Second Edition

   Environmental Management Systems:

      An Implementation Guide for

  Small and Medium-Sized Organizations
                Environmental
                   Policy
  Management
    Review
           Checking /
        Corrective Action
     Planning
Implementation,
NSF International
Ann Arbor, Michigan
January 2001

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                                Second Edition

                    Environmental Management Systems:

    An Implementation Guide for Small and Medium-Sized Organizations
                                  Written by:



                          Philip J. Stapleton, Principal
                          Margaret A. Glover, Principal
                          Glover-Stapleton Associates, Inc.
                                 3 Bunkers Court
                              Grasonville, MD 21638
                                  410-827-7232

                                      and


                        S. Petie  Davis, Project Manager
                                    NSF ISR
                               789 N. Dixboro Road
                               Ann Arbor,  Ml 48158
                                 1-888-NSF-9000
Copyright ฉ NSF 2001
All rights reserved

This work has been copyrighted by NSF to preserve all rights under U.S. Copyright law and
Copyright laws of Foreign Nations. It is not the intent of NSF to limit by this Copyright the fair
use of these materials.  Fair use shall not include the preparation of derivative works.

Published by NSF International: E-mail: information@nsf-isr.org    Web: www.nsf-isr.org

ฉ 2001 NSF              I

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                                Acknowledgments


When the first edition of this Guide was published in November 1996, the use of environmental
management systems (EMS) was a relatively new, but rapidly expanding phenomenon. Considerable
experience in EMS design and implementation has been gained since the first edition of this Guide was
published. The authors' primary goal in preparing this second edition of the Guide was to take
advantage of the many new developments in the EMS field as well as the insights and experiences of
many organizations that have implemented EMS over the past few years.

Hie second edition was prepared by NSF International with funding through a cooperative agreement
with  the U.S.  Environmental Protection Agency's Office of  Wastewater  Management;  Office of
Enforcement and Compliance Assistance; Office of Pesticides, Prevention and Toxic Substances; and
Office of Policy Economics - Innovation.

In preparing the second edition,  the authors solicited input from a variety of organizations that used the
Guide in EMS planning and implementation activities. Feedback from  the user community was very
helpful in framing the changes that are reflected in this second edition.  In particular, the authors would
like to thank the following individuals for sharing experiences and insights on their use of the first edition
of the Guide.

•  Sue  Mills, Champion International,
•  Charles Tellas, Milan Screw  Products, Inc.,
•  Ronda Moore, Zexel Corporation
•  Susan Briggs, Brookhaven National Laboratory

NSF International also would  like to acknowledge the following individuals for their many contributions
to the first edition of this Guide:

   Jeffrey R. Adrian, The John Roberts Company
   Lemuel D. Amen, Washtenaw County Department of Environment & Infrastructure Services
   Stephen P. Ashkin, Rochester Midland
   Christine A. Branson, Industrial Technology Institute
   Ken  Burzelius, Midwest Assistance Programs, LeSueur County
   Marci Carter, Iowa Waste Reduction Center, University of Northern Iowa
   John Dombrowski, U. S. Environmental Protection Agency (Office of Compliance)
   David Fiedler, Michigan Department of Environmental Quality (Environmental Assistance Div.)
   Wendy Miller, U. S. Environmental Protection Agency (Office of Compliance)
   Charles Tellas, Milan Screw  Products,  Inc.
   Bryant Winterholer, K. J. Quinn & Co., Inc.


