national
Compliance Assistance Centers for four specific industry sectors (and is currently working on
two new centers). The existing centers include: the National Metal Finishing Resource Center
(N.MFRC); Printer's National Compliance Assistance Center (PNEAC); GreenLink - the
Automotive Compliance Information Assistance Center; and the National Agriculture
Compliance Assistance Center. Office of Compliance staff is planning to develop a Chemical
Manufacturers* Center and Printed Wjring Board Center.
The Small Business Administration (SBA) provides assistance to small and medium-sized
organizations. The SBA can provide information and assistance related to: operation and
management of a business; sources of financial assistance; international trade; as well as laws
and regulations.
State Agencies
Your state environmental regulatory agency can provide assistance with the development of an
EMS. Contact your state environmental agency and inquire about education and outreach
programs for businesses that are developing an EMS. Many state environmental agencies can
also provide publications, pamphlets, and on-line help related to environmental laws, innovative
pollution prevention technologies, waste reduction, and permitting. Some states, such as
Minnesota and Pennsylvania, are developing programs specifically designed to help
organizations seeking ISO 14001 registration.
Associations
Industry trade associations can provide assistance with the development 'of an EMS. These
organizations can provide information on a number Of industry-specific environmental
management issues, and can be instrumentalin placing you in contact with other organizations
that can share their experience and expertise in EMS implementation.
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Your local or state chamber of commerce can be helpful in providing information about
legislative and regulatory issues that affect environmental management for small and medium-
sized organizations. Other services that are commonly offered include handbooks, workshops,
conferences and seminars.
Non-Profit Organizations
Another resource to consider is the Manufacturing Extension Partnership (MEP), which is a
growing nationwide system of services that provide technical support to businesses interested
in assessing and improving their current manufacturing processes. The MEP is a partnership of
local manufacturing extension centers which typically involve federal, state, and local
governments, educational institutions, and other sources of information and funding support.
The MEP can also often provide assistance with quality management, development of training
programs and business systems.
The Industrial Technology Institute (ITl) is a non-profit organization dedicated to expanding
technology access and technology management among U.S. manufacturers. ITl provides
technical assistance, to small and -medium-sized organizations through the Michigan
Manufacturing Technology Center. ITl also has experience with the development of business
performance tools and provides services for energy, environment, and manufacturing
assessments; as well as, QS 9000 and ISO 14000 training and implementation.
Other Companies
Another recommended source of information and expertise is the companies with which you do
business. It is likely that your suppliers and customers, have experience with many of the
aspects of an EMS, and are willing to share their experiences and provide advice to your
organization. s
On-line Resources . '
There is a wealth of information related to EMS implementation available electronically via the
Internet. Many state, federal, and local agencies have home pages on the Internet containing
information that can be useful to your organization. Numerous non-governmental organizations
have home pages that contain information on topics such as ISO 14000, pollution prevention,
recycling and waste minimization,. environmental laws and regulations, innovative
manufacturing technologies, and materials substitution. If your organization does not have
Internet access, contact your local library to see if it provides Internet access to its users.
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Appendix A
Case Studies
MILAN SCREW PRODUCTS
Background
Milan Screw Products is a small manufacturing firm located in southeastern Michigan that
employs 32 individuals. Milan Screw Products manufactures precision fittings for the fluid
power, automotive, and refrigeration industries, and is registered to the ISO 9002 quality
management system Standard. There,are approximately 1,500 companies in the United
States in the screw-machine products industry. Most of these companies are family-owned and
family-managed, and typically have approximately 50 employees. - .
While there are generally few hazardous materials used in the screw-machine industry, there
are environmental issues associated with the containment of coolants and cutting oils, the
substitution of chlorinated solvents, and the disposal of waste oils. The most persistent
environmental challenge is the containment of cutting oil within production machines. Many
screw-machine shops have production equipment that was manufactured in the 1950s, which
may tiave leaky gearbox covers and inadequate oil splash guards. The cutting oils also create
cleaning and disposal issues (e.g., stained carpets; waste bins filled with saturated oil
absorbents swept from the shop floor; and liquid wastes from the solvents and soaps used in
cleaning).
While many shops have simply accepted the oily film that soon coats everything from the light
fixtures to the floors, Milan Screw Products decided that it was going to improve the
management of its environmental issues. Top management recognized that a clear
environmental policy, objectives and targets, written procedures, training, and corrective action
(elements similar to its quality management system), would help them to proactively manage
their environmental practices. The motivation to implement an EMS was derived from the
company's desire to improve its environmental performance, and in light of the company's
quality management system experience, the EMS approach seemed to be the best way to
achieve it. Milan Screw Products was soon committed to implementing an environmental
management system.
EMS Implementation .
One of the first steps in the implementation of the EMS at Milan Screw Products was the
establishment of a cross-functional environmental task group. Top management appointed
five representatives from production, support, and management. The environmental task group
is responsible for assuring continued regulatory compliance (including the submission of all
permits/forms to federal, state, and county environmental agencies), and improving the
company's environmental performance. Milan Screw Products found that participation of
shop-floor employees is essential to the successful implementation of an EMS because it
encourages their ownership of the process. Top management was pleased with the heightened
environmental awareness among task group members and their growing understanding of the
: .' . - .' . '65 ' . . ' . -' " ' :--;
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company's environmental responsibilities. In addition, environmental compliance acCities were
soon effectively managed by the environmental task group and would only requ.re .top
management review.
While progress had been made, the organization was lacking a structure for its EMS program
Td haTnomeans to measure progress. In March 1995, Milan Screw Products jomed he
Sponsored EMS Demonstration Project at NSF International. One o the firsstepMithe
project was the self-assessment process. Milan Screw Products completed NSF s. EMS Self-
Assessment Tool, which is a checklist that enables an organization to determine how its EMS
measured "p Igaฐnst an EMS standard, such as ISO 14001. Milan Screw Products' score was
Sow because they did not have a formal EMS in place. The score did not discourage Milan
Sw ProSts and the company set a goal for itself - complete EMS implementat,on by June
1996. . .
Policy
Milan Screw Products developed an environmental policy that includes a commitment to
Srtory compliance, continual improvement, and the prevention of pollution. The
environmental policy was modeled after the organization's quality policy, wh.ch was developed
with the help of a consultant.
Planning
In order to determine the'company's environmental aspects, the environmental task group
members set up an easel and participated in a brainstorming session. The task group listed all
S the company's inputs (e.g. energy, water), outputs (e.g. oil mist, no.se), and conversions
(e.g. steel bars to chips, and cutting oils to-mist). The task group examined the company s
purchases, processes, and waste .streams. The task group also identified the company s
stakeholders Some of the stakeholders were interviewed so that the company could gain a
better understanding of their environmental concerns. These stakeholder concerns were added
to the list of environmental aspects. A neighbor reported that their only concern was that oi
from the shop could damage their lawn. A supplier's sales representative reported that the oil
on his shoes was a nuisance. Customers were pleased to learn that the company was
implementing an EMS because they want to be assured of continued production (fines imposed
on a small company could result in a shut down). The task group also interviewed employees
and some of their family members. All in all, the environmental task group had done an
excellent job at identifying their environmental aspects. The task group then rated the
probability of an environmental impact occurring against the seventy of the impact. They then
grouped the environmental aspects/impacts in general categories (e.g. oil-related problems).
It soon became clear that the company's primary objective was oil recovery The top
management at Milan Screw Products had been contemplating the need for a new facility. The
identification of the company's environmental aspects/impacts provided additional motivation for
the development of a new facility. The environmental aspects/impacts that were identified and
the company's EMS have played a role in determining how the ne.w facility will be bu.lt The
company wiH continue to perform oil recovery practices, but will not set numencal targets unW
the new facility is complete. Milan Screw Products started its first EMS cycle with reasonable
objectives that focus on its manufacturing practices. Over time, the company will continually
improve its EMS, and hopes to include objectives such as the recycling of office paper.
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The environmental task group will continue to be responsible for keeping Milan Screw Products
fully In compliance. The company has found that its trade association has,been a tremendous
help in keeping them abreast of environmental compliance issues.
Milan Screw Products intends to develop its environmental management program at its
current facility and will improve the EMS at the new facility. The new facility will help the
company to achieve its environmental objectives and targets.
Implementation and Operation
Milan Screw Products has found that the structure and responsibility requirements of the ISO
14001 Standard are easier to manage in a small company. Milan Screw Products has
developed six teams (each composed of individuals with similar job descriptions) for the quality
management system; the teams have been given more decision-making authority and have
been an effective element of the quality management system. These teams will help with
environmental issues over time. The environmental task group will cqntinue to spearhead the
EMS program the owner, plant manager, quality manager, safety manager, plant
supervisor/environmental coordinator, and a representative from production staff are actively
involved. The key to success in a small company appears to be the team approach, since
there is often no one that can be solely dedicated to managing environmental affairs.
Since finding the time to do employee training can be a challenging aspect of running a small
business,. Milan Screw Products has scheduled training sessions a half hour before or after the
employees' normal shift. Their best success has been with "brown bag" sessions where the
employees bring their lunches, listen to the training presentation, and remain "on-the-clock" for
their lunch/training period. Milan Screw Products has also found that videotaping training
sessions can be helpful for new-hire training. The environmental task group has helped with
training by gathering training materials.
The team approach that has been developed at Milan Screw Products has been an effective
means of fostering good internal communication procedures. In addition, Milan Screw
Products has gone beyond the requirements of the ISO 14001 Standard by soliciting the
opinions of external interested parties. The company has found that a good external
communication program has resulted in a lot of benefits because it builds trust. The company
has been straightforward with its community about potential oil problems, andihe community
has been very supportive of their efforts and of their plans for a new facility. The external
communication program helped them identify some-of their environmental'aspects, and has.
helped them to communicate .with their customers. Milan Screw Products' customers
appreciate that it is an environmentally-responsible company that is a leader in its industry.
Since Milan Screw Products has a registered quality management system, they have a sound
document control program in place. As mentioned previously, a quality management system
consultant helped the company with their ISO 9002 implementation, and the document control
procedures for quality will be adapted where applicable for the EMS. Milan Screw Products is
still in the process of establishing its EMS documentation.
As part of their brainstorming session, the environmental task group also listed potential
emergencies. The company used this information -when it reviewed its emergency
preparedness and response procedures. The EMS implementation process helped the
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company to consider possible areas of liability that it had previously overlooked (e.g. a delivery
truck leak).
Checking and Corrective Action
Milan Screw Products has made some preliminary calculations of some of its environmental
aspects. The new facility will facilitate the quantification of its environmental aspects and
impacts. The company intends to build on its quality management system corrective and
preventive action procedures to help them develop their EMS. In addition, the company
intends to utilize some of the lessons it has learned about data collection and monitoring and
measurement through its quality operating system and will apply these lessons to the EMS
overtime.
Milan Screw Products has gained experience with management system audits through its
quality management system implementation. Top management has performed quality
management system audits with the help of an auditor training guide that their quality
management system consultant developed for their organization. The company has done in-
house auditor training with the help of the guide and has used the auditor training guide for its
EMS audits where applicable. Top management and the plant supervisor/environmental
coordinator have performed an EMS audit, even though they have not yet fully implemented the
ISO 14001 Standard.
