r/EPA
United States
Environmental Protection
Agency
Office of Water
(4204)
January 2000
Final Report: The US EPA
Environmental Management
System Pilot Program for Local
Government Entities
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ACKNOWLEDGEMENTS
This document was prepared with funding through a grant from the U.S. Environmental
Protection Agency's Office of Wastewater Manasement and Office of Compliance.
GETF gratefully acknowledges the following p^/^l
design and content of this report.
for their invaluable contributions to the
Faith Leavitt, Project Manager and principal author, GETF
Craig Ruberti, GETF
Joanne McKeman, GETF
Kelly Lacher, GETF
Candi Carpenter, GETF
Christine Haymes, GETF
Stephen R. Wassersug, GETF
Jim Home, US EPA - Office of Wastewater Management, Project Co-Manager
John Dombrowski, US EPA Office of Compliance, Project Co-Manager
Project Participants
Randy Grant, Chief Environmental Officer
Larry Person, Senior Environmental Coordinator
Dennis Enriquez, Environmental Coordinator
Garen McClure, Environmental Programs Specialist
Scottsdale, Arizona
Ron Fadoir, Environmental Specialist
Ronald Rees, Superintendent
Wayne County, Michigan
Dave Baseheart, Assistant City Manager
Mark Pfefferle, Environmental Specialist
Gaithersburg, Maryland
Mike Toledo, Deputy of Operations
Massachusetts Corrections Institute Norfolk, Massachusetts
James Smith, Assistant City Manager
Mark Young, Director
Matt Donahue, City Councilman (Former)
Lowell, Massachusetts
Liz Todd, Solid Waste/Recycling Coordinator
Troy Brown, Director of Administrative Services
Peter Lowitt, Town Planner (Former)
Town of Londonderry, New Hampshire
Ajay Singh, Director Internal Controls and Special Projects, CPM
Jim Strycharz, Deputy Director, Internal Controls
Bill Jehle, Chief, Environmental Engineering
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Thomas Abdallah, Environmental Engineering
Candace Mertone, Director, Quality Programs
Vijay Verma, Construction Manager
Amy McClure, Project Manager
Kendall Coad, Project Manager
City of Indianapolis, Indiana
Irene Armock, Environmental Analyst
City of Lansing, Michigan
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Table of Contents
Organization of iv
Final Report
Executive Summary 1
Section I Why an EMS Pilot Proj ect for Local Government Entities?.... 9
Section II What is an EMS? 12
Section III How was the EMS Pilot Project Structured? 14
Section IV What did the Participants Do? 21
Section V Implementation Status and Resource Commitment 48
Section VI Benefits, Barriers and Keys to Success 51
Section VII Sources for More EMS Information 59
Appendix A Glossary of Terms 60
Appendix B Participant Case Studies 63
City of Lowell, Massachusetts 64
City of Gaithersburg, Maryland 69
City Londonderry, New Hampshire 75
Massachusetts Corrections Institute - Norfolk, Massachusetts. 79
New York City Transit Authority - New York, New York 83
City of Scottsdale, Arizona 89
Wayne County, Michigan 100
Indianapolis, Indiana 106
Lansing, Michigan Ill
Appendix C Sample Documentation 115
Appendix D Completed EMS Requirements 123
Appendix E Memorandum of Understanding (MOU) 125
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For the last several years the US Environmental Protection Agency (EPA) has been
evaluating new initiatives to help organizations address environmental problems "that
have yet to be solved through the current system."1 These initiatives include an emphasis
on streamlining the regulatory process and introducing innovative programs for managing
environmental issues more effectively. Environmental Management Systems (EMSs) are
important new tools to encourage organizations to improve compliance, pollution
prevention, and environmental performance and to promote greater environmental
stewardship throughout the workforce.
What is an EMS?
An EMS is a set of problem identification and problem-solving tools that can be
implemented by the employees in an organization in many different ways, depending
on the organization's activities and needs. EMSs follow Shewart and Deming's well-
known Quality Management approach of "plan, do, check, and act" which is a
systems methodology rather than the traditional command and control approach.
Personnel evaluate the processes and procedures they use to manage environmental
issues and incorporate strong operational controls and environmental roles and
responsibilities into existing job descriptions and work instructions. They set
objectives and targets for managing their environmental issues. They monitor and
measure and evaluate their progress in environmental performance both in areas that
are regulated and areas that are not (e.g., demand-side issues such as water or
electricity use). The EMS integrates the environment into everyday business
operations, and environmental stewardship becomes part of the daily responsibility
for employees across the entire organization, not just in the environmental
department.
Why did EPA Sponsor the Initiative?
From August 1997 through July 1999, EPA sponsored an EMS pilot program to test the
applicability and benefit of an EMS on environmental performance, compliance,
pollution prevention and stakeholder involvement in local government operations. The
project reflects the growing awareness and support within EPA for voluntary adoption of
EMSs.
Who Provided Technical Assistance and Training?
EPA selected the Global Environment & Technology Foundation (GETF) to lead the
initiative. GETF conducted the candidate screening, provided training, coaching, and
1 EPA Innovations Task Force, Aiming for Excellence, Actions to Encourage Stewardship and Accelerate
Environmental Progress, EPA 100-R-99-006, July 1999, p. 3.
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technical assistance to each participant, developed implementation materials and toolkits,
and collected data and information about the benefits, barriers, and keys to success
throughout the two-year program. EPA did not provide direct financial assistance to
participating organizations and did not offer any regulatory flexibility.
Who were the Project Participants?
Nine local government entities were selected from a field of applicant. Each participant
selected a department, division, or operation to which they would apply their EMS. This
entity was called then: "fenceline."
Participants hi the initiative included:
Local Government Entity
Town of Londonderry,
New Hampshire
City of Lowell, Massachusetts
Wayne County, Michigan
City of Indianapolis, Indiana
Massachusetts Department of Corrections -
Norfolk
City of Gaithersburg, Maryland
Lansing Board of Water & Light,
Michigan
New York City Transit Authority
City of Scottsdale, Arizona
"Fenceline"
Department of Public Works
Wastewater Treatment Facility
Wastewater Treatment Facility
Department of Public Works
State Prison Facility:
Power Plant,
Wastewater Treatment & Industries
Department of Public Works
Electric Generating Facility
Capital Programs Management
Department of Water Resources
Department of Financial Services
#of
Employees
15
46
100
150
31
80
35
1,700
1,500
Why were Municipalities Interested in an EMS?
A number of factors motivated municipal organizations to apply for participation in the
EMS initiative, including but not limited to:
p Compliance responsibilities: concerns for potential; environmental problems,
incidents and enforcement actions.
a Management confidence: management wanted assurance that their organization was
adequately handling its environmental responsibilities and identifying opportunities
for improvement.
a Organizational factors: better efficiency, worker health and safety concerns,
employee morale, and reduced costs.
p Public image concerns: improving poor relationships with neighbors and
counteracting bad press.
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a Improved regulatory relationships: "Every time EPA shows up it's a compliance
issue or a consent decree."
a Privatization issues: remaining competitive with private industry or privatized
operations.
a Growth management: address smart growth and sprawl issues, consider using EMS
as an incentive to attract the right type of industry and send a message that the city
has a strong environmental consciousness.
a Municipalities as leaders and innovators: several participants wanted to play a
strong role in leading and mentoring their communities in environmental stewardship
initiatives.
What are the Key Characteristics of an EMS?
Participants were asked to complete seventeen key elements in their EMSs.
EMS ELEMENTS
1. Environmental Policy
2. Environmental Aspects
3. Legal and Other Requirements
4. Objectives & Targets
5. Environmental Management Programs
6. Structure and Responsibility
7. Training: Awareness & Competence
8. Communication
9. EMS Documentation
10. Document Control
1 1. Operational Control
12. Emergency Preparedness and
Response
13. Monitoring and Measurement
14. Nonconformance & Corrective and
Preventative Action
15. Records
16. EMS Audit
17. Management Review
guidance for use.
Environmental Management Systems - Specification with
What Implementation Strategy was Developed?
GETF and EPA developed a four-phased EMS implementation program to help each
local government entity develop and implement an EMS at the fenceline of their choice.
Each phase focused employees on completing a number of EMS requirements. Intensive
2 J/2 day workshops were scheduled at the beginning of each new phase of activity to
prepare participants to train and lead their EMS Implementation Teams through
successful completion of the EMS requirements in each implementation phase.
PHASE I
August 1997-
January 1998
Establishing
the Program
PHASE II
February 1998- June
1998
Developing the
Environmental
PHASE III
July 1998-
January 1999
o Establishing
Objectives and
PHASE IV
February 1999- July
1999
Checking and
Corrective
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Infrastructure
inside the
Organization
Policy;
Determining legal
and other require-
ments
Determining
significant aspects
Targets
Designing
Environmental
Management
Programs
Action;
Management
Review
What was the Average Resource Commitment?
Throughout the life of the project, participants tracked monthly expenses associated with
their EMS activities throughout each of the four phases of implementation. The direct
internal labor costs accounted for the bulk of the financial resources participants invested.
Other costs include travel to training sessions, in-kind contributions, and materials.
Figure 1 illustrates the direct internal labor costs (average) incurred for implementing the
EMS over a 21-month period (The expenses of each participant are examined in
Appendix B - Case Studies).
Figure 1
Direct Internal Labor Costs (Average)
Dollar*
(Thousand)
The number in parentheses indicates the number of participants in that size category.
In addition to the EMS Management Representative and the Implementation Team, city
government personnel, community activists, administrative support staff, legal
departments, and environmental managers contributed tune to the EMS program. Figure
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2 illustrates the total direct internal labor time (average) committed to implement the
EMS over a 21-month period.
Figure 2
Direct Internal Labor Time (Average)
Houis
10-49
50-150
Number of Employees in Fenceline
1.000 - 2.000
Four of the nine participants sought outside services to support their employee efforts.
Consultants addressed specific individual needs ranging from training, to documentation,
to assistance developing policies, procedures, and work instructions. Resource
commitments for these outside services are reflected below in Table 1:
Table 1
Organization
Wayne County
Indianapolis
Lowell
New York City Transit
Authority
Consultant Time
80 hours
102 hours
210 hours
1,1 10 hours
Consultant Costs
$2,400
$9,700
$10,500
$143,000
As can be seen from Table 1, one of the participants, the New York City Transit
Authority, chose to rely heavily on consultants to develop their EMS. While this is
certainly an acceptable approach for any organization, it is not, in most cases, necessary
to rely heavily on consultants to develop an effective EMS.
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What were the Benefits?
1. A positive effect on environmental compliance and performance
"With regard to environmental compliance, we have a better understanding of our legal
requirements. We have better-trained employees whose competence in their work area is
critical to the environment. We expect that our EMS efforts will increase our ability to
stay in compliance."
2. Improved environmental awareness, involvement and competency throughout
the organization
"There's a much better understanding of environmental issues in every department of the
fenceline, not just in the environmental department. We are recognizing simple internal
"housekeeping" measures that are having a positive effect on our environmental
performance. We have self-imposed additional requirements to help prevent pollution,
reduce energy use, manage our contractor, and expand environmental education for our
citizens. Employees are bringing ideas for reducing our waste streams and suggesting the
procurement of less toxic products. There has been a definite improvement in
involvement and morale! "
3. Better communication about environmental issues inside and outside the
organization
"We know much more about our environmental issues than we did 18 months ago.
Consequently we are more articulate in our conversations with other departments, other
bureaucratic systems, with the state, with our own regulators, and with our neighbors. "
4. Improved efficiency, reduced costs, greater consistency
"In a relatively short period of time we have learned and implemented efficient
management tools for defining our environmental.priorities and responsibilities. We have
developed performance partnerships with our city organizations. We can better prioritize
and defend our resource needs. The EMS tools give us a better understanding of what we
are required to do and the means to do it consistently, competently, and efficiently."
5. Better relationships with regulator
"The pilot project has provided an opportunity to reshape our interactions with our
regulators. Our past dealings with EPA had a confrontational quality. The pilot project
allowed the agency to take on a new role as mentor and partner. This was one of the
more valuable outcomes of the project."
What were the Barriers?
1. Managing organizational change
"As we develop programs that build environmental stewardship and improve how we
manage our environmental obligations, we must also develop programs that manage
human and organizational resistance to change."
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2. Lack of top management visibility and involvement
"Change management requires top management leadership and visibility and personal
involvement, not just lip service. Management needs a better grasp/understanding of
what an EMS requires of an organization and of their role in the process before deciding
to implement it."
3. Organizational issues
"Time, Time, Time! Time is an essential resource ...it's very limited and there is an
erroneous perception that the EMS is above and beyond normal work duties. Dollars are
abstract - but time is concrete and while management has assured us the necessary
dollars they allow too little staff time. Getting first tier management buy-in and cross-
functional responsibility for EMS implementation has been a challenge. EMS
implementation is viewed as the Implementation Team's project.
4. Lack of public awareness, understanding and buy-in
"There's a lack of awareness or understanding about the benefits that the EMS has
brought to the organization and the value it will bring in the future. Local government
entities can realize many more benefits than just being in compliance, and we 've
broadened the performance indicators we are using to measure our success. We haven't
communicated this fact well to the city management or to the public, so there's little
demand from our clients - the citizens -for the EMS. "
5. Political uncertainty
"The EMS is not institutionalized yet. We have a new administration in the wings. We
hope the EMS won't be seen as the last regime's program. "
What are the Keys to Success?
Participants agreed on four pivotal issues among the many lessons that they learned:
1. Top Management commitment and support is essential to the success of the EMS
process.
2. Organizations who build on existing organizational processes and procedures
are more successful than those who create new EMS elements.
3. The Implementation Team is pivotal to the success of the EMS program.
4. Employee awareness, understanding and involvement in the EMS should extend
across the entire organization and be recognized as an organizational priority.
Data and information collected in the project suggests that EMSs are entirely applicable
to operations managed by local governments. Without exception, participants found the
EMS to be a useful tool for managing environmental issues, promoting compliance and
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pollution prevention approaches, increasing environmental awareness and stewardship,
and improving operational efficiency and control.
Based on these project results, and the Agency's continuing interest in promoting and
encouraging the use of EMSs in local government entities, EPA decided to conduct a
second EMS Pilot Project for local government entities starting in early 2000. GETF will
once again lead the second round of participants in their efforts to develop and implement
an EMS. The information below is based on the findings and experiences of the nine
participants from the first local government EMS implementation project.
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In May 1997, the US Environmental Protection Agency's Office of Wastewater
Management and Office of Compliance launched a unique pilot program to test the value
of an EMS for improving environmental performance and compliance in local
government entities.
Nine local government entities participated in the two-year initiative. Each developed
and implemented an EMS (using the ISO 14001 International standard as a starting point)
in a facility or operation of their choosing which is called their "fenceline".
Participants included:
Local Government Entity
Town of Londonderry,
New Hampshire
City of Lowell, Massachusetts
Wayne County, Michigan
City of Indianapolis, Indiana
Massachusetts Department of Corrections -
Norfolk
City of Gaithersburg, Maryland
Lansing Board of Water & Light,
Michigan
New York City Transit Authority
City of Scottsdale, Arizona
"Fenceline"
Department of Public Works
Wastewater Treatment Facility
Wastewater Treatment Facility
Department of Public Works
State Prison Facility:
Power Plant,
Wastewater Treatment & Industries
Department of Public Works
Electric Generating Facility
Capital Programs Management
Department of Water Resources
Department of Financial Services
#of
Employees
15
46
100
150
31
80
35
1,700
1,500
Additional information about each participant can be found in Appendix B.
US EPA Objectives for the EMS Pilot Program
US EPA wanted to determine if the EMS approach for managing environmental activities
was relevant to local government organizations and could provide the basis for a positive
effect on environmental performance, compliance, pollution prevention and stakeholder
involvement in local government operations. Implementation of voluntary EMSs to date
focused primarily on private sector organizations, but it was becoming increasingly clear
that they might provide significant benefits to the public sector.
Jim Home, Assistant to the Director of the US EPA Office of Wastewater, remarked,
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"We recognize that public sector organizations are faced with the same resource
shortages-as
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An EMS is a powerful tool for addressing the large-scale problems of operating and
maintaining physical plants, power and water systems, and complex roadway systems.
An EMS can often provide municipal governments with opportunities to serve as
environmental mentors for their communities since they both regulate and are regulated.
Entities who implement and maintain an EMS have a firsthand ability to share benefits,
barriers, and lessons learned with their public and private sector colleagues.
Consequently there is a broader understanding of disparate stakeholder concerns, a
common language to discuss environmental issues, and an increase in non-adversarial
performance partnerships between the regulator and the regulated communities.
A number of motivating factors led organizations to apply for participation in the EMS
pilot project:
a Compliance responsibilities: concerns for potential; environmental problems,
incidents and enforcement actions.
p Management confidence: management wanted assurance that their organization was
adequately handling its environmental responsibilities and identifying opportunities
for improvement.
a Organizational factors: better efficiency, worker health and safety concerns,
employee morale, and reduced costs.
a Public image concerns: improving poor relationships with neighbors and
counteracting bad press.
a Improving regulatory relationships: "Every time EPA shows up it's a compliance
issue or a consent decree."
a EPA's sponsorship of the project: this was a primary motivator because the public
entity could play a role in impacting national policy.
a Privatization: remaining competitive with private industry or privatized operations
a Growth issues: address smart growth and sprawl issues, consider using EMS as an
incentive to attract the right type of industry and send a message that the city has a
strong environmental consciousness.
a Responsible economic development: some are considering Eco-Industrial Parks and
requiring potential tenants to develop EMSs as a prerequisite to moving in.
a Risk avoidance and risk reduction approaches: to prevent non-compliance instead of
responding reactively to compliance issues ("create our future instead of predict it").
a Reducing cost of remediation: some participants host Superfund sites; participants
realized that it would be cheaper to prevent pollution than to clean it up after the fact
and wanted the EMS to help them initiate stronger proactive programs.
a Leadership potential in cutting edge programs: several wanted to play a strong role in
leading and mentoring their communities in environmental stewardship initiatives.
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An EMS is a set of problem identification and problem-solving tools that can be
implemented in an organization in many different ways, depending on the
organization's activities and needs. EMSs follow Shewart and Deming's well-known
Quality Management approach of "plan, do, check, and act" which is a systems
methodology rather than the traditional command and control approach. Personnel
evaluate the processes and procedures they use to manage environmental issues and
incorporate strong operational controls and environmental roles and responsibilities
into existing job descriptions and work instructions. They set objectives and targets
for managing their environmental issues. They monitor and measure and evaluate
then: progress in environmental performance both in areas that are regulated and areas
that are not (e.g., demand-side issues such as water or electricity use). The EMS
integrates the environment into everyday business operations, and environmental
stewardship becomes part of the daily responsibility for employees across the entire
organization, not just in the environmental department.
EMSs are a part of the organization's overall management system. They provide a
number of benchmarked tools to manage environmental risk effectively and offer
great potential for continuous improvement in compliance and other areas of
environmental performance.
An EMS engages an organization in:
a Understanding how their operations and activities impact the environment.
a Evaluating the extent of risk posed by their environmental issues.
a Defining an environmental policy that guides the organization's approach and
commitments to environmental management.
a Establishing measurable objectives and targets for environmental performance.
p Allocating necessary resources to achieve the objective(s).
a Establishing and maintaining specific procedures to ensure that work activities
minimize or eliminate a negative impact to the environment.
a Communicating responsibilities and work instructions throughout the
organization and training employees to effectively carry out their obligations.
Q Monitoring and measuring performance against established standards and
indicators.
Q Revising and improving the system based on the monitoring results.
a Communicating with people inside and outside the organization about the
organization's progress.
An EMS is not intended to be a substitute for regulatory requirements nor does it offer
regulatory relief from the law. EMSs can improve an organization's compliance,
pollution prevention and overall environmental performance and hopefully build greater
confidence with local stakeholders. EMSs are proactive programs that identify and
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address the root causes of potential compliance problem areas. They use pollution
prevention approaches. Senior management plays an active role in the EMS, monitoring
and measuring the organization's progress toward its environmental goals, and
continually looking for ways to improve environmental management.
EPA defines an EMS as a "framework" that helps an organization achieve its
environmental goals through consistent control of its operations. The assumption is that
this increased control will improve the environmental performance of the organization.
The EMS itself does not dictate a level of environmental performance that must be
achieved; each organization's EMS is tailored to its individual activities and goals.
An EMS encourages a company to continuously improve its environmental performance.
The system follows a repeating cycle.
Environmental Management Systems
CONTINUAL IMPROVEMENT
Management
Review
Measurement
and
Evaluation
Commitment
and
Policy
PREVENTION OF POLLUTION
"The most commonly used framework for an EMS is the one developed by the
International Organization for Standardization (ISO) for the ISO 14001 standard.
Established in 1996, this framework is the official international standard for an EMS."3
1 EPA's Internet site http://www.epa.gov/opptintr/dfe/tools/ems/bulletins/bullet01/whatems.html
13
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., ' ** * l.'<",'-- f f^~ ^^
SECTION JH: How was the EMS Pilot Project Structured?
EPA selected the Global Environment & Technology Foundation (GETF) to manage the
project. GETF, a 501-[c] [3] not-for-profit organization, provides EMS training and
technical assistance to numerous public and private sector organizations across the
United States, including similar implementation pilots for other Federal agencies and
international organizations. GETF conducted the candidate screening, provided training,
coaching, and technical assistance to each participant, developed implementation
materials and toolkits, and collected data and information about the benefits, barriers, and
keys to success throughout the two-year program.
EPA did not provide direct financial assistance to participating organizations and did not
offer any regulatory flexibility. The project was "registration-blind" - that is, there was
no expectation for participating organizations to have a third party verify that their EMS
contained all the characteristic elements contained in the ISO 14001 standard. EPA
anticipated that participants would complete the requirements of the EMS in the
"fenceline" of their choice by the time the pilot program ended in July 1999, but realized
that some organizations might need more time beyond the project to fully implement the
EMS.
Candidate Selection
GETF and EPA created a recruitment process, publicized their intention to recruit
candidates, and established selection criteria and scoring procedures. The project
announcement in May 1997 attracted interest from municipalities across the United
States. Candidates submitted a letter of application signed by top managers from the local
government entity and from the facility to which the EMS would be applied. These letters
outlined a brief description of the organization and its responsibilities; a preliminary
indication of the operations within the organization that would be developing the EMS; a
description of the reasons why the organization wished to participate; and, some of the
benefits it anticipated receiving from the adoption of the EMS.
Over a three-month period, GETF staff evaluated a variety of data and information and
conducted screening interviews by phone with each candidate. Screening topics included:
Commitment of sufficient resources (staffing and financial) available for the project.
Potential for successful completion (including top management commitment and
other layers of support available to complete the project).
Understanding the principles of Environmental Management Systems and the scope
of the activity.
Anticipated environmental benefit.
14
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Willingness to collect and share baseline data and report progress in implementing
their EMSs.
Consultation with EPA Regions.
Using a consistent protocol of evaluation criteria and numerical scoring strategy, GETF
and EPA chose nine participants in a competitive, blind selection process.
After selection, top managers from each local government entity signed a Memorandum
of Understanding (MOU) with GETF accepting the roles and responsibilities of each of
the parties and restating their commitment to provide sufficient resources to complete the
requirements of the EMS in the two-year period. A sample of the MOU is included in
Appendix E.
Within the first six months, one of the local government entities asked to withdraw from
the project because of personnel issues. Both members of the Implementation Team had
to withdraw from the project. Top management was not fully committed to the program
and did not appoint additional staff. EPA decided to re-compete the vacancy using the
same process described above, and an alternate ninth participant was selected. Additional
information about each participant can be found in Appendix B.
Developing the Program Structure
> GETF worked closely with EPA to develop a program that provided sufficient structure
to shepherd the group through the EMS requirements yet was flexible enough to satisfy
individual participant needs. Several key program elements included:
a An implementation strategy that divided EMS requirements into four sequenced
phases, each with discrete measurable milestones.
a Intensive "train-the trainer" workshops involving all participants were scheduled at
the beginning of each implementation phase. The "just-in-time" approach to training
sessions (worksessions covering just the milestones in the current phase) provided
participants with sufficient knowledge, understanding, and materials to build
expertise, understanding and experience and lead their individual implementation
teams in completing the EMS requirements.
a EMS training materials, models and templates were specifically tailored for each
workshop. Leading experts in the field assisted with instruction and discussion as did
other local government entities engaged in EMS activities.
a Frequent, regular, and consistent communication among project participants and with
external stakeholders was an important component of the project structure. Between
workshops, weekly email communication, monthly all-hands conference calls, a
password protected Intranet Website, written and electronic toolkits, and individual
phone consultations maintained on-going technical assistance and coaching. GETF
15
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D
and EPA personnel made periodic on-site visits throughout the project, to assist
implementation teams with training, auditing, technical assistance, procedure writing
and change management issues.
Team building activities to develop synergy and a strong support network among the
participants were built into every workshop. Participants realized early in the project
that together they formed an excellent knowledge and problem-solving base.
Information'and data tracking protocols were developed so that organizations could
collect and share common sets of data related to the establishment and
implementation of their EMS.
A password protected Intranet Website was developed to assist in communication,
data sharing and data collection. A requirement for participation in the project was
that the EMS Implementation Team had easy access to the Internet.
Baseline environmental data about existing EMSs, environmental performance,
compliance, stakeholder involvement, and pollution prevention activities was
collected using a series of "baseline protocols" (developed by the University of North
Carolina (UNC) and the Environmental Law Institute (ELI) and also used in a parallel
project with ten state EMS pilot programs). The data will be collated and stored in a
national database managed by UNC at Chapel Hill.
It was decided that EPA would not review individual environmental data provided by
participants. Data would be collected by GETF, aggregated by the neutral third party
and added to a national EMS database.
Each phase of implementation would span a defined time period; however, it was
accepted that participants would move through the milestones in each phase at
somewhat varying rates depending on the barriers each encountered in their
organizations.
While some healthy competition among participants was inevitable, it was
emphasized that participants were not involved in an "EMS horserace." In fact, a
mentoring mentality developed rather quickly among the nine participants in the
program. Rather than delineating a winner, the synergy of the group helped to move
each member more steadily toward achieving their individual objectives.
Throughout the project GETF provided EPA with monthly and quarterly reports
about the conduct of the program.
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The EMS Requirements
International Standard ISO 14001, Environmental Management Systems Specification
with guidance for use, served as the baseline for the EMS requirements used in the pilot
project. This document specifies the seventeen elements participants would complete to
implement their conformant EMSs.
EMS ELEMENTS
1. Environmental Policy
2. Environmental Aspects
3. Legal and Other Requirements
4. Objectives & Targets
5. Environmental Management Programs
6. Structure and Responsibility
7. Training: Awareness & Competence
8. Communication
9. EMS Documentation
10. Document Control
11. Operational Control
12. Emergency Preparedness and
Response
13. Monitoring and Measurement
14. Nonconformance & Corrective and
Preventative Action
15. Records
16. EMS Audit
17. Management Review
The EMS elements are linked as follows:
EMS Framework
ORG. GOALS
ENVIRONMENTAL
POLICY
ENVIRONMENTAL
ASPECTS
COMMUNICATION
DOCUMENTATION
DOCUMENT CONTROL
RECORDS
NONCONFORMANCE
SIGNIFICANT
ASPECTS
MONITORING
&
MEASUREMENT
LEGAL & OTHER
REQUIREMENTS
OBJECTIVES &
TARGETS
1
MANAGEMENT
PROGRAMS
i
r
MANAGEMENT
REVIEW
*
STRUCTURE
TRAINING
EMERGENCIES
OPERATIONAL CONTROLS
EMS
AUDITS
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Training Sessions and Workshops
Four intensive 2 1A day workshops were scheduled, one at the beginning of each new
phase of activity.
