United States
Environmental Protection
 August 2004
Making Permitting More Efficient and
Effective Through the Use of Environmental
Management Systems
     What is an EMS?

           An EMS is a continual cycle of planning, implementing, reviewing and improving
    the processes and actions that an organization undertakes to meet its business and
    environmental goals. EMSs are purely voluntary and do not replace the need for regula-
    tory and enforcement programs, they simply create an environment in which regulators
    and regulations can work more efficiently and effectively. The maj or components of an
    EMS are: 1) Policy, 2) Planning, 3) Implementation and Operation, 4) Checking and
    Corrective Action, 5) Management Review.

    Why are we promoting the use of EMSs?

           EPAbelieves that using EMSs can improve environmental performance, and we
    are actively promoting EMSs in a variety of programs and forums including the Agency's
    Innovation Strategy, the Performance Track Program and through compliance assistance.
    In these contexts, EPA is increasingly confronted with questions of whether EMSs can be
    used to improve the efficiency and effectiveness of regulatory tools (such as rules and
    permits) and what roles, if any, regulatory tools should play in promoting EMSs. EMSs
    have also been identified as one of the key strategies to provide further direction to the
    Resource Conservation Challenge.

           OSW wants to facilitate and encourage the widespread adoption of successful,
    high quality EMSs at RCRA facilities, and ensure that, at a minimum, the RCRA permit-
    ting program is constructed in a way that allows for and facilitates EMS implementation,
    with continuous emphasis on pollution prevention, improved environmental performance
    and compliance. To accomplish this, OSW is working with the Regions and States to use
    EMSs as a tool in voluntary programs and to pilot changes in the permitting program that
    allow EMS-based changes to be made under the issued permit through dissemination of
    EMS information and the development of appropriate assistance programs.

       OSW initiatives underway include EMS training for staff and management,
sector-based EMS assistance to specific industrial sectors (e.g., mining, oil and gas),
and potential additional RCRA incentives for Performance Track facilities.

       As we move forward with integrating EMSs into the RCRA program, we are
working with States that are interested in setting up a statewide EMS program.
We are also interested in hearing from states, regions, and/or industry groups to
provide us with additional ideas and feedback on EMS-related projects. Interested
parties can talk with OSW EMS listed below.

       Over the last ten years, there has been a growing commitment in the private
sector toward improved environmental practices. The emergence of voluntary environ-
mental management systems (EMSs), such as those suggested by ISO and others,
coupled with the adoption of those systems, bears witness to this growing commitment.
Clearly, operational practices that continually reduce environmental impact are not only
good for the environment, but good for businesses as well.

       In May of 2002, U.S. EPA Administrator Christine Todd Whitman released a
position statement describing a new regulatory  model revolving around the concept
of EMSs. The announcement was made quietly and without fanfare, but many believe
it to be the dawning of a new regulatory era of cooperative working relationships between
the regulator and the regulated, one that will ultimately streamline the permitting process,
and benefit the environment.

For More Information
       Call Glynis Hill at (703) 308-0032 or George Faison at (703) 305-7652.
       An EMS serves the organization and its mission.  It's a process, not an
event, it's the people and their actions, not the words and aspirations.  Improve-
ment rests on changing attitudes and behaviors to ''want to, not have  to. "