Management Review
Milan Screw Products Management Review Board meets monthly. The company also performs
an annual review of its operations. A third-party (consultant) is used to verify the results of the
company's annual in-house review. The EMS is being incorporated in the management review
process of the company.
The Milan Screw Products' Experience
While Milan Screw Products has not completely implemented its EMS, it has made significant
progress over 1 % years. Due to the groundbreaking for the new facility in June 1996, the
organization had to shift its priorities to new construction (it is now hoping to completely
implement its EMS by April 1997). Top management at Milan Screw Products stated that
organizations that choose to implement an EMS should not get discouraged if the EMS
implementation needs to be set aside occasionally. You can start, stop, and resume your
efforts as needed your aspects won't change unless you change your processes or products
and any progress that you have made will still be there.
Milan Screw Products' top management believes that there are numerous potential benefits
associated with a successful EMS. Specifically, the company determined that an EMS could
improve employee retention, new hire selection, working conditions, and the perceptions of its
suppliers, lenders, customers, neighbors, and regulators. The EMS will also ease management
concerns that an environmental problem could arise from simple ignorance or lack of training.
The company's top management has stated that it may be difficult to perform a cost/benefit
analysis on the value of EMS implementation because several of the potential benefits are
intangible and cannot be given a monetary value. Milan Screw Products' proactive
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environmental program has improved, its stature and fostered communication with
regulatory agencies. Top management also believes that the company will benefit from being
one of the first in their industry to successfully implement an EMS it may encourage their
customers to perceive the company as being more innovative, more responsible, and perhaps
more desirable than their competitors. Top management has reported that it is impossible to
tally citations that are not written, fines that are not levied, nor lawsuits that are not filed.
Milan Screw Products' top management has also stated that many of the benefits of an EMS
cannot be anticipated beforehand, and that an organization will discover them as pleasant
surprises at some point after implementation.
To date, the biggest challenge that Milan Screw Products has encountered while
implementing an EMS has been allocating the human resources to the EMS project while
production demands are high. The company has also had to overcome old practices by
explaining the rationale behind its desire to successfully implement an EMS.
Milan Screw Products has not calculated the costs of EMS implementation to date. Top
management reports that it is difficult to attribute costs/benefits at this stage of EMS
implementation, particularly since the company is in a transition phase due to the new
construction. While it is too early to quantify costs and benefits, top management is confident
that the benefits will outweigh the costs early projections of their oil recovery savings at the
new facility are estimated to be $20,000 per year.
Milan Screw Products will integrate its ISO 9002 quality management system with its ISO
14001 EMS. The company is developing one manual that will incorporate both quality and
environmental management system elements. For example, the organization has a quality
policy on white paper and its environmental policy on blue paper on facing pages. The
documents also refer to one another where appropriate. The document control programs for
both systems willbe fully integrated as well. In addition, the audit function will be integrated
once auditor training for the EMS is complete. '
Top management at Milan Screw Products has not determined if the company will pursue EMS
registration in the future. Top management has stated that it will depend pn factors such as
costs and customer demand. The company intends to completely implement its EMS and will
evaluate the need for registration next year. Top management has stated that obtaining EMS
registration would be a great satisfaction and it may improve their customers' perception of the
company, but it has'not determined whether or not it can justify the costs.
Milan Screw Products encourages other small companies to implement an EMS because it
believes that small companies may not have sufficient resources to mitigate environmental
problems. An EMS can help a small or medium-sized organization prevent environmental
problems which may keep a small company in business. Top management at Milan Screw
Products has stated that an EMS enables an organization to'look at its business from another
perspective. Organizations have considered quality, safety, etc., as integral parts of their
business and should look at their business from the environmental perspective as well. All of
the various perspectives result in greater opportunities for improving the organization as a
whole.
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HACH COMPANY
Background
Hach Company is an international manufacturer and distributor of instruments and reagents'for
cplorimetric testing, with annual sales over $100 million. Hach Company manufactures
spectrophotometers, colorimeters, turbidimeters, and portable testing equipment for the water
and wastewater markets. The company manufactures instruments at its headquarters in
Loveland, Colorado, and has a chemical manufacturing and distribution plant in Ames, Iowa.
The Hach Company is registered to ISO 9001 and is a member of the Chemical
Manufacturers Association's Responsible Care* program.
Hach Company participated in the EPA-sponsored EMS Demonstration Project at NSF
International, and decided to pilot EMS implementation at its Ames facility. The Ames facility
has approximately 300 employees and faces environmental management challenges due to its
many chemical production processes. The Ames facility is the only Hach facility that is
currently participating in the CMA's Responsible Care* program. Hach Company decided to
implement an EMS at its Ames facility for several reasons. The company felt that a sound
EMS would: 1) provide assurance to the officers, board of directors, and company stockholders
that the company will continue to meet regulatory compliance requirements and is prepared to
handle other environmental issues; 2) provide a framework to maintain support and resources
from senior management to meet environmental objectives and targets; 3) help create market
opportunities for the organization; 4) be a mechanism to gauge environmental performance;
and 5) help the company identify its responsibilities beyond compliance in order to meet the
needs of stockholders,'employees, neighbors, customers, vendors, and suppliers.
i ,
EMS implementation
In order to examine the Ames facility's environmental strengths and weaknesses, the facility's
Quality Director performed an initial self-assessment of the EMS. The Quality Director
reviewed the EMS standard and interviewed the environmental safety and health staff at length.
The Quality Director determined that the facility's EMS complied with approximately 30 percent
of the EMS standard, which was consistent with the expectations of the Environmental, Safety
and Health (ESH) staff at this early stage of EMS implementation. This process provided the
ESH staff with a benchmark from which they could measure progress as they continued to
improve the facility's EMS.
Policy
Hach Company had previously developed an environmental policy but added additional policies
to completely fulfill the CMA's Responsible Careฎ Program's objectives, and the policy
requirements of the EMS. Hach Company has issued its Corporate Environmental and Safety
Policies which address continuous improvement, periodic assessments, product stewardship,
regulatory compliance, operations, facilities, and employee health and safety. In addition, the
President of Hach Company has issued The President's Commitment, which expresses top
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management's commitment to environmental stewardship and safety for employees and
customers.
Planning
In order,to determine the Ames facility's environmental aspects, the environmental safety and
health department reviewed the table of contents of their new ESH manual. The table of
contents helped them to develop an informal environmental effects register and a safety
register. The group then examined how environmental regulations affect thejr company; they
examined federal requirements (e.g. Clean Water Act, Safe Drinking Water Act, Glean Air Act,
etc.), in addition to state and local environmental regulations. The ESH staff proceeded to
explore the facility's environmental aspects and resulting impacts beyond those addressed
by environmental regulations. They always strive to do the right thing even if it is not
required by law. The group developed a three to four page document that focused on the
facility's operations and processes and less on aspects such as energy use.
The group developed their environmental effects register to help them set objectives and
targets. The ESH staff is taking a systematic approach to setting objectives and targets. While
the EMS is still being developed, the objectives are .focused at maintaining compliance and
tackling issues that had previously been unresolved, such as waste disposal costs. One
particularly important environmental issue for the company is determining the impact that the
company's chemical products have on its international customers (35% of the company's
products are sold internationally). These impacts will also be considered when setting
objectives and targets.
The ESH staff have access to copies of federal and state regulations, manuals, journals, on-line
resources, and software packages that help them to keep abreast of all pertinent environmental
regulations and statutory requirements. While the company is very good at maintaining
regulatory compliance, the procedures that they have developed for their legal and other
requirements have helped to make their compliance activities more focused and efficient. The
procedures that they follow to ensure compliance are properly documented and will protect the
company in the event of employee turnover. The ESH staff at the Ames facility is developing
extensive written procedures to address their compliance activities that are above and beyond
those required by the ISO 14001 Standard.
Hach Company has staff members that are dedicated to managing the company's
environmental, health, and safety issues; hence, the company rarely uses outside consultants.
The environmental management program at the Ames facility is well positioned to meet its
environmental objectives and targets.
Implementation and Operation
The ESH staff at the Ames facility believes that the structure and responsibility requirements
of an EMS are easier to achieve in a medium-sized organization than in a large one. The staff
at the Ames facility has been given the autonomy to implement an EMS at their facility without
extensive corporate supervision. This has made the process easier because the lines of
communication are shorter and the EMS can be focused on the operations of one facility.
The Ames facility has an excellent training program due in part to the commitment of
resources in this area (the facility has a full-time ESH training coordinator). Implementing the
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EMS has helped with the facility's ESH training by helping to define training objectives. The
ESH staff is also developing procedures for all ESH training curricula, The documented
procedures will describe the goals and objectives of training and establish a curriculum for
applicable programs. .
Internal communication within the Ames facility has improved due to EMS implementation.
The ESH staff are working with members of the operations, design, and purchasing
departments so that the groups can work together to set reasonable objectives and targets that
complement the goals set by other departments within the organization. Environmental issues
are becoming an integral part of the business.
The Ames facility is still in the process of completing its EMS documentation. The ESH staff
started to develop an ESH manual in September 1995. The group was hoping to have the
manual completed in one year; they now expect to complete it by May 1997. The ESH manual
that is being developed by the Ames facility staff is somewhat unique in that it must be able to
accommodate the extreme diversity of their operations the manual must address over 6,500
chemicals (the Chemical Hygiene Program alone is described in approximately 90 pages).
The ESH staff at the facility includes two college students that are working at the facility as
"temporary employees to develop some of the documentation (i.e. procedures) necessary for a
successful EMS. The students have been very helpful they ask a lot of questions and
explain the procedures clearly and without jargon. The ESH staff has also run some mock-drills
or table-top exercises of its procedures.
Because Hach Company is registered to ISO 9001, the ESH staff has been able to learn
valuable lessons from the quality management system staff, including information about
document 'control practices. As the ESH staff began implementing their EMS, they
discovered that they were not as good at document control as they had previously believed.
The ESH staff has indicated that a sound document control system is crucial to a successful
EMS without it, sooner or later someone will be working from an old version of a procedure.
The ESH staff has not used any software packages to revise their document control system;
the system is managed electronically by a top ESH staff member.
Checking and Corrective Action
As mentioned previously, the ESH staff at the Ames facility are developing extensive written
procedures to address their compliance activities including those that pertain to monitoring
and measuring activities. These procedures will be included in the ESH manual. The ESH
staff has the opportunity to build upon the facility's quality management system corrective and
preventive action procedures to help them develop and successfully implement their EMS.
After the initial self-assessment audit which was performed by the Quality Director, the ESH
staff performed an informal interim audit. The Quality Director performed a second formal audit
of the EMS after one year of implementation. The ESH staff was pleased with the audit
process because the quality management system staff had extensive experience with auditing
management systems. The Quality Department acted as an independent party and performed
a very thorough audit. The Quality Department has stressed that the ESH staff must
document how they do things. There were times when the EMS element was in place but
needed to be documented.
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Management Review
The management review requirements in the ISO 14001 Standard have not been implemented
at the Ames facility. The ESH staff members at the facility do not intend to fulfill the
requirements of the management review section of the standard unless they decide to pursue
EMS registration. They do not believe that the management review process adds value to the
EMS until registration is sought. Hach Company believes that all other elements of an EMS
can be implemented without management review.