PHASE I
August 1997-
January 1998
Training -
August 1997
Boston, Mass.
PHASE II
February 1998-
June 1998
Training
January 1998
Scottsdale, AZ
PHASE III
July 1998-
January 1999
Training -
June 1998
Lowell, Mass.
PHASE IV
February 1999-
July 1999
Training -
January 1999
Ft. Myers, Fla.
CLOSING
MEETING
July, 1999
New York City,
New York
The goal of these sessions was to prepare participants to train and lead their EMS
Implementation Teams through completion of the EMS requirements. The structure of
each workshop was essentially the same for the first four meetings:
a An overview of the EMS requirements (based on the ISO 14001 standard) that were
to be accomplished in the phase.
a Review of how these requirements were linked to the system.
a Overview of records and documents that would be generated in this phase.
a "Train the trainer" sessions to provide an in-depth coverage of the ISO 14001 EMS
requirements and prepare participants to teach their Implementation Teams.
a Role-playing exercises. Breakout groups became the EMS "core teams" of
hypothetical case study facilities. Teams developed environmental policies;
flowcharted "fenceline" operations; identified significant aspects and impacts;
identified roles, responsibilities and authorities; evaluated training needs; developed
system procedures; audited documents. Using case study activities, they confronted
all the tasks they would encounter in each of the phases.
a Guest speakers to provide additional training and discussion.
a A "Swap Meet" where participants could "show and tell" their EMS
accomplishments.
a Review of tracking sheets and data collection protocols.
a Guidance, usually in the form of an Action Item List for completing tasks in each
phase.
a Individual trouble-shooting sessions.
D Logistics planning for the next meeting.
A portion of each meeting, usually on the first day, provided an opportunity for other
interested parties from nearby local government entities, regulatory agencies, industries,
citizen groups to listen to the discussions and issues and to take the information back to
their own organizations. Trade journalists who attended the meetings wrote articles about
the program.
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The fifth and closing meeting in July 1999 in New York provided a public forum for
discussing project results and publicly recognizing each of the participants by EPA and
GETF.4
Tracking the Project
Throughout the project GETF used monthly tracking sheets and conference calls to
collect information about benefits, barriers, and keys to success in the implementation
process. Participants discovered that to build support for the EMS across the
organization, and particularly with management, it was very important to publicize the
benefits that the EMS was providing to the organization. Regular documentation of this
information provided material to present to top management in monthly briefings. Many
participants started with a small fenceline and planned to expand the EMS to other
departments and facilities over time. Consequently it was critical to document strategies
for dealing with organizational barriers, lessons learned, and keys to success, and
historical information about the implementation strategy for use in future departments
and facilities. This information also provided management with information for the
management review process. In this report a "Lessons Learned" section highlights some
of these issues relevant to each phase of implementation activity. Additionally, a "Keys
to Success" section in Section VI presents participants' views on the factors that were
most vital to their EMS implementation efforts.
Next Steps
EPA intends to maintain informal contact with project participants to keep abreast of the
status of their EMS and to learn more about the affect the EMS has on the organization as
the systems matures. Areas of continuing interest include:
a
a
a
a
a
Q
environmental performance
compliance
pollution prevention
stakeholder involvement
changes in the EMS design
opportunities to mentor national and international local government agencies
Throughout the project and even more after the project has been completed participants
have been called upon to present papers and case study reports at national meetings
across the United States. The benefits participants described have led many other local
government entities to consider the value of EMS in managing their own environmental
issues. As an example, the Massachusetts Department of Corrections has recently called
for three volunteers among its correction facilities to implement an EMS applying lessons
learned from the prison fenceline in the pilot initiative. The City of Lowell has been
4 This meeting was videotaped and is publicly available by contacting the New York City Transit Authority
EMS Management Representative (See Appendix for contact information).
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asked to assist a major textile manufacturer in their city with EMS implementation. The
City of Gaithersburg has been contacted by another Maryland municipality with a request
for technical assistance and mentoring in their EMS efforts.
Many of the participants have volunteered their time to mentor other local government
entities engaged in EMS activities. Recently a US Agency for International Development
(AID) training course brought twenty municipal managers from countries in transition to
the United States to learn about the application of Environmental Management Systems.
Part of the curriculum included site visits and worksessions at four cities in the US EPA
pilot project and the opportunity to dialogue with US municipal colleagues about EMS
application, documentation, benefits, barriers, and keys to success. Pilot participants will
also assist in training and technical assistance in the second US EPA EMS Pilot Project
for Local Government Entities which will begin early in 2000.
In their own organizations, Implementation Teams are expanding the scope of their EMS
to additional departments and facilities. One of the organizations has received third party
verification that its system is conformant with benchmarked EMS requirements and four
others plan to seek external (third party) verification of the EMS conformance. Lowell,
Massachusetts has interviewed five third-party certifiers and expects to schedule an EMS
certification audit of its Wastewater Treatment Plant in February or March 2000. The
Town of Londonderry, NH will seek third party verification as soon as the budget can
accommodate the cost. Gaithersburg, Maryland is scheduling certification activities for
late 2000. Wayne County, Michigan is seeking outside consulting services to continue its
EMS efforts leading to certification. Other participants have not decided whether to seek
third-party verification or self-certification that their systems are EMS conformant. Most
reported mat they are expanding the scope of their EMS to additional departments and
facilities beyond their initial fenceline. All have expressed an interest in mentoring other
local government entities interested in implementing an EMS in their operations.
Whether participants choose to certify their EMS or not, they all acknowledge that they
will use EMS tools (e.g., competency training, documentation, monitoring,
communication, operational control) to help them manage their compliance issues.
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SECTION IV: What did the Participants Do?
Participants used a four-phased implementation schedule to develop and implement the
EMS in their fencelines.
THE FOUR PHASED IMPLEMENTATION PLAN
Phase I
Developing
Project
Infrastructure
8/97-1/98
Phase II
Identifying
Significant
Aspects &
Objectives
and Targets
2/98-6/98
Phase III
Developing
Environmental
Management
Programs
7/98 - 1/99
Phase IV
Monitoring and
Measurement
& Management
Review
2/99-7/99
"Just-in-time" training and materials were provided in a workshop at the beginning of
each implementation phase to prepare Implementation Teams to lead their organizations
in the completion of tasks.
Phase I: Developing Project Infrastructure
August 1997-January 1998
Tasks in Phase I included:
a Selecting a project scope ("fenceline").
a Establishing an EMS program infrastructure: allocate resources, appoint a
Management Representative (project manager) and select an Implementation Team
to lead the EMS effort.
a Evaluating their state of compliance with local, state, and federal environmental laws
and regulations.
a Conducting a gap analysis to determine what EMS processes and procedures the
organization already had in place and what needed to be created.
a Defining the implementation team's roles, responsibilities and authorities
a Confirming top management understanding and commitment.
a Drafting and communicating an environmental policy.
a Determining a procedure for understanding and communicating legal and other
requirements.
a Planning an EMS "kickoff" for familiarizing employees across the organization with
the EMS concept and getting employee buy-in.
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ISSUES IN PHASE I
A Steep Learning Curve
While most participants were quite familiar with command and control approaches to
environmental management, only one or two had experience with other process
management or quality management systems like the ISO 9000 Quality Management
Standard. Three of the participants who attended the first training session had been
involved in their organization's decision to apply to the program and in the application
process. The rest were not fully briefed about EMS or the pilot program goals and
objectives. Consequently there was a tremendous "ramp up" of learning involved in
understanding the EMS requirements and the process management approach.
Participants have suggested that on-site training with EMS experts at each location at the
very beginning of the project would have been a more efficient and effective way to
jump-start the EMS program. This recommendation will be incorporated into the
planning of the second US EPA EMS initiative. Three-day site visits including separate
sessions with the Implementation Team, with top management, and with selected
employees will establish a solid basis of understanding about the elements of the EMS
and top management's and the implementation team's EMS roles and responsibilities.
As well as establishing a solid basis of EMS understanding, the EMS expert will assist
the team hi conducting the gap analysis, preparing a project plan, estimating a project
budget, developing an implementation schedule and milestones, and presenting this
information to top management and other key staff in the organization (e.g., first tier
managers, union stewards, city councilmen). Early intervention of this type promotes
understanding of how the EMS elements are linked to each other and prepares the team to
guide the organization through the EMS milestones and activities in the initial phase.
The language of the EMS posed some challenges early in the project. Participants were
familiar and comfortable with the more prescriptive command and control approach that
generally offered little flexibility in how organizations assessed their environmental
impacts and how they satisfied environmental requirements. In contrast, they thought the
EMS language and terminology was somewhat vague and open to interpretation and that
the EMS requirements lacked sufficient direction. "I think I understand what I'm
supposed to do, but the standard doesn't tell me how to do it," was a familiar complaint.
Early in the program participants discovered the importance of involving employees in
understanding and developing the EMS. The City of Lowell, Massachusetts remarked,
"When employees are brought into the EMS process they begin to accept that
environmental responsibilities are a part of everyone's job in the organization, just as
safety is everyone's responsibility. When they are involved in developing a solution to
the problem, they are more willing to accept the additional responsibilities that the
solutions require. This is a change that can only come through employee involvement at
every level." In Lowell, a laboratory technician decided to investigate alternatives to
some chemicals used hi the organization's processes that have a potential impact but are
unregulated. Similarly in Londonderry, New Hampshire, the highway garage
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superintendent began to look into non-toxic cleaners as alternatives to those currently
used. Employees were aware of their responsibilities in accomplishing their
organization's environmental policy goals and took the initiative to reduce their
departments' actual and potential environmental impacts. In another case, an employee
attended a seminar and learned about a technology to recycle an element used in their
operations, potentially saving money and reducing the landfill impact. The employee was
interested because he knew that waste minimization was one of the organization's
environmental policy goals, and he brought the technology to the attention of
management.
The number of "non-environmental" staff and management that began to think
proactively about environmental issues as a result of the EMS program (e.g., pollution
prevention opportunities, stronger compliance management, and product substitution)
was significant. Organizations were going beyond what was required by law. In fact,
many examples of changes that entities made in their operations were at the suggestion of
people who were not formally trained or had formal responsibility for environmental
matters, but recognized the value of factoring environmental issues into their daily
business operations and business decisions.
Top Management Involvement
During the first phase every participant complained that there was too much to do and too
little time to do it. It was difficult to schedule training sessions and meetings during the
workweek. Not every department manager provided time during the workday for EMS
activities, and often the work had to be done after hours, or on the weekends. Whether the
organization is large or small, public or private, EMS activities are a change from the
existing organizational culture. Implementation teams dealt with employees who were
uncomfortable with changes in procedure and with new responsibilities. They negotiated
with department managers whose priorities may not have included EMS activities.
Awareness takes time to filter throughout the organization, about six months for
employees to become reasonably familiar and somewhat comfortable with the idea of the
EMS. Participants worked hard to bring management into the process. The City of
Indianapolis, Indiana remarked, "The demands on management's time have affected
their active participation in the process. We hope that in the next few months
management can provide the visible support needed to bring the facility workforce
together to implement the EMS program." This was a priority for all participants. Top
management's leadership, involvement and visibility in the EMS was a critical key to
success.
The Implementation Team
An early and key decision in the EMS process was the selection of the EMS Management
Representative and the Implementation Team. The EMS Management Representative is
the Project Manager and has been delegated top management authority. The Team has a
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vital leadership role in planning the EMS project, delegating the tasks, establishing
deadlines, collecting and evaluating the work, and providing training, guidance and
assistance where needed. The Team members are the organization's EMS experts and
champions. Some participants enlisted volunteers for their Team; others made
assignments. Teams were varied in structure and in size (See Appendix B for the
individual case studies). The most successful teams included representatives from both
facility and city management domains, as well as up and down the organizational
structure of the fenceline. Team members should have sufficient organizational
knowledge and authority in their respective departments. The entire team needs in-depth
EMS training and a clear understanding of their roles and responsibilities in order to plan
and lead the implementation effort. The City of Scottsdale remarked, "We played more of
a 'doing' role than an advisory one in the initial phases. We wanted more experience and
expertise ourselves before we delegated tasks to others."
Selecting the "Fenceline"
Participants had already selected a "fenceline" to which they would apply the EMS.
Some participants decided to "pilot" the EMS in a smaller section of their organizations
(e.g., the water resources department), and then apply the lessons learned throughout the
entire local government entity. The City of Lowell remarked, "My facility (a utility) is
just a beginning ultimately, we plan to extend these good practices across other
departments like Public Works, Transportation, even the Fire Department, but the initial
scope of the project must be manageable." Whatever their fenceline, organizational
charts had to be developed or updated. Operations were mapped or flowcharted. It was
critical to provide department managers with a clear understanding of the EMS process
and its priority to the organization in order to gain their support in gathering information.
Many of the participants initially defined project fencelines that were too large and had to
be scaled back. All participants recommend starting small, and adding more departments
and facilities as EMS experience and expertise grows.
Collecting Baseline Information
Participants conducted a gap analysis to determine what EMS elements already existed in
the organization and what had to be revised or developed. A gap analysis is not a
compliance audit. It is a snapshot of the organization's management processes, not of its
compliance status. The gap analysis is designed to answer the following questions:
1) How well are the organization and its existing environmental programs performing?
2) What standards of environmental performance does the organization hope to achieve?
3) What are the gaps between objectives and performance?
4) What existing programs and activities (structure, training programs, policies, and
procedures) conform to the EMS requirements and can serve as the best foundation
for improved environmental performance?
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Management support, employee involvement, and good communication were critical to
complete the gap analysis. Without these, it was difficult to collect information,
particularly in areas that had a history of problems with environmental issues.
Participants agreed that the gap analysis was a task that could be completed by internal
staff and was a good way for the implementation team and employees to learn more the
activities in each department of the fenceline.
Also, participants completed comprehensive baseline protocols developed by UNC at
Chapel Hill and ELI to describe their existing EMSs, their pollution prevention practices,
stakeholder involvement, compliance and environmental performance. They also
completed monthly "tracking sheets" for GETF.
Developing an Environmental Policy
Implementation Teams focused their attention on developing or revising existing
environmental policies to conform to EMS requirements (See Appendix C). MCI-
Norfolk, Massachusetts remarked, "It was not necessary to create a new environmental
policy. After we reviewed our environmental impacts and organizational goals we revised
our existing environmental policy to be sure it conformed to EMS requirements."
Policies were communicated to all employees in the organization and made available to
the public. Three of the most common ways of communicating the policy were 1)
publishing them in the annual report, 2) posting them in the reception area of the
fenceline, 3) posting them on the municipal website. The Lowell Wastewater Treatment
Plant had a unique approach: they imprinted their policy on a custom-made manhole
cover and displayed it in the lobby of the facility. Lowell remarks, "We found that
communicating the environmental policy to employees throughout the fenceline was a
good way to initiate the employee kickoff program. When top management signs the
policy, it's clear that they are committing the organization to accomplishing certain goals
and objectives and that the EMS is a priority. We also made sure that our implementation
team wore their EMS team-shirts so employees could easily identify them during the
kickoff." Lowell also printed its environmental policy on laminated wallet cards for
every employee in the wastewater treatment facility. These are given to all new
employees, contractors, and vendors.
Determining Legal and Other Requirements
By far the most challenging but most beneficial task in Phase I was determining legal and
other requirements. Participants in every organization involved in the pilot program
discovered that there was usually no consistent process and generally no clear
responsibility or time schedule in place for collecting this information. Initially there was
insufficient awareness about reliable sources to seek this information. Participants shared
their favorite sources (Internet, software, trade associations, state and Federal Agencies).
In many organizations there was redundancy and inefficiency: personnel in many
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departments were determining what laws applied to them. When information was
available it was not always well communicated or it was not in a form that was
understandable to employees who needed the information. Participants wanted employees
to know what laws governed the jobs they were doing every day, and that their individual
actions help the organization stay in compliance with the law.
Participants unanimously agreed that this information must not only be made available,
but must also be understood by those who needed it at every level and function
throughout the fenceline. The City of Scottsdale, Arizona designed a process using their
internal website. They posted information about their legal and other requirements on
their website. Department managers had the responsibility for assuring understanding of x
the information in their respective departments. The process was designed to guarantee
that every employee throughout the organization had easy access and understanding of
the laws and regulations that applied to them. Scottsdale used "read-only" files to
maintain their document control procedures and ensure that only authorized staff could
update or change the information according to schedule. Scottsdale has found this to be
an extremely efficient and effective way to maintain and disseminate this information. A
benefit from centralizing their regulatory requirements was the realization that Scottsdale
could consolidate its permit process. Scottsdale has been able to consolidate their
permitting processes across fifteen departments city wide and reduce their air permits
from 23 to 8. Reducing the paperwork streamlined the reporting process, reduced the
number of people involved in the administrative activity, and improved the likelihood
that more staff could work more effectively on issues that were of higher priority -
environmental performance improvements and compliance issues. The EMS process in
this case helped the regulatory agency as well as the public entity to reduce paper load. It
also resulted in annual savings of $16,000 for the city.
In spite of the challenge, participants reported that determining their legal and other
requirements brought immediate benefit to the organization. Without exception
participants believe that this knowledge was an important first step in developing stronger
compliance management programs and ultimately in promoting better compliance and
environmental performance. Many employees who previously had no understanding of
how their jobs fit into the organization's environmental goals and programs now
understood they personally could make a difference in the organization's environmental
performance and compliance.
The City of Londonderry, New Hampshire commented, "While each division of Public
Works is aware of what the current regulations are, there is now a consolidated list of
those regulations and a designated person responsible for keeping the list current. There
is a much wider organizational understanding of legal and regulatory requirements.
We'll adjust our procedures and work instructions to make sure that employees
understand that it's what they do or don't do every day that will have the greatest impact
on our compliance record."
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Employee Kickoff
Participants used some innovative approaches for their employee kickoff meetings. The
City of Scottsdale, Arizona conducted a stage show, complete with mascot, music,
choreography and costumes. They videotaped the production to use in other awareness
efforts throughout the city. The Town of Londonderry, New Hampshire developed
employee material celebrating the municipality's extensive apple orchards and featuring
the EMS as a way to protect that important resource while managing growth. The City of
Lowell, Massachusetts held a series of all-hands meetings at their wastewater treatment
plant, one for each shift. Political and facility top management presented the
environmental policy and answered questions about what involvement in the EMS would
mean to each employee. The union at the Lowell Wastewater Treatment Plant offered a
$200 incentive for employees when the plant becomes ISO 14001 EMS certified. Every
kickoff meeting encouraged employees, even those in "non-environmental" departments,
to be aware and involved in meeting the organization's environmental objectives.
a Top managers need training to prepare for their leadership role in the EMS.
Most managers were not sufficiently briefed about the scope of the EMS project, the
resource requirements, the change management issues inherent in EMS
implementation, or the leadership role required of them. This issue can be addressed
with custom-focused training for management and with regular and frequent
communication established with implementation teams.
a The Implementation Team is pivotal to the success of the EMS program. Team
members should be selected for their organizational knowledge, their excellent
interpersonal, organizational, and communication skills, and strong project
management ability. All of the departments of the fenceline should be represented on
the Implementation Team. They must have authority as well as responsibility. The
team leader is called the Management Representative because top management has
delegated him/her the necessary authority to implement the EMS. The Team
functions in an advisory capacity, developing the project plan, enlisting buy-in from
employees, collecting EMS information and disseminating it across the organization,
and providing guidance and leadership as the requirements are being addressed.
Implementation Teams need in-depth EMS training to ensure that they have a clear
understanding of the intent of the EMS and how each of the elements can be
integrated with the current programs.
a The role of the Implementation Team is to lead the project not to take
responsibility for completing all the EMS requirements. The team provides
guidance and assistance to employees throughout the organization in every aspect of
EMS activities. In order to do this they must have thorough training, sufficient
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Q
authority to delegate responsibilities and top management support, visibility and
leadership in establishing that the EMS is an organizational priority.
The language of the ISO 14001 EMS can be vague and subject to interpretation.
This was an initial barrier to participants who are used to more directive protocols.
Time should be spent at the beginning of an EMS program decoding the semantics of
the standard and understanding the intent of each requirement and how it is linked to
the others in the system.
There are resources in the community that can provide support in the EMS
effort. Many organizations that have implemented an EMS are willing to share
valuable shortcuts and keys to success with those newly engaged in the process. EPA
regional offices and state environmental agencies have information and materials that
support pollution prevention and compliance activities. For example, the EPA
Headquarters Office of Compliance has developed a Sector Notebook for
Municipalities 5, which can be extremely useful, particularly in determining legal and
other requirements. Many local universities and community colleges have been
strongly engaged in providing EMS support (e.g., Georgia Tech, University of
Florida TREEO Center, and University of Tennessee at Knoxville) and are sources of
reasonably priced training and consulting services.
Awareness, understanding and involvement in the EMS should extend across the
entire organization and be recognized as an organizational priority. One of the
central features of the EMS approach is that environmental stewardship is the
responsibility of every function and process and employee in the organization.
Employees come to enjoy and take pride in their active involvement in the
organization's environmental efforts. EMS awareness takes time to filter throughout
the organization and for employees to become comfortable with new ideas and
responsibilities. Employees will follow management's example, and it is the job of
management to develop enthusiasm and commitment for environmental protection
and for the EMS. Managers who model EMS involvement and who acknowledge
employee contributions have good success in achieving a culture change in their
organizations. Regular communication about benefits and successes of the EMS is
also important to building motivation and commitment.
The pilot project provided an opportunity to begin reshaping participants'
interactions with regulators. Many commented that past dealings with EPA had a
confrontational quality. The pilot project allowed the agency to take on a new role as
mentor and partner. All participants interviewed felt this was one of the more
valuable outcomes of the project.
It is not sufficient to provide training only to the EMS Project Manager. The
entire Implementation Team must be trained, ideally by an EMS expert, ideally on-
site, and at the very beginning of the project to establish a strong foundation of
5 US EPA Office of Compliance, Sector Notebook Project - Government Series EPA 310-R-99-001,
Profile of Local Government Operations, January 1999.
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understanding. Management must be willing to commit resources to this training
initially, and as needed throughout the program. Additionally, a team dynamic must
be fostered and maintained. Thelmplementation Team has a pivotal role in successful
EMS implementation and their ability to work together effectively and to understand
and master EMS concepts is a critical key to success.
Phase II: Significant Aspects and Objectives and Targets
February 1998- June 1998
Tasks in Phase II included:
a Conducting a thorough inventory of the environmental aspects (both regulated and
non-regulated) of their operations, activities, and services.
a Developing criteria for determining the "significance" of their environmental aspects
and identifying them based on these criteria.
a Setting realistic objectives and targets in conjunction with significant aspects and
environmental policy commitments.
The tasks in Phase II are at the very heart of developing the EMS. They require a
thorough and in-depth analysis of the environmental impact of operations, the
establishment of environmental objectives and targets, and meaningful employee input
and involvement in every department of the fenceline.
ISSUES IN PHASE H
Determining Significant Environmental Aspects
The first task in Phase II was to document a list of the organization's significant
environmental aspects. Significant environmental aspects form the very core of the EMS.
An environmental aspect is that part of an organization's activities, products or services
that can interact with the environment. A significant environmental aspect is one that
poses a significant risk or can have a significant environmental impact. Various
techniques have been used successfully for evaluating significant environmental impacts.
The EMS Pilot Project participants used a simple Significant Environmental Aspect
Assessment Matrix to compare potential environmental impacts against a set of
significance criteria. An example of the significant aspect assessment matrix is in the
Appendix C.
First, teams met with each department and constructed workflow diagrams that "mapped"
their activities. Then they evaluated the inputs, outputs and processes of these activities
for real and potential environmental impacts. Some participants chose to consider the
impacts from their contractors and suppliers. Suppliers provide local government entities
with necessary goods (e.g., salt and sand for road usage, chemicals for wastewater
treatment plants). Contractors operated some of the municipal facilities (wastewater
treatment plants) or provided services (roadwork).
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Once the list of environmental aspects was completed, each organization chose a set of
criteria to determine which environmental aspects were "significant" - that is, which
aspects were most critical to manage and control and which were not. Organizations
considered a variety of significance characteristics and values based on their individual
environmental and organizational goals. The Town of Londonderry, NH surveyed
residents about what environmental issues were of most concern to them (See Appendix
C for a sample of the survey). Most significance criteria were clearly focused on the
organization's environmental goals, but can also include health and safety concerns
depending on the organization's mission and vision.
The following chart gives examples of significance criteria participants used. There was
no requirement to use these specific criteria; participants could select none, one, or more
of them or use others that were entirely different. This list is included to describe some of
the more commonly used characteristics.
Characteristic
Regulation
Toxicity
Solid Wastes
Volume
Frequency
Energy Use
Water Usage
Complaints
Public Perception
Significant if
Everything regulated is significant
Note: the EMS operates within the frame-work of the
environmental regulatory system. The EMS must manage
regulated aspects
The impacts are significant to environment and health where
toxics alone pose a danger.
Any waste stream greater than 5 tons per year
Any occurrence where volume alone might pose a danger
(e.g., releases of water)
A repeated occurrence which creates a nuisance because of its
frequency
Any use that costs $1,000.00 or more per month or total usage
if greater than $10,000.00 per month
Any use over 5,000 gallons or total use over 25,000 gallons
per week
Five complaints or more annually for an existing nuisance
Any potential situation or occurrence that is likely to impact
public relations if it occurs
The City of Scottsdale and the Town of Londonderry decided to poll their citizens about
what environmental aspects were considered most significant. They conducted a
community-wide survey to discover which environmental issues most concerned their
citizens and factored the results into their prioritization criteria. This was also an
excellent method to publicize information about the EMS and their participation in a
national pilot program.
Once chosen, the significance criteria were applied consistently to the list of impacts.
Those impacts that met or exceeded the significance values were designated as
"significant aspects" and would be addressed by the EMS. Finally, participants
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documented their procedure for determining significant aspects and formally entered it
into their document control system.
Stronger Operational Control
Without exception, every participant in the program felt that the significant aspect
analysis was one of the most valuable tools of the EMS process. Organizational benefits
included better understanding and management of operational issues, expanded capacity
to address both regulated and non-regulated issues in their operations, and increased
opportunities to implement pollution prevention strategies. For example, the
Massachusetts Corrections Institute (MCI) at Norfolk recently ordered a new above
ground tank for storing small amounts of oil at its power plant. The tank was double
walled and met all the legal requirements regarding its construction and placement on
site. The EMS Management Representative remarked, "Before our significant aspect
analysis we would not have considered that we could take steps to prevent possible
environmental impacts associated with this new piece of equipment. We would have
accepted at face value that the tank met all its legal requirements and that would have
been that. However, we realized that placing a pad under the new tank would help us
contain a spill if one occurred. We convinced management that the few extra dollars
spent now for the pad would be ultimately much less expensive than the cost of
remediating the area later if a spill occurred." The City of Indianapolis remarked, "A
listing of a current inventory of chemicals and Material Safety Data Sheets has been
generated for operations. Chemicals identified as out of use were eliminated and
inventoried for re-use potential. The Environmental Resource Division has arranged that
all orphan drums be immediately disposed of by our Hazardous Waste Disposal
contractor instead of being staged at the operations site for disposal. The Training
Division has become more aware of additional training needs within operations."