The Hach Company Experience
'''-'".'.: . -'-'' "" V -
The initial assessment of the Ames facility's, EMS showed that the EMS complied with
approximately 30 percent of the EMS Standard. After six months of fairly dedicated
implementation efforts, the ESH staff successfully implemented approximately 58 percent of the
Standard, and after one year of implementation they have successfully implemented
approximately 71 percent of the ISO 14001 Standard. During this time, the ESH staff's
primary goal was to continue to ensure regulatory compliance. EMS implementation efforts
were carried out whenever time permitted. ' ^
Hach Company believes that there are numerous potential benefits associated with the
successful implementation of an EMS (e.g. assurances to stakeholders; a framework to
maintain support and resources from senior management; market opportunities; a mechanism
to gauge environmental performance and to identify responsibilities beyond compliance).
During the EMS implementation process, the Ames facility started to observe improvements in
its environmental performance. .Waste disposal costs dropped 70 percent in one year. The
EMS was a contributing factor to the cost reduction, along with the company's quality focus and
continuous improvement efforts.
Since the EMS has not been completely implemented and the system is relatively new, the
benefits have been hard to quantify, but they are there. The EMS program helped to
spearhead a major renovation program within the facility for safety and environmental
improvements. Employees have started to. ask questions and are carefully following
procedures. In addition, the ESH Department is getting additional respect from other business .
units. The ESH staff will continue to ensure compliance and they are working closely with plant
managers to minimize the impact of compliance activities on production. The ESH staff is now
in the position to discuss why they want to go beyond compliance and what the business
reasons are for doing so.
One of the challenges that the ESH staff at the Ames facility experienced as they implemented
the EMS, was the difficulty they had driving the EMS down through the organization and up
through the management. The ESH function is often viewed as a separate entity in many
organizations and not an integral part of the business. This perception was initially a barrier to
EMS implementation. ESH is now viewed as a more integral part of the operation.
The implementation of the EMS and its associated costs can be difficult tp quantify. The ESH
staff does not intend to complete a comprehensive analysis of EMS implementation costs
unless the organization chooses to further explore EMS registration. To date, the most
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significant costs are due to personnel expenditures and office supplies. The ESH staff at the
Ames facility has estimated that if the facility had to start from scratch, EMS implementation
over a two-year period would cost approximately $20,000 - $30,000 per year. Hach Company
estimates that a company must be willing to commit at least one person-year to implementation
of an EMS. The ESH staff cautioned that some of the costs of implementation can be hidden,
but must be accounted for (e.g., indirect labor, training, etc.). The Ames facility spent
approximately $5,000 on supplies and printing costs for EMS implementation. The ESH staff
reported that initially the costs of EMS implementation can outweigh the benefits, but an EMS
can help prevent an environmental problem and strengthen an organization's commitment to be
a good corporate citizen.
Currently, there are no plans to integrate the ISO 14001-based EMS and ISO 9001
programs at the Ames facility. The quality management system staff has suggested that
operating parallel systems is the best approach for both the ESH and quality departments at
this time. The quality management system was adapted from existing procedures and could
possibly be more efficient; the EMS has the opportunity to start from scratch and may be able
to develop elements that are more effective and more appropriate for ESH issues. In addition,
the quality management system staff are hesitant about fully integrating an "immature" EMS
into their quality'management system in the event that it might jeopardize the company's ISO
9001 registration status. In the event that the company chooses to pursue EMS registration,
the issue of integration will be revisited, because integration could result in synergy and cost-
savings for both programs.
Hach Company has not determined if it will pursue EMS registration. The company will "wait
and see" if market forces, particularly demands from their international customers, and potential
regulatory incentives will provide sufficient benefits to offset the costs of registration. The ESH
staff may not attempt to comply with the remaining 20 - 25 percent of the ISO 14001 Standard
unless the company decides to pursue EMS registration. In the event that the company
decides to pursue EMS registration, the ESH staff is confident that it will be easy to put the
remaining elements in place, given sufficient notice, time, and planning.
While questions remain about the value of EMS registration, Hach Company has been able to
^make some conclusions about EMS implementation at its Ames facility. There were concerns
initially about the EMS fitting within the company's culture, but the ESH staff is pleased to report
that the EMS. has helped to bring about a positive culture change within the organization. The
EMS approach agrees with the company's audit policies and procedures, because it fosters a
systematic approach that lends itself to reevaluation. In addition, the process of evaluating the
strengths and weaknesses of the facility's EMS has identified opportunities for improvement.
Hach Company believes that it has benefited from assessing and improving the EMS at
Us Ames facility.
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Appendix B
Background on EMS Standards
The Development of ISO 14000 '
The International Organization for Standardization (ISO) is responsible for the development
of the ISO 14000 series of international environmental management standards. ISO was
founded in 1946 and its headquarters is located in Geneva, Switzerland. ISO has developed
international voluntary consensus standards for manufacturing, communication, trade, and
management systems. Its mission is to promote international trade by harmonizing standards.
Over 100 countries have national standards bodies that are members of ISO. The American
National Standards Institute (ANSI) is the U.S. representative to ISO.
In June 1991, ISO created the Strategic Advisory Group on the Environment (SAGE).
SAGE assessed the need for international environmental management standards and
recommended that ISO move forward with their development. In January 1993, ISO created
Technical Committee 207 (TC 207) which is charged with the development of the ISO 14000
series of standards. TO 207 is comprised of various subcommittees and working groups.
Representatives from the ISO member countries contribute their input to TC 207 through
national delegations.
In the United States, the U.S. Technical Advisory Group (U.S. TAG) develops the U.S.
position on the various ISQ 14000 standards. The U.S. TAG is comprised of approximately 500
members representing industry, government, not-for-profit organizations, standards
organizations, environmental groups, and other interested stakeholders. The U.S. TAG has the
largest number of'members of any ISO member delegation. There are several organizations
involved in the administration of the U.S. TAG'S input to TC 207, including: ANSI; the American
Society for Testing and Materials (ASTM); the American Society for Quality Control (ASQC);
and NSF International. ,
TC 207 is developing the ISO 14001 Standard which specifies requirements for an
environmental management system (the ISO 14001 Standard is the standard to which an
organization's EMS would be registered). In addition to ISO 14001, several guidance
documents are also being developed by TC 207. (See Annex B, Table I). The documents being
produced are in various stages of development. ISO 14001, ISO 14004 (an EMS guidance
document), and three environmental auditing guidelines (ISO 14010, ISO 14011, and ISO
14012), were finalized and published in September 1996 Published ISO standards must be
reviewed and revised every five years.
The Emergence of EMS Standards
Numerous factors have contributed to the emergence of EMS standards. The following is a
brief overview of some of the major contributing factors.
-------
ISO 9000
The ISO 9000 series of international quality management standards was published in 1987.
The standards were created to promote consistent quality practices and to facilitate
international trade. The ISO 9000 series of standards .has been adopted by more than 80
countries and is used as a benchmark for quality management by industry and government
bodies worldwide. In some cases, ISO 9000 registration has become a prerequisite for dojng
business domestically and internationally. In North America, over 13,000 companies are
registered to ISO 9000. , ' .
The quality management system framework can serve as a foundation for environmental
management systems. In essence, an EMS is the application of quality management system
principles to the management of environmental affairs. While the ISO 9000 and ISO 14001
standards have different focuses, they share similar requirements. (See Annex B, Table H).
The three specification documents for ISO 9000 series are ISO 9001, ISO 9002, and ISO 9003.
The key difference between ISO 9000 and ISO 14001 is that ISO 14001 requires planning
steps to Identify environmental aspects and significant environmental impacts which become
the basis of continual improvement, whereas ISO 9000 focuses on consistency of process.
Sustainable Development
In 1987, the World Commission on Environment and Development (Brundtland Commission)
coined the term "sustainable development" in its report entitled Our Common Future. This
report emphasized the need to balance environmental protection and economic growth.
/
In 1991, the International Chamber of Commerce (ICC) created the Business Charter for
' Sustainable Development. The ICC Charter is comprised of sixteen Principles for
environmental management that foster sustainable development. The Principles in this
document include some of the basic elements of environmental management systems.
In 1992, the United Nations Conference on Environment and Development (UNCED) was held
in Rio de Janeiro. The conference, also called the Earth Summit (or Rio Summit), resulted in
two noteworthy documents - Agenda 21 and the Rio Declaration. Agenda 21 is a
comprehensive'guidance document for sustainable development, while the Rio Declaration is
a set of 27 principles for achieving sustainable development.
The international initiatives on sustainable development marked the dawning of a new age in
environmental protection. The business community.worldwide was asked to consider its impact
on the environment and to take steps to mitigate that impact.
Private Sector Programs & Public Concern for the Environment
Private sector programs, such as the Chemical Manufacturers Association's Responsible Careฎ
program, the Global Environmental Management Initiative (GEMI), and the Coalition for
Environmentally Responsible Economies (CERES) Principles (formerly the Valdez Principles),
resulted in model codes of conduct that encourage environmental stewardship. In addition,
public concern for the environment has provided strong motivation for the, development of EMS
standards. ' - '
'76'"
-------
National EMS Standards & Regional EMS Legislation
In 1992, the British Standards Institute published BS 7750, the first national standard for
environmental management systems. The British Standards Institute had previously published
BS 5750 (a national quality management system standard) which was a significant contribution
to the development of ISO 9000. ISO 14001 was largely based on BS 7750, and the two
standards share many similar requirements. The BS 7750 Standard, however, is viewed by
many to be more stringent than ISO 14001. For example, BS 7750-requires that an
organization compile a register of its significant environmental effects, and a register of all
legislative, regulatory, and other policy requirements, in addition, BS 7750 requires an
organization to make its environmental objectives publicly available.
Following the publication of the United Kingdom's BS 7750, a proliferation -of national EMS
standards emerged, including standards from Ireland, France, South Africa, and Spain. The
various EMS standards did not all share the same requirements, and in some cases the
requirements were contradictory. It became clear that in order to facilitate international trade,
there would have to be one international EMS standard that would be accepted around the
globe.
In addition to the national EMS standards, regional EMS legislation was developed. The Eco-
Management and Audit Scheme (EMAS) was adopted by the European Union (EU) in 1993.
EM AS is a regulation that enables industries to voluntarily implement formal environmental
management systems in order to improve their environmental performance. While ISO 14001
and BS 7750 apply to organizations (or parts thereof), EMAS is restricted to site-specific
industrial activities. EMAS participants mlist prepare an environmental statement specific to
each site concerned, and provide information to the public about their environmental aspects.
Third-party verification of, the EMS is an essential component of EMAS. Participating
organizations are included on the EU list of participating sites.
'77
-------
Documents Being Produced by TC 207's Subcommittees and Working Groups:
ANNEX B. TABLE I
Subcommittee
1
2
3
4
5
6
Working Group 1
Document #
14001
14004 .
14010
14011
14012
14015
14020
14021
14022
14023
14024
14025
14031
14040
14041
14042
14043
14050
ISO Guide 64
Title
Environmental Management Systems - . .