EMS tools were extremely useful in risk management, and in that context, liabilities,
accidents, and privatization. Participants used workflow diagrams and significant aspect
analyses to identify operational hotspots where an accident might occur. They developed
plans and programs to reduce the probability of these incidents. Staff and management
developed a more comprehensive understanding of their potential exposure. With
reduced liability the asset value of the facility was increased. The EMS offered a
consistent process and tools to assess and reduce environmental liabilities, potentially
reducing insurance premiums, improving municipal bond ratings, and increasing the
value of the municipal assets. A stronger bond rating offers a major financial incentive to
a community. The Town of Londonderry saw their bond rating increase from Al to Aa3
during their EMS implementation. While they did not attribute this to their EMS alone,
the EMS Project Manager remarked, "We believe the EMS played a major role in our
bond rating change. The EMS and our Sustainable City Initiative were the only
significant changes in our application." In another example, Wayne County, Michigan
was facing the privatization of a number of its county facilities. Wyandotte Wastewater
Treatment Plant believes that the EMS will help them be more competitive and viable as
a business entity. Finally, New York City Transit Authority has included EMS
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requirements in contract specifications and they expect to reduce the overall costs of
rehabilitation projects.
Every participant has a similar story about how the EMS provided tools and opportunities
to prevent non-compliance by institutionalizing a proactive approach for managing
environmental issues. The EMS Management Representative from Lowell, Massachusetts
remarked, "We have learned and implemented an effective tool for defining our
environmental priorities and responsibilities. We have identified areas where we can
really mess up and where we need strong operational control. We have identified areas
where employee competence in a particular area is critical to the environment. We expect
that identifying our significant environmental aspects will increase our ability to stay in
compliance." Some organizations credit the EMS for helping them go "beyond
compliance", to address some environmental aspects that are not regulated, e.g., odor
management and energy efficiency. The EMS Management Representative from Wayne
County, Michigan reported, "Prioritizing our significant environmental impacts helps us
push the envelope and raise with management more environmental issues that we feel we
can address through the development of additional programs."
As previously mentioned, an added and unexpected benefit of the significant aspect
analysis was the usefulness of the workflow diagrams. Organizations used them to clearly
identify their actual and potential environmental "hotspots" and to indicate areas where
employee competence was particularly important. They made note of the operations that
were associated with significant aspects. They indicated which activities needed
operating criteria, procedures and controls; regular monitoring and measuring activities;
and emergency preparedness and response plans, which would be developed in future
phases of EMS activity. The workflow diagrams were also useful for evaluating the
adequacy of then: employee training programs to ensure that all staff understood the
environmental implications of their jobs and were competent to perform in the most
environmentally and operationally responsible manner. The Erickson Station Electric
Utility in Lansing, Michigan used the diagrams beyond the EMS. The EMS Management
Representative remarked, "The facility diagrams have also been used in situations
outside the scope of the EMS development. These are a valuable resource when
identifying process changes, in training new employees and for promoting understanding
between departments." Through the significant aspect analysis, participants began to
experience the potential of the EMS as a problem identification tool. Once the problems
were identified and prioritized, organizations were asked to establish some measurable
performance goals for managing meeting their environmental and organizational
objectives.
Objectives and Targets
Because significant environmental aspects are the environmental hotspots of operations,
organizations generally set goals for what they want to achieve in their management of'
these areas. Objectives are the environmental goals organizations want to accomplish in
their environmental programs. Municipalities not only want to maintain and expand their
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good compliance practices, but also want to take advantage of pollution prevention
opportunities in non-regulated areas and provide services to their stakeholders in an
economically and environmentally responsible way. Targets set out the detailed
performance requirements arid the schedule organizations will maintain in progressing
toward achieving their environmental objectives.
Each municipality in the pilot project established its own objectives and targets based on
its individual organizational goals, environmental priorities, and policy commitments.
Some of the objectives applied to the entire local government entity, some to the entire
fenceline, some to individual departments. Examples of objectives and targets for each
participant can be found in individual case studies in the Appendix B.
Measurable Indicators
A key element in the EMS process is measuring progress toward achieving objectives
and targets. Top management reviewed the objectives to ensure that they reflected the
organization's business, financial, operational and technological realities. Each
organization's objectives were quantifiable or measurable, so that progress could be
tracked and reported. For example, the City of Gaithersburg, Maryland's Department of
Public Works (DPW) identified runoff from outdoor vehicle washing as a significant
aspect. One of their objectives was to reduce oil, grease, and other pollutants entering the
storm sewer system. A target was to construct a new wash bay for equipment and
vehicles to minimize water runoff from outdoor vehicle washing. After reviewing this
objective, the city council estimated that raising necessary funds for this capital
expenditure would take five years. The Implementation Team changed the target to
"reducing the frequency of outdoor vehicle washings by 10% each year for the next five
years until the new technology will be fully funded." This was a target that could be
measured, would reduce the environmental impact of outdoor vehicle washing over time,.
would increase the environmental understanding and stewardship of DPW employees,
and gave the city governors time to meet the budget demands of a new technology.
Another objective was to reduce oily debris in the waste stream. Their target was to
report in three months the cost/benefit of using a vendor to pickup oily shop rags from the
maintenance garage, clean and return the rags for reuse. The City of Gaithersburg found
that it was both economically and environmentally feasible to recycle their shop rags in
this way.
Reducing energy use was an objective of the Wastewater Treatment Plant in Lowell,
Massachusetts. Their electric usage averaged $1 million per year. A number of
environmental management programs have helped reduce energy costs including the use
of motion sensors to control lighting in three buildings. This has saved the City $20,000
over a one year period. Other programs involving the efficiency of pumps and aeration
equipment are also being investigated.
The City of Scottsdale wanted to reduce paper use in City offices. Their target was for all
existing copiers to "double sided" as the default setting (instead of single sided default
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setting) and to write the same default requirements into contract specifications for new
copiers. They expect to reduce their paper use and save a considerable amount of money.
This expectation is based on a similar program at Intel Inc. a company located in
Scottsdale, who found that by changing from a single sided to a double sided default
setting saved them $ 100,000 over three years.
MCI-Norfolk set an objective to establish a new chemical management program in their
power plant. One target was to complete a chemical inventory within a one-month period.
As a result of the inventory, MCI-Norfolk revised its chemical buying and storage
procedures to safely store chemicals in quantities below regulated volumes. Not only did
they reduce their potential for environmental impacts; they promoted greater employee
awareness, understanding and competence in handling chemicals, and eliminated some
regulatory requirements as well.
While some participants set targets to reduce their environmental impact, others plan to
maintain their current status. For example, the Town of Londonderry, New Hampshire
has experienced 45% growth over ten years and continues to grow at a rate of 4%
annually. One of their objectives is to maintain their present volume of curbside
residential waste pickup in spite of their continuing growth. One way they plan to
accomplish this goal is through expanded community education and outreach programs
for the Town recycling and solid waste programs.
It was during this phase of EMS activity, that participants began to see a change in
organizational culture with regard to the environment. Previously, where organizations
had described their environmental goals only in terms of compliance with environmental
laws and regulations, they were now seeking opportunities to prevent pollution, to reduce
the demand-side of their operations, and to initiate programs for non-regulated issues like
odor management and energy efficiency. Some participants involved their contractors
and suppliers. For example, the Director of the Capital Programs Management Division,
New York City Transit Authority (NYCTA), sent letters to 600 contractors and
consultants informing them of NYCTA's EMS program and encouraging them to do the
same. Some of these have already called and asked for more information and what they
should do.
In fact, after about twelve months of EMS activity, participants were broadening their
definition of environmental protection and the role that each should play in
environmental stewardship. The Town of Londonderry remarked, "As part of the EMS,
better materials management was identified as a commitment in our Environmental
Policy. In line with that policy, decreased water usage has been identified as a benefit.
Thanks to the EMS, employees at the Highway Garage took it upon themselves to look at
High Pressure-Low Volume nozzles and other pollution prevention techniques to reduce
water usage. This tells us that environmental awareness and stewardship are beginning to
be institutionalized. Of course, supplemental benefits are lower costs as well"
Although participants had not had the opportunity to gather data on the effect of the EMS
on each organization's environmental performance and compliance, by the end of the
first year of the program, participants were reporting in monthly tracking documents a
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greater understanding of environmental issues and enhanced confidence in the
organization's ability to manage them. They expectedthat they would have a better
compliance record as a result of the EMS. The EMS Management Representative from
the New York City Transit Authority reports, "In relatively short period of time we have
learned and implemented efficient management tools for defining our environmental
priorities and responsibilities. We have developed performance partnerships with our city
organizations. We can better prioritize and defend our resource needs. We have raised
stakeholder issues, political issues, and technical issues. We have considered financial
implication, legal implications and business realities. As a result we have established a
much fuller definition of what environmental protection means in our organization.
Individually we have grown in our positions over the last few months and can handle our
responsibilities with better confidence and competency."
- ..
Lessons Learned in Phase II
o The significant aspect analysis is critically important and a useful tool in the
EMS process. First, it establishes a basis for building all the other elements of the
EMS. Second it inculcates the EMS more fully into the organizational culture
because it relies on employee input and involvement in every department and at every
level from top to shop. New York City Transit Authority appreciated that the
significant aspect analysis made it "easier to have a environmental focus in our
discussions because there was better understanding of our operations and
environmental issues."
a Successful EMS implementation is not possible without top management
leadership, visibility, and involvement. Lansing, Michigan remarks, "In order to
provide leadership, management must fully understand what an EMS implies for the
organization, be part of developing the project plan, and have a good idea of the
human and financial resources that will be required to complete the project." Top
management must understand the change management issues inherent in
implementing the EMS and the leadership role this requires. They must establish the
organizational priority of the EMS, ensure that authority has been delegated to the
EMS management representative and the implementation team, and make resources
available for completing EMS activities. Regular and frequent communication with
the EMS Management Representative and the Implementation Team will help prepare
top managers for their leadership role in EMS implementation.
Q Successful implementation of the EMS depends on employee input and
involvement, understanding and buy-in at every level in the organization.
Involving employees in the EMS from the very beginning of the process builds
understanding, involvement and commitment for the EMS and helps to
institutionalize the EMS into organizational culture. Employees are the ones who
know their operations best and will be carrying out the programs, measuring the
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progress, and ultimately achieving the goals. They are in the best position to
recognize and suggest opportunities for pollution prevention and environmental
stewardship in their areas of expertise. The City of Lowell reported that as the facility
employees became more familiar with the EMS and their role in it, they began to
enjoy their involvement in the cutting edge program. They were motivated by the
opportunity to impact national environmental policy as a result of participation in the
pilot program and enjoyed being leaders in an innovative project.
Managing organizational change is a significant part of EMS implementation.
"You're asking an organization to change the way it does things, and that's huge,"
Lowell, Massachusetts remarked. "It takes every day of two years to permeate, to get
into the organization ... it's very difficult to do. Organizations should expect and plan
for cultural change that occurs during EMS implementation."
Management must ensure that sufficient resources are available to develop and
implement the EMS. Implementation Teams depended on sufficient time for
training sessions and regular meetings with employees to accomplish the tasks in
Phase IL They set schedules for collecting and disseminating information and
conducting analyses. When asked about barriers in this phase, the City of Indianapolis
remarked, "TIME, TIME, TIME! We are committed to the EMS as a benefit to our
organization. However, everyone has multiple priorities and our lists keep getting
bigger!"
Workflow diagrams, maps, or flowcharts are useful tools in the Planning stages
of the EMS and in later stages as well. Process maps helped everyone understand
and agree on the inputs, outputs and processes in the department and provided a
visual representation of potential environmental "hotspots" and areas where strong
operational control and employee training would minimize potential environmental
risks.
Phase DDE: Environmental Management Programs
July 1998- January 1999
Tasks in Phase HE include:
a Developing environmental management programs (BMP) to accomplish each
objective and target they had set.
Phases I and II focused on establishing an organizational basis for the EMS, developing
an environmental policy, determining and understanding legal and other requirements,
defining environmental priorities and setting environmental objectives and targets. In
Phase in participants developed environmental management programs (EMP) or action
plans which described how they would achieve the objectives they had set in Phase II.
The plans defined organizational arrangements, structures and relationships. They tasked
personnel with responsibility and authority to ensure that the programs worked; allocated
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resources; refined procedures and work instructions and provided training where
necessary. EMPs required participants to identify potential problems, recommend
solutions and provide controlling activities until the suggested changes were in place.
Departments also tested and verified that their emergency response plans were effective.
Management programs were adjusted or developed to meet compliance obligations and
policy commitments.
The resulting set of environmental management programs provided dynamic, short-term
blueprints that fully described the activities, resources, and responsibilities for
accomplishing the organization's environmental goals.
ISSUES IN PHASE IH
Environmental Management Programs Should be Linked to Policy Commitments
An environmental management program involves narrowing down broad long-term
policy commitments and the management of significant aspects through objectives and
targets, to a plan of action for meeting environmental performance goals and measuring
progress.
For example, an organization's environmental policy might state that it wants to reduce
waste and waste disposal costs. An analysis of significant environmental aspects
identifies that the organization accumulates a large number of wood pallets from
suppliers, and that these increase their impact on the landfill and their disposal costs. A
possible environmental objective might be to eliminate pallets from their waste stream by
returning them to their suppliers after the pallets are unloaded. The target might be to
reduce the number of pallets by 30% in December 1999, 70% by April 2000 and 100 %
by September 2000. They anticipate that their waste stream will be reduced and their
landfill costs decreased by a certain dollar amount, perhaps $70 a ton.
An initial overview matrix in the case of pallets described above might look like this:
Policy
Commitment
Prevention of
Pollution:
Reduce
quantities of
solid waste
Significant
Aspect
Wood
pallets
Objective
Reduce waste
stream to
landfill and
reduce waste
disposal costs
Environmental
Management
Program
Inform suppliers
that wood pallets
must be removed
after delivery.
Specify date
when program will
begin
Count # of
pallets currently on
site
Review # tons
sent to landfill per
quarter
Count pallets on
site in December,
Department
Involved
Receiving
Responsible
Person
Receiving
Manager
(name)
Receiving
clerk
Budget
$1000
(direct
labor
costs)
Timing
Fully
Implement
by Sept
2000
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1999, April and
September 2000
Evaluate effect
on landfill tonnage
and cost
Accounting
Bookkeeper
An environmental management program provides answers to the questions what should
be done, when should it be done, who -will do it, how will they do it, and how do we
measure if it -worked.
The Town of Londonderry, New Hampshire identified a number of significant aspects in
its Department of Public Works Highway Garage: solvents, disposal of oily rags, vehicle
painting and washing of garage floors and vehicles. Londonderry's overview matrix
looked like this:
Policy
Commitment
Prevention of
Pollution:
Improve
materials
management
Objective
Prevent any
solvent spills
Ensure proper
health and
safety
measures and
handling
requirements
are taken when
painting
vehicles
Environmental
Management
Program
Construct berm
and fasten tank to
wall
Audit current
painting
procedures and
incorporate
necessary
recommendations
or abandon
activity
Invite non-
regulatory arm of
OSHAforawalk
through at garage
Develop plan
to address grey
water, including
dates of
implementation
Hire laundry
service to clean
and recycle shop
rags
Departments
Involved
Highway
Engineering
Highway
Responsible
Person
Highway
Garage Mgr
and department
personnel
(names)
Engineering
and Highway
Garage Mgrs
and department
personnel
(names)
Budget
$xxxx
(direct labor
costs)
Sxxxxx (direct
labor costs)
Sxxxxx
Time
Frame
April 1999
July 1998
October 1998
May 1998
November
1998
When fully developed, the participants' environmental management programs will:
1) Identify specific action steps;
2) Set defined schedules;
3) Allocate staff and financial resources;
4) Establish individual and group responsibilities;
5) Identify any training needs for the staff involved;
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6) Establish a monitoring/measuring and reporting system to ensure that individual and
departmental obligations were being met; and,
7) Establish emergency preparedness and response plans.
Developing Environmental Management Programs
As a first step in developing environmental management programs Implementation
Teams reviewed their list of significant aspects and the workflow diagrams that identified
where in the organization these occurred and how they would be monitored and
measured. Implementation Teams met with the appropriate department personnel and
confirmed the environmental "hotspots" that involved these significant aspects.
Departments reviewed their applicable legal and other requirements, and examined
existing operational procedures and wo'rk instructions, making necessary adjustments to
reduce possible environmental effects. They verified that appropriate operational controls
were identified and verified that employees were fully informed of these obligations in
their job descriptions. Department managers made note of which employees would
require additional competency or awareness training and which job descriptions needed
amending.
EMS Documentation
These activities generated a heavier load of documentation responsibility than in previous
phases, and some participants hired outside consultants to manage EMS documentation
(Lowell, Gaithersburg, and New York City Transit Authority). Others hired college
interns and students (Londonderry). The City of Scottsdale managed their documentation
via the City website (password and write-protected). Some Teams tasked one member as
the "document guru" (MCI-Norfolk, Wayne County, Lansing) to be responsible for
making the identified changes. Some recorded interviews with employees "on the shop
floor" and drafted written procedures from these conversations. Some created procedure
writing teams in each department to draft or modify procedures. Some facilities had
procedures and work instructions that were not documented, and this increased the
workload. Most were pleased to discover that their existing procedures and work
instructions needed very little revision and that the EMS requirements for documentation
and document control meshed well with their current systems. MCI-Norfolk remarked
"This part of the project has been fairly easy. Our organization is already driven by the
types of systems and documentation that is required in an EMS."
Although the documentation of procedures and work instructions was time consuming,
participants found that it was very useful. The manager of the Lowell WWTP remarked,
"This process has brought unity to our facility. We know exactly where to find all of our
work instructions and procedures, and they are all written in the same format. This makes
it very easy to have good communication and for training and provides better consistency
in our three shifts. Additionally, we have five departments, and now each knows what the
other group does and sees how we are all integrated and how important we each are to the
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safe functioning of this facility. This has eliminated jealousies between groups. There's
also a feeling that responsibility for what goes on here trickles down from top
management through the whole staff."
MCI-Norfolk remarked, "We have always had documented procedures and manuals for
the security end of our business. We now have them in place for the environmental
aspects of our business. We built our EMS documentation very easily on our existing
post orders (procedures and work instructions). As each procedure is drawn up it allows
us to implement work procedures that better control activities in each area. We have a
high turnover rate of employees, but there's no confusion in anyone's mind about exactly
what each employee is required to do. It's all written down in these binders. These post
orders ensure that we communicate our expectations in a consistent way. Our employees
sign that they have read them and we check frequently on the job that they understand
them and are following them. This more than anything else has institutionalized the EMS
in our facility. As a result, we are developing sound work procedures for areas that have
historically caused us concern because of sloppy work behavior or performance."
Structure and Responsibility
Implementing the management programs moved the EMS from the planning table onto
the shop floor of the organization's day to day activities. The EMS approach holds all
personnel, even those outside of the organization's environmental functions accountable
for the environmental issues associated with their jobs. Implementation Teams worked
closely with each department hi the fenceline to clearly identify and communicate
employee roles and responsibilities vis a vis the environment. Most employees responded
positively, and regardless of then: job or status in the organization, were interested in
helping to protect the environment. In a short time, as described previously, employees
throughout the fenceline began to notice and report potential environmental concerns in
their areas of responsibility before they became a problem and were eager to discover an
opportunity for improvement that could reduce risks and save money for the
organization.
The EMS Management Representative and the Implementation Team clearly defined and
communicated their own roles and responsibilities and the roles and responsibilities of
departmental staff with respect to implementing the EMS. Participants developed the
following structural guidelines from their experiences in the pilot program:
a Department managers are responsible for completing environmental management
activities in their respective departments.
p Department personnel will be assigned specific task responsibilities identified in the
environmental management programs.
a All employees must know what they are to do, how they are to do it, and that they
have authority to do what is required.
a The Implementation Team acts as advisors, coordinators, and facilitators to these
efforts.
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a In order to complete their responsibilities all employees must be supported by the
necessary authority, resources, and training.
a Ultimate responsibility for accomplishing environmental goals remains with senior
management.
Training, Awareness and Competency
Once the operating procedures and work instructions were documented and roles and
responsibilities clarified, it was important to assess the skills employees required to carry
out their environmental responsibilities competently. All employees were given a broad
understanding of the organization's environmental issues and policy and awareness of
how their job potentially affected the environment, and some were given task specific
training.
Two Areas of EMS Training
AWARENESS
(ALL EMPLOYEES)
TASK SPECIFIC
For employees
Associated with
ignificant Aspects
As mentioned previously, participants used a variety of training methods and materials
for awareness training: wallet cards, T-shirts, shopping bags, and posters for awareness
training and understanding of the organization's environmental goals and priorities. For
task specific or competency training they used on-the-job-training; brown bag lunch
sessions; all-hands meetings, process charts, videos, and CD-ROMs. In addition,
participants kept their training records up to date. They built on their existing training
programs and used their documented procedures and work instructions to assure
competency in jobs associated with significant environmental aspects. Participants found
that incorporating the EMS requirements for training into their operations was relatively
easy to complete. MCI-Norfolk remarked, "Employees in the fenceline begin following
the new procedures with relatively little complaint because they know that they worked
on developing them." Participants gained compelling benefits from their focus on
employee competence. For example, the Lowell WWTP set an objective to develop a
strong chemical management program. They stepped up their training on chemical
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handling procedures across the entire fenceline and "in the past two years have had no
chemical spills or mishaps and in fact no near spills."
Emergency Preparedness and Response
There's no denying that accidents and emergencies can happen in organizations, but are
less likely in organizations that have strong operational control. As part of the EMS
approach, participants evaluated and analyzed their potential for accidents and
emergencies. They reviewed past occurrences, evaluated why they had occurred, and
used them as indicators to where future accidents might happen. Was the accident caused
by a lack of training? Insufficient operating criteria or operational control? Was it
equipment failure? What could they learn from their previous experience?
Employees evaluated emergency response programs currently in place to ensure that
there would be appropriate responses to unexpected or accidental incidents. These
responses included procedures for preventing and mitigating environmental impacts
during emergency response. Participants reviewed and modified emergency procedures
where necessary (particularly after an accident and root cause analysis showed needed
changes). Many had not tested their emergency response procedures in a while, and
conducted them where feasible. They verified that all employees, including those just
recently hired, knew what to do (including communication channels) in an emergency
and that roles and responsibilities were clearly defined and communicated. They provided
training where necessary.
Some extended these requirements to their contractors and suppliers. For example, the
Town of Londonderry, New Hampshire announced tenders for waste hauling and
included in their contractor specifications a requirement to review the handler's
emergency preparedness and response plans. Five companies responded to the tender,
none objected to the requirement, and those that did not have emergency response plans
developed them in order to compete.
ssons Learned in Phase HI:
D The key to successful environmental management programs is to integrate
environmental responsibilities into the daily responsibilities of all employees.
Environmental management is part of everyone's job. All employees (and sometimes
contractors and suppliers) will be carrying out environmental management programs
and accomplishing objectives and targets as part of the day to day operations.
Existing job descriptions and work instructions will be revised or amended to reflect
environmental management roles and responsibilities.
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a Roles and responsibilities must be clearly identified and communicated
throughout the organization. Effective delegation, explicit responsibilities and clear
lines of reporting will minimize problems and confusion. EMS roles and
responsibilities are more easily understood and become part of everyday business if
they follow existent organizational hierarchy rather than forming a separate structure.
An organizational chart is fundamental to define structure and lines of
communication. Problems occur without a clear understanding of roles and
responsibilities. Resources may not be properly allocated. Employees may feel that
"this is not my job". There may be a duplication of effort or lack of coverage of some
tasks. The organization may not be adequately prepared to respond to emergencies.
Responsibilities that are supported by the necessary authority and sufficient training
will enable employees to carry out their tasks effectively.
a Senior management is ultimately responsible for the organization's
environmental performance. Management delegates some of its responsibility to
qualified and experienced personnel. In the case of the EMS, management delegates
responsibility to the EMS Management Representative. Appropriate authority
accompanies the responsibility, and management clearly communicates throughout
the organization the limits of authority and responsibility for this individual.
Management commits sufficient resources and training to ensure the EMS
Management Representative and the Implementation Team are competent to carry out
EMS duties.
a Senior management leads by example. One of the most important responsibilities
for management is to set an example that the EMS is a priority and that
environmental stewardship must be integrated into everyday business activities and
decisions.
d The Implementation Team facilitates the EMS approach. They are cheerleaders,
advisors, trainers, problem solvers, but it is not their management system. Top
management commits the organization to an EMS approach and is responsible for the
commitments made in the environmental policy. The responsibility for the
implementation and maintenance of the EMS rests with top management.
a Implementing an EMS changes the organizational culture. There is a shift in
focus, away from a singular focus such as environmental compliance, to a broader
commitment to manage all the organization's impacts, both regulated and non-
regulated. All functional areas of the entity are involved in environmental
management, not just the environmental department. Process improvements and
changes occur as a result of better employee understanding and involvement.
a Documented procedures and work instructions are useful training tools. They
promote operational consistency, cross-functional understanding, and help to
institutionalize the EMS. They do not need to be newly created, but are best built on
existing practices.
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For some organizations, outside support is useful for managing the EMS
documentation requirements. Some participants hired consultants; others used the
services of interns or college students.
Phase TV: Monitoring and Measuring and Management Review
February 1999- July 1999
Tasks in Phase IV included:
Q
a
Q
Q
Q
Monitoring and measuring key characteristics of the management system.
Conducting EMS audits.
Developing and implementing procedures for handling EMS nonconformance.
Determining the organization's compliance status.
Initiating a Management Review cycle.
Measuring, monitoring and evaluating are the activities that ensure the organization is
performing hi accordance with its environmental management programs. Organizations make
policy commitments to compliance, prevention of pollution and continual improvement, so
getting feedback on how well their planned activities are working and what modifications are
needed is an important part of the EMS process.
Senior management needed data and information as part of the management review process
to judge if the organization was achieving its environmental goals. Was the EMS being
carried out as planned? Was the organization achieving its policy commitments and its
objectives and targets? During the final phase, Implementation Teams gathered information
and data so that senior management could answer these questions and make a determination
if the EMS was suitable, adequate and effective.
ISSUES IN PHASE IV
Monitoring and Measurement
Participants looked first at the procedures for operations and activities that could impose
a serious threat to the environment and then at the monitoring and measuring procedures
they presently used in these areas. Were environmental performance indicators,
operational controls, and conformance with environmental objectives and targets being
tracked and was the information being recorded and supplied to management? How were
they evaluating their compliance with environmental laws and regulations? MCI-Norfolk
remarked, "The designated fenceline is conducting business in a much cleaner manner.
We just don't do some of the things that caused us problems in the past. I think this is
because of an awareness of the program and the fact that people know that systems are in
place that monitor and measure then* everyday activities."
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Monitoring equipment was calibrated and maintained and records of the process were
kept according to the organization's documentation procedures. The City of Indianapolis
remarked, "The drum rack system is in place, and all existing expendable drums have
been removed. Better housekeeping in the garages is evident. Also, we have begun a
regular monitoring program which will include touring the garages on a regular basis to
ensure that there is not a build-up in the number of drums." The City of Gaithersburg was
able to reduce the amount of salt and sand they used to treat roads in winter. When they
began to measure the volumes used, they realized that a lesser amount would do the job
just as efficiently. This reduction had a positive effect on their wastewater treatment plant
load.
Procedures for determining how the organization would measure progress toward
achieving its objectives and targets were developed and participants made decisions
about how they would evaluate their compliance with applicable environmental laws and
regulations.
Conducting Compliance and EMS Audits
Participants developed procedures for evaluating their compliance with the law (e.g.,
compliance audits or inspections) and will use these procedures as they implement their
EMS.
Participants had been encouraged to begin the EMS audit process very early in the EMS
development. Group audit sessions provided the opportunity for participants to audit and
discuss each other's documentation at a number of the training sessions. Some
participants (New York City Transit Authority) hired outside consultants for the internal
audit function, but most selected staff members to serve on EMS internal audit teams.
Most organizations chose to break down the management system into auditable parts
rather than audit the entire system at one time. The Town of Londonderry, NH chose to
audit its environmental policy before moving on to the rest of the EMS (See Appendix C
for the Londonderry, NH audit sheet), Initial preparatory activities included selecting and
training the audit team, allocating resources for the audit function, determining the audit
scope, developing auditing procedures and audit protocols, establishing an audit
schedule, and maintaining audit records. Management was fully briefed on the conduct of
the audit and received the audit report. Information from the audit activity provided
constructive input into the development of the environmental management programs and
aided in the process of continual environmental improvement.
During the audits, teams sometimes found "nonconformances," a term that describes
management programs which are not conducted in conformance with the organization's
set policies, procedures, objectives or targets. In areas where nonconformances were
found, organizations were encouraged to investigate the problem and identify the root
cause of the nonconformance (e.g., insufficient training, deviation from procedures or
operational controls) and implement a corrective action. Some thought was also given to
preventive actions that would prevent repetition of the nonconformance in the future.
45
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The corrective and preventive actions were documented and tracked, with the expectation
that these patterns would be useful for avoiding future occurrences.
The Management Review
It was the job of the Implementation Team, and particularly the EMS Management
Representative to provide senior management with sufficient information and records to
make an assessment of the effectiveness of the EMS. Information that was provided to
management included EMS audit results, corrective and preventive actions, progress on
objectives and targets, reports of emergencies, new legislation affecting the organization,
suggestions for improvement from employees, new customers, growth and development
plans, change in land use, results of compliance assessments and the results of previous
management reviews.
ssons Xearned in Phase IV:
Train an audit team of two or three employees. Auditors must have some
independence of the function they are auditing in order to maintain objectivity and
impartiality. A team of more than one auditor allows for employee turnover and
scheduling difficulties. The initial audit team will be invaluable in training additional
auditors as audit demands increase. Staff who have excellent interpersonal skills,
good judgement, tact, and respect for confidentiality make good auditors. Auditors
are good listeners and observers who are able to make decisions based on objective
evidence. They need strong organizational skills, and the ability communicate well
both orally and in writing.
Audit frequently and early in the EMS process to gain on-the-job experiences
and confidence. Don't wait for the entire system to be developed and implemented
before beginning the audit function. Early in the EMS implementation auditors can
audit the environmental policy and the system procedures for determining legal and
other requirements and for identifying significant environmental aspects. Audit teams
gain confidence and skills quickly with plenty of on-the-job experience and the audit
findings are good lessons learned in developing subsequent portions of the
management system. Management must provide sufficient resources (e.g., time and
training) for the audit function to be conducted.
Audit teams are encouraged to keep a balanced perspective. It is as important to
identify areas where arrangements are working well as to identify areas where
improvements are required.
Keep documents and records simple. Document only what is required and what
you absolutely need.
46
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Start small and simple and build monitoring, measuring and evaluating systems
over time. The checking and corrective action activities are key functions in an
EMS. Developing organizational competency takes time.
47
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SECTION ^
It was expected that all of the participants would complete the seventeen EMS
requirements during the two-year period of the pilot project; however, this was not the
case. One of the participants completed all of the requirements and achieved verification
of their EMS from an independent third party verifier during the term of the project. Five
others will seek third-party verification in the near future. Three are undecided whether to
seek external or internal verification about the conformance of their EMS.
Appendix D shows the range of EMS requirements that each organization completed.
Resource Requirements
Participants tracked monthly expenses associated with their EMS activities throughout
each of the four phases of implementation. Direct labor costs account for the bulk of the
financial resources participants invested. Other costs include travel to training sessions,
in-kind contributions, and materials. Figure 1 illustrates the direct internal labor costs
(average) incurred for implementing the EMS over a 21-month period. The expenses of
each participant are examined in Appendix B Case Studies.
Figure 1:
Direct Internal Labor Costs (Average)
Dollars
(Thousand)
20-
10-49
50-150
Number of Employees in Fenceline
1,000-2,000
The number in parentheses indicates the number of participants in that size category.
48
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In addition to the EMS Management Representative and the Implementation Team, city
government personnel, community activists, administrative support staff, legal
departments, and environmental managers contributed time to the EMS program. Figure
2 illustrates the total direct internal labor time (average) committed to implement the
EMS over a 21 -month period.
Figure 2:
Direct Internal Labor Time (Average)
Hours
10-49
50-150
Number of Employees in Fenceline
1,000-2,000
The number in parentheses indicates the numbers of participants in that size category.
Consultants
Four of the participants utilized the assistance of consultants. Each of these participants
used a consultant to address specific needs. The services provided by the consultants
ranged from additional training, to establishing a documentation system, to full-blown
assistance with implementation. Table 1 breaks down the time and cost of the
consultants' services for each of the participants.
Table 1
Organization
Wayne County
Indianapolis
Lowell
NYCTA
Consultant Time
80 hours
102 hours
210 hours
1,110 hours
Consultant Costs
$2,400
$9,700
$10,500
$143,000
49
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As can be seen from Table 1, one of the participants, the New York City Transit
Authority, chose to rely heavily on consultants to develop their EMS. While this is
certainly an acceptable approach for any organization, it is not, in most cases, necessary
to rely heavily on consultants to develop an effective EMS.
50
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SECTION ^Benefits; Barriers
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to Success "
At the final meeting in New York project participants discussed the benefits and barriers
their organizations had experienced during the two-year project.
BENEFITS
1. A positive effect on environmental compliance and performance
PARTICIPANTS REPORT:
With regard to environmental compliance, -we have a better understanding of our legal
requirements. We have better-trained employees whose competence in their work area is
critical to the environment. We expect that our EMS efforts will increase our ability to
stay in compliance.
We now know where our operational hotspots are and are beginning to investigate the
root causes of some of our noncompliances. This gives us a feeling of control over our
environmental issues, rather than responding reactively with a "Band-Aid" approach.
The EMS has provided us a consistent method for finding the root causes of our
noncompliances. We are no longer applying reactive quick fixes for violations, but are
seeking to eliminate the causes of these violations and prevent future occurrences.
Training, communication, monitoring and measuring and regular management review
are the EMS tools we use every day that make this possible
We 're able to push the envelope a bit. We 've been able to carry environmental protection
into areas where EPA doesn 't have regulatory programs, but which are of significant
concern to our citizens, such as odor control. There are unregulated environmental
issues that we 'II develop management programs for in an effort to serve our customers
better.
2. Improved environmental awareness, involvement and competency throughout
the organization
PARTICIPANTS REPORT:
As a manager my skills have improved as a result of an increased understanding of the
organization and its environmental issues. My knowledge about operations has been
broadened and I have an increased understanding of technical and personnel issues.
There's a much better understanding of environmental issues in every department of the
fenceline, not just in the environmental department. We are recognizing simple internal
"housekeeping" measures that are having a positive effect on our environmental
performance. We have self-imposed additional requirements to help prevent pollution,
51
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reduce energy use, manage our contractor, and expand environmental education for our
citizens. Employees are bringing ideas for reducing our waste streams, for less toxic
products. There has been a definite improvement in involvement and morale!
There are many more people aware and involved in environmental protection and
stewardship than ever before. There's a sharing of responsibly because a link has been
formed between the environmental department and other departments.
3. Better communication about environmental issues inside and outside the
organization
PARTICIPANTS REPORT:
We know much more about our environmental issues than we did 18 months ago.
Consequently we are more articulate in our conversations with other departments, other
bureaucratic systems, with the state, with our own regulators, and with our neighbors.
People now have an avenue to bring up environmental issues. There are fewer stigmas in
being involved in environmental programs.
We have better communication with our vendors. It's easier to require them to maintain
an environmental focus that is consistent with our policy and our objectives.
One would think government agencies would be in compliance but more often than not
they aren 't. State agencies have an ethical obligation to stay on the right side of
environmental issues. Public recognition is a crucial factor. There's a better recognition
and fuller understanding of the appeal to voters of reducing environmental liability and
the costs associated with it.
4. Improved efficiency, reduced costs, greater consistency
PARTICIPANTS REPORT:
Systematically analyzing compliance issues revealed an opportunity to save money.
Fifteen departments were responsible for obtaining their own air quality permits - 23
altogether. The implementation team consolidated these permits into 8, saving the city
$16,000/year.
In a relatively short period of time we have learned and implemented efficient
management tools for defining our environmental priorities and responsibilities. We have
developed performance partnerships with our city organizations. We can better prioritize
and defend our resource needs. The EMS tools give us a better understanding of what we
are required to do and the means to do it consistently, competently, and efficiently.
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5. Better relationships with regulators
PARTICIPANTS REPORT:
In the past, every time the EPA showed up it was because of a compliance issue or a
consent decree. The EMS is our opportunity to develop a proactive program.
We have seen improved relations with our state regulatory agency as a result of our EMS
activities. We believe the state is quicker to provide technical support, and has been
much more supportive of us in general.
We have discovered several state and federal EPA offices that can (and have) provide us
technical assistance in our sector.
The pilot project has provided an opportunity to reshape our interactions with our
regulators. Our past dealings with EPA had a confrontational quality. The pilot project
allowed the agency to take on a new role as mentor and partner. This was one of the
more valuable outcomes of the project.
BARRIERS
1. Managing organizational change
PARTICIPANTS REPORT:
A systems approach requires a fundamental change in how the organization addresses its
environmental issues. The most common remark we hear is, "That's not my job it's the
environmental department's job. It's beyond our job description. "
As we develop programs that build environmental stewardship and improve how we
manage our environmental obligations, we must also develop programs that manage
human and organizational resistance to change.
An EMS promotes increased awareness and understanding across the entire
organization. A 30-year employee has acquired a considerable knowledge base over his
employment period. In our organization knowledge is power and not always readily
shared. System thinking can be threatening to employees.
Overcoming the "Jirefighting mentality" has been challenging - in our organization a
reactive response to environmental issues produces one or two heroes. There are entire
departments of heroes in an EMS because it's proactive the entire organization shares
the credit for managing environmental issues.
There's a motivational barrier here - no news is good news - good news is no news.
53
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2. Lack of top management visibility and involvement
PARTICIPANTS REPORT:
Change management requires top management leadership and visibility and personal
involvement, not just lip service. Management needs a better grasp/understanding of
what an EMS requires of an organization and of their role in the process before deciding
to implement it.
3. Organizational issues
PARTICIPANTS REPORT:
There's a steep learning curve. We 've had frequent management change, downsizing and
staff"streamlining, and employee changes in our Implementation Team.
Moving beyond the planning stage and integrating the EMS approach into existing
systems has been really difficult because there is not understanding and buy-in
organization-wide. We have not involved enough staff "on the shop floor. "
Time, Time, Time! Time is an essential resource ...it's very limited and there is an
erroneous perception that the EMS is above and beyond normal work duties. Dollars are
abstract but time is concrete and while management has assured us the necessary
dollars they allow too little staff time during the Getting first tier management buy-in and
cross-functional responsibility for EMS implementation has been a challenge. EMS
implementation is viewed as the Implementation Team's project.
The EMS Implementation Team has been given the responsibility but not the authority it
needs to facilitate implementation.
Establishing and maintaining a paper trail of consistent processes, procedures, and
records is time consuming.
4. Lack of public awareness, understanding and buy-in
PARTICIPANTS REPORT:
"Is this a regulatory requirement? We already have programs to manage our
compliance." If it isn 't required by compliance, top management isn 't going to do it.
You are expected as a municipality to already do this. There is little public knowledge,
interest or appreciation - "Why should we be excited? Isn't that your job? " If the public
demands the EMS then it will happen. Lack of public awareness or concern makes it
difficult to prioritize the EMS in the budget process.
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There's a lack of awareness or understanding about the benefits that the EMS has
brought to the organization and the value it will bring in the future. Local government
entities can realize many more benefits than just being in compliance, and we 've
broadened the performance indicators we are using to measure our success. We haven't
communicated this fact well to the city management or to the public, so there's little
demand from our clients - the citizens -for the EMS.
5. Political uncertainty
PARTICIPANTS REPORT:
"The EMS is not institutionalized yet. We have a new administration in the wings. We
hope the EMS won't be seen as the last regime's program. "
"If your top management support (city manager or select board) leaves, you are back to
ground zero and need to go back and educate to regain support. "
KEYS TO SUCCESS
While there were many lessons learned in the program, participants agreed there were
four essential keys to EMS success:
1. Top management commitment and support is essential to the success of the EMS
process.
Employees are always eager to determine who is leading the charge for a new initiative.
If management is visibly involved, there is a clear indication that the initiative has a high
priority and deserves employee attention. In a local government entity it's particularly
useful for facility managers and political leaders to be united in their support and
involvement in the EMS.
Top managers must be sufficiently prepared to understand and take on their leadership
roles. Many take their EMS training along with the Implementation Team. Topics that
should be addressed in EMS training include an understanding of the EMS principles and
requirements; top management role and responsibilities; the implementation schedule;
human and financial resource requirements, and the change management issues that will
be involved in EMS implementation. The Implementation Team can help management
stay involved by communicating regularly and frequently about the progress of the EMS
and the organizational benefits accrued during development and implementation. Above
all, managers will convince employees that the EMS is a priority more by then- deeds
than then- words.
2. Organizations who build on existing organizational processes and procedures
are more successful than those who create new EMS elements.
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Most organizations already have in place about 85% of the elements required by the
EMS. Rather than recreating what already exists, efforts should be concentrated on
reevaluating the usefulness of existing processes, making revisions as appropriate,
eliminating redundancy, and improving communication and access to the information
throughout the organization. An EMS is a dynamic system that relies on continual
improvement of management processes and matures over years of implementation.
3. The Implementation Team is pivotal to the success of the EMS program.
Team members should be selected for their organizational knowledge, their excellent
interpersonal, organizational, and communication skills, and strong project management
ability. All of the departments of the fenceline should be represented on the
Implementation Team. The team leader, called the EMS Management Representative, has
been delegated the necessary authority to implement the EMS, and in fact the entire team
must have authority as well as responsibility. The Implementation Team functions in an
advisory capacity, developing the project plan, enlisting buy-in from employees,
collecting EMS information and disseminating it across the organization, and providing
guidance and leadership as the requirements are being addressed by employees
throughout the fenceline. Implementation Teams need in-depth EMS training to ensure
that they have a clear understanding of the intent of the EMS and how each of the
elements can be integrated with the current programs.
4. Employee awareness, understanding and involvement in the EMS should extend
across the entire organization and be recognized as an organizational priority.
Involving employees in the EMS from the very beginning of the process builds
understanding, involvement and commitment for the EMS and helps to institutionalize
the EMS into organizational culture. Employees are the ones who know their operations
best and will be carrying out the programs, measuring the progress, and ultimately
achieving the goals. One of the central precepts of the EMS approach is that
environmental stewardship is the responsibility of every employee in the organization.
Employees come to realize and take pride hi the active role they play in the
organization's efforts to protect the environment. EMS awareness takes time to filter
throughout the organization and for employees to become comfortable with new ideas
and responsibilities. Employees who are involved in the EMS process and who contribute
to the development of procedures and work instructions in their respective departments
are more willing to accept organizational changes inherent hi the EMS implementation.
Managers who expect EMS involvement across the entire organization and who
acknowledge employee contributions have good success in achieving this culture change.
Regular communication about benefits and successes of the EMS is also important to
building motivation and commitment. Employees will take their cue from management
whose job it is to develop enthusiasm and commitment for environmental protection.
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CONCLUSION
Data and information collected in the pilot project shows that an EMS provides local
governments with incentives and strong management tools to meet regulatory and
compliance responsibilities and integrates well with existing compliance and health and
safety programs. In the words of the EMS Management Representative from Lowell,
Massachusetts, "This worked!"
The EMS helped government entities factor citizen and other stakeholder concerns and
organizational priorities into their annual environmental objectives and targets and to
design robust management programs for meeting these objectives. In addition to better
environmental performance and compliance, the EMS approach encouraged pollution
prevention approaches, increased employee awareness and competence, and extended
consistency and operational control in areas that have the greatest potential to impact the
environment.
Costs for implementing the EMS were primarily the intellectual capital and direct labor
charges of the workforce. The fact that all employees facility-wide - not just those in the
environmental department - are engaged in environmental protection and environmental
stewardship and take pride in their involvement and leadership in cutting edge programs
is a step toward realizing a goal in EPA's Aiming for Excellence - "getting more of our
society to achieve environmental excellence." 2
Each of the nine participating entities took a risk in committing to a program that
required new ways of thinking and new ways of doing business. The public entities that
participated in the pilot project not only acted as environmental leaders, but also offered
their citizens a higher level of public service. They set standards of excellence that will
define future municipal practices for themselves and their peers.
Each city was rewarded with a unique set of benefits that often exceeded their
expectations, not the least of these benefits was a more positive relationship with their
EPA partners. Without question, the partnership between EPA and participants created an
atmosphere that encouraged each entity to take more responsibility, to try unique
approaches, and to think more proactively and more broadly about environmental issues
than they had before.
These nine local government entities, advanced their environmental management
capabilities, resolved some of their environmental challenges, and promoted operational
efficiency, consistency and stakeholder involvement as well. This program has
demonstrated that public sector organizations, like their colleagues in the private sector,
can be strong environmental leaders.
2 EPA Innovations Task Force, Aiming for Excellence, Actions to Encourage Stewardship and Accelerate
Environmental Progress, EPA 100-R-99-006, July 1999, p. 6.
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There is little doubt that an EMS approach is beneficial for managing environmental
issues in local government entities. The local government entities that participated in the
EMS pilot project realized most if not all of the environmental goals that originally
prompted their participation. They continue to realize additional environmental and
organizational benefits as the EMS matures and becomes more fully institutionalized in
their organization.
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Information
4r
F.
,y*
'"i:ฃjj&ฃ- * fj-
U.S. Environmental Protection Agency
Office of Wastewater Management
Web:
http://www.epa.gov/OWM/wm046200.htm
U.S. Environmental Protection Agency
Office of Reinvention
Web: http://www.epa.gov/ems
Global Environment & Technology Foundation
7010 Little River Turnpike, Suite 300
Annandale, VA 22003
Phone: (703) 750-6401
E-mail getf@getf.org
Web: http://www.getf.org/muni.htm
NSF International
PO Box 130140
789 N. Dixboro Road
Ann Arbor, MI 48113 -0140, USA
Phone: (+1)734-769-8010
Toll Free (USA): 800-NSF-MARK
E-mail info(5),nsf.org.
Web: http://www.nsf-
isr.org/html/iso_l 40QO.htmI'
American National Standards Institute (ANSI)
11 West 42nd Street.
New York, New York, 10036
Phone:(212)642-4900
Web: http://web.ansi.org
American Society for Quality Control (ASQC)
611 East Wisconsin Avenue
P.O. Box 3005
Milwaukee, WI 53201
Phone: (800) 248-1946
American Society for Testing and Materials
100 Barr Harbor Drive
West Conshohocken, PA 19428
Phone: (610) 832-9585
Web: http://www.astm.org
Internet Resource
globeNet http://www.isol4000.net
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Appendix A
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Glossary of Terms
Audit - A planned, independent, and documented assessment to determine whether agreed-upon
requirements are being met.
Certification - Procedure by which a third party gives written assurance that a product, process, or service
conforms to specified requirements.
Certification Body - Body that conducts certification of conformity.
Certify - To provide written assurance that a product, process, or service conforms to specified
requirements.
Certified - The EMS of a company, location, or plant is certified for conformance with ISO 14001 after it
has demonstrated such conformance through the audit process. When used to indicate EMS
certification, it means the same thing as registration.
Compliance - An affirmative indication or judgment that the supplier of a product or service has met the
requirements of the relevant regulation; also the state of meeting the requirements.
Compliance Audit - A systematic, documented, periodic and objective review by regulated entities of
facility operations and practices related to meeting environmental requirements.
Conformance - An affirmative indication or judgment that a product or service has met the requirements
of the relevant specifications; also the state of meeting the requirements. Usually refers to meeting
requirements of the ISO 14000 management standards.
Continual Improvement - Process of enhancing the environmental management system to achieve
improvements in overall environmental performance, in line with the organization's environmental policy.
Note - The process need not take place in all areas of activity simultaneously. (ISO 14001)
Environmental Performance - The measurable results of the environmental management system, related
to an organization's control of its environmental aspects, based on its environmental policy, objectives,'and
targets. (ISO 14001)
Environment - Surroundings in which an organization operates, including air, water, land, natural
resources, flora, fauna, humans, and their interrelation. Note - Surroundings in this context extend from
within an organization to the global system. (ISO 14001)
Environmental Aspect - Element of an organization's activities, products, and services that can interact
with the environment. (ISO 14001)
Environmental Audit - Systematic, documented verification process of objectively obtaining and
evaluating audit evidence to determine whether specified environmental activities, events, conditions,
management systems, or information about these matters conform with audit criteria, and communicate the
results of this process to the client. (ISO 14010)
Environmental Impact - Any change to the environment, whether adverse or beneficial, wholly or
partially resulting from an organization's activities, products, or services. (ISO 14001)
Environmental Management System (EMS) - Organizational structure, responsibilities, practices,
procedures, process, and resources for developing, implementing, achieving, reviewing, and maintaining
the environmental policy. (ISO 14001)
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EMS Audit - A systematic and documented verification process to objectively obtain and evaluate
evidence to determine whether an organization's environmental management system conforms to the
EMS audit criteria set by the organization, and to communicate the results of this process to management.
(ISO 14001)
EMS Audit Criteria - Policies, practices, procedures, or requirements, such as covered by ISO 14001, and,
if applicable, any additional EMS requirements against which the auditor compares collected evidence
about the organization's EMS. (ISO 14011)
Environmental Performance Evaluation - Process to measure, analyze, assess, report, and communicate
an organization's environmental performance against criteria set by management. (ISO 14031 WD4)
Environmental Policy - Statement by the organization of its intentions and principles in relation to its
overall environmental performance, which provides a framework for action and for setting of its
environmental objectives and targets. (ISO 14001)
Environmental Target - Detailed performance requirement, quantified wherever 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. (ISO 14001)
Fenceline-The area in which an organization chooses to implement its environmental management
system a department, division or specific operation.
Gap Analysis -A comparison of an organization's existing management structure for environmental
aspects against the elements of an environmental management system. Used to identify what EMS elements
are missing.
Interested Party - Individual or group concerned with or affected by the environmental performance of
an organization.
Quality System - Organization structure, procedures, processes, and resources needed to implement
quality management. (ISO 8402)
Stakeholders - Those groups and organizations having an interest or stake in a company's EMS program
(e.g., regulators, shareholders, customers, suppliers, special interest groups, residents, competitors,
investors, bankers, media, lawyers, insurance companies, trade groups, unions, ecosystems, cultural
heritage, and geology).
Standard - A recognized unit of comparison which provides a gauge of the "correctness" of those things
we are comparing.
System - Collection of unit processes that when acting together, perform some defined function; what an
organization will do, who will do it, how will it be done. (ISO 14004)
Third Party - Person or body recognized as being independent of issue involved, as concerns the issue in
question. Note - Parries involved are usually supplier ("first party") and purchaser ("second party") and
external auditor ("third party"). (ISO/IEC Guide 2)
Verification - Process of authenticating evidence. (ISO 14010) The act of reviewing, inspecting, testing,
checking, auditing, or otherwise establishing and documenting whether items, processes, services, or
documents conform to specified requirements. (ANSI/ASQC A3)
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Appendix B
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CITY OF LOWELL, MASSACHUSETTS
SECTION I: BRIEF DESCRIPTION OF THE MUNICIPALITY
The City of Lowell is located in northeastern Massachusetts 12 miles from the Route 128
Beltway "America's Technology Highway." Just seven miles from the New Hampshire boarder
and 25 miles from Boston, the City finds itself well-positioned in the center of the leading
manufacturing region in Massachusetts. Manufacturing represents 32% of the jobs in the area
with the majority found in the fields of plastics, high technology and medical technology. Based
on the 1990 Census, Lowell has a population of 103,440 and occupies a land area of 13.4 square
miles.
Lowell was incorporated as a township in 1826 and was later incorporated as a city in 1836. The
City is governed by a nine-member elected City Council and a City Manager who is appointed by
the Council. The Mayor is elected by the members of the City Council and serves as its presiding
officer.
Part of Lowell's public commitment is as follows: "Our community is proud of its past, ambitious
in its current progress and excited about its future prospects. Whether you are considering moving
your business or your family to Lowell, you will find a warm welcome waiting for you."
SECTION H: "FENCELINE" DATA
As its fenceline, Lowell chose the Lowell Wastewater Utility for this pilot project. It was chosen
because of the environmental nature of its primary mission. The City also felt this was a perfect
fit due to the Department's progressive approach in searching out new methods to improve its
operations. The Utility is an activated sludge wastewater treatment facility with a design flow of
32 million gallons a day (mgd). Its average flow is 31 mgd. In 1998, the facility produced
approximately 23,540 tons of quality biosolid for land application or composting. Some of its
environmental impacts include: odor, air emissions, noise pollution, soil and water contamination
from chemical leaks, energy consumption, resource recycling, and effluent quality.
The facility provides primary and secondary treatment to more than 170,000 users located in five
communities, Lowell included. The system includes 230 miles of sewer lines, 5000 catch basins,
and the same number of manholes. The facility is staffed with 46 employees.
SECTION HI: TOP MANAGEMENT FOR THIS PROJECT
Assistant City Manager
Executive Director of Lowell Regional Wastewater Utility
SECTION IV: THE CORE TEAM
Before the project was initiated, information concerning the ISO 14001 standard and
Environmental Management Systems (EMSs) was posted throughout the Utility. Once everyone
was given a chance to read the information, a memo was posted asking for volunteers interested
in making a commitment to an ISO 14001 Implementation Team. Thirteen employees
volunteered, one of which is from management.
The core team consists of:
64
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Executive Director
Maintenance Division - 4 employees
Operations Division 2 employees
Engineering/Pretreatment Division - 2 employees
Laboratory -1 employee
During the course of the project, the original 13 member core team lost 3 members due to
members leaving for new positions. The Core Team currently consists of 10 members.
SECTION V: WHY AN EMS - DRIVERS
The City of Lowell believes the EMS will:
Enhance City's overall image;
Improve its environmental performance;
Help lead the region's private sector toward compliance with the ISO standards through
education, training and awareness; and,
Maximize efficiency, reduce costs and avoid costly environmental emergencies thereby
saving taxpayers money.