Specification with Guidance for Use
Guidelines on Environmental Management
Principles, Systems, and Supporting Techniques
Guidelines for Environmental Auditing - General
Principles on Environmental Auditing
Guidelines for Environmental Auditing - Audit
Procedures for Environmental Management Systems
Guidelines for Environmental Auditing - Qualification
Criteria for Environmental Auditors
Environmental Site Assessments
Goals and Principles of All Environmental Labeling
Environmental Labels and Declarations -'
Environmental Claims - Terms and Definitions
Environmental Labels and Declarations - Self
Declaration Environmental Claims - Symbols
Environmental Labels and Declarations - Self
Declaration Environmental Claims - Testing and
Verification
Environmental Labels and Declarations -
Environmental Labeling Type 1 -. Guiding Principles
and Procedures
Type III Labeling
Evaluation of Environmental Performance
Life Cycle Assessment - Principles and Framework
Life Cycle Assessment - Life Cycle Inventory
Analysis
Life Cycle Assessment - Impact Assessment
Life Cycle Assessment - Interpretation
Terms and Definitions
Guide for the Inclusion of Environmental Aspects in
Product Standards
-------
Linkages Between ISO 9000 and ISO 14001
ANNEX B, TABLE II
ISO 9000 (9001", 9002", or 9003*")
Quality Management Systems
Quality Policy
Resources
Organization
Training ,
, Management Representative
Process Control
System Documentation
Document Control
Inspection & Testing
Corrective & Preventive Action
System Audits
Management Review
ISO 14001
Environmental Management Systems
Environmental Policy
Resources
Structure & Responsibility
Training .
Management Representative
Operational Control
System Documentation
Document Control
Monitoring & Measurement
Non-conformance and
Corrective & Preventive Action
System Audits
Management Review
ISO 9001: Quality Systems Model for Quality Assurance in Design/Development, Production, Installation and
Servicing.
ISO 9002: Quality Systems Model for Quality Assurance in Production, Installation and Servicing.
ISO 9003: Quality Systems Model for Quality Assurance in Final Inspection and Test
Note: This table does not represent a comprehensive comparison of ISO 9000 and ISO 14001.
79
-------
Appendix C
r Contacts
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Information and Ot
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Source!
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Comprehensive environmental compliance,
technical assistance, & pollution prevention
information for metal finishing industry.
eac. Complete compliance assistance & pollution
prevention information for printing industry.
202/564-7013
http://cai.eclipse.net/home2.htm
National Metal Finishing
Resource Center
1
202/564-7041
http://www.hazard.uiuc.edu/pnes
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Printers' National
Compliance Assistance
Center
> for Information on a variety of topics, e.g., used
oil management, storm water, USTs,
antifreeze, hazardous waste, and pollution
prevention alternatives.
||
1-888-GRN-LINK - or - 202/564-
voice, facsimile or mailed inform!
http://www.ccar-greenlink.org
GreenLink - The
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community.
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http://es.inel.gov/oeca/ag/aghrnp
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202/564-7124
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waste minimization and pollution prevention.
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Glossary of Acronyms
ANSI American National Standards Institute
API STEP American Petroleum Institute's "Strategies for Today's'Environmental Partnership"
CAA Clean Air Act
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
CERES Coalition for Environmentally Responsible Economies
CFC's Chlorofluorocarbons
CMA Chemical Manufacturers Association
CWA Clean Water Act
EHS Environment, Health and Safety
EMAS Eco-Management and Audit Scheme
EMS Environmental Management System
EPA (Also USEPA) U.S. Environmental Protection Agency
EPCRA Emergency Planning and Community Right-to-Know Act
FIFRA Federal Insecticide', Fungicide and Rpdenticide Act
HMTA Hazardous Materials Transportation Act
ICC International Chamber of Commerce
ISO International Organization for Standardization -
ITI Industrial Technology Institute
MEP Manufacturing Extension Partnership
OSHA Occupational Safety and Health Administration . .
PCBs Polychlorinated Biphenyls
RCRA Resource Conservation and Recovery Act ' '. . '
SBA U.S. Small Business Administration
SPCC Spill Prevention Control and Countermeasure
TC207 Technical Committee 207
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Bibliography
Canadian Standards Association, Competing Leaner, Keener and Greener: A Small Business
Guide to ISO 14000, 1995.
Cascio, Joseph, editor. The ISO 14000 Handbook. GEEM Information Services with ASQG
Quality Press, 1996.
Diamond, Craig P., "Voluntary Environmental Management System Standards: Case Studies
in Implementation." Total Quality Environmental Management, (Winter 1995/1996), pp. 9-23.
Institute of Quality Assurance, Quality Systems in the Small Firm: a Guide to the Use of the
ISO 9000 Series, March 1995.
International Organization for Standardization, ISO 14001: Environmental Management
Systems - Specification with Guidance for Use. 1996.
International Organization for Standardization, ISO 14004: Environmental Management
Systems -General Guidelines on Principles, Systems, and Supporting Techniques. 1996.
Kuhre, W. Lee, ISO 14001 Certification: Environmental Management Systems .Prentice Hall,
1995.
Michigan Department of Commerce and Natural Resources, Environmental Services Division,
Business Waste Reduction: Creating An Action Plan. November 1994.
Tibor, Tom with Ira Feldman, ISO 14000: A Guide to the New Environmental Management
Standards, Irwin Professional Publishing, 1996.
The United Nations Environment Programme (UNEP), the International Chamber of
Commerce (ICC), and the International Federation of Consulting Engineers (FIDIC).
Environmental Management System Training Resource Kit. Version 1.0, December 1995.
The United States Postal Service, Environmental Resources Handbook. November 1995.
Voehl, Frank; Jackson; and Ashton, ISO 9000: An implementation Guide For Small and Mid-
SizedBusinesses, St. Lucie Press, 1994.
90
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APPENDIX D
TOOLKIT
Sample Environmental Policies,......,. ..92
Sample Process Flow Chart ;.................. 96
Descriptions of Environmental Aspect Identification Techniques... 98
Sample Procedure: Environmental Aspects Identification........ 100
Resources for Tracking Environmental Laws and Regulations 104
Sample Procedure: Tracking Environmental Laws and Regulations, 106
Worksheet: Setting Objectives and Targets................ 109
Sample Procedure: Setting Objectives and Targets........ ... 113
Sample Tool: Environmental Management Program :........... .. 116
Sample Schedule for EMS Action Plan ...118
Responsibility Matrix : 120
Environmental Training Log 123
Sample Procedure: Internal Communications........ 125
Sample Procedure: Communications with External Parties 128
Sample Document Index 131
Outline of Sample EMS Manual, Other Documents 133
Sample Procedure: Document Control ;: ..,- 135
Sample Procedure: Corrective Action (Includes Tracking Log) 139
Environmental Records Organizer 144
Sample Procedure: EMS Audits....... , 148
Sample Procedure: Management Review.... ...154
i '
' - ' ' 91 .
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Sample Environmental Policies
i
92
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-------
Sample Policy Actual policy reproduced with permission. Policy is not in original format.
NEO INDUSTRIES
HEALTH, SAFETY AND ENVIRONMENTAL POLICY
Neo Industries is committed to managing health, safety and environmental (HS&E) matters as an
integral part of our business. In particular, it is our policy to assure the HS&E integrity of our processes
and facilities at all times and at all places. We will do so by adhering to the following principles:
Compliance
We will comply with all applicable laws and regulations and will implement programs and procedures
to assure compliance. Strict compliance with HS&E standards will be a key ingredient in the training,
performance reviews and incentives of all employees.
Where existing laws and regulations are not adequate to assure protection of human health, safety and
the environment, we will establish and meet our own HS&E quality standards.
Prevention
We will employ management systems and procedures specifically designed to prevent activities and / or
conditions that pose a threat to human health, safety or the environment. We will minimize risk and
protect our employees and the communities in which we operate by employing safe technologies and
operating procedures, as well as being prepared for emergencies.
We will strive to prevent releases to the atmosphere, land or water. We will minimize the amount and
toxicity of waste generated and will ensure the safe treatment and disposal of waste.
Communication
We will communicate our commitment to HS&E quality to our employees, vendors and customers. We
will solicit their input in meeting our HS&E goals and in turn will offer assistance to meet their goals.
Continuous Improvement
We will continuously seek opportunities to improve our adherence to these, principles, and will
periodically report progress to our stakeholders. .
{Signature}
' Neil K. Holt
President
March 1995
93
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Sample Policy Actual policy reproduced with permission. Policy is not in original format.
PacificjGas and Electric Company
Environmental Quality policy statement
PG&E is committed to a
clean, healthy environment.
We will provide our
customers with safe, reliable,
and responsive utility
service in an environmentally
sensitive and responsible
manner. We believe that
sound environmental policy
contributes to our competitive
strength and benefits our
customers, shareholders, and
employees by contributing to
the overall well-being
and economic health of the
communities we serve.
September 1995
(Actual policy is printed on recycled paper)
We will:
Comply fully with the letter and spirit of
environmental laws and regulations, and strive to
secure fundamental reforms that will improve their
environmental effectiveness and reduce the cost of
compliance, - -
Consider environmental factors and the full
acquisition, use, and disposal costs when making
planning, purchasing, and operating decisions.
Work continuously.to improve the effectiveness of
our environmental management.
Provide appropriate environmental training and
educate employees to be environmentally responsible
on the job and at home.
Monitor our environmental performance regularly
through rigorous evaluations.
Seek to prevent pollution before it is produced,
reduce the amount of waste at ourfacilities, and
support pollution prevention by our customers and
suppliers.
Manage land, water, wildlife, and timber resources in
an environmentally sensitive manner.
\
Use energy efficiently throughout our operations! and
support the efficient use of gas and electricity by our
customers and suppliers.
Re-use and recycle whenever possible.
Use environmentally preferred materials.
Clean up residual pollution from past operations in a
cost-effective manner.
Work cooperatively with others to further cdmmon
environmental objectives.
Communicate and reinforce this policy throughout
the company.
94
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Sample Policy Actual policy reproduced with permission. Policy is not in original format.
EMS Addendum
Statement of Corporate Environmental Policy
Milan Screw Products Inc. is committed to continual improvement qf its
Environmental Management System (EMS), which includes waste minimization,
the prevention of pollution, and compliance with all relevant federal, state, and
local environmental legislation and regulations, The company will meet or exceed
the environmental requirements of other organizations to which Milan Screw
Products subscribes. To sustain this commitment, the requirements of the
Environmental Management System described in this Manual applies to all
activities, equipment, material and employees.
The company's Environmental Compliance Officer is the company's EMS
Management Representative who has the responsibility and authority to plan,
enforce, and maintain the company's Environmental Management System. This
responsibility also includes, stoppage of activities that deviate from the
requirements of this Manual. The Environmental Compliance Officer, with the
assistance of the Environmental Task Group, will propose annual targets and
objectives to be approved by the Management Review Board.
The EMS Management Representative may delegate some of this authority
downward through the organization in order to effectively implement the system.