SECTION VT: OBJECTIVES AND TARGETS
The initial identification of the Utility's objectives and targets was first assigned to each division
to identify those pertinent to that division. Objectives and targets were identified for Operations,
Maintenance, Engineering/Pretreatment, Laboratory and Administration. Once this task was
completed, the Implementation Team identified the objectives and targets of each division with
the greatest impact on the environment.
The areas the team identified were:
Landfill/Waste Management;
Chemical Management;
Odors;
. Energy Usage; and,
Industrial Waste Stream Notification.
The identification of these objectives led to the development of targets for each of the programs
developed.
SECTION VH: STATUS OF THE EMS
The following are the five major programs identified for the EMS:
1. Waste Stream Management
2. Chemical Use Management
3. Energy Reduction
4. Odor Control
5. Industrial Notification
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The EMS Implementation Team has conducted Utility-wide training and has performed an in-
house audit on the EMS policy and the Waste Stream Management and Chemical Use
Management programs.
The core team will complete final Utility-wide training and then perform an audit of the
remaining programs (Energy Reduction, Odor Control and Industrial Notification). After this is
completed, the Core Team will prepare for an external audit of our program. We anticipate
conducting a complete Utility-wide audit of the EMS in January 2000.
The Waste Stream Management Program was implemented in April 1999. As a result, the Utility
has seen an increase in the amount of recyclable material collected and a decrease in the amount
of material disposed of at the landfill.
Recyclable materials collected (April 1999 - June 1999):
Pounds of Paper 1,853
Pounds of Cardboard 4,000
Pound of Co-mingled 319
Pounds of Batteries 79
Pounds of Broken Mercury Vapor Lamps 16
Pounds of Lamp Ballasts 430
Feet of Mercury Vapor Lamps 2060
During this three-month period, the program has reduced the waste stream load to the landfill by
about four tons and has saved the Utility over $300.00. Through preliminary energy reduction
strategies, the Utility has seen energy savings of $7,400 over a 10-month period.
SECTION VIH: KEYS TO SUCCESS
1. The top key to our success in developing and implementing the Environmental Management
System has been a supportive upper management as well as a hard working and dedicated
staff at the Wastewater Utility. Once support was obtained from Management, the City
Council and other elected officials it made it possible for the Department Head and the staff
at the Wastewater Utility to move ahead with the project. If it wasn't for the dedicated staff
and their high skill level and understanding of the EMS concept, implementing it and making
it happen, we would not be where we are today.
2. Another key to success was our decision to hire a consultant to assist with document control
and the development of the EMS manual. These two areas were a weakness for our team, the
consultant filled this gap and will help prepare the Utility for certification.
SECTION IX: HURDLES
The following hurdles were encountered during the development of the EMS:
Time there is a tremendous amount of time involved in training and implementation.
Educating employees about the ISO 14001 concept can be time consuming as well.
Money - The members of the Implementation Team and Core Team committed a significant
amount of work time to be involved in this project. Money was also spent on consultants and
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will be spent on certification. In-kind contributions by members of the community were also
significant.
Turnover in staff- Our Core Team suffered a loss in key staff that were involved in the
documentation process which ultimately cost a significant amount of time developing the
Environmental Management System.
Show of support and buy-in from the community- There was some support from the City
Council and the local media channels but support was lacking from the community.
Councilor support was demonstrated by funding the ISO trips and presentations. Local media
provided positive stories about the project. However, we did not see a strong excitement level
in the community concerning the project.
SECTION X: BENEFITS
Improved communication - Communication was improved at all levels - communication
within the plant among divisions, from staff members to the Department Head and Executive
Director through all levels of the administration including the City Manager's Office. This
increased communication led to a better operation of the plant as well as the top management
having an increased knowledge of the issues which ultimately leads to better support of the
projects in the department, and a better understanding of resources needed to create a top-
notch facility.
Shared decision making - The Core Team developed a strong inter-relationship which led to
improved operations through risk taking and improved communications - going out on a limb
knowing that there was a trust level at the facility that had been created because of the EMS
process. This trust led to real open discussion of the issues in the department and generated
potential and creative solutions.
Employee empowerment - The employees in the department, for the first time, received a big
picture view of the department and of the City and how all the different divisions tie together
to form an efficient operation.
Increased efficiency - Reducing the material waste sent to the landfill will result in cost
sayings. Improved permitting review will result in a more efficient operation. Established
objectives and targets will lead to an overall better plant and better service to our customers.
SECTION XI: LESSONS LEARNED
1.
2.
Bring on a consultant early on - It would have been helpful to have a consultant on board
during the early stages of implementation to assist with the training of the Core Members and
members of the facility. Training and education of the ISO 14001 standard took quite a bit of
time. This time sink could have been minimized had we hired a consultant to aggressively
train all the members of the facility. Consequently, we hired a consultant a year and half into
the project to assist with our documentation that we found very useful. This assistance would
have proved very beneficial during the preliminary stages of the project.
If we were to do it over again, the City of Lowell would have included an additional facility
within its fenceline - we are examining the possibility of developing an EMS for another City
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Department. The two-year project was a long and involved process. Including another facility
in the training and education phase would have eliminated duplicating our efforts.
3. We had difficulty with some sections of the project - specifically, the development of metrics.
The whole metrics discussion threw us off track and was very difficult to put together. We
lacked documentation regarding the quantification of municipal production numbers, which
hindered our ability to develop a baseline analysis of our past performance. This practice is
still relatively new in the municipal sector; development of the EMS helps facilitate this
process.
SECTION XH: CONTACT INFORMATION
Mark Young
Executive Director
Lowell Regional Wastewater Utility
James Smith
Assistant City Manager
City of Lowell
Matthew Donahue
EMS Advisor
City of Lowell
SECTION XDDE: TOTAL COST/RESOURCE COMMITMENT DURING THIS
PROJECT
The table below indicates the dollars spent by the City of Lowell from August 1997 through July
1999 in planning, developing, and implementing the City's EMS. Travel costs represent costs for
the City of Lowell personnel to attend meetings and workshops hosted by the U.S. Environmental
Protection Agency during the pilot program. All figures are in nominal dollars.
Labor
$27,100
Consultant
$10,500
Travel
$3,100
Materials
$1,700
SECTION XTV: FUTURE EMS PLANS
The City of Lowell is committed to getting certified as an ISO 14001 entity at our Wastewater
Treatment Facility. The City is also examining the possibility of developing and implementing
an ISO 14001 system at our Department of Public Works and eventually at other City
Departments.
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CITY OF GAITHERSBURG, MARYLAND
SECTION I: BRIEF DESCRIPTION OF THE MUNICIPALITY
The City of Gaithersburg is located along the 1-270 high technology corridor in the heart of
Montgomery Ceunty, Maryland. The southeastern border of the City lies 12 miles from the
northwestern border of Washington, B.C., and 18.5 miles northwest of the U.S. Capitol Building.
The City of Gaithersburg occupies 9.93 square miles, with an estimated 1999 population of
49,500 people and per capita income, based on the 1990 Census, of $18,845. The City is host to
more than 2,000 businesses and is one of the three core locations for the biotech industry in the
United States. In addition, the National Institutes of Standards and Technology (NIST)
headquarters is located in Gaithersburg.
Gaithersburg became an incorporated town in 1878 and was elevated to city status in 1968. The
City operates under the council-manager form of municipal government, with the City Manager
being appointed by the City Council. The Mayor and City Council are elected to staggered four-
year terms and the Mayor serves as Council President.
The City's Mission is as follows: "The Gaithersburg City government exists to provide quality,
cost effective, priority community services for its citizens. We are a CHARACTER COUNTS!
City that serves as a catalyst for the involvement of residents, businesses and organizations to
ensure that Gaithersburg is a great place to live, work, and play".
SECTION II: "FENCELINE" DATA
Gaithersburg chose its Public Works, Parks Maintenance & Engineering Administration's facility
as the fenceline for this pilot project. The activities and services provided by this Department
have the greatest impact on the environment as compared to other City departments. The potential
impacts include air emissions, potential spills and accidental releases, hazardous material storage,
energy consumption, road salt usage and storage, and storm water discharges. Since the
Department provides some of the services valued most by the citizens, the City felt that
implementing an Environmental Management System (EMS) for this Department would help
improve operating efficiency thus improving service delivery to our customers.
This department provides a variety of services such as:
Snow removal;
Street sweeping;
Storm water management and maintenance of storm water infrastructure;
Repair and maintenance of streets and sidewalks;
Beautification of the City's streets, public buildings and parks;
Curbside recycling;
Recycling drop-off for used oil, used antifreeze, mixed paper, aluminum, and metal cans;
Maintenance for all City facilities;
Construction and capital improvements for all City-owned buildings and facilities; and,
Fleet and equipment maintenance.
The Department also reviews storm water management and sediment control plans, street
locations and configurations, traffic routing, lighting, paving, and site plans for proposed
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commercial and residential developments. The Department's engineering staff administers capital
improvement projects for road and storm drain projects.
The Department operates with a staff of over 60 full-time, up to 20 part-time and 4 contract
employees. The Department of Public Works has a budget of $6.6 million for fiscal year 2000.
This includes labor and overhead costs and capital improvements.
SECTION HI: TOP MANAGEMENT FOR TfflS PROJECT
City Manager
Deputy City Manager
SECTION IV: THE CORE TEAM
Gaithersburg has appointed a ten person Core Team to plan, develop and implement the EMS for
the Department of Public Works. The EMS Project Manager is the Assistant to the City Manager.
The Core Team consists of the following personnel:
Assistant to the City Manager
Director of Public Works
Superintendent of Public Works
Environmental Specialist
Engineering Technician .
Team Leaders from the 5 functional areas (fleet maintenance, beautification and landscaping,
parks maintenance, street maintenance, and recycling/mowing).
SECTION V: WHY AN EMS - DRIVERS
A major force for developing an EMS for the City of Gaithersburg's Department of Public Works
were members of the City's volunteer Environmental Affairs Committee. In particular, one
member believed that in conjunction with the City's new environmental standards, the
development of an EMS would depict the City as a leader in environmental protection.
Gaithersburg believes that the EMS will:
Help the City do a more thorough and accurate job in monitoring and controlling the
environmental impact of the services provided to residents;
Increase the efficiency and productivity of Public Works' operations while meeting all
environmental obligations;
Increase employee and citizen environmental awareness in order to improve the work
environment for employees and the quality of life for citizens;
Help attract new businesses; and,
Identify areas for continuous improvement through measuring and monitoring.
SECTION VI: OBJECTIVES AND TARGETS
The City of Gaithersburg conducted a thorough analysis of the real and potential environmental
impacts from the significant activities performed by the Department of Public Works. In
conjunction with a review of the legal requirements for all the activities, services, and products
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provided by the Department, the Core Team developed the following list of Objectives and
Targets.
Objective ;
Reduce oil, grease, and other
pollutants entering storm
sewer system.
Eliminate the need to dispose
of hazardous waste generated
by parts washer.
Reduce oily debris in waste
stream.
Eliminate the potential for
battery acid to enter the storm
sewer system.
Algae control in ponds.
Assess soil conditions and
fertilizer needs of grass on
city property.
Reduce amount of salt
applied to City streets.
Reduce air emissions
Environmental awareness
training
UST compliance
Emergency Response Plan
Storm water pollution
prevention plan
. : - . ' '.-"' Target --'- " ''''.' --.' :.' ;
Use indoors wash area as much as possible.
Install oil/grit separator between storm drain inlet and outlet
to stream
Construct new wash bay for equipment and vehicles.
Acquire new parts washer that separates oil and grease and
recycles water.
Use vendor to pickup and clean oily rags.
Store abandoned batteries indoors.
Purchase containment structure to capture and contain any
potential releases from abandoned batteries.
Assess the potential to reduce alga growth by aeration and
barely bales.
Have soil samples taken and analyzed for nutrients and the
need for future fertilizing.
Calibrate salt trucks.
Acquire ground sensors to monitor truck speed.
Purchase and use "Ice Ban".
Explore the possibility of mixing ash and salt.
Emission testing for diesel trucks.
Explore the potential of using alternative fuel vehicles.
Conduct environmental awareness training for all
Department employees.
Review tank size requirements and conditions of tanks to
ensure compliance with State UST regulations.
Develop, or update, plan.
Develop and implement SWPPP.
SECTION VII: STATUS OF THE EMS
As of July 1999, the City of Gaithersburg produced a "working draft" of the EMS Manual and
environmental procedures for;
Identification of Aspects and Impacts;
Tracking of Legal and Other Requirements;
Setting and Tracking Objectives and Targets;
Employee Training and Environmental Awareness;
Internal Communications;
External Communications;
Document Control;
Document Changes;
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Emergency Preparedness and Response;
Preventive and Corrective Action;
Audits; and,
Management Review.
The status of each procedure varies. Many of the procedures are implemented and others are
drafts. Those that are drafts depend on training appropriate people in specific activities, such as
conducting audits, before they can be fully implemented.
In addition, the City of Gaithersburg has developed and implemented environmental programs for
each of the objectives and targets identified earlier.
SECTION VTfl: KEYS TO SUCCESS
The success of the EMS has been the Core Team. The Core Team was carefully designed to
include representatives from the City Manager's Office and the Department of Public Works. The
inclusion of the Director and Superintendent of the Department of Public Works has been vital
because it incorporates individuals most responsible for the Department's budget and capital
improvement projects.
Another key to success has been the unwavering support of the City Manager and Deputy City
Manager for the project. Without their support, the project may have died during the planning
process. They made funds available to ensure a qualified professional was hired to be the project
champion.
The final key ingredient was the Environmental Specialist. One of the job goals for the creation
of the Environmental Specialist position was to lead the planning, development, and
implementation of the EMS. This person was able to bring a level of expertise that was lacking in
the City government in compliance audits and in the development of the EMS.
SECTION IX: HURDLES
The City of Gaithersburg faced a number of hurdles in developing the EMS. These include:
Identifying legal requirements;
Introducing project to employees;
Conducting a useful gap analysis;
Developing a baseline;
Developing a documentation plan;
Implementing documentation in areas where documentation may not have been required in
the past; and,
Missing work procedures.
SECTION X: BENEFITS
Although the City of Gaithersburg has not fully implemented an EMS by this time (July 1999) a
number of benefits are occurring at this time. Once completed and implemented, additional
benefits will accrue. The benefits the City of Gaithersburg has or expects to realize with an EMS
include:
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Greater operational efficiency;
Increased employee awareness regarding environmental and safety issues;
Reduced solid and hazardous waste generation;
Cost savings from reduced disposal costs;
Reduced energy use;
Cost savings from reduced energy use;
An environmental baseline from which all future activities may be measured;
Ease in transferring of work roles or replacement of existing employees;
Keeping current with legal and regulatory changes;
Identification of potential problem areas that were previously overlooked or viewed as non-
consequential; and
Empowering all employees to raise environmental concerns.
SECTION XI: LESSONS LEARNED
The City of Gaithersburg would have approached the development and implementation of the
EMS differently based on knowledge gained. However, the EMS Project Manager took many
initial steps in securing the long-term viability of the Department of Public Works' EMS. The
lessons learned over the life of the pilot project include:
The Core Team was and is the strength of the City's EMS. It incorporates personnel from the
City Manager's Office and the Department of Public Works.
The inclusion of Department of Public Works management as members of the Core Team
was critical. This enabled quick decisions on capital expenditures and knowledge of potential
future capital improvements for future budget discussions.
Familiarity with EMS and environmental compliance is necessary at the beginning of the
project.
The EMS "Champion" needs to be dedicated to the planning, development and
implementation of the EMS.
SECTION XII: CONTACT INFORMATION
For more information please contact:
Mark Pfefferle (301) 258-6310
mpfefferle@ci.gaithersburg.md.us.
SECTION XHI: TOTAL COST/RESOURCE COMMITMENT DURING THIS
PROJECT
The table below indicates the dollars spent by the City of Gaithersburg from August 1997 through
July 1999 in planning, developing, and implementing the City's EMS. Travel costs represent costs
for City of Gaithersburg personnel to attend meetings and workshops hosted by the U.S.
Environmental Protection Agency during the pilot program. All figures are in nominal dollars.
Labor
$19,310
Consultant
$0
Travel
$4,600
Materials
$800
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SECTION XIV: FUTURE EMS PLANS
Once the EMS is completed and fully implemented, the decision to seek certification with the
ISO 14001 standard will depend on guidance from the Mayor and Council. The Core Team
intends to complete and implement the EMS by January 2000. If Mayor and Council desire to
pursue certification, certification will be sought during calendar year 2000.
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TOWN OF LONDONERRY, NEW HAMPSHIRE
SECTION I: BRIEF DESCRIPTION OF THE MUNICIPALITY
Londonderry had a total population of approximately 23,000 in 1998 and is currently growing at a
rate of around 4-5% per year. The Town is located sixty miles north of Boston in the southeast
corner of New Hampshire. Due to its proximity to the technology highway just north of Boston it
has become one of the fastest growing communities in the state. The town has experienced a 45%
increase in its population from 1980 to 1990.
This rapid growth prompted the Town to develop a Master Plan to ensure its historical, small
town atmosphere is preserved. This plan includes maintaining open spaces, expanding
recreational facilities, managing future growth and supporting business development to stabilize
the tax base. The town government consists of a Town Council with five elected officers. A
charter was adopted in March of 1996 that allows a Town Manager to administer the Town's
operations, services and contracts.
Londonderry's five orchards - Woodmont, Sunnycrest, Elwood, Moose Hill, and Merrils - are a
vital part of what makes Londonderry special. The apple growers not only contribute to the local
economy, but also provide valuable open spaces. Londonderry's Apple Way, is a designated New
Hampshire Scenic and Cultural Byway, which winds past orchards, old farmhouses and local
landmarks.
Londonderry also has a Sustainable Development program to encourage economic growth in
Londonderry while maintaining its rural quality of life. Part of that plan is the Londonderry Eco-
Park which is one of only 20 Ecological Industrial Parks in the country. Londonderry's efforts are
paying off with a cleaner environment, a protected rural lifestyle, and recognition from federal
and state government, including the first ever State of New Hampshire Municipal Pollution
Prevention Award.
SECTION H: "FENCELINE" DATA
Londonderry chose its Public Works Department as its fenceline. The Public Works Department
was chosen over the other departments because of its immediate environmental impact. The
Department consists of the divisions of Solid Waste, Sewer, Highway, and Engineering. The
Solid Waste Division has a supervisor and one Solid Waste operator for the Drop Off Center. The
Sewer Division consists of one superintendent. The Engineering Division has a Town Engineer,
who also acts as the Public Works Director, and one junior engineer as staff. The Highway
Division has the largest number of employees with 8 full time and one foreman. The total
number of employees in the Public Works Department is 15, including one for administrative
duties.
Londonderry contracts much of its services due to its small size. It contracts with the neighboring
Town of Deny and City of Manchester for is wastewater treatment. It also contracts with a
private hauler for its curbside trash and recycling collections. The town has no transfer station but
provides a Drop Off Center that accepts limited materials. The Highway Garage maintains the
roads for the Town and has some heavy grade construction vehicles along with trucks used to salt
and sand the roads during the winter. Large road projects are contracted out. The Town Engineer
reviews and inspects development plans.
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SECTION HI: TOP MANAGEMENT FOR THIS PROJECT
Public Works Director/Town Engineer
Town Manager
Division Supervisors, Sewer & Solid Waste
Five Town Councilors are committed to the project and kept informed but are not directly
involved in its development
SECTION IV: THE CORE TEAM
Due to the small size of the organization and its limited resources, three representatives were
deemed adequate to complete the project. The Core Team Initially was composed of the Solid
Waste Supervisor (Project Director), Administrative Services Director (Environmental
Management Representative) and the Planning and Economic Director. The Public Works
Director replaced the Planner half way through the project.
SECTION V: WHY AN EMS - DRIVERS
Londonderry has three Superfund sites, including the Auburn Road landfill that was closed in the
late 1970's. While the landfill has now been cleaned up and capped these sites show what can
happen when environment issues are not planned for.
Londonderry hopes its EMS will:
Lower its environmental impact;
Improve its image as a healthy and safe community; and,
Increase efficiency and lower risk and liability.
SECTION VI: OBJECTIVES AND TARGETS
Objective
.Target
Decrease Solid Waste Quantities
Increase education efforts by %50
Increase # of Master Recyclers from 6 to 12
Two school events
Quarterly newsletter instead of bi-annual
Maintain 1998 waste volumes for 1999
Increase participation of 1st time HHW users by
5% with a corresponding 5% decrease in 2nd time
users. Increase collection of used oil by 5%
Increase diversion rate to transfer station by 10%.
Increase curbside recycling rate by 5%
Eliminate disposal of shop rags
Improve Waste Water Quality
Develop P2 pamphlet to be distributed to all SIUs.
Add pamphlet to Town website.
Ensure the proper disposal of grey water from
garage floor.
Improve Materials Management
Prevent any solvent spills
Ensure proper health and safety measures and
handling requirements are taken when painting
vehicles.
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SECTION VH: STATUS OF THE EMS
The status of Londonderrys EMS is currently seventy five percent complete. The Londonderry
DPW has an Environmental Policy, developed roles and responsibilities of all those involved and
completed documentation of its legal requirements. The environmental aspects and impacts of
each division have been identified which generated a list of significant environmental aspects.
From these, objectives and targets were established and Environmental Management Programs
developed. The Town has completed its first internal audit and is working on procedures for
checking and corrective action and management review.
SECTION VHI: KEYS TO SUCCESS
The two keys to success for Londonderry: 1) having a group of motivated Core Team members to
maintain the enthusiasm and momentum for the project and 2) having a temporary project
assistant from Antioch College in Keene, NH to help with development and implementation.
Number two was extremely beneficial as Londonderry is a small community with limited
resources.
SECTION IX: HURDLES
A more defined list of roles and responsibilities should help in distributing the work load.
Documentation is ongoing, locating templates and talking to other businesses to find out how
they document their process is of help.
The most difficult issue currently is keeping to a schedule in a timely manner, sharing the
work load and documentation. Regular meetings have helped with scheduling, however with
the additional tracking and metrics requirements the work load is becoming difficult and the
schedule may have to be lengthened.
The core team has had some hurdles with staff members with regard to time and resource
issues. As we implement the EMS budgetary issues were raised as far as "spending money to
save money". Will it cost the Town money in purchasing equipment or materials to make the
program work and where will the funding come from. The core team is focusing on the
savings that will be achieved in reduced hazardous waste disposal costs and the benefits of
being beyond compliance.
SECTION X: BENEFITS
The greatest benefit to this program so far has been in defining roles and responsibilities with
regard to legal requirements. The organizational role of each division supervisor has been
defined. With the EMS in place, a consolidated list of legal requirements has been developed
increasing the overall awareness of each division.
Identifying responsibility for compliance issues
Better communication between divisions
Documentation of procedures and work instructions provides consistent and reliable methods
of dealing with environmental aspects
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Identification of goals to lessen the environmental impact of the town's activities. I could see
this aspect providing support during the budget process when justification for services and
activities is required.
Improved safety for workers by implementing pollution prevention techniques and providing
hazardous awareness training.
As part of the EMS, better materials management was identified as a commitment in our
Environmental Policy. In line with that policy, although not part of an environmental
management program, was decreased water usage. The Highway Garage is now looking at
High Pressure low volume nozzles and other pollution prevention techniques to reduce water
- a supplemental benefit, as it will lower costs as well.
SECTION XI: LESSONS LEARNED
The main lesson Londonderry learned was to involve everyone in the project from the beginning.
If your employees are not motivated to participate then the process can take twice as long and
encounter many difficulties. Also, your community can be doing many environmentally
responsible programs already - utilize these efforts to build on your own.
SECTION XH: CONTACT INFORMATION
Liz Todd
Solid Waste Division
Town Hall
Londonderry, NH 03053
SECTION XBtt: TOTAL COST/RESOURCE COMMITMENT DURING THIS
PROJECT
The table below indicates the dollars spent by the Town of Londonderry from August 1997
through July 1999 in planning, developing, and implementing the Town's EMS. Travel costs
represent costs for Town of Londonderry personnel to attend meetings and workshops hosted by
the U.S. Environmental Protection Agency during the pilot program. All figures are in nominal
dollars.
Labor
$22,600
Consultant
$0
Travel
$3,600
Materials
$700
XIV: FUTURE EMS PLANS
Londonderry plans to continue to finalize its environmental management programs and
eventually seek third party registration. Registration will probably not be achieved until next year,
as the funding must be approved through the Town budget process. However, at a recent update
on the project for the Town Council, mention was made of expanding the program to include
other departments in the town. This would be a significant achievement if the Fire, Police,
Recreation and possibly even the schools were included at some later date. The Councilors were
very pleased with the project and the benefits it has provided, not the least of which is how it
factored into an improved bond rating for the Town last September.
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MASSACHUSETTS CORRECTIONS INSTITUTE - NORFOLK
NORFOLK, MASSACHUSETTS
SECTION I: BRIEF DESCRIPTION OF THE MUNICIPALITY
The Massachusetts Correction Institute at Norfolk (MCI-Norfolk) is one of 25 facilities used to
incarcerate more than 11,000 inmates in Massachusetts. MCI-Norfolk is a medium security
facility just south of Boston, with an average daily population of 1,490 inmates. Though it is rated
medium security, MCI-Norfolk has a maximum-security perimeter with a wall five thousand feet
long and nineteen feet high, enclosing an area of thirty-five acres. Within the confinement of the
wall, there is a minimum-security environment of eighteen dormitory-style living units and two
modular units divided by a large central grass quadrangle. Other buildings within the perimeter
provide space for administrative and security personnel, health services, support staff and
services, and other vocational and educational programs.
Originally opened as the first "community-based" prison in the United States, the history and
background of MCI-Norfolk is detailed and fascinating. The first of the MCI-Norfolk inmates
were transferred from the state prison in Charlestown, MA in 1927, and lived in houses located in
The Oval, which is currently at the southwest corner of the wall surrounding the compound. In its
early years of operation, a major portion of the present institution, including the prison wall, was
constructed by inmates who lived in the State Prison Colony. The more spacious and campus-like
atmosphere and architecture permitted an approach to "community life" that was not available at
other institutions, and represented a new step in Massachusetts Penology. In the mid-1950's, the
name of the prison was officially changed to the Massachusetts Correctional Institute at Norfolk.
MCI-Norfolk is the largest facility of its type in the Commonwealth of Massachusetts. Eighty-
percent of the inmate population at the facility is serving time for violent crimes. Of that eighty-
percent, approximately 275 inmates are serving life sentences for commission of murder in the
first or second degree. The next largest crime category is armed robbery, followed by sex
offenders.
SECTION H: "FENCELEVE" DATA
The Massachusetts Department of Corrections (DOC) chose MCI-Norfolk for its pilot project.
The EMS developed at MCI-Norfolk will be used as a model for all DOC facilities. With close to
1500 inmates and 500 staff MCI-Norfolk can be considered a small city. It provides food service,
support services, such as health care and education and maintains a fleet of vehicles while the
inmates manufacture various products. Such activities generate significant amounts of solid
waste, sewage, air pollution and hazardous waste.
MCI-Norfolk focused its efforts on three operational areas: 1) Power plant; 2) Waste Water
Treatment Plant; and 3) Correctional Industries Complex. The power plant generates steam and
hot water to the entire facility and generates electricity via a diesel generator during emergencies.
The wastewater treatment plant handles all waste water/sewerage for four correctional institutions
within the complex. The Industries Complex includes 6 shops: metal fabrication, assembling and
painting shop, clothing/sewing, industrial janitorial supplies shop, silk screening and drapery
shop, and a upholstering and mattress shop.