Charles Tellas
President and CEO
December 10, 1995
95
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Sample Process Flow Chart
96
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Packaging
- skids & pallets
kraft wraps
I Supplies
- spray powder
shop towels
Raw
Materials
- plates
- paper & ink
-water
Chemicals
-cleaning
solvents
- ink preservers
-.plate gums
' ' . ' >, ป
1 '
PRODUCTS
brochures
catalogs
art prints
annuals
waste paper
1 r
[ recycled ^
fugitive air
emissions
I-
. [ atmosphere
d
.( recycled
*
i i '
PRINTING
1
webc
emiss
.1
thei
. oxid
i
r . ,
L
ryer ' I
ions I
l^l^i^^^p^^
r
mal !
izer '.
Kw^^^^^m |
p
[ atmosphere i
14
)
1 '
isti Nation
1 r
5 PRESS 1,
*
* waste plates
i '
1 r
C centrifuge .
i F '
recovered
solvents
If. :
secondary use in
parts washers
back to company \
.
r i ^
r~^ recycieo j
1 fcf f. ,.-.) Kl<->ni-| fe
^|Tuemienoj
K recycled |
*{ sewer |
K recycled 1
__L^J> . ^
, . i ปi recycieo J
j Vf1 . . ^
* s i
*{ recycled j
, 1 r
spun shop
towels
1 r
commercial .laundry
i
[ sewer 1
97
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Descriptions of Environmental
Aspect Identification
Techniques
98
-------
s
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TECHNIQUES FOR IDENTIFYING AND EVALUATING
ENVIRONMENTAL IMPACTS
Used to identify and assess potential impacts associated
with unplanned releases of hazardous materials..
Methods in common use (due to OSHA Process Safety
Management regulations), but some subjective. Typically
uses team approach to identify and rank hazards.
Process Hazard Analysis
Used to quantify emissions of pollutants to the air. Some
data may already by available to the organization, based
on EPCRA requirements and CAA Title V permitting
program.
Emission Inventory
Used to satisfy requirements of National Environmental
Policy Act (NEPA) regarding the evaluation of
environmental impacts associated with proposed
projects. Methodology is in common use, but is not
typically used to assess environmental impacts
associated with existing operations.
Environmental Impact
Assessment
Used to assess full range of impacts from products, from
raw material procurement through product disposal.
Emerging methods somewhat subjective and can be
resource intensive. Methods will be described in
developing ISO 14000 standards.
Life Cycle Assessment
Used to incorporate environmental considerations into
product design. Methods currently under development.
Design for the
Environment
Pollution Prevention or
Waste Minimization
Audits
Used to identify opportunities to reduce or eliminate
pollution at the source and to identify recycling options.
Requires fairly rigorous assessment of facility operations.
Typically does not examine off-site impacts.
Used to assess potential environmental liabilities
associated with facility or business acquisitions or
divestitures. Scope and level of detail is variable.
Typically does not assess impacts associated with
products or services.
Environmental Property
Assessments
Used to assess potential health and/or environment risks
typically associated with chemical exposure. Variety of
qualitative and quantitative methods in common use.
Risk Assessment
Environmental Cost
Accounting
Used to assess full environmental costs associated with
activities and/or products. Emerging protocols require
comprehensive assessment to quantify costs.
Used to assess compliance with federal, state and local
environmental regulations. Methods in common use.
Scope and detail vary, but typically not directed at
examining environmental impacts (particularly for
products).-
Environmental
Compliance Audits
Used to assess and mitigate potential safety hazards
associated with new or modified projects. Methods in
common use, but do not typically focus on environmental
issues. . -
Project Safety / Hazard
Reviews
99
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Sample Procedure:
Environmental Aspects
Identification
loo
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EMS Procedure: Environmental Aspects Identification
I. Purpose
To identify the environmental aspects of the organization's activities, products and
services in order to determine those which may have a significant impact on the
environment. _ .
II. Scope
This procedure covers all activities, services and products of the organization. For
purposes of evaluation, activities, services and products with similar characteristics
may be grouped.
A baseline evaluation will be conducted of existing products, activities, and
services. The need for follow-up evaluations is determined based on changes in
evaluation methodology or significant changes in the organization's mission,
products, or processes.
III. Definitions
Environmental aspects- Components of the organization's activities, products
and services that are likely to interact with the environment.
7 -'."' ",''' -
Environmental impact- Any change to the environment, whether adverse of
beneficial, wholly or partially resulting from the activities, products and services of
the organization.
IV. General
This procedure covers those environmental aspects of activities, products and
services that the organization can control or over which it can be expected to have
an influence. Significant environmental aspects identified through this process are
considered in the setting of environmental objectives and targets.
The procedure consists of an initial screening of activities, products and services,
based on available data by a cross-functional team of organization personnel. The
cross-functional team assesses the environmental aspects, determines which of
these might result in significant impacts, then sets priorities for further analysis, as
needed.
The Company reviews the information developed during the evaluation on a
regular basis to ensure that it is up-to-date.
101
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V. Procedure
i, ' 1 ,',,,',
A. The environmental manager assembles a cross-functional team to perform the
evaluation. The team may include representatives from environmental, health &
safety, product design, engineering, line management, maintenance, and
shipping / receiving, or other functions as appropriate. Separate teams may be
formed to evaluate particular groups of products, activities and services. The
team may call upon other individuals in the organization, as needed.
B. The team considers each of the stages in the life cycle of the organization's
products, services and activities, including (where appropriate):
pre-production or service strategy (design, procurement, etc.),
manufacturing,
production/distribution,
use / service, and
disposal / waste management.
Each product, service or activity is evaluated for environmental impacts in each
of these areas; however, products, services or activities may be "grouped" such
that those with similar characteristics can be evaluated concurrently. The team
rates the product, service or activity (or groups of same) against the factors
shown on Table 1 to identify those that may result in significant impacts.
C. For purposes of this evaluation, "activities" are those activities that are not
directly linked to a specific product, service or activity (such as equipment
maintenance). .-Activities that are directly linked to the manufacture of a
particular product are evaluated when that product is evaluated.
D. Results of team findings are documented. If the team determines that
additional information is needed to evaluate a particular product or activity, the
Team Leader assigns the responsibility for collecting that information to an
appropriate team member.
E. The .environmental manager is responsible for working with plant management
to ensure that significant environmental aspects identified by the team-are
considered in setting environmental objectives and targets for the site. (See
Procedure #).
F. The results of the most recent environmental aspect / impact identification are
reviewed as part of the Management Review process (See Procedure #).
Based on this review, the organization's management determines the need to
update the environmental impact evaluation. Factors such as improved
assessment methodologies, or major changes to the organization's mission,
products, and processes are considered in determining the need to update the
assessment.
,102
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TABLE 1. SCORING GUIDE FOR
ENVIRONMENTAL ASPECTS EVALUATION
For each product, service or activity (or group of products, services or activities),
each element in the table will be assigned two scores:
Degree of Impact
4 = SeriOUS (likely to result in severe or widespread damage to human health or the environment)
3 = moderate
2 = minor
1 = no impact (unlikely to have an adverse impact on human health or the environment)
Frequency of Impact
4 = continuous (impact occurs on an on-going basis)
3 = frequent (impact occurs more than once/month)
2 = infrequent (impact occurs more than once / year, less than once / month)
1 = improbable / never (impact has never occurred or is highly unlikely)
Category
Human Health
Environment
Resource Use
Indicator
Employees
Surrounding
Community '
Global
Air Quality
Surface Water
Ground Water
Land / Soil
Ecosystem
. Effects
Noise
Fuels
Water
Raw Materials
Pre- Manufacturing Production/
Production Distribution
Use / Service Waste
Management
103
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Resources for Tracking
Environmental Laws and
.f
Regulations
104
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Resources for Tracking Environmental Laws and Regulations
(Note: This table describes a variety of commercial and non-commercial
sources of information on federal and state environmental laws and
regulations. This list is not intended to be comprehensive. Appearance on
this list should not be construed as an endorsement by NSF of any
commercial products listed here).
1 Source
USEPA
1-800-368-5888
Small Business Assistance
Programs (various states)
US Small Business
Administration . .
US Government Printing Office
1-202-512-1800
Trade and Professional .
Associations (various)
Counterpoint Publishing
.1-800-998-4515
Bureau of National Affairs
1-800-372-1033
Thompson Publishing Group
1-800-677-3789
Achieve Technology, Inc.
Business and Legal Reports,
Inc.
1-800-727-5257
Elsevier Science, Inc. "
1-212-633-3950 .
Description
Regulatory explanations and guidance, research, case
studies, contacts for additional information. Variety of hotlines
available for particular statutes (such as RCRA). Internet
access also available (http://www.epa.gov)
Guidance on regulations and compliance issues. Initially
focused on clean Air Act requirements, but expanding into
other environmental media.
Various services available to small businesses in the US. .
_
Federal Register published daily with all federal proposed and
final rules. (Also available on line via GPO Access)
Provide a variety of services related to environmental laws
and regulations, including regulatory updates and training.
Contact individual associations for details.
CD-ROM and Internet dial-up access to legal / regulatory
information for federal government and all 50 states, updated
daily. .
Information on EHS laws, regulations and activities at .
international, national, and state level. Paper and electronic
access available.
Manuals on a variety of federal and state environmental
programs with monthly updates and newsletters. .
Access to federal and state regulations with monthly, quarterly
or annual updates on available on CD-ROM or diskette.
Access to federal and state regulations with monthly, updates
on available on CD-ROM.
Publishes compliance rnanuals with regular update service for
RCRA and Clean Air Act.
105
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Sample Procedure:
Track!ng Environmental Laws
and Regulations
106
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EMS PROCEDURE: REGULATORY TRACKING
AND ANALYSIS
I. Purpose
To ensure that the organization identifies, has access to, and evaluates laws,
regulations, and internal organizational requirements that apply to the
environmental aspects of its activities, products, and services.
II. Scope
This procedure covers laws, regulations, and other requirements established at
the federal, state, and local level that apply to the environmental aspects of the
organization's activities, services and products. The organization takes these
requirements intd account when setting its environmental objectives, as discussed
in Procedure #.
III. Definitions :
Applicable laws and regulations- Legal requirements promulgated by federal,
state or local government authorities that apply to environmental aspects of the
organization's products, activities dr services.
IV. Procedure
A. The environmental manager is responsible for tracking applicable laws and
regulations, identifying those related-to the organization 's activities, products
and services. The environmental manager is also responsible for evaluating
the potential impacts of these laws and regulations on the organization and its
products, activities and services.
B. The environmental manager employs a variety of techniques and information
sources to track, identify and evaluate applicable laws and regulations. These
include, but are not limited to: commercial services/ databases; information
provided by its trade association; communications with federal and state
regulatory agencies; company environmental meetings; and periodic
environmental refresher training. The environmental manager monitors these
information .sources on a regular basis to ensure that new issues are identified
on a timely basis. ,
-C. As necessary, "off-site" resources (such as consultants and attorneys) may be
called upon to assist the environmental manager in evaluating applicable laws
and regulations or in developing programs in response to applicable laws and
regulations. Where off-site resources are used in this manner, the
organization's environmental manager coordinates such efforts.
107
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IV. Procedure (cont'd.)
D. The environmental manager disseminates information on applicable laws and
regulations (and their potential impacts on the organization's activities,
products and services) to appropriate personnel. The determination of which
organization personnel must be informed and the method for providing this
information is at the discretion of the environmental manager, based on the
circumstances of the case.
E. The environmental manager compiles and maintains copies of significant
applicable environmental laws and regulations. Where copies of such laws
and regulations are not maintained at the organization's offices, the
environmental manager ensures that ready access is available from other
sources, such as those listed above.
F. If site audits indicate that additional laws and regulations must be tracked and
evaluated, the environmental manager ensures that these activities take place.
108
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Worksheet:
Setting Objectives & Targets
109
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Worksheet: Setting Objectives and Targets
Step 1: A cross-functional team is a good way for your organization to set realistic
objectives and targets. List here who needs to be involved on the team:
Name
Contacted?
Step 2: Think about what information sources your team will need to establish
objectives and targets.. Pull together information sources such as:
Information Sources
process maps
waste, and emission data -.
site maps .
compliance audit reports
descriptions of identified environmental
aspects
communications from interested parties
others??
(you may also want to do a plant tour of
"walk through" to identify other issues)
How the will hel
identify process steps with environmental aspects
determine current wastes and sources
etc.
Step 3: Is there other information that might be helpful to the' team?
Other Information Needed
where we will get it
110
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Step 4: List the significant environmental impacts (you identified these earlier).
Categorize these impacts by type:
Energy
Use
Raw
Materials
Air
Impacts
Water
Impacts
Waste
Impacts
Land
Issues
Other
(specify)
Step 5: Look at processes (such as/plating or assembly) and activities (such as
shipping or purchasing). Are there any other issues the team should consider,
in addition to those listed above as significant impacts? (For example, you
might want to establish an objective to reduce spills of hazardous materials at
the loading dock, even if this was not identified as a potentially significant
environmental impact.)
Process or activity
issues.
possible UDjectives & Targets
Step 6: List any new regulatory requirements that affect the facility (or other
regulations fpr which the need for additional actions has been identified).
Regulations, other requirements
Possible Objectives & Targets
Step 7: List communications with interested parties. Any need for additional
objectives related to views of neighbors, community groups or other parties?.
Communications With Interested Parties
Possible Objectives &
Targets
111
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Step 8: Look at the lists of possible objectives developed in Steps 4 -7.
Brainstorm with the team on whether these objectives are:
reasonable
technologically feasible
consistent with the business plan
affoVdable.
List preliminary objectives and targets based on this exercise:
Selected Preliminary Objectives
Step 9: Determine how you will measure each of the selected preliminary objectives.
(If you cannot establish an effective way to measure it, put that objective "on-
hold" for later consideration).
Selected Objectives
Performance Indicator(s)
Step 10: For each objectives that you selected, determine who is going to develop the
action plan (who, what, when, where, how). List these names below:
Selected Objectives
Responsibility for Action Plan
112
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Sample Procedure:
Setting Objectives & Targets
113
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EMS PROCEDURE: SETTING AND TRACKING OF ENVIRONMENTAL
OBJECTIVES AND TARGETS
I. Purpose
The purpose of this procedure is to ensure that the organization establishes and
maintains documented environmental objectives and targets.
II Scope
/This procedure applies to environmental objectives and targets set at all relevant
levels within the organizatipn. .
III. Definitions '
Environmental (or environmental) objective- A site goal that is consistent with
the environmental policies and considers significant environmental impacts and
applicable laws and regulations. Objectives are quantified wherever practicable.
Environmental (environmental) target- A detailed performance requirement
(quantified wherever practicable) based on an environmental objective. A target
should be met in order for the underlying objective to be achieved. .
' '- '
IV. General . :
The organization establishes environmental objectives and targets in order to
implement the environmental policies. Objectives and targets also provide a
means for the organization to measure the effectiveness of.its environmental
efforts and improve the performance of the environmental management system.
In establishing environmental objectives, the organization considers:
applicable laws and regulations (and requirements of other programs, such as
/' . ' .- '''- ' ' , " ' -,
environmental aspects of the organizatioh's'activities and products; .
technological, financial, operational, and other business requirements; and,
the views of employees and other interested parties.
Based on the organization 's environmental objectives, targets are established for
different functions within the organization and for different areas of the plant. For
example/the organization may establish an environmental objective to "reduce
waste generation by 10% per year". Based on this .objective, different areas of the
plant might set targets for reducing individual waste streams in order to ensure
that the organization's objective was achieved. An organization-wide .
environmental objective might also be translated into individual projects .(such as
114
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changes in production processes, materials or pollution control equipment) in
different plant areas. . ,
V. Procedure
A. The organization's top management js responsible for establishing
environmental objectives on an annual basis. To initiate the process, the Plant
Manager holds a meeting of all staff members to discuss the development of
environmental objectives. -
B. Objectives are action- and prevention-oriented and are intended to result in
meaningful improvements in the organization 's environmental performance.
C. Each plant area or functional manager is responsible for providing input from
his / her own function (Finance, Engineering, etc.) or shop area (Fabrication,
Assembly, Shipping / Receiving, etc.). The organization's environmental
manager is responsible for providing input on applicable laws and regulations,
significant site environmental.impacts, and the views of interested parties.
(These inputs are obtained from the separate analyses required by Procedure
#'s). .'''''.'
D. As a starting point, the organization's management evaluates its performance
against environmental objectives for the current year. As part of this effort,
management examines the results of its environmental performance
evaluations.
E. Preliminary environmental objectives are developed for further discussion and
evaluation. Each manager is responsible for evaluating the potential impacts
within his / her functional or shop area (if any) of the proposed environmental
objectives. The organization's environmental manager reviews proposed
objectives to ensure consistency with the overall environmental policy.
F. Environmental objectives are finalized, based on review comments from site
managers and employees. Each manager identifies the impacts of the
objectives in his / her function or shop area, establishes targets to achieve the
objectives, and develops appropriate measures to track progress towards
. meeting the objectives and targets.
G. Each manager is responsible for communicating objectives and targets (and
the means for achieving'them) to others in his /. her part of the organization.
H. Proqress towards the objectives and targets is reviewed on a regular basis at
management meetings. The progress is also communicated to plant employees
via bulletin boards and other similar means.
1 At the end of each calendar year, the organization's management reviews its
performance with regard to achieving the objectives and targets. This
information is used as input to-setting objectives and targets for the succeeding
year.
115
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Sample Tool:
Environmental Management
116
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Sample Schedule
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Sample Schedule for EMS Action Plan
Tasks . .
Management Commits
Choose Champion
Prepare Schedule / ,
Budget (prelim.)
Project Team Meetings
Involve Employees
Preliminary Review
Modify Plan
prepare Documents
Train Employees
Assess Performance
-119
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Responsibility Matrix
120
-------
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Legend:
L = Lead Role
-S = Supporting Role
Responsibility Matrix
Communicate importance of
environmental management
Coordinate auditing efforts
Track / analyze new
regulations (and maintain
library) .
Obtain permits and develop
compliance plans
Prepare reports required by
regulations
Coordinate
:ommunications with
interested parties
Train employees
Integrate environmental into
recruiting practices
Integrate environmental into
performance appraisal'
process
Communicate with
contractors on
environmental expectations
Comply with applicable .
regulatory requirements
Conform with organization's
EMS requirements
Maintain equipment / tools
o control environmental
impact
Monitor key processes
Coordinate emergency
response efforts
Identify environmental
aspects of products,
activities, or services
Establish environmental
objectives and targets
Develop budget for
environmental management
Maintain EMS records
trailing, etc.)
Coordinate EMS document
control efforts .
' .
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M'gr
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EHS
M'gr
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121
-------
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Legend:
L = Lead Role
S = Supporting Role
Responsibility Matrix
- ' '.''
Communicate importance of
environmental management
Coordinate auditing efforts
Track / analyze new
regulations (and maintain
library)
Obtain permits arid develop
compliance plans
Prepare reports required by
regulations , . *
Coordinate
communications with
interested parties
Train employees
Integrate environmental into
recruiting practices
Integrate environmental into
performance appraisal
process
Communicate with.
contractors on
environmental expectations
Comply with applicable'
regulatory requirements
Conform with organization's
EMS requirements
Maintain equipment / tools
to control environmental .
impact
Monitor key processes
Coordinate emergency
response efforts .
Identify environmental
aspects of .products,
activities, or services
Establish environmental
objectives and targets
Develop budget for
environmental management
Maintain EMS records
(training, etc.)
Coordinate EMS document
control efforts
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122
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Environmental Training Log
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1 Hazardous Waste
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I Emergency Response
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Sample Procedure:
Internal Communications
125
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EMS PROCEDURE: INTERNAL COMMUNICATIONS
I. Purpose
The purpose of this procedure is to ensure effective and timely communication of , .
environmentally-related information within the organization.
II. Scope
This procedure describes processes for internal communications on various elements of
the organization 's environmental management system, including the environmental policy
and objectives. This procedure also can be used for employee reporting of health &
safety hazards, or for other related purposes.
111. General > . .
A variety of processes are used for internal communication on environmentally-related
matters. The effectiveness of these communication processes are evaluated on an on-
going basis, through employee surveys, environmental training programs, organization
audits and inspections, and informal discussions.
Major topics of internal communication include:
environmental policy, objectives, and targets; ;
environmental management roles and responsibilities; *.
organization performance compared to environmental objectives and targets;
environmental policies and procedures; and, '
hazards and emergency situations.
IV. Procedure . . .
General ' .
A. The Plant Manager is responsible for communicating the organization 's environmental
policies and procedures to all employees. The Plant Manager is also responsible for
communicating roles and responsibilities for environmental management.
/''.'''. ' .,-'. . ' , . ,
'- - ,_,.".',',". i . - -
B. Area and functional managers are responsible for communicating environmental
targets (and performance vs. objectives and targets) to employees in their areas or
functions, as well as to the management team. - ' '-'.'..=
126
-------
W. Procedure (confd.)
C. Area and functional leaders are responsible for communicating environmental
procedures (and any changes to the. procedures), results of accident and "near miss"
investigations in their areas, and other significant environmentally-related information
(such as upcoming training classes). ' ;
D. The selection of the most appropriate mechanism(s) used for internal communication is
left to the discretion of the responsible manager. Mechanisms that are used for various
types of communications include, but are not limited to:
* "all employee" meetings,
area environmental meetings,- , .
workstation procedures, ,
bulletin boards and posters, .
memoranda and employee letters, and
* newsletters. . -
* ,'_**" _
Hazard and Emergency {Reporting ,
A. AH employees are responsible for reporting environmental or health & safety hazards or
emergencies (including spills and fires) immediately upon discovery. Such hazards are
reported to the Area Manager. If necessary, such hazards should also be reported to
the appropriate emergency contacts (as identified in the emergency response
procedures {Procedure #}). The Area Manager in turn notifies the organization's
environmental manager.
B. If the Area Manager is not available, employees report environmental or health & safety
hazards directly to the environmental manager.
' ' f
C. The organization's environmental manager maintains a log of all reported
environmental or health & safety hazards. The environmental manager tracks the
investigation and correction (as needed) for all reported hazards.
D. Communication of the results of investigating / correcting reported hazards is the
responsibility of the appropriate Area Manager.
E. Emergency response procedures are described in Procedure #.
127
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Sample Procedure:
Communications with
External Parties
128"
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EMS PROCEDURE: COMMUNICATIONS
WITH EXTERNAL PARTIES
I; Purpose
This procedure is intended to establish a process for outreach and communication with
external parties regarding the organization 's environmental management system (Note:
the organization should also consider external communication regarding its significant
environmental aspects);
' . ' I . ' ' .