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SECTION DI: TOP MANAGEMENT FOR THIS PROJECT
MCI-Norfolk Superintendent
MCI-Norfolk Deputy of Operations
SECTION IV: THE CORE TEAM
The core team consists of individuals whose responsibilities revolve around health and safety
issues in addition to overseeing the day to day operations of the operational areas* Each
individual brings insight and significant experience to the table which was helpful in
implementing the EMS.
MCI-Norfolk Environmental Health & Safety Officer
Director of Engineering Services
Supervisors of each operational area
SECTION V: WHY AN EMS - DRIVERS
The Massachusetts Commissioner of Corrections chose MCI-Norfolk site to participate in the
pilot project. The MCI-Norfolk EMS may serve as a model for the other corrections institutions.
The MA Department of Corrections continually seeks ways to improve their public relations with
the local community and environmental regulatory agencies and improve the way operations are
conducted on a day to day basis. Further, implementation of an EMS provides a valuable means
by which to monitor compliance with regulatory mandates.
SECTION VI: OBJECTIVES AND TARGETS
MCI-Norfolk's objectives and targets were focused mainly on establishing written work
instructions, called Post Orders, and the documented training of employees in those instructions.
They mainly dealt with prevention of fuel spills and leaks, cleanup and reporting, monitoring air
emissions, safe storage and handling of chemicals and hazardous materials and the generation and
disposal of hazardous waste. Lastly, and this became one of our more frequently realized
significant aspects, worker safety.
SECTION VH: STATUS OF THE EMS
The EMS process has been a roller coaster ride. We began at a crawl and stayed that way for the
initial 8 months of the project. After that, things progressed rapidly and smoothly and we had
made significant headway. Then everything changed: our Core Team all but dissolved, due
mainly to job reassignments, extended sick leaves, etc. Our EHSO and Project Manager with
others, spared as much time as they could to help out, picked up much of the void. Fortunately,
some of the original Core Team members had returned and we had reached the point where most
of the "heavy lifting" had been completed. Currently, we are at the stage where all of our
procedures and policies have been written, signed off and are in place. Training has been
documented in the post orders/work instructions for 2 of the 3 areas in our fenceline. All of the
management staff have been given an overview of the project and the EMS process. Remaining
tasks include: training in work instructions for the wastewater treatment plant employees and the
conducting of audits, corrective and follow up actions, etc.
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SECTION Vffl: KEYS TO SUCCESS
Our keys to success were in three major areas: 1- Commitment from top management; 2-
Assistance from the people at GETF who came to our institution, spending 3 days getting us
jump-started; 3- Hard work and commitment from those who helped, spending many long off-
duty ours on this project.
SECTION IX: HURDLES
Time constraints are always a problem. Designating one day as ISO day has solved most of the
problem. Unforeseen circumstances still make getting everyone together difficult.
We have experienced difficulty in setting goals and objectives for industries.
The usual, lack of time, money, and staff.
SECTION X: BENEFITS
As each procedure is drawn up it allows us to implement work procedures that better control activities
in each area.
We are developing sound work procedures for areas that have historically caused us concern because
of sloppy work behavior or performance.
Again, we have been able to incorporate procedures into our work practices and now have them
documented. We have the same manuals that drive the security end now in place for the
environmental aspects of our business.
SECTION XI: LESSONS LEARNED
Get real commitment from your top level managers along with a commitment to provide the
resources needed, to include staff with a knowledge and background in environmental laws and
regulations as well as an ability to spend the time - uninterrupted - that is needed. There is a
tendency to take on too much for a fenceline...keep it small and manageable. Also, by keeping it
small and manageable, it enables you to bring in more staff that actually work in the areas of the
fence line and encourages them to buy into the whole process and the system itself. Do not
hesitate to ask the experts (i.e.; GETF, DEP, etc.) for assistance and advise.
SECTION XH: CONTACT INFORMATION
Timothy Hall, Superintendent, Massachusetts Correctional Institution at Norfolk
Michael Toledo, Deputy Superintendent of Operations, M.C.I.-Norfolk
POBox43 ,
Norfolk, MA 02056
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SECTION XIH: TOTAL COST/RESOURCE COMMITMENT DURING THIS
PROJECT
The table below indicates the dollars spent by the MCI-Norfolk from August 1997 through July
1999 in planning, developing, and implementing MCI-I Norfolk's EMS. Travel costs represent
costs for MCI-Norfolk personnel to attend meetings and workshops hosted by the U.S.
Environmental Protection Agency during the pilot program. All figures are in nominal dollars.
Labor
$53,000
Consultant
$0
Travel
$2,700
Materials
$1,100
SECTION XTV: FUTURE EMS PLANS
Our immediate plans are to complete the project within the last area of our fence line (WWTP),
then, conduct our audits, assess how well we're really doing, make the needed corrections and
basically maintain the system. Plans for expansion or the seeking of certification has yet to be
determined. However, a better assessment can be made after audits have been completed.
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NEW YORK CITY TRANSIT AUTHORITY
NEW YORK, NEW YORK
SECTION I: BRIEF DESCRIPTION OF THE MUNICIPALITY
Metropolitan Transportation Authority (MTA) New York City Transit is the largest agency in the
MTA network. In fact, New York City Transit is one of the most extensive and complex public
transportation systems in the world, operating 24-hour-a-day bus and subway service throughout
the five boroughs. New York City Transit has more buses than any other public agency in North
America, and the largest subway car fleet anywhere. Each day, close to six million people use
New York City Transit - more than 1.8 billion customers annually.
Ridership - The New York City subway system officially opened on Thursday, October 27,
1904. That Sunday, nearly a million customers tried to use it. Average ridership grew to five
million daily passengers by the late 1940s. Public transit ridership declined due to the car and
highway boom of the '50s and '60s and New York City's fiscal crisis in the 70's. However,
ridership figures for the subway and bus are rising steadily again. One reason is the customer
benefits that MetroCard offers, especially free transfers, free rides and unlimited rides.
Administration - MTA New York City Transit (The New York City Transit Authority) was
created in June 1953 to assume responsibility for the subway system and for bus routes formerly
run by New York City's Board of Transportation. From 1953 to 1955, five full-time
commissioners were in charge of New York City Transit. This number was reduced to three until
1968, when the Metropolitan Transportation Authority (MTA) was created to oversee New York
City Transit's activities. The MTA designated four New York City Transit executive officers to
run the organization until 1971, when the MTA appointed a single chief Executive Officer. The
title of "president" became effective in 1980. MTA New York City Transit's current president,
Lawrence G. Reuter, took office in March 1996. President Reuter and his 12 department heads
comprise New York City Transit's senior staff. The President reports to the MTA Executive
Director, Marc V. Shaw.
Employees - New York City Transit employs more than 44,000 people in 27 major departments
and divisions. In addition to employees responsible for bus and subway operations and
maintenance, the work force also includes attorneys, engineers, electricians, computer
programmers, iron workers, masons, teachers, physicians, mechanics, carpenters, accountants,
environmental specialists and about 250 other types of job titles.
Work Facilities - New York City Transit employees work at 1,500 locations throughout the five
boroughs, including 468 subway stations. Locations range from the Jay Street and Livingston
Plaza main offices in Brooklyn to the system's 73 storerooms and 54 security posts.
Unions - New York City Transit has contracts with 21 local unions and supervisory organizations
representing about 40,000 employees.
SECTION H: "FENCELINE" DATA
The New York City Transit Authority chose its Capital Program Management Department (CPM)
as its fenceline. CPM employees 1,700 people in capital projects and numerous subcontractors at
any given time. It has direct oversight for $2 billion per annum of capital projects. CPM is one
of the largest engineering and construction organizations in the country: designing for, building
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and maintaining, servicing and rehabilitating one of the oldest and best known urban public
transport systems in the world.
Initial planning and implementation efforts focused on two sites: 100th Street Bus Depot
Replacement and the 72nd Street Station Reconstruction. These two sites represent two different
kinds of typical projects in the CPM project range. From this experience, CPM developed
procedures for the implementation of ISO 14001 throughout the organization and to register CPM
as a whole.
SECTION HI: TOP MANAGEMENT FOR TfflS PROJECT
Senior Vice President & Chief Engineer, CPM
SECTION IV: THE CORE TEAM
The EMS Core Team as a whole, functions as the steering committee of the EMS Cross-
Functional Team (CFT). It is led by the EMS Coordinator, and includes the EMS Director, the
EMS Document Administrator and the CPM Chief, Environmental Engineering Division (BED)
and a consultant from Clayton Management Consultants.
Ajay Singh, Chief Internal, Controls & Special Projects, is the EMS Coordinator and the
designated management representative for the CPM EMS. He is responsible for overseeing the
design, implementation and maintenance of the CPM EMS and for making recommendations,
reports and presentations to top management, Mysore L. Nagaraja, Senior Vice President, Chief
Engineer, CPM.
Jim Strycharz, the EMS Director, a member of the NYCTA CPM Division of Internal Controls
and Special Projects appointed by the EMS Coordinator, is responsible for performing such duties
as the EMS Coordinator directs and shall otherwise assist the EMS Coordinator with fulfilling his
or her EMS responsibilities.
Bill Jehle, Chief EED is an integral part of the EMS. He is responsible for establishing and
maintaining a staff of Environmental Specialists who are the link between Program and Support
Areas, CPM Projects throughout their life cycles and Project Master Plan Managers.
Environmental Specialists conduct environmental aspects/impacts assessments, legal compliance
reviews and training assessments and programs.
Bud Smith, Managing Director, Clayton Management Consultants, is the consultant who has
helped with design of the EMS as a whole, the implementation strategy and drafting the EMS
procedures manual.
SECTION V: WHY AN EMS - DRIVERS
New York City Transit (NYCTA) believes that the EMS will:
Improve overall environmental performance
Increase energy efficiency
Improve resource conservation
Reduce environmental impacts
Incorporate Design For Environment in planning, design and construction
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SECTION VI: OBJECTIVES AND TARGETS
Objectives
Target
Fully implement EMS by
1/31/2000
Environmental Objectives, Targets and Environmental
Management Programs established by CPM Program
Managers, Design Managers and Construction
Managers by April 30, 1999
Commence Implementation Master Plan, Pre-Design
and Design Stages Environmental Operational Controls
by July 1,1999
Commence Implementation of Bidding Stage
Environmental Management Controls by December 1
1999
Review and revise, as appropriate, standard form
Consultant and Contractor Environmental
Specifications in contract language by January 1,2000
Fully Implement Evaluations of Consultant and
Contractor compliance with applicable Environmental
Legal and Other Requirements by January 1, 2000.
Assure by May 1, 1999 that CPM documents relating to
Emergency Preparedness and Response are appropriately
revised to conform with PMP 313-010 requirements
Assure by December 1, 1999 that non-CPM NYCTA
documents relating to Emergency Preparedness and
Response (EPR) are appropriately revised to conform
with PMP 313-010 requirements
Within 12 months, Design and
Implement a System for Tracking
and Reducing Additional Work
Orders (AWOs) of Environmental
Origin (EAWOs)
Complete a study of 1997 and 1998 EASWOs by
March 26, 1999
Set EAWOs reduction targets for remainder of 1999
and monitor and report on performance.
Within 12 months, bring all
NYCTA Underground Storage
Tanks (USTs) into full compliance
with government requirements
Within 12 months, upgrade or replace USTs to bring
them into compliance with governmental requirements
SECTION VH: STATUS OF THE EMS
The CPM EMS has implemented and been certified to the ISO 14001 Standard by a third-party,
Underwriters Laboratories, since March of 1999. The first Surveillance Audit is scheduled for'
September of 1999.
SECTION VIH: KEYS TO SUCCESS
Team approach
Excellent communication and follow-up skills
Dedicated top management support
Dedicated leadership and management
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Building good working relationships with the various CPM functions and levels and with
management of different divisions/areas of overall NYCTA
Exercising patience
Being a good listener
Allowing widespread EMS ownership by CPM managers and employees
Using effective project management skills, such as good monitoring and follow-up practices
Effective briefing of top management during the Management Review is important so that they are
knowledgeable when talking to internal and registration auditors <
A strict Internal EMS Audit is best for the organization because it serves to identify and resolve issues
prior to the registration audit
Pre-qualifying and having an open dialogue with the ISO 14001 registrar prior to the commencement
of the registration audit serves to resolve potential ISO 14001 interpretation issues up front and avoid
surprises and confrontations during the registration audit
Realizing that the EMS should be continually changing to reflect "lessons learned" and to make it
more user-friendly, rather than being "stuck" with the original EMS design
SECTION IX: HURDLES
The biggest hurdle encountered during the initial implementation of the EMS was discovering and
dealing with the fact that implementing some of the CPM's Procedures and Environmental
Management Programs will require cooperation of other areas of the parent NYCTA and MTA
organization over which CPM does not have control.
For example, contractor selection and management issues make up the bulk of CPM's operational
controls. However, to alter the current contractor specifications and contracts requires working with
many different areas of the NYCTA and MTA. Gaining cooperation from management of these other
parts of the organization requires much patience, dedication and time. The overall organization
culture and established authorities make it difficult to obtain the required external cooperation
promptly and efficiently.
Another example of this hurdle was placing the EMS Manual on the intranet. Specific formatting
guidelines had to be followed and time frames could not be controlled by CPM, because they are
governed by other areas of the organization.
A third example relates to Emergency Preparedness and Response (EP&R). This activity is
handled by another division of the NYCTA. The task of convincing that division to revise its
procedures to meet ISO 14001 and CPM EP&R criteria promises to be very "political" and
time consuming.
Controlling documents created outside of CPM or prior to the implementation of the EMS
proved challenging. Gathering them, labeling them appropriately and ensuring they fit into
the overall system was difficult.
When determining significant environmental aspects, a reasonable number of aspects must be
identified, as they must be monitored and managed. CPM originally deemed all aspects
(about 80 in all) significant, which if left unchanged, could result in monitoring and
measurement conformance problems.
Learned some of the initial elements of the EMS were too ambitious or overly complicated and have
now simplified the programs/procedures.
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Quantitative indicators for monitoring and measuring may not be easy to devise or they may
be inappropriate and may have to look for alternative means.
SECTION X: BENEFITS
The EMS has encouraged CPM to evaluate some of its current programs, such as how
contractors and consultants are evaluated, from a new perspective with added insight
Provides structure, discipline and context to the strong environmental programs previously in place
throughout the CPM organization
Forces collection and storage of records in an organized manner, making them readily retrievable
Has promoted Design for the Environment within the CPM organization
Promotes improved communications with departments outside of CPM
Volunteer team has provided an employee outlet for energy and excitement about the EMS which
aids the EMS Core Team in meeting goals.
Improved environmental performance
Improved environmental communication between employees in various areas of the organization,
who might not otherwise interact
Potential cost savings
Improved public image
Positive external publicity for the organization
Increased internal credibility and awareness of CPM's EMS
SECTION XI: LESSONS LEARNED
Key lessons learned that aid in EMS implementation process:
Total commitment of senior management
Positive/committed employees through awareness training and volunteers
Define fence line of organization
Early involvement of all units/operating departments
SECTION XH: CONTACT INFORMATION
Mr. Ajay Singh
CPM, Internal Controls and Special Projects
Audit Services
370 Jay Street
Brooklyn, NY 11201-5106
Tel: (718)243-8397
Fax: (718)243-3805
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SECTION XIH: TOTAL COST/RESOURCE COMMITMENT DURING THIS
PROJECT
The table below indicates the dollars spent by NYCTA - CPM from August 1997 through July
1999 in planning, developing, and implementing the Authority's EMS. Travel costs represent
costs for CPM personnel to attend meetings and workshops hosted by the U.S. Environmental
Protection Agency during the pilot program. All figures are in nominal dollars.
Labor
$121,000
Consultant
$143,000
Travel
$14,000
Materials
$900
SECTION XIV: FUTURE EMS PLANS
CPM plans to continue to implement the environmental management programs it has designed for
its EMS and work to continually improve the EMS. Other divisions of the MTA are currently
considering implementing EMSs based on the ISO 14001 Standard.
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CITY OF SCOTTSDALE, ARIZONA
SECTION I: BRIEF DESCRIPTION OF THE MUNICIPALITY
The City of Scottsdale, Arizona is located in eastern Maricopa County and shares its western
boundary with Phoenix. From a tiny farming community of only 2,000 people occupying less
than one square mile in 1951, Scottsdale has grown to a vibrant city of 196,310 and 194 square
miles. The city is host to 21,000 businesses with a majority found in the retail and services
industry. One in four are employed in the hospitality industry.
Scottsdale became incorporated as a town in 1951 and was declared by the Mayor as the "West's
most western Town." The Charter was adopted in 1961. The city has a council-manager form of
government. The mayor and six council members are elected at large to serve four-year terms.
The City's Vision is as follows: "On our way to the year 2000, City of Scottsdale employees will
be recognized as innovative, environmentally sensitive and committed to quality service;
members of an organization in which leadership, teamwork and all individuals are valued, and
employees take pride in everything they do."
SECTION H: "FENCELINE" DATA
The City of Scottsdale has selected two departments (Financial Services and Water Resources) as
its fenceline. Included within the fenceline are the cirywide environmental aspects.
The financial services department consists of two facilities and 120 staff. The Water Resources
Department consists of seven facilities and 82 staff. The cirywide environmental aspects include
19 facilities and 1,500 staff. The facilities include the following:
Civic Center Campus
Water Campus
Fire Stations
Water Treatment Plants
Libraries & Senior Centers
Westworld
Transit Center
Citizen Services Centers
City-owned Leased Properties
Via Linda Campus
Old Corporation Yard
City Parks
Planet Ranch
Airport
Paiute Center
Other Offices
Unmanned Well Sites/Pump Sta.
Contract Employees/Companies
*
City Park/Pool/Maintenance Compounds
The City selected the two departments based on their regulated and unregulated challenges and
expects to model our cirywide implementation efforts based on their lessons learned.
SECTION HI: TOP MANAGEMENT FOR THIS PROJECT
David Ellison, Assistant City Manager
SECTION IV: THE CORE TEAM
Three teams (Oversight/Technical Support Team, Core Team, Steering Committee) comprising of
City staff, private industry and regulatory agencies, both professional and technical, were
established to help develop, implement and oversee the building of a comprehensive
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Environmental Management System (EcoSystem) for the City of Scottsdale. These three teams
will support the project managers who are responsible for orchestrating this project.
Project Managers:
Four Members from the Environmental Division
Special Advisors: Risk Management
Public Information Officer
Oversight/Technical Support - Team I
The 9 member Oversight/Technical Support Team is built with representatives of the private
industry who have experience in ISO 14001 certifications. This team is responsible for providing
technical support to the Core Team and Steering Committee. As part of the stakeholder process,
the City's citizen advisory board, the Environmental Quality Advisory Board (EQAB) members
also provide input.
Motorola GSTS
Allied Signal
' AZ Attorney General Office
Motorola FPDD
Arizona Department of Environmental Quality
America West Airlines
SRP
1 Yuma Proving Grounds
IBM
Core Team - Team II
The 9 member Core Team is built with top city management and is responsible for providing the
support staff from their respective areas to carry out the EcoSystem mission.
Financial Services, General Manager Organizational Effectiveness, Administrator
* City Attorneys Office, Deputy City Attorney CAPA, Director
Emergency Services, Director Municipal Services, General Manager
Community Planning, Administrator Water Resources, General Manager
Community Maintenance/Rec., General Manager
Steering Committee - Team III
The 42 member Steering Committee comprised of City middle management staff, will be
responsible for identifying environmental impacts within their respective areas and provide
methods to control and maintain.
Environmental Management Office
Airport
Financial Services
Warehouse
Graphics
Water Resources
Water Operations
Community Maintenance & Recreation
Contracts
Field Services
IS/Advanced Technology
Transportation
Traffic Signals
Community Development
Inspection Services
Project Review
Water Quality/Engineering
Municipal Services
Solid Waste Management
Capitol Projects Management
Facilities
Organization Effectiveness
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Preservation Library
Legal Police
Emergency Services
SECTION V: WHY AN EMS - DRIVERS
Scottsdale believes an EMS will result in:
Improved environmental performance;
Enhanced customer trust;
Improved regulatory partnerships;
Reduced liability;
Improved compliance;
Improved public image;
Improved environmental sustainability indicators; and,
Reduced costs.
"An EMS enables Scottsdale to create our future rather than predicting it!"
SECTION VI: OBJECTIVES AND TARGETS
See Attached Objectives and Targets Document
SECTION VH: STATUS OF THE EMS
The City of Scottsdale is presently embarking upon a relationship with Intelex, a Canadian
Software Company out of Toronto, while continuing to implement the EMS components in the
pilot fenceline departments (Water Resources and Financial Services). The purpose of the
software is to allow the entire City to have access to EMS documents and procedures as well as
create a central location to store, track and monitor all documentation.
The City is currently at the implementation stage of its EMS for Financial Services and Water
Resources. The Environmental Management Programs (EMPs) are complete and are being
implemented through training. Once this is complete auditing of the already existing components
will begin. The City is also currently continuing to go to great detail concerning legal
requirements. A regulatory guidebook has been created and is available on the EMS web site. In
addition, the City is examining past environmental audit procedures and is planning to revisit this
process in an attempt to ensure compliance is addressed. Once the departments defined in the
fenceline have completed each section of the ISO 14001 standard, the City will begin to
implement the system citywide.
SECTION VHI: KEYS TO SUCCESS
Partnering with local organization who are creating an EMS through the State EMS Pilot
Program
Communication throughout organization
Example of benefits and how it adds value
Identify departmental champions
Resource commitments (human and financial)
Establish a strong core team
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Have core team meet on a regular basis
Keep accurate documentation
Keep top management involved in the project throughout
Attain the support of not only top management but also middle management
Demonstrate to those involved that the outcome of the EMS process will benefit their
department/division
SECTION IX: HURDLES
Initial establishment of organizational structure for Oversight, Core Team, and Steering Committee.
It has been difficult to complete the legal and regulatory requirements matrix and environmental
aspects for operations so widely varying as the entire city. Generating buy-in at all levels takes time
and marketing, and jumping into these two deliverables without fully integrating into the
departmental structure first is cumbersome. Either we are seen as doing it for them, and they become
territorial, or they draw back and depend on the Project Managers to complete the tasks for them.
First, we approached the communications plan with the construction of a Web page to provide real-
time information to employees, which THEN got us full participation in these two tasks. The Project
Managers are completing the forms in order to meet expectations of us, but we are concerned that this
approach may damage our ability to effectively guide the process later.
Flowcharting the Aspects for all city operations is a huge task. Again, we are approaching this in two
phases, the first being an evaluation of all activities (on a broad scale) at each individual facility and
the impacts of each activity. For example, the office building in which the EM office is located has
generalized office functions that will share potential impacts. Facilities Maintenance performs tasks
in all facilities that have common potential impacts. The second task is to review each activity within
each facility and detail the potential impacts of each. Facilities Maintenance will also have activities
at pool sites that they do not have at other facilities, so the second phase will identify those unique
impacts. The value of this process is to work from general to specific, involving more and more
people as we go. With an organization as large as this, this appears to us to be the most effective
approach.
SECTION X: BENEFITS
Coordination of environmental issues, reduction of liability, local publicity, improvement in
relationship with private business community.
Wider organizational understanding of project and legal and regulatory requirements.
The city has been criticized recently because of its decentralized structure and the perceived flaws (in
this case with compliance tracking) that comes from a non-hierarchical system. Developing the
baseline documents has allowed for dialogue across departmental lines on these issues and has
resulted in a higher organizational awareness of compliance requirements. Ultimately, we believe that
the tracking system will allow us to maintain departmental control of compliance issues but centralize
tracking, recordkeeping and document control processes and establish the Environmental
Management Office as the central "consultant" on compliance issues.
SECTION XI: LESSONS LEARNED
Create EMS infrastructure from the outset, instead of incrementally
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Communicate effectively with staff involved through various forms of media
Direct communications based on audience's needs
Identify issues or outcomes that staff can relate to
Involve top management
Meet regularly with core team
Benchmark with other organizations throughout process
Limit size of oversight/technical support and steering committee
Know and understand the ISO 14001 Standard
Implement policies and procedures as you go
Applaud all those involved efforts
SECTION XII: CONTACT INFORMATION
City of Scottsdale Environmental Management Office
7447 E. Indian School Rd., Suite 300
Scottsdale, AZ 85251
(480)312-7990
Fax (480) 312-2455
Email: ecogecko@ci.scottsdale.az.us
EcoSystem(EMS) web site: http://www.ci.scottsdale.az.us/ecostem
Randy Grant, Chief Environmental Officer
(480)312-7995
email: rgrant@ci.scottsdale.az.us
Dennis Enriquez, Environmental Coordinator
(480)312-7778
email: denriquez@ci.scottsdale.az.us
Larry Person, Sr. Environmental Coordinator
(480)312-7889
email: lperson(g),ci.scottsdale.az.us
Garen McClure, Environmental Programs Specialist
(480)312-2743
email: gmcclure@,ci.scottsdale.az.us
SECTION XIH: TOTAL COST/RESOURCE COMMITMENT DURING THIS
PROJECT
The table below indicates the dollars spent by the City of Scottsdale from August 1997 through
July 1999 in planning, developing, and implementing the City's EMS. Travel costs represent costs
for City of Scottsdale personnel to attend meetings and workshops hosted by the U.S.
Environmental Protection Agency during the pilot program. All figures are in nominal dollars.
Labor
$103,000
Consultant
$0
Travel
$10,000
Materials
$23,000
SECTION XTV: FUTURE EMS PLANS
The City plans to complete implementation of the EMS in the defined fenceline departments.
From that point, the remainder of the organization will begin creating and implementing the EMS
in their respective departments. The software, along with the tools that have already been created
will aid the remaining departments in this process. There are also preliminary plans to bring in an
outside consultant to aid in the set up of a citywide EMS, based on the existing infrastructure.
The City has not determined whether or not to seek a third party registration. The focus at this
point is to create an implement an EMS that works for Scottsdale.
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Compiled List of Objectives and Targets for Water Resources and
Financial Services
Water Resources - Water Operations - Chris Heinz, Water Distribution Supervisor
and Gary Covert, Water Production Manager
A.
#1 Objective Prevent contamination from sewer stoppage/spill caused by grease
and root intrusion
Target Proactively reduce number of incidents of sewer stoppages/spills caused
by grease by 10% in the next year
Measurement - Proactive restaurant inspection program documenting number
and location of grease related sewer blockages
Strategies
A. Determine source
B. Contact generating source
1. Check for grease trap and maintenance records
2. Educate on grease prevention
C. Follow up inspections of grease generator
D. Document condition of main lines during routine cleaning
#2
B.
#1
Target Proactively eliminate 100% of the root related problems
Measurement - Proactive program to identify number of actual and potential
root caused sewer breaks and abate problems
Strategies
A. Determine location of roots
B. Remove source of stoppage
1. Remove tree if possible
2. Remove roots from inside of line mechanically or chemically
3. Put location on annual maintenance program
Objective Prevent contamination from repairing a water line
Target Reduce number of incidents of contamination of water system caused by
city water line repair by 10% in the next year
Measurement - Document number or repairs per year of waterline and number
of incidents of suspected contamination
Strategies
A. Shut down leaking water line
B. Remove/replace damaged line
C. Chlorinate replacement pipe with household bleach
D. After repair, flush line before reset of meter flush line to house
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#2
C.
#1
#2
#3
D.
#1
Target - Reduce contamination of water system caused by consumer water line
repair by 10% in the next year
Measurement - Document number or repairs per year of waterline and number of
incidents of suspected contamination
Strategies
A. Shut off house valve
B. Dig out adequate work space to prevent drained water from entering consumer
line
C. Plug consumer line
D. Purge and flush after work is completed
Objective - Keep water outages to a minimum and their effect on a particular
area and the amount of time they persist
Target - Proactively reduce the effect on an area from water outages by
increasing the number of valves on the entire system by 25 years
Measurement - total number of valves on the system
Strategies - New valve installation to minimize area affected by shut down
Target - Proactively reduce the length of time of a water outage by 10% over the
next year
Measurement- Average time between breakage and restoration of service
Strategies
A. Customer notification
1. Scheduled emergency shut down minimum of 24 hours
B. Semi-emergency shut down; not an immediate hazard to public health or
property
1. Notification to affected area with 1 hour advance notice
C. Emergency shut down; water doing extreme damage, notification not possible
1. Notify office of situations with estimated time of outage
2. Arrange for secondary water supply; i.e. bottled water for consumption to
hospitals, nursing homes, etc...
Target - Reduce the volume of water released during a water outage incident by
10%
Measurement - Estimated volume released per incident
Strategies
A. Valves are accessible
1. Valves plotted correctly on % section maps
2. Valves to be graded
B. Valve preventive maintenance (P.M.) program
1. Valves are exercised every 4 years
2. Broken valves are identified and repaired as soon as possible
Objective - Safely paint fire hydrants every four years and perform blue staking
with least amount of complaints/impact to property
Target - Proactively reduce the number of health related injuries resulting from
painting fire hydrants by 10% within the next the 4 years
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#2
Measurement- Track workers compensation claims/incidents annually related to
this activity
Strategies
A. Hydrant painting
1. use non-lead paint
2. use proper personal protective equipment, i.e. masks, eye protection
3. Prevent over spray with use of tarps
Target - Proactively reduce the number of blue staking/perception of graffiti
complaints by 10% within the next year
Measurement Document number of phones complaints
Strategies
A. Use of chalk instead of paint in residential areas
B. Use least amount of marking and still comply with request (dots vs. lines)
C. Use temporary "stake chasers" instead of chalk
D. Educate public that the function of blue staking is required by law
Water Resources - Water Production - Mike Mahoney, Water Quality Analyst
E.
#1 Objective - Protect the health and safety of staff and citizens while delivering
environmental services with quality and efficiency.
Target - Promote and ensure 100% accident free days for staff each year
Measurement - Track workers compensation claims/incidents annually related to
this activity
Strategies - Provide staff with the proper training, time, resources, and equipment
to safely and effectively eliminate the hazards associated with open manholes,
noise exposure, airborne pathogens, toxic vapors, and wastewater gas exposure.
#2 Objective - Comply with federal, state, and local regulations on schedule and in a
quality manner.
Target Develop compliance schedule tracking system.
Measurement - Proactive schedule implemented by Summer 1999
Strategies - Maintain accessible files and databases that document compliance
issues.
R
Water Resources - Central Groundwater Treatment Facility -Maria Mahar, Water
Quality Analyst
#1 Objective - To reclassify the spent carbon at the appropriate waste level.
Target Reclassification from large quantity generator of hazardous waste to
conditionally exempt status
Measurement - Status change by 1st quarter 1999
Strategy - Compile and submit TCLP results to submit to ADEQ RCRA for
evaluation.
#2 Objective - To continue to serve safe drinking.
TargetZero tolerance for drinking water standard violations
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#3
Measurement - Daily sampling results
Strategy - Operate under the Operation and Blending plan guidance document
and appropriate sampling plans.
Objective - To operate the air treatment system to optimize VOC removal and
carbon'life.
Target - Zero tolerance break through carbon
Measurement - Carbon efficiency data
Strategy - Operate under the Air O & M plan and evaluate air samples upon to
receipt to confirm change out intervals.
G.
Water Resources - Water Quality -Michelle Dehaan. Water Quality Analvst
_U-* s*i* ." , " **, t* -. "" . " " ' ' '' "' "
#1
#2
Objective - Safe chlorine gas use
Target - Zero tolerance for major release of chlorine
Measurement - Conduct RMP's and/or Process Hazard Analysis (PHA) on all
chlorine gas use facilities
Strategies - Install scrubbers on all facilities with 1 ton chlorine cylinders or more.
The City has no history of chlorine gas releases. Chlorine scrubbers would be
activated at sites if there were a release where there are large amounts of chlorine
gas. Chlorine gas sites will be identified and addressed within the EPA Mandated
Water Operations Risk Management Plan.
Objective - Improve untreated water sampling protocol
Target - Zero tolerance for release of contaminated untreated water from sampling.
Measurement - Testing and alternatives development results by 3rd quarter 1999.
Implement new procedures by 4th quarter 1999.
Strategies - Pilot study to develop procedures to avoid running non-potable water
with high nitrates and/or high levels of TCE on the ground while flushing for
sampling.
#3 Objective - Control chlorine by-product levels in drinking water
Target - The ultimate goal is to serve water below the current MCL (100 ppb
TTHMs) and below the proposed MCL (80 ppb TTHMs) to all residents.
Measurement - Reduce the number of occurrences of individual MCL
excedences by 10% and reduce annual running average by 1%
Strategies - Water Resources staff has identified many ways to potentially reduce
the occurrence of serving water with TTHM levels greater than the MCL. [The
City is in compliance with regulations, because the MCL is based off an annual
running average of all sites within the distribution system.] Options that need to
be reviewed include:
Retrofit reservoirs avoiding inlet and outlet short-circuiting.
Create mixing or baffling scenario.
Reevaluate "fire-flow" requirements and altering amount of stored water
Evaluate change in disinfectant.
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H.
Financial Services - Graphics Department - Ron Tatum, Bid/Contract Specialist
#1 Objective- Reduce / eliminate the output of wastewater contaminants produced
by the graphics film processors and the costs of containment and disposal per
EPA mandate, (federal compliance standards for heavy metals wastewater
discharge: < 5 p.p.m.)- (See attachments for current chemical analysis)
Target 1) Reduce total volume of wastewater discharge by 10% 2) Reduce
wastewater contaminants by 10% 3) Reduce costs for treatment/disposal by 10%
Measurement 1) Estimated volume of wastewater discharged from processor 2)
results of lab analysis on wastewater 3) disposal and treatment budget
expenditures
Strategies - 1) Installation of technology to capture and reduce or eliminate waste
water contaminants (Purchase of silver recovery/effluent treatment equipment) 2)
Explore emerging alternative digital technologies to eliminate the use of these
contaminants altogether in the future.(ongoing) 3) Graphics / EMS needs
assessment of treatment equipment. Preparation of formal request for Grant
moneys for purchase of above technology
#2 Objective - The use of environmentally friendly ink products to reduce hazardous
waste.
TargetIncrease use of vegetable base inks by 10%
Measurement - Inventory of vegetable based inks purchased annually
Strategy - To purchase and use vegetable ink products that reduce contaminants
harmful to the environment, (ongoing)
#3 Objective - Reduce Environmental Impacts such as Deforestation and Landfill
glut through the use and reuse of recycled papers
Target 1) Reduce amount of paper purchased citywide by 5%
Measurement - Budget for paper purchases
Strategy - 1) Reduce volume of paper used by 5% per department and Reset
Copiers to utilize 2 sided copying as a default setting 2) Purchase only those paper
products that contain a minimum of 15% post consumer recycled paper, (ongoing)
Re-utilization of used paper (back side note pads)
#4 Objective - Enhance the air quality in Graphics Industrial Shop environment.
Target Reduce number of complaints by 10 %
Measurement - Document number of complaints annually
Strategies - Installation of ventilation equipment to remove harmful fumes from
the work environment. Research and purchase low V.O.C. press chemicals.
(ongoing)
I.
Financial Services - Jim Jenkins, General Manager
#1 Objective - Reduce paper use in Financial Services over prior year
Target - Reduce paper use related to printers and copiers by 10% over the prior
year.
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Measurement: Through monitoring paper purchases and copy machine copy
counts.
Strategies -
a) Purchasing Director will select a designee to gather data related
to FS paper purchases and copier counts for prior year
b) Set copier defaults to duplex mode so that all copies are double
sided.
c) Encourage use of telephone and e-mail to send
communications electronically
d) Re-educate employees on how to most efficiently use their
copiers.
#2 Objective - Continue office recycling as a means of conserving natural resources.
Target - Increase volume of office recyceables by 5%
Measurement: - Volume of office recyclables from Financial Services offices
Strategies -
a) re-educate employees on the values of recycling (quarterly)
b) Work with Solid Waste Management to install consistently
colored recycling and waste bins at the corporation yard
#3 Objective- Increase by 20% the amount of batteries our department recycles.
Target - Increase volume recycled by 20 %
Measurement -Compare the volume of batteries recycled in prior year to those
recycled in current year.
Strategies -
a) re-educate employees on battery recycling program (quarterly)
b) encourage employees to bring used batteries from home
c) encourage use of rechargeable batteries wherever possible
d) purchase and install consistently colored battery recycling bins
and install them in designated office recycling areas.
#4 Objective - Work with EMO and Risk Management to ensure department
compliance with EPA and OSHA regulations.
Target - Zero tolerance for OSHA/EPA NOV's
Measurements - Number of NOV EPA or OSHA issued annually
Strategies -
a) conduct regular safety inspections of department facilities
b) applicable employees shall participate in OSHA required
training
c) ensure all EPA and OSHA required filings are made on a
timely basis.
d) continue participation in OSHA VPP and EPA ISO 14000
programs.
e) continue annual evaluation of safety program.
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WAYNE COUNTY, MICHIGAN
SECTION I: BRIEF DESCRIPTION OF THE MUNICIPALITY
Wayne County is located in southeastern Michigan, encompassing approximately 623 square
miles. It is made up of 33 cities, including the City of Detroit, 10 townships, one village, and 47
public school districts. Its population of approximately 2.2 million makes it the most populous
county in Michigan. During the first half of the 20th Century the economy was fueled by the
significant growth of the automobile industry. Today, the auto industry continues to play a key
role in Wayne County, but the economy has diversified to include world-class companies devoted
to engineering, banking, health care, and even plumbing fixtures.
Wayne County was established in 1796, as a key unit of the Northwest Territories. The County
was incorporated as a charter county in 1967. It is governed by a Chief Executive Officer, who is
elected on an at large basis for a four-year term, and a county commission comprised of 15
members elected on a partisan basis for two-year terms. The commission, acting as the County's
legislative body, establishes policy and adopts the County budget.
The county services the citizens of Wayne County through the operation and support of
numerous Departments including, Adult Probation, Airports, County Commission, Circuit and
Probate Court, Community Justice, Corporation Counsel, County Clerk, County / Detroit Public
Municipal Reference Library, Detroit/ Wayne Joint Building Authority, Detroit / Wayne County
Port Authority, Employee Unions, County Executive, Emergency Management, Environment,
Health and Community Services, Huron-Clinton Metropolitan Authority, Information Processing,
Jobs and Economic Development, Management and Budget, Personnel and Human Resources,
Prosecuting Attorney, Public Services, Register of Deeds, Retirement, Sheriff, and Treasurer.
Wayne County Executive, Ed McNamara, states: "The cornerstone and perhaps the most
important objective of this administration is its commitment to providing quality services to its
citizens, employees, businesses, and other stakeholders of Wayne County."
SECTION H: "FENCELINE" DATA
The Wayne County Department of Environment (DOE) chose the Wyandotte Wastewater
Treatment Facility (WWTF) as its fenceline. The Division of Public Works, part of the DOE,
operates the facility which accommodates 13 communities. Each community has a contract with
the county to discharge a specific amount of wastewater into the county's interceptor sewers. The
origins of the Facility date back to the 1920s. The Facility handles about 60 million gallons of
sewage per day (MOD) with a total capacity of 100 MGD. The WWTF is under renovation and
upgrading its treatment processes which will more than double the plants capacity. When
completed in 2000, the plant will have a treatment capacity of 150 MGD under normal
conditions, and 225 MGD under extreme wet weather conditions.
SECTION HI: TOP MANAGEMENT FOR THIS PROJECT
Director of Compliance and Public Affairs
Director of DPW
Superintendent Wyandotte WWTF
Supervisor of Industrial Pretreatment, Henry Ruff Field Office
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SECTION IV: THE CORE TEAM
Wyandotte WWTF - Training Manager
Laboratory Manager
Engineer
Departmental Manager
Industrial
Pretreatment
Compliance and
Public Affairs
DPW
(Administrative)
- Departmental Manager
Environmental Specialist
- Engineer
SECTION V: WHY AN EMS - DRIVERS
Wayne County believes that the EMS will
Increase the efficiency in which the facility is managed and resources are utilized
Reduce risk and liability associated with potential EH&S violations*
Improve community relations
Promote effective inter-communication and sharing of informational resources between
departmental/divisional components.
Improve competitiveness and reduce the risk of privatization
SECTION VI: OBJECTIVES AND TARGETS
The facility has developed objectives and targets which will focus on improvements in Solids
Handling Area. These include:
Odor Management System
Odor needs assessment and equipment
evaluation
Preventive maintenance and operational
procedures for odor control equipment
Housekeeping program
Employee training program
Complaint tracking and complaint response
procedures
Chemical Management Program
Chemical evaluation and waste
minimization
Chemical hazard assessment
Chemical storage and handling procedures
Chemical cost evaluation
NPDES Permit Compliance for TSS (Total
Suspended Solids)
Preventive maintenance program
Equipment evaluation and modification
Operational procedures, review
modification and training
Plant recycle monitoring and reduction
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Reduction in sludge volume being landfilled
Preventive Maintenance Program
Incinerator Ash Disposal
plan
Feasibility studies for alternative sludge
disposal and reclamation options
Program to track % solids of sludge being
lanfilled
Computerized maintenance management
program
Ash characterization
Project plan for cleanup and disposal
Contract for cleanup and disposal
SECTION VH: STATUS OF THE EMS
The core team has developed Environmental Management Plans (EMPs) for their defined
objectives and targets for the solids handling area. The facility has move forward with
implementing the tasks defined to complete their objectives and targets for the Odor Management
System. Odor control, odor source reduction, odor complaint procedures, documentation control,
and both internal and communication procedures are currently being written. Training, auditing
and management review procedures are being developed. Once the system is in place the facility
will move forward with implementation of all of their EMPs for the solids handling area and
developing objectives and targets for facility wide implementation of the EMS. The Division is
also moving forward with plans for ISO 14000 Certification of the EMS and registration of the
facility.
SECTION VIH: KEYS TO SUCCESS
Keys to success which have been identified from having gone through the EMS development
process would include:
Research Environmental Management Systems, talk to businesses that have designed and
implemented Environmental Management Systems. Try to find similar industries that have
done an EMS and use their knowledge in analyzing what type of system would be best for
your business.
Choose a fenceline or area to develop an EMS where objectives and targets will be within the
organizational resources to accomplish them.
Make sure there is commitment to developing an EMS from all top management and
interested parties before starting the project
Try to put together a core team to develop the EMS that has a wide knowledge base of how
the organization operates. This should include, as much as possible, all of the internal and
external requirements and components which allow the organization to operate, as well as the
technical expertise to evaluate the target fenceline processes and activities.
Top management commitment (this means more than just a "yes" statement) is imperative
throughout the project. Roles and responsibilities must be clearly defined, project plans,
timelines and accountability must be in place. An EMS point person (champion) must be
established as soon as possible with both the commitment of resources and authority to put
the plan in place, implement it and hold staff assigned procedures under the EMS
accountable.
Communication is the most critical item. Everyone's role and responsibility with the
organization and their importance to having, and continuing to have a successful EMS must
be defined and clearly communicated. Successes along the road to implementing an EMS
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need to be celebrated and communicated to the employees, to the communities the
organization resides in, and to any organizational partners and interested parties. Continual
organizational commitment to the EMS and successes achieved need to be communicated,
continually!
SECTION IX: HURDLES
Determining training needs and providing training has been difficult. The project
management team has spent a great deal of time trying to understand the ISO 14001 Standard
and EMS development processes. Identifying the Key concepts of ISO 14001 and the
development and implementation process for an EMS has to occur first before a basis for
training needs could be established.
Availability of training materials has been a problem internally. Providing materials to
program staff at the 3 different locations has been difficult. In keeping with the theme of the
project it is the goal of the project support staff not to generate excessive paper waste by
supplying multiple copies of training materials to project members, but to find alternative
methods for distribution. Computer Networking and electronic distribution of materials has
not come up to speed as quickly as planned. Links between divisional networks have just
recently been established. Protocol for transference of information between Departments and
Divisions over Local Area Networks (LANs) and Wide Area Networks (WANs) is still being
established. Methodologies, guidelines and procedures for transference and storage of
information and documents between project members still need to be established.
The largest hurdle was getting the project management together to identify key components
of the EMS and to move the project forward. The conference deadlines for completing the
gap analysis, identifying legal and other requirements, and drafting an environmental policy
began the process of creating a procedure for, pulling information together, setting time
frames and delegating responsibilities to project members to accomplish defined tasks.
The Project Management and core team training has progressed but there seems to be
difficulty in moving the project from a strictly managerial and planning stage to an
implementation stage. Creation of workgroups, communication to employees and
involvement of employees other than project management and core team members has not
happened. Commitment of staff time and employee availability seems to a major issue.
The core team has developed quite an extensive list of defined tasks and an implementation
schedule. Many of these tasks, though well formulated, have not been defined enough to be
implemented within the time frame indicated. No formal training program has been
developed to begin coordination of transferring the responsibility of task completion to the
assigned coordinators and facility staff. Close examination of tasks related to sludge disposal,
odor equipment evaluation and replacement indicate that items should have been budgeted
for at the beginning of the process. Objectives and targets that require 3rd party consulting
may not be able to be budgeted for until 2000 or 2001. The core team also needs to develop a
training plan and begin delegating tasks out into the facility and bringing additional staff on-
line to coordinate task implementation. The multitude and magnitude of defined tasks will be
difficult if not impossible to complete within the defined time frames unless the EMS
development format changes drastically.
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SECTION X: BENEFITS
Some organizational benefits have been realized such as the beginnings of interdepartmental
data sharing, communication and cooperation to achieve a common goal. Some heightened
awareness of the environmental importance and impact of the activities surrounding Waste
Water Treatment Facility has been attained at the upper management, facility management
and employee level. The education of the Wayne County Board of Commissioners, regarding
the importance of the Waste Water Treatment Facility and implementation of the ISO 14000
standards and EMS is a major step toward educating the community.
Organizational benefits that have been realized include, better interdepartmental
communication, allocation of resources, and time to accomplish defined tasks.
There has definitely been an increase in the knowledge base of environmental, regulatory,
and legal policies and procedures that impact the facility.
The impact that the facility has on the environment, and its direct (and indirect) correlation
with organizational polices and procedures (or lack of) is beginning to be realized, at least at
managerial level.
The facility management and core team are beginning to realize the complexity of the issue of
environmental management and connecting processes, services and activities at the facility with
environmental aspects and related environmental laws rules and regulations. A realization is
beginning to set in that a facility wide and employee based process needs to be in place to manage
this system if it is to be a continually ongoing, sustainable process.
The addition of a DPW administrative staff person to the core team has been very helpful.
This addition has added knowledge of divisional and departmental budgeting procedures and
experience in writing requests for proposals and contracts for DPW with 3rd party
consultants. The core team was very encouraged by participating in the conference and
worked hard to have materials prepared for the presentation. The ISO project was also
featured at a departmental wide employee in-service training session held in January 1999.
This has raised the interests of other divisional mangers about the project and ISO 14001
standard.
Top management commitment to EMS development and ISO 14001 certification has helped
move the project forward by demanding the development of clearly defined and obtainable
goals, assignment of responsibilities and timelines for completion of tasks and deliverables. It
has also put EMS development and certification objectives into Departmental and Divisional
planning for goals and the budget for the upcoming fiscal year.
SECTION XI: LESSONS LEARNED
Keep it simple. Try to design the EMS to fit into already existing management and
documentation systems. Most of what is needed to develop an EMS already exists within the
facility, it just needs to be pulled together in and organized and documentable system.
Spread the responsibility for developing the EMS out into the organization. Let the staff
know that they will be responsible for following procedures. Also, involve them in the
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development process. Don't try to develop every component of the EMS before
implementing it. As soon as something is developed, get it out into the organization.
It is important that the top management and the core team understand the components of the
EMS to be developed and have a clear understanding of what it will take to develop and
implement it within the given fenceline. Identification and commitment of resources, staff
and timelines necessary to complete each EMS component early on is imperative.
SECTION XII: CONTACT INFORMATION
Wayne County Department of Environment
Division of Public Works
415 Clifford, 5th Floor
Detroit MI. 48226
Phone:(313)224-3620
Fax:(313)224-7650
www.wcdoe.com
Contact: Lynn Renaud, EMS coordinator
Wayne County Department of Environment
Compliance and Public Affairs Division
415 Clifford, 7th Floor
Detroit, MI. 48226
Phone: (734) 285-3363
Fax: (734) 285-5248
E-Mail: lrenaud@,co.wavne.mi.us
SECTION XIH: TOTAL COST/RESOURCE COMMITMENT DURING THIS
PROJECT
The table below indicates the dollars spent by the Wayne County from August 1997 through July
1999 in planning, developing, and implementing the County's EMS. Travel costs represent costs
for Wayne County personnel to attend meetings and workshops hosted by the U.S. Environmental
Protection Agency during the pilot program. All figures are in nominal dollars.
James A. Abron, Director
Wyandotte Wastewater Treatment Facility
797 Central Avenue
Wyandotte, Michigan 48197
Phone: (734) 285-5500
Fax: (734) 285-5248
Contact: Ron Fadoir, Environmental Specialist
Phone:(313)224-5087
Fax:(313)224-0045
E-Mail: rfadoir 1 @co.wavne.mi.us
Labor
$88,320
Consultant
$2,400
Travel
$15,719
Materials
$4,150
SECTION XTV: FUTURE EMS PLANS
The facility plans to move forward with implementation of their EMS. Once the components of
the EMS are in place they plan to seek ISO 14001 Certification and registration. The Department
will use the lessons learned from the Municipalities Pilot Project, and the Wyandotte Wastewater
Treatment Facility certification process in evaluating future plans to develop an EMS on a
divisional or possible departmental level.
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CITY OF INDIANAPOLIS, INDIANA
SECTION I: BRIEF DESCRIPTION OF THE MUNICIPALITY
Indiana became a State in 1816. It's first capital was located at Corydon, in southwest Indiana.
Soon thereafter, the State legislature recognized the importance of a more centralized location for
government and in 1821, approved a new State Capital at the geographic center of the State. The
new capital was named Indianapolis. Though Indianapolis was located near the center of the State
and immediately adjacent to the White River, its development was curtailed because the river was
not navigable year round. This serious impediment to growth and development disappeared with
the advent of rail transportation beginning in the mid-1800s. In 1850 the City's population
numbered just over 8,000.
Today, Indianapolis has capitalized on its central location as a major distribution center proximate
to other major metropolitan centers including: Chicago, St. Louis, Cincinnati, Detroit, Cleveland,
Columbus, and Louisville. Indianapolis has developed a diversified economy that includes
manufacturing and heavy industry, with a growing reputation in finance, communication, high
technology, and amateur athletics. With a population of 818,014 situated on 402 square miles,
Indianapolis ranks as the 12th largest city in the nation. This, despite the fact that the City is not
accessible by water. The metropolitan area encompasses nine counties with a population of
approximately 1.5 million people.
The City of Indianapolis and Marion County currently operate under a consolidated city-county
government known as "Unigov". As part of the consolidation, the boundaries of the City of
Indianapolis became the same as the County with many public services combined. However,
numerous local governments and taxing units remain independent within the boundaries of the
City/County. The Mayor who is elected to an unlimited number of four-year terms heads the
executive branch of "Unigov". Several appointed deputy mayors, department directors and
division heads support the mayor.
Indianapolis operates under the "competitive government" philosophy of Mayor Stephen
Goldsmith. Under that approach, the City has undertaken a concerted effort to identify the costs
of its various activities, privatize activities that can more effectively be performed by the private
sector and set measurable performance objectives for the activities retained by the City. A
primary goal of the ISO pilot was to direct scarce City resources to activities that produced the
best bang for the buck. Consequently, the ability of a project to reduce environmental impacts
was considered along with cost reductions and efficiencies gained from the project in setting
priorities.
SECTION H: "FENCELINE" DATA
Indianapolis chose to focus its pilot project on the operations garages within the Department of
Public Works. The operations garages house a variety of functions and maintain the following
operations: Traffic signals, street repair, buildings and grounds, sign manufacturing, snow
removal, pavement striping, and road crack sealing. There are approximately 150 employees
located at these facilities. After an initial assessment, the City selected drum management as its
pilot project.
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SECTION HI: TOP MANAGEMENT FOR TfflS PROJECT
Mayor - Establishes environmental policy that includes the development of an EMS system.
Mayor's Environmental Policy Advisor - Recommends environmental policy consistent with
overall City policy and monitors progress in fulfilling the policy.
DPW Department Director - Authorizes use of the DPW Environmental Resources Division in
assisting in the development of EMS projects. Authorizes the development of EMS activities
within the DPW.
Relevant Department Director [other than DPW] - Authorizes the development of EMS activities
within the department.
Relevant Department Operations Director - Prioritizes EMS activities within the department
Assures funding for EMS activities for the department and authorizes the work of the core team
and implementation of the EMS.
SECTION IV: THE CORE TEAM
EMS Coordinator - The coordinator is housed in DPW's Environmental Resources Management
Division. The coordinator solicits interest in the EMS program, develops core teams, and assists
the core teams in the development and implementation of EMS projects. The coordinator tracks
the overall progress of the EMS program.
Project Manager - The Project Manager reviews department operations with the Operations
Manager and identifies environmental aspects and impacts of existing activities The Project
Manager recommends environmental objectives to Top Management which reduce operation
costs or improve efficiency and safety while reducing environmental impacts. The Project
Manager provides guidance and communicates with Operations Department during
implementation of EMS, and tracks the progress and benefits of the EMS project.
Operations Manager - The Operations Manager review department operations with the Project
Manager and identifies the environmental aspects and impacts of existing activities The
Operations Manager recommends environmental objectives to Top Management which reduce
operation costs or improve efficiency while improving safety and reducing environmental
impacts. The Operations Manager provides expertise and communicates with supervisors and
union employees for the implementation of changes to existing operations.
SECTION V: WHY AN EMS - DRIVERS
Indianapolis believes the EMS will:
Reduce environmental impacts in a cost-effective manner;
Support the City's overall philosophy of constant improvements in efficient and effective
service to its customers;
Improve the working environment for its employees;
Enhance the City's image as an environmentally responsible and competitive City; and,
Provide the City with significant experience in making cost-effective environmental
improvements that will place the City in a better position to argue against regulatory
initiatives that are not cost effective.
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SECTION VI: PILOT PROJECT OBJECTIVES AND TARGETS
Control and improve waste drum management
Develop and implement drum management
program by January 1, 1999
SECTION VH: STATUS OF THE EMS
The implementation and development of the EMS is pretty much complete. There are some areas
that are lacking, such as emergency preparedness, with others, such as auditing and management
review, that have yet to be addressed. The Environmental Management Program (BMP) we set
out to develop for management of waste drums has been completely developed and is about 90%
implemented.