II. Scope
This procedure describes how the organization receives, documents, and responds to
.communications from external parties. In addition, it discusses proactive steps that the.
organization takes to maintain a meaningful dialogue with external parties on
environmental matters. -..:.-.
111. Definitions .
Interested Parties- Individuals or groups with an interest in the environmental impacts of
the organization's products, activities or services/ These parties include regulators, local
residents, employees, stockholders, insurers, customers, environmental groups and the
general public (adapted from ISO 14001). . .
IV. General .
' . ' " i . .
The organization uses a number of mechanisms to ensure effective communicatio'n with
interested parties. These mechanisms include regulatory filings (such as permit
applications and reports), open houses, the media, and. informal discussions with
regulators, community representatives, and local business leaders.
^ - _ ' , ' - ,
To solicit the views of interested parties, the organization may use additional techniques,
including (but not limited to) surveys, community advisory panels, newsletters, or informal
meetings with representatives of external groups,
General rules for external communications require that the information provided by the
organization: .
be understandable and adequately explained to the fecipient(s); and
present an accurate and verifiable picture of the organization arid its environmental
management system, its environmental performance, or other, related matters.
129
-------
VT Procedure ' . .
A. Management of Communications from External Parties
1 Inquiries and other communications (received by mail, fax, telephone, or in
person) from external parties concerning the organization's EMS or
environmental performance may be received by a number of the organization s
representatives, including the Plant Manager, the environmental manager, and
the human resources manager, among others. All such communications are
reviewed by the Plant Manager or his / her designee to determine the
appropriate response. .
2 Communication with representatives of regulatory agencies is delegated to the
organization's environmental manager, who maintains records of all such '
communications (both incoming and outgoing). In the absence of the
environmental manager,, communications with regulatory officials are delegated
to the human resources manager.
3 Copies of all other written communications on environmental matters are
maintained by the human resources manager. All non-written communications
from external parties are documented using telephone logs or similar means.
All records of external communications are maintained as discussed in
Procedure # (Records Management).
4. A record of the responses to all communications from external parties is
maintained by the human resources manager in files designated for that
. purpose.
B. Outreach to Interested Parties
'1. On an as-needed basis, the organization solicits the views of interested parties
on its environmental management system, its environmental performance, and
other related matters. In particular, such outreach is conducted when significant
changes at the facility are being considered, such as facility expansion or other
actions that might affect the actual or potential environmental impacts of the
organization's products, activities, or.services. . .
2. As part of the Management Review process, the team designated to conduct
the Review evaluates proactive efforts to communicate with external parties.
Based on this evaluation and other factors, the organization's management
determines the need for outreach with external parties in the coming year and
how such communications can be. carried out most effectively.
External Hazard and Emergency Communication
Note: All external communication regarding emergency response are addressed in
Procedure #.
* * ' * , '
130 .
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Sample Document Index
131
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-------
Sample Document Index .
(sample indicates individual that revised document, his/her position/department, arid date(s) of revision)
Document
Environmental Policy
Environmental Manual
Procedure 1: -
Environmental Aspects
Identification
Procedure 2: Access to
Laws and Regulations
Procedure 3: Setting
Objectives & Targets
Procedure 4:
Environmental Training
Procedure 5: External
Communications
Procedure 6: Internal
Communications
Procedure 7; Document
Control
Procedure 8:
Emergency
Preparedness
Procedure 9: Corrective
Action
Procedure 10: Records
Management
Procedure 11: EMS
Audits ,
Procedure 12:
Management Reviews
Procedures 13-X (list
individually)
EMS Audit Checklist
Other plans &
documents related to
above procedures (list
separately , e.g. SPCC
Plan, Emergency
Response Plan, etc.).
Other forms and
checklists (list) .
1
John Smith
Plant Manager
1/1/95
. .
;.
2
John Smith
Plant Manager
1/1/96
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132
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Outline of Sample EMS Manual,
Other Documents
133.
-------
-------
Outline of Sample EMS Manual, Other Documents
Basic EMS Manual
1 Index / Revision History / Distribution List
Environmental Policy
Description of How Our EMS Addresses Each of the EMS Elements
-'How We Identify-Significant Environmental Aspects
- How We Access Legal and Other Requirements
- How We Establish Objectives and Targets
- How the Organization Supports EMS (organization charts, key responsibilities)
, - How We Train our Employees ' '
- How We Communicate (internally and externally)
- How We Control EMS Documents
- How We Identify and Control Key Processes
- How We Prepare for and Respond to Emergencies
- How We Monitor Key Characteristics of Operations and Activities ,
- How We Handle and Investigate Nonconforrnance
-etc:
. Environmental Management Program Manual
Annual Objectives and Targets
> Action Plan (to achieve objectives and targets)
Tracking and Measuring Progress
EMS Procedures Manual .
> Index I Revision History / Distribution List
> Organization-wide Procedures (in some cases, could be several procedures)
- Environmental Aspects identification
-Access to Legal and Other Requirements
- Training, Awareness and Competence
- Internal Communication , '
- External Communication '
- Document Control ..-.'" -p . ''.'- .
' -Change Management.Process(es)
- Management of Suppliers / Vendors .
- Emergency Preparedness and Response
- Monitoring and Measurement
- Calibration and Maintenance of Monitoring Equipment
- Compliance Evaluation
- Corrective and Preventive Action
- Records Management
- EMS Auditing
- Management Review .
Procedures / Work Instructions for Specific Operations or Activities
.-Waste Management
- Wastewater Treatment (These are examples pnly)
- Operation of the Paint Line
- Operation of Plating Line
Forms, Drawings, and Checklists (that support the EMS procedures)
.134
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Sample Procedure:
Document Control
135
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EMS PROCEDURE: CONTROL OF EMS DOCUMENTS
".'. ' .' .'.-''... . .
I. Purpose
This procedure establishes a process for the review, distribution, and implementation of
documents that describe and control the EMS.
II. Scope
This procedure applies to the following documents;(and any changes to them) which must be
controlled: . : . ,
the environmental manual; .
facility-wide environmental procedures; ,
process - br.activity-specific procedures and work instructions; and
forms, checklists, and drawings used for EMS purposes. .
HI. General
A: Distribution lists are maintained by the ISO Management Representative (or designee).
Document distribution may be either controlled or uncontrolled,
B. Depending on the type of document, controlled copies are identified by stamp, signature,
or other similar means. ;
C. Uncontrolled copies of documents may exist for illustrative, instructional, knowledge
preservation, or external distribution purposes only.
D. -All controlled documents are approved prior to issue. All controlled documents are marked
with the revision number and the revision date.
' .' . ' ', . . ' t i
E. Initial distribution of documents may be determined by the originator of the document or
the ISO Management Representative.
' " ' ' ' .1 .
F. Unless otherwise specified, the originator of a document is responsible for review and
approval of any subsequent changes to the document. .
"* . s ' ' ..'" -.*' u
G. The ISO Management Representative (or designee) is responsible for removal of obsolete
. controlled documents from all points of issue and use.
\ '' ' . ^ r
H. The ISO Management Representative (or designee) is responsible for ensuring that
changes to controlled documents are understood, distributed, and communicated to the
affected functions within the organization.
136
-------
I. All controlled documents are listed on the EMS Document Index. The Index shows the
dale(s) of any revisions and the person(s) initiating the revisions.
IV. Procedure .
A. -Environmental Manual "
1. Copies of the environmental manual are numbered sequentially. Distribution of controlled
copies is the responsibility of the ISO Management Representative (or designee).
a. Controlled copies are stamped "Controlled" with the distribution date.
b. Uncontrolled copies can be issued by the ISO Management Representative (or
.designeej. .All uncontrolled copies are stamped "Uncontrolled - For Reference Only".
2. A Distribution List of controlled documents is maintained by the ISO Management
Representative (or designee). Each recipient initials the Distribution List to indicate his/her
receipt of the Manual.
3. Each individual issued a controlled copy of the Environmental Manual is responsible for its
safekeeping. . .
4. "Uncontrolled copies of the Environmental Manual may be distributed outside the
organization (for example, to customers). All uncontrolled copies are stamped
"Uncontrolled - For Reference Only". . .
5. The process for revising the Environmental Manual is described in Procedure #.
B. Facility-wide Procedures -
1. Revision of facility-wide procedures is controlled as per Procedure # and is the
" responsibility of the ISO Management Representative (or designee).
2. Distribution of facility-wide environmental procedures is specified on the Distribution List.
3. The ISO Management Representative (or designee) is responsible for distributing new
and revised procedures. A copy of the Distribution List is signed and dated by the ISO
Management Representative, and initialed by each recipient. This copy of this list is
maintained for at least one year. .
4. When a new individual must be added to the controlled distribution for a procedure, the
requester notifies the ISO Management Representative. The ISO Management
Representative is then responsible for updating the Distribution List.
5. The ISO Management Representative, is responsible for coordinating and executing the
implementation of facility-wide procedures, as well as for documenting any resulting
training. Evidence of such training is maintained in the employee training records.
137
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6. Control of forms, checklists, and drawing used for EMS purposes follows the same process
, as described in steps B.1 through B.5 (above).
C. Process- or Activity-Specific Procedures and Work Instructions
'.' * "..'*.'' '.' "'..
1. Revision of process- or activity-specific procedures and work mstructions is controlled as
per Procedure # and is the responsibility of the ISO Management Representative (or
designee). -.'-.-'
2 Distribution of processor activity-specific procedures and work instructions is specified on
the Distribution List. Controlled copies are stamped "Controlled" with the distribution date.
3. The ISO Management Representative (Or designee) is responsible for distribution of new .
and revised procedures and work instructions. A copy of the Distribution List is signed and
dated by the ISO Management Representative, and initialed by each recipient. This copy of
the Jist is maintained for at least one year.
4. Area or functional managers are responsible for coordinating and executing the
implementation of activity- or process-specific procedures and work instructions in their
areas, as well as for documenting any resulting training. Evidence of such training is
. maintained in the employee training records.
138
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Sample Procedure:
Corrective Action
(includes tracking log)
139
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EMS PROCEDURE: PREVENTIVE AND CORRECTIVE ACTION
Purpose
The purpose of this procedure is to establish and outline the process for identifying,
documenting, analyzing, and implementing preventive and corrective actions.
II. Scope
Preventive or corrective actions may be initiated using this procedure for any environmental
problem affecting the organization.
III. General .
A. Corrective action is generally a reactive process used to address problems after they have
occurred. Corrective action is initiated using the Corrective Action Notice (CAN) document
as the primary vehicle for communication. Corrective action may be triggered by a variety of
events, including internal audits'and management reviews. Other items which might result in
a CAN include neighbor complaints or results of monitoring and measurement.
B. Preventive action is generally a proactive process intended to prevent potential problems
before they occur or become more severe. Preventive action is initiated using the
Preventive Action Notice (PAN). Preventive action focuses on identifying negative trends
and addressing them before they become significant. Events that might trigger a PAN
include monitoring and measurement, trends analysis, tracking of progress on achieving
objectives and targets, response to emergencies and near misses, and customer or
neighbor complaints, among other events.