SECTION Vm: KEYS TO SUCCESS
Active support by upper management is the major key to success of the EMS. Without it the
project cannot be fully developed. Management support should include not just the "okay" to
do the program, but an active role and accountability of those implementing to those in
management.
Clear measures of success are needed to sell the value of the program to potential
participants.
Clear definition of responsibilities for various participants in the EMS effort is needed.
The Core Team should include a respected representative of the employees (e.g. union) most
affected by the proposed changes. This will help expedite implementation of the EMS and
improve communications between management and those employees.
Maintenance of momentum is critical. Start with easily achievable goals that can provide
clear measures of success. Celebrate goals achieved. This is especially important at the
beginning of the EMS process since measurable progress seems slow if not non-existent. As
goals are achieved and celebrated, the enthusiasm, cooperation, and awareness of others,
especially those who are involved in implementation but not on the Core Team, is critical to
the success of the program. Once momentum is lost it is difficult to regain interest.
SECTION K: HURDLES
The initial assessment of an operation can produce an apparently overwhelming number of
issues. The discipline of the EMS system helps keep the issues under control and prioritized.
Our initial assessment of the operations building turned up more questions than answers.
Chemical hazard communication, storage, handling, pollution prevention and disposal have
numerous facets. The ERMD team has specialists in each of these areas and dedicated time
not only to assembling information but distributing information, as needed, to the training and
operations divisions.
An inability to quantify the benefits of EMS projects can significantly reduce enthusiasm for
the system. The ability to identify both a reduction in environmental impacts and either cost
reductions or increased efficiencies is essential to promoting the expansion of the EMS to
other departments and projects.
Competing priorities sometimes result in the redirection of personnel from EMS projects to
other projects. As we are able to identify the benefits of the EMS more clearly, we anticipate
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that the EMS program will become a higher priority, and the redirection of employees will be
substantially reduced.
Effort should be made to avoid reassigning staff critical to the development of the program.,
especially during the program's formative stages.
Failure to clearly define roles at the outset of the EMS process can reduce the effectiveness of
the program effort.
SECTION X: BENEFITS
The EMS provided a mechanism for supervisors, workers and management to express the
need for a unified system for the inventory, management and disposal of chemicals.
The-EMS provided a mechanism for shared awareness by environmental staff and operations
regarding activities that have environmental aspects.
The EMS resulted in the development of a New Products Committee, through which Union
representatives from each garage meet on a monthly basis to discuss environmental and
safety issues with the Core Team. The monthly meetings have resulted in the replacement of
existing chemicals with chemicals with less environmental impact. The Committee has also
initiated equipment changes that more effectively protect workers.
The EMS has improved communications and the relationship between operations
management and the union line workers.
The EMS resulted in the implementation of a drum management program. That program:
Reduces waste;
Greatly reduces the risk of spills; and,
Saves disposal costs.
SECTION XI: LESSONS LEARNED
Obtain both the philosophical, personnel and monetary commitment to the program from
upper management up front.
Recognize that the EMS can be used to promote worker safety as well as accomplish a
reduction of environmental impacts.
Select small projects initially, then expand to more complex issues.
Select initial projects that will produce easily quantifiable benefits in terms of reduction of
environmental impact, efficiencies gained or costs reduced.
Clearly define the roles of upper management and the core team members in developing and
implementing the EMS.
Ensure the inclusion, on the Core Team, of a trusted representative of the workers most
affected by the proposed changes.
Avoid reassignment of key EMS development personnel especially during the inception of
the EMS.
Be flexible in applying the ISO 14000 guidelines to your organization. If the fit is not perfect,
use those elements of the program that work for your situation.
Solicit a third party cheerleader for your EMS efforts. The third party could represent the
local Chamber of Commerce, environmental groups, neighborhoods or other entities
interested in promoting environmentally responsible actions.
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SECTION XH: CONTACT INFORMATION
Amy McClure
City of Indianapolis
DPW-ERMD
2700 South Belmont Avenue
Indianapolis, IN 46221
(317)327-2470
Kendall Coad
City of Indianapolis
DPW-ERMD
2700 South Belmont Avenue
Indianapolis, IN 46221
(317)327-2175
SECTION XEI: TOTAL COST/RESOURCE COMMITMENT DURING THIS
PROJECT
The table below indicates the dollars spent by the City of Indianapolis from August 1997 through
July 1999 in planning, developing, and implementing the City's EMS. Travel costs represent costs
for City of Indianapolis personnel to attend meetings and workshops hosted by the U.S.
Environmental Protection Agency during the pilot program. All figures are in nominal dollars.
Labor
$39,000
Consultant
$9,700
Travel
$6,000
Materials
$0
SECTION XTV: FUTURE EMS PLANS
Our future EMS plans include finishing up what remains to be done on the first aspect we decided
to tackle, which is waste drum management. We are developing a plan to look at a second aspect
within our organization that needs to be addressed, the sign manufacturing shop. We will use our
success in developing the drum management system to expand the program to additional projects
and departments. We have designed our documentation system so that any department within the
city can take what we have done and mimic it to develop its own EMS. The future of our
program depends, to a large degree, on the interest of the next administration in promoting the
program.
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LANSING BOARD OF WATER & LIGHT
LANSING, MICHIGAN
SECTION I: BRIEF DESCRIPTION OF THE MUNICIPALITY
Lansing is located in the south central part of Michigan, 90 miles west of Detroit and is the state's
capital. The City has a population of 127,321 according to the 1990 Census and a per capita
income of $14,043. The Lansing economy is supported by the State of Michigan, General
Motors, and Michigan State University. These three employers, however, account for only about
twenty percent of the area's employment. Lansing is an important governmental center as
Michigan's Capital. It is also the headquarters of General Motors' small car division. A diverse
group of other industries including, insurance companies, trade associations, schools, and banks
round out the list of major employers.
Lansing operates under the mayor-council form of municipal government. The Mayor is elected
by the City at large and serves for a four-year term. The City Council consists of eight members,
four elected at large and one from each of the four wards. Lansing Board of Water & Light
(LBWL) is an administrative board, delegated executive and policy making responsibilities by the
City of Lansing, Michigan. LBWL has full and exclusive management of the water, heat, steam
and electrical services of the City of Lansing and is responsible to the mayor, City Council, and
the residents of Lansing for providing these services.
LBWL is a municipal utility, owned by the citizens of Lansing, Michigan. Its roots go back to
1885, when Lansing citizens approved a $100,000 bond issue to build a water system to provide
for drinking water and fire protection. Electricity was added to its list of utility services in 1892,
and steam heat in 1919. Owned and operated by hometown people, LBWL has grown to become
the third largest electric utility in the state, the largest municipally owned utility in Michigan and
a major employer in the Lansing area.
SECTION H: "FENCELINE" DATA
LBWL chose Erickson Station as its fenceline. Erickson Station is a coal burning electric
generating plant. It houses one steam electric generating unit. This unit generates 165 megawatts,
1800-psi throttle pressure and 1,100,00 Ib. of steam per hour. Make up water is supplied to this
unit from a demineralizer. Cooling water is supplied to the plant from a closed cooling tower
circuit with its blowdown being returned to the Grand River. Cooling tower make-up is taken in
from the Grand River.
Erickson Station was chosen as the fenceline because it is the newest LBWL electric generating
facility. The age and location of the facility makes it the easiest of the LBWL facilities for
initiating an EMS pilot project. LBWL has 730 employees, 35 of which work at Erickson Station.
SECTION HI: TOP MANAGEMENT FOR THIS PROJECT
Manager Electric Production
Manager - Environmental Services Department
111
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SECTION IV: THE CORE TEAM
The Core Team consisted of seven members. The Team Leader was an Environmental Analyst
from the Environmental Services Department. The remaining members were 1 Environmental
Analyst, 2 Environmental Engineers, Erickson Station Chemist, Electric Water Quality
Supervisor, and Fuel Quality Analyst.
SECTION V: WHY AN EMS: DRIVERS
This project was viewed as an opportunity to improve internal and external communication and to
organize, streamline, and consistently manage environmental issues and regulatory
responsibilities.
SECTION VI: OBJECTIVES AND TARGETS
Draft Objectives and Targets for operating the circulating and cooling water system.
5ป>4: / *?&*&2&'%^e&^^^3@$gi$$ฎ
Safe Handling and control of all oil and
chemical spills
Operate the cooling water system to optimize
Heat Rate (BTU coal/megawatts produced)
No chemical spills or release
No equipment oil leaks
No chemical related employee injuries
Maintain equipment and chemical balance
to prevent corrosion, scale and biological
deposits
Comply with all discharge permits
SECTION VH: STATUS OF THE EMS
Formal adoption of the ISO 14000 EMS is on hold. Components of the system will be used as
issues and opportunities present themselves.
SECTION VHI: KEYS TO SUCCESS
Highly skilled technical core team.
Ability of the core team to work as a group, providing positive support in all problem-solving
activities.
SECTION IX: HURDLES
The organization was undergoing restructuring during the same time as the EMS project.
There were major changes in organizational roles and personnel, and limited resources for
design and implementation.
It is very difficult to overcome an organizational attitude and culture that anything not
directly tied to production is important.
Difficulty in scheduling meetings where everyone is available.
112
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TIME, TIME, TIME!! The team is committed to the EMS as a benefit to our organization.
However, all members are all working on multiple priorities, and since starting this project
nothing was removed from their list.
A possible problem is that our team really wanted to do things as a group. The team leader
usually developed draft documents, but the group was more comfortable (and formally agreed
on this format) with all edits being reviewed in a meeting, rather than as homework sent back
to the team leader. As long as we could maintain some degree of efficiency in this it was not
a problem. Because we were all learning the process together we felt this was the best
approach.
SECTION X: BENEFITS
An understanding of the ISO 14001 system.
Process analysis and mapping. As we worked through the aspect identification and impact
analysis we created facility process block diagrams. These diagrams have potential for
training and operational problem solving. One is already in use for a regulatory permit issue.
The facility block diagrams have been used in several situations outside the scope of the ISO
14001 EMS development. These drawings will be a valuable resource when identifying
process changes. These will probably continue to be used and maintained even if the EMS is
not formally adopted.
SECTION XI: LESSONS LEARNED
We needed to have more diverse participation on the core team. There were no active
participants from management or plant operations. All team members were from support
departments.
At the beginning a detailed project schedule is needed, with task lists, participant
responsibilities, resource identification, and time line for completion. This needs to be agreed
upon by management and the participants at the start. Meeting times must be scheduled with
appropriate release time for participation. A project of this scope, including participants from
several work groups, needs to be prioritized with existing responsibilities, not just added to
them.
From the very start management needs to understand and commit to tangible participation
and endorsement of EMS elements. Management is in the best position to become the
"champion" of the project. Management must be committed to participate at each step
according the ISO 14001 EMS elements
As each stage of the EMS is developed it should be immediately implemented with the
appropriate management review and employee training. Waiting until the end does not
provide the important feed back needed to make continual improvements. This will give
immediate feed back to the core team and management regarding employee acceptance,
training requirements, EMS benefits, and environmental and operational issues.
113
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SECTION XII: CONTACT INFORMATION
Irene Armock - Environmental Analyst
P.O. Box 13007
Lansing Board of Water & Light
Lansing, Mich.
Phone-517-371-6385
E-mail irene@LBWL.com
SECTION XID: TOTAL COST/RESOURCE COMMITMENT DURING THIS PROJECT
The table below indicates the dollars spent by the LBWL from August 1997 through July 1999 in
planning, developing, and implementing LBWL's EMS. Travel costs represent costs for LBWL
personnel to attend meetings and workshops hosted by the U.S. Environmental Protection Agency
during the pilot program. All figures are in nominal dollars.
Labor
$53,500
Consultant
$0
Travel
$2,100
Materials
$0
SECTION XTV: FUTURE EMS PLANS
Unsure at this point
114
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Appendix C
115
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CITY OF INDIANAPOLIS
ENVIRONMENTAL POLICY
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-------
Town of Londonderry
Public Works Department
Environmental Policy
management practices,
The Depaitment
11
T Laws nnd
Federal,, State and
througii the followiiig
ns --tfeet 3emrtinegit is etsmiiitted to complying with relevant
* '.t-" - - '"- r y *?
minimizing the use of h
striving to: -
H Improve materials
m reduce qiiantitles of solid waste
improve
ioii of aii; \\-ater, and/or land by
release of jpoteatiaily harfflM contaminants by
Improvement - enwronmcntEl pmerices are
environmental otgectives and taigets,
improved by setting and reviewing
117
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Document Control
Number EM01000
Original Date
10/12/98 ;
Date last ;
revised i
Document Titled: Environmental Policy
Revised by:
When Printed Approximately
Pages
Environmental Policy
Scottsdale's Vision Statement includes the expectation that "....on the way to the year 2000, our
employees will be recognized as environmentally sensitive."
The City of Scottsdale is committed to continuously improve citywide environmental management
practices and to become a model of environmental performance. The City empowers each
individual employee to proactively promote environmental leadership through the following four
environmental stewardship principles:
Conservation - to actively explore, create, and communicate new ways to
prevent pollution and to preserve natural resources.
Co-operation - to build partnerships, inside and outside the organization,
to sustain and enhance our environment.
Environmental Compliance and Risk Reduction - to ensure that
technologies, facilities, processes and operating procedures meet or
exceed environmental, health, and safety requirements and other
requirements that the City has committed to meet.
Restoration - to promptly and responsibly correct conditions which hinder
sustainable environments.
In order to assist in the promotion of these stewardship principles, the city will maintain an
environmental management system, including environmental objectives and targets consistent
with this policy that are measurable, meaningful, and understandable. This policy, including
progress toward the achievement of the objectives and targets, will be communicated to our
employees and to our citizens and other stakeholders.
A healthy and sustainable environment is important to our citizens, our economy, and our future.
The City of Scottsdale will strive to be a model of environmental performance.
118
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NYCT - Capital Program Management
Environmental Policy
Environmental
Management
System
ISO 14001
Moving Towards
Environmental
Excellence
370 Jay Street, 10* Floor
Brooklyn, NY 11201
Capital Program Management (CPM) is committed to the safe
des&n, management, construction and renovation of NYC
Transit Authority subway, bus and train fecifiies. The safety of
all giaff, contractors, passengers and the public, and protection
of the environment are among our highest priodttes-
!n confcmance with NYCTs Environmental Management
Policy and Program, CPM will estabHsh, snplBm*nt and
maintain an Environmental Management System (EMS) that
conforms with the ISO 14001 EMS Standard and provides a
rfjscipfined framework within which we will fulfill our
environmental responsibilities and continually Improve our
environmental
In this endeavor, wewHI:
* Consider the actual and potential environmental aspects
and impacts of our operations and activities at all stages of
our projects,
* Set iMS objectives and targeds, and periodically review
Ihem In order to continually Improve our EMS and
environmental performance.
* Establish department environmental procedures and
programs, including those fostering the prevention of
pollution.
4 Adhere to all applicable environmental laws and
regulations, as well as to our voluntary environmental
oommitrnsnis.
* Use our best efforts to minimize, and eliminate whore
practicable, significant adverse environmental impacts of
our projects on our employees, contractor personnel,
passengers and the communities in which projects are
located,
Document, implement and maintain our EMS and
contmunlcate it to all employees.
TWs environmental policy shall be available to the public.
Signed;
Date: January 201999
Mysore Nagaraja
Senior W & Chief Engineer
119
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Fall '98
Londonderry Household Hazardous Waste Collection
Participant Exit Survey
1. How many households do you represent?
One Two Three
Four
More than four
2. Do you have additional hazardous materials in your home which you do not know how to
dispose of properly? yes no
If yes, what are they?
asbestos
motor oil
other
3. How often do you need to dispose of hazardous waste?
Monthly quarterly twice a year annually
4. How did you hear about this collection?
less than once a year
_ Newsletter
word of mouth
newspaper
Town sign
TV
FireDept.
5. Did you bring any of the following household hazardous waste?
.Paint
household batteries
solvent or thinner
pesticides
household cleaners
herbicides
6. Have you attended a household hazardous waste collection before?
Yes No
7. Are you aware that the Londonderry Public Works Department is implementing an
EMS?
Yes No
8. Which of the following Public Works activities are you most concerned with having an
environmental impact on the Town?
Salt/sanding.
Trash disposal sewage treatment
increased Town development
burning brush
Access to recycling hazardous spills ___ environmental education
other
120
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Londonderry Internal Audit Worksheet
Department of Public Works
Division: Highway Garage
Document #: IA1-HG
Audit Period: Implementation period
Audit Date: July 2, 1999
CLAUSE
l,EHmฉNMENTALP0LICr "" >- n.-t _
1 . 1 . is the policy appropriate to the nature, scale and
environmental impacts of this division of the DPW's
activities, products or services?
1.2. does it include a commitment to continual
improvement and prevention of pollution?
1.3 does it include a commitment to comply with the
relevant environmental legislation and regulations, and
with other requirements to which the organization
subscribes?
1 .4 does it provide the framework for setting and
reviewing environmental objectives and targets?
1.4 has there been training for employees on the
environmental policy?
1.6 are all employees of this division aware of the
environmental policy?
1.7 are the employees aware of the content of the
environmental policy?
1.8 has the division implemented environmental
programs to promote the environmental policy?
1 . 9 is it available to the public?
2.0 is this information up-to-date?
YES/NO
-ป,;3^
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
N/A
Yes
COMMENTS
* '\, 4. * ^
Documented at
Town Offices
Not posted but
are aware
Building not
open to the
public
Corrective
action
required?
YES/NO
-, ,* ** *>
No
No
No
No
No
Will Post
No
No
No
No
Reviewed by v
Brown, Environmental Management Rep.
Reviewed by
Date
Date
Liz Todja, Project Director
121
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Significant Environmental Aspect Assessment Matrix
THE RATING SYSTEM FOR ACTIVITY, PRODUCT, AND SERVICE BASED FOR THE TABLE
Not Applicable
Low
Moderate
High
Very High
122
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Appendix D
123
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124
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Appendix E
125
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Global Environment & Technology Foundation
U.S. EPA Municipalities Project
MEMORANDUM OF UNDERSTANDING
THIS Memorandum of Understanding (MOU), effective as of the date last signed below
by and between the Global Environment & Technology Foundation (GETF), a non-profit
foundation with offices located at 7010 Little River Turnpike, Suite 300, Annandale, Virginia
22003-9998, and The Town of Londonderry . with offices' located at 50 Nashua Road
(hereinafter the Parties);
WHEREAS, GETF has received a grant from the U.S. EPA's Office of Water and Office
of Enforcement and Compliance to assist a group of municipalities and counties in their
implementation of an ISO 14000 EMS;
WHEREAS, Londonderry has been selected through a review process to
participate in this implementation project;
WHEREAS, Londonderry
wishes to pursue ISO 14000 EMS implementation; and
WHEREAS, GETF proposes to provide services as outlined in the Scope of Work, to
Londonderry in pursuit of its ISO 14000 EMS implementation initiative. The
specified services will be provided at no cost to the facility/organization as part of a pilot project
under grant X 825557-01-0 between the U.S. Environmental Protection Agency, Office of Water
and Office of Enforcement and Compliance, and the Global Environment & Technology
Foundation. As consideration for the provision of these services, Londonderry shall meet the
obligations as outlined below at their choice of at least one facility/organization/organization;
NOW, THEREFORE, in consideration of the promises hereinafter contained, the Parties agree to
the following:
1. As currently structured, the EPA ISO 14000 pilot project will continue through the end of
September 1999.
2. GETF agrees to provide trainers at a central location for four quarterly training sessions
each year of the project, training materials, implementation tools, and coaching support
for the tasks outlined in the Scope of Work (hereinafter referred to as Attachment A)
incorporated herein by reference, to facilitate the facility/organization's readiness for a
registration audit. The Parties clearly understand that the municipality will facilitate,
oversee, and be responsible for the development and implementation of the ISO 14001 at
the facility/organization, according to a schedule mutually agreed upon by the parties.
Under this Agreement, GETF is not responsible for providing on site training, for
actually writing the facility/organization's policies, procedures, etc. or for conducting and
on-site gap analysis or on-site internal audits, except as part of a separate agreement with
the facility/organization.
3. Londonderry agrees to determine the time schedule and allocate necessary staff
resources for completing each of the tasks outlined in the attached Scope of
Work. Londonderry shall also be responsible for developing the internal
procedures necessary for ISO 14000 implementation. Londonderry further agrees
to complete an EMS Tracking Sheet on a monthly basis and provide it to GETF by the
first Tuesday of each month for the preceding month.
126
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4.
5.
6.
Londonderry agrees to collect data as agreed upon by the Parties concerning the
development, implementation, and operation of the ISO 14001 EMS. This data may be
collected into case studies and used in a common database, which will be shared with
GETF, EPA, and other project participants.
If at any point during the period of this MOU, GETF determines at its sole discretion that
Londonderry is not meeting its obligations hereunder, GETF shall have the right to
withdraw its services under this MOU. In such case, GETF shall not be liable to
Londonderry for any reason whatsoever.
The parties hereto acknowledge and agree that during the course of this Agreement they
shall exchange confidential and proprietary technical, business, and training information
("Confidential Information"), if applicable. Neither Party nor their subsidiaries, divisions,
employees, agents, representatives, independent contractors or other persons or
organizations over which they have control will at any time during the term of this
Agreement directly or indirectly disclose such Confidential Information to any third
parties for any purposes without prior written agreement of the other Party.
Confidential Information is defined as, but not limited to, performance, sales, financial,
contractual and special marketing information, personnel, ideas, technical data and
concepts originated by the disclosing Party, only if such information is conspicuously
designated as "Confidential"; (i) in writing, if communicated in writing, or (ii) confirmed
in writing within seven (7) calendar days of disclosure if disclosed orally; and provided
further that the Confidential Information shall not include information that: 1) is now or
subsequently becomes generally available to the public through no fault or breach on the
part of Recipient; @) Recipient can demonstrate to have had rightfully in its possession
prior to disclosure to Recipient by Disclose; 3) is independently developed by Recipient
without the use of any Confidential Information; 4) Recipient rightfully obtains from a
third party who has the right to transfer or disclose it; 5) is disclosed three years from
receipt of the information; or 6) is disclosed with the written approval of the other party.
Recipient agrees to use reasonable care, but in no event no less than the same degree of
care that it uses to protect its own confidential and proprietary information of similar
importance, to prevent the unauthorized use, disclosure, publication, reproduction or
dissemination of Confidential Information by itself or by their subsidiaries, divisions,
employees, agents, representatives, independent contractors or other persons or
organizations over which they have control at any time during the term of this
Agreement. Recipient agrees to use Disclosure's Confidential Information for sole
purpose of conducting activities under this agreement. Recipient agrees not to use
Confidential Information if required by any judicial or government request, requirement
or order; provided that Recipient will take reasonable steps to give Disclosure sufficient
prior notice in order to contest such request, requirement ,or order by notifying
Disclosure of such request.
Neither Party shall be liable for the inadvertent or accidental disclosure of on
Confidential Information if such disclosure occurs despite the exercise of the same degree of care
as such party normally takes to preserve its own data or information.
127
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7. Nothing contained in this MOU shall, by express grant, implication, estoppel or
otherwise, create in either party any right, title, interest, or license in or to the inventions* patents,
technical data, computer software, or software documentation of the other party.
8. Nothing contained in this MOU shall grant to either party the right to make commitments
of any kind for or on behalf of any other party without the prior written consent of that party.
9. This agreement shall be governed and construed in accordance with the laws of the State
ofVirgina.
10. This MOU may not be assigned or otherwise transferred by either party in whole or in
part without the express prior written consent of the other party, which consent shall not
unreasonably be withheld. This consent of the other party, shall not apply in the event either party
shall change its corporate name or merge with another corporation. This MOU shall benefit and
be binding upon the successors and assigns of the parties hereto.
11. For purposes of this MOU, the respective points of contact shall be:
ForGETF:
Lynne Rasmussen
Executive Director, Environment Management
Global Environmental & Technology Foundation
7010 Little River Turnpike, Suite 300
Annandale, VA 22003
For Londonderry
Richard Plante
Town Manager
Londonerrv Town Offices
50 Nashua Road. Suite 100
Londonderry. NH 3053
Ph: 703-750-6401
Fx: 703-750-5438
name@getf.org
IN WITNESS WHEREOF, the Parties hereto have caused this MOU to be
executed as of the effective date last written below.
Global Environment &
Technology Foundation
(Municipality)
Title
Date:
Date:
128
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Summary of Participants Responsibilities
The Scope of the Work for this project includes thirteen tasks designed to develop, implement,
collect, information, and report on an ISO 14001 EMS at a facility/organization. The
Municipality/County is responsible for selecting the facility/orgnaization for this initiative and
taking all reasonable actions to ensure that each of these tasks is completed at the
facility/organization.
1. Communicating management commitment to implementing an ISO 14001 EMS across the
organization.
2. Providing ISO 14001 training for all relevant personnel that are to be involved in developing
and implementing the EMS at that facility/organization. This can include but is not limited to:
Introduction to the ISO 14000 family of environmental management standards
Comprehensive overview of ISO 14001 elements and requirements
Comprehensive overview of implementation issues
Review of relevant ISO 14001 implementation tools (e.g. Gap analysis, implementation
schedules, environmental aspects assessments, training logs, document control
procedures, computer based training modules and CD-ROMs)
Overview of internal auditing and procedures
3. Committing to develop, implement, support and report on the ISO 14001 EMS
Select and EMS management representative at the facility/organization
Allocate resources and develop a schedule
Develop job descriptions for management representatives
Use agreed on tracking mechanisms for the project
4. Selecting and EMS core team and defining roles, responsibilities and authorities for the team
members
5. Conducting a gap analysis at the facility/organization
6. Developing an environmental policy at the facility/organization that conforms to the
requirements of the ISO 14001 EMS.
7. Determine external criteria(legal and other requirements)
129
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8. Planning and conducting an employee awareness program and kick off meeting
9. Establishing internal criteria
Describe workflow processes of each functional unit in the facility/organization
Identify environmental aspects and impacts of products, activities, and services in each
functional unit
Determine significant impacts
Identify operations and activities associated with significant environmental aspects and
specify controls for these.
List objectives and targets for each significant aspect
Develop environmental management programs
Assign responsibility for writing EMS procedures and work instructions
List critical documents, records, and document control procedures for each functional
unit
Establish strong internal and external communication processes
Monitor and measure activities as described by the ISO 14001 Standard
10. Developing an EMS that conforms to the requirements of the ISO 14001 EMS
Train development teams
Document the EMS
Write the internal audit plan
Select and tram internal auditors
Train employees
11. Implementing the plan
Monitor, measure, track, record, adjust, and verify the EMS
Update employees as needed
Perform management reviews
Conduct internal audits
Make corrections and improvements
Report on progress
12. Tracking progress and supplying data as agreed upon by the Parties in ISO 14001 EMS
Implementation Initiative concerning the development, implementation, operation, and
environmental performance of the ISO 14001 EMS at the facility/organization
130
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13. Ensuring continual improvement of the EMS
The parties agree to make all reasonable efforts to complete these tasks within the two-year
timeframe established for this project. The parties also understand that the completion of these
thirteen tasks does not automatically indicate that the facility/organization will be successful if it
decides to pursue ISO 14001 certification.
131
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