C. Preventive and corrective action notices are prepared, managed and tracked using the
preventive and corrective action database.
D. The ISO Management Representative (or designee) is responsible for reviewing issues
affecting the EMS, the application and maintenance of this procedure, and any updates to.
EMS documents affected by the preventive and corrective actions.
, '
E. The ISO Management Representative is responsible for logging the PAN or CAN into the
data base, and tracking and recording submission of solutions in the database. The
requester and recipient of the CAN or PAN are responsible for verifying the effectiveness of
the solution. The ISO Management Representative is responsible for overall tracking and
reporting on preventive and corrective actions,
F. Personnel receiving PAN's and CAN's are responsible for instituting the required corrective
or preventive action, reporting completion of the required action to the ISO Management
Representative, and assuring sustained effectiveness. ',--..-
140
-------
///. General (confd.)
G. .Completed records of PAN's and CAN's are maintained in the database for at least two
* years after completion of the corrective or preventive action.
IV. Procedure ,
A. Issuing a CAN or PAN
1. A CAN or PAN may be requested by any employee. The employee requesting the CAN
or PAN is responsible for bringing the problem to the attention of the ISO Management
Representative. The JSQ Management Representative is responsible for determining
whether a CAN or PAN is appropriate and enters the appropriate information into the
corrective and preventive action database. Responsibility for resolvirig the problem is
assigned to a specific individual ("the recipient")-
. 2. The ISO Management Representative, working with the recipient, determines an
appropriate due date for resolving the CAN or PAN.
B/Determining and Implementing Corrective and Preventive Actions
1. The CAN or PAN is issued to the recipient, who is responsible for investigation and
resolution of the problem. The recipient is also responsible for communicating the
corrective or preventive action taken. . .
2. If the recipient cannot resolve the problem by the specified due date, he / she is
responsible for determining an acceptable alternate due date with the ISO Management
Representative/
* *. , , ' .' ' '..-.
C. Tracking CAN'S and PAN's
1. CAN'S or PAN's whose resolution dates are overdue appear on the Overdue Solutions
report. The ISO Management Representative is responsible for issuing this report on a
weekly basis to the Plant Manager and the recipients of any overdue CANs or PANs.
2. Records of PANs and CANs are maintained in the database for at least two years after
completion of the corrective or preventive-action.
D, Tracking Effectiveness of-Solutions
1. The recipient of a CAN or PAN, in conjunction with the requester, are responsible for
verifying the effectiveness of the solution. If the solution is deemed not effective, the
CAN or PAN will be reissued to the original recipient. .
141
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SAMPLE CORRECTIVE ACTION NOTICE
L *> ', ' . ' ' ' ' ' ' ' . '
CAN Number: Issue Date: Solution Due Date:
Name Location Phone:
Requested By: . -
Issued To:
Problem Statement (completed by ISO Management Representative):
Most Likely Causes (completed by ISO Management Representative):
Implemented Solutions (completed by recipient - include dates as applicable):
Results (confirming effectiveness):
Closed by: Closing Date:
... 142
-------
CORRECTIVE ACTION TRACKING LOG
CAN
Number
Requested
By
Issued
To
-
Solution
Due
(Date)
Solution
Identified
(Date)
Completed '
(Date)
.
Verified
(Date)
.
.
CAN
Closed
(Date)
.
143
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Environmental Records
Organizer
144
-------
-------
Environmental Records Organizer (SAMPLE)
Permits & Applications*
Air Emissions Permit .
Air Permit Application
Previous Air Permit
Wastewater Permit
Solid Waste Permit
Hazardous Waste Permit
Stormwater Permit
Annual Licenses & Fees*
Air Emissions Fees
Wastewater Fees
Hazardous Waste Fees
Solid Waste Fees
P2 Fees
Compliance Reporting*
Air Emissions** :
. , y ,145
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-------
VOC/HAPs Reporting
\ ,
Ink Usage Reports ' ' -
VOC Annual Analysis
Air Emissions Inventories
Historical Data
Wastewater**
Semi-Annual Wastewater Testing Reports
Pollution Prevention**
Annual P2 Report
' ป
Biannual Hazardous Waste Report
Hazardous Waste**
ซ
Open Manifests
Closed Manifests
- ~ *
Special Wastes**, -
Fluorescent Lamps .
Ink Recycling
SARA 313*
" "
Environmental Census Reports*
146
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-------
Compliance Plans*
Community Right-to-Know
Employee Right-to-Know
OSHA Lock Out
Minnesota AWAIR
Loss Prevention
Indoor Air Quality*
OSHA*,
OSHA Posters
1996 OSHA Inspection
1994 OSHA Inspection
Safety Shoes
First Aid*
Spills Clean-Up*
147
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Sample Procedure;
EMS Audits
148
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-------
EMS Procedure: Environmental Management System Audits
I. Purpose
To define the process for conducting periodic audits of the environmental management system
(EMS). The procedure defines the process for scheduling, conducting, and reporting of EMS
audits. . .
II. Scope
This procedure applies to all internal EMS audits conducted at the site:
The scope of EMS audits may cover all activities and processes comprising the EMS or
selected elements thereof. . i
III. General ; .
Internal EMS audits help to ensure the proper implementation and maintenance of the EMS by
verifying that activities conform with documented procedures and that corrective actions are
undertaken and are effective. '
All audits are conducted by trained auditors. Auditor training is defined by Procedure #.,..-
Records of auditor training are maintained in accordance with Procedure #.
When a candidate for EMS auditor is assigned to an audit team, the Lead Auditor will prepare '.
an evaluation of the candidate auditor's performance following the audit.
The ISO Management Representative is responsible for maintaining EMS audit records,
including a list of trained auditors, auditor training records, audit schedules and protocols, and
audit reports. - .
EMS audits are scheduled to ensure that all EMS elements and plant functions are audited at
f least once each year.
The ISO Management Representative is responsible for notifying EMS auditors of any
upcoming audits a reasonable time prior to the scheduled audit date. Plant areas and
. functions subject to the EMS audit will also be notified a reasonable time prior to the audit.
The Lead Auditor is responsible for ensuring that the audit, audit report and any feedback to
the plant areas or functions covered by the audit is completed per the audit schedule.
The ISO Management Representative, in conjunction with the Lead Auditor, is responsible for
ensuring that Corrective Action Notices are prepared for audit findings, as appropriate.
149
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IV. Procedure
/L Audit Team Selection - One or more auditors comprise an audit team. When the team
consists of more than one auditor, a Lead Auditor will be designated. The Lead Auditor is
' responsible for audit team orientation, coordinating the audit process, and coordinating the
preparation of the audit report.
B^ Audit Team Orientation - the Lead Auditor will assure that the team is adequately prepared
to initiate the audit. Pertinent policies, procedures, standards, regulatory requirements and
prior audit reports are made available for review by the audit team. Each auditor will have
appropriate audit training, as defined by Procedure #.
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C. Written Audit Plan - The Lead Auditor is responsible for ensuring the preparation of a
written plan for the audit. The Internal EMS Audit Checklist may be used as a guide for this
plan.
D. Prior Notification - The plant areas and / or functions to be.audited are to be notified a
reasonable time prior to the audit.
E. Conducting the Audit
1. A pre-audit conference is held with appropriate personnel to review the scope, plan and
; schedule for the audit.
2. Auditors are at liberty to modify the audit scope and plan if conditions warrant..
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3. Objective evidence is.examined to verify conformance to EMS requirements, including
operating procedures. All audit findings must be documented. .
4. Specific attention is given to corrective actions for audit findings from previous audits.
5. A post-audit conference is held to present audit findings, clarify any misunderstandings,
and summarize the audit results.
F. Reporting Audit Results
1. The Team Leader prepares the audit report, which summarizes the audit scope,
identifies the audit team, describes sources of evidence used, and summarizes the audit
results. , .
2. Findings requiring corrective action are entered into the corrective action database.
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IV. Procedure (cont'd.) . .
G. Audit Report Distribution
1. The ISO Management Representative is responsible for communicating the audit results
to responsible area and / or functional management. Copies of the audit report are
. made available by the ISO Management Representative.
2. The ISO Management Representative is responsible for ensuring availability of audit
reports for purposes of the annual Management review (see Procedure #).
H. Audit Follow-up . .
1. Management in the affected areas and / or functions are responsible for any follow-up
actions needed as a result of the audit. ;
2. The ISO Management Representative is responsible for tracking the completion and
effectiveness of corrective actions.
I. Record keeping
1. Audit reports are retained for at least two years from the date of audit completion. The
ISO Management Representative is responsible for maintaining such records,
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Audit Plan
Area or Lead Audit Team Target Special
Function to be Auditor Members Date Instructions
' Audited
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Sample Communications to Audit Team
ENVIRONMENTAL MANAGEMENT SYSTEM AUDIT
Lead Auditor:
Audit Team Members:
Audit Area:
Target Due Date:
Listed above is the area to be audited. The due date given is the target to have the entire audit completed,
including the report and follow-up meeting with the responsible area management. Listed below are the areas of
environmental management systems criteria that you are to assess. If you have any questions, please call me;
Special instructions, if any, are listed below. Thank you for your help. Effective audits help make an effective
environmental management system.
__ Policy
_ Environmental Aspect identification
Environmental Management Program
__ Training, Awareness, Competence
__ EMS Documentation
'_ Operational Controls
Monitoring and Measurement
_ Records
; Management Review
__ Legal and dher Requirements
_ Objectives and Targets
Structure and Responsibility
Communication
Document Control
__ Emergency Preparedness .
Nonconformance / Corrective Action
_ Management System Audits
Special Instructions:
ISO Representative (signature)
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Sample Procedure:
Management Reviews
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EMS PROCEDURE: MANAGEMENT REVIEW
I. Purpose
The purpose of this procedure is to document the process and primary agenda of issues to be
.included in the Management Review meetings for evaluating the status of the organization's
environmental management system (EMS).
II. Scope
This procedure applies to all Management Review meetings conducted by the organization.
III. General .
The Management Review process is intended to provide a forum for discussion and
improvement of the EMS and to provide management with a vehicle for making any changes to
the EMS necessary to achieve the organization's goals.
IV. Procedure . .
A. The ISO Management Representative is responsible for scheduling and conducting a
minimum of two Management Review meetings during each 12-month period. The ISO
Management'Representative is also responsible for ensuring that the necessary data and
other information is cpllected prior to the meeting./
B. At a minimum, each Management Review meeting will consider the following:
the suitability,, adequacy and effectiveness of the environmental policy;
the suitability, adequacy and effectiveness of the environmental objectives (as well as
the organization's current status against these objectives);
the overall suitability, adequacy and effectiveness of the EMS;
the status of corrective and preventive actions;
the results of any EMS audits conducted since the last Management Review meeting;
the suitability, adequacy and effectiveness of training efforts; and,
the results of any action items from the previous Management Review meeting,
C. Minutes of the Management Review meeting will be documented. These meeting minutes
will include, at a minimum:
a list of attendees; . , , ' .
a summary of key issues discussed; and, .
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any actions items arising from the meeting.
D. A copy of the meeting minutes will be distributed to attendees and .any individuals assigned
action items. A copy of the meeting minutes will also be retained on file.
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