Finally, the authors of this Guide would like to  thank Jim Home of the U. S. Environmental Protection
Agency  (Office of Wastewater Management) for his significant contributions to the development of this
Guide.
ฉ 2001 NSF

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                             Second Edition

                 Environmental Management Systems:
 An Implementation Guide for Small and Medium-Sized Organizations
                               CONTENTS
Introduction to Second Edition	1
Section 1: Why Your Organization Should Have an EMS	4
Section 2: Key EMS Concepts	8
Section 3: READY! (Initial EMS Planning)	10
Section 4: SET!  (Key Elements of an EMS)	14
Environmental Policy	16
Identifying Environmental Aspects	20
Legal and Other Requirements	25
Objectives and Targets	28
Environmental Management Program(s)	32
Structure and Responsibility	35
Training, Awareness and Competency	39
Communications	43
EMS Documentation	47
Document Control	50
Operational Control	53
Emergency Preparedness and Response	57
Monitoring and Measurement	60
Nonconformance and Corrective/ Preventive Action	65
Records	69
EMS Auditing	71
Management Review	75
Section 5: GO! (Roadmap for EMS Development)	78
     Creating Your EMS: Step by Step	80
Appendix A:  TOOLKIT	88
Sample Environmental Policies	89
Environmental Impact Identification and Evaluation:  Techniques and Data Sources...96
Sample Procedure:  Instructions for Environmental Aspects Identification Form	98

ฉ2001 NSF             ii

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Sample Procedure:  Instructions for Environmental Aspects Identification Form	103
Environmental Aspects Identification	106
Sample Environmental Aspect Evaluation and Scoring Tools	108
Resources for Tracking Environmental Laws and Regulations	111
Sample Process Tool:  Setting Objectives & Targets	113
Sample Procedure:  Setting Objectives & Targets	117
Sample Tools: Environmental Management Program	120
Sample Responsibility Matrix	123
Sample Environmental Training Log	125
Sample Procedure: Communications with External Parties	127
Sample Document Index	130
Outline of Sample EMS Manual and  Other EMS Documents	132
Sample Records Management Form (supplied courtesy of	134
General Oil Company)	134
Sample Procedure:  Corrective and Preventive Action	136
(includes tracking log)	136
Sample Environmental Records Organizer	141
Sample Procedure: EMS Audits	143
Sample EMS Audit Forms	149
Sample EMS Audit Questions	152
Sample Procedure: Management Review	157
Appendix B: EPA's Performance Track and Other Government EMS Initiatives	159
Appendix C: Information on Process Mapping and Design for Environment	169
Appendix D: Registration of Environmental Management Systems	178
Appendix E: Integration of Environmental Management Systems and Quality
Management Systems	182
Appendix F: Additional Sources of Information and Contacts	186
Glossary of Acronyms	195
Bibliography	196
ฉ 2001 NSF

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                        Introduction to Second Edition

The first edition of this Guide was published in  November 1996.  Like its predecessor,  this second
edition is designed to explain environmental management system (EMS) concepts and to  support and
facilitate the development of EMS among small and medium-sized organizations. Implementation of an
EMS is a voluntary approach to improving environmental performance.  Over the past several years,
many public and private sector  organizations have implemented EMS and their numbers grow daily.
These organizations report a number of important EMS benefits, as described in this Guide.

Many changes were made in this edition of the  Guide to improve  its usefulness and to  reflect EMS
experience  gained over the  last four years  The  changes were based on  feedback solicited  from
selected users of the first edition of the Guide, lessons learned and  implementation examples from the
NSF/EPA projects, the Multi-State Working Group,  Guide users, and  Technical Committee 207-Small
and Medium-Sized Enterprise efforts. In particular, the authors have provided  additional information  on
certain EMS elements that many  organizations have found to be particularly challenging - including
environmental aspects, communications and operational controls, among others.  Sections 3 through 5
have been reconfigured into a new "Ready-Set-Go" format.  The new Section  5 (GO!) has  been added
to provide a "roadmap" or logical sequence for implementing the key elements of an EMS.  In addition,
pollution prevention success stories and examples of EMS implementation practices from public sector
and service based-organizations have been added to help demonstrate the value of EMS.

This Guide is  designed primarily for use by EMS  implementers — the people in a  small  or medium-
sized  organization that lead the EMS development effort.  The heart of the Guide is found in Section 4,
"Key Elements of an EMS." For each of the key EMS elements, this section describes the importance of
the  element,  how to get started on implementation, and  other key  suggestions.   In  this edition,
worksheets have been added to help users "capture their  learning" as they  progress from one EMS
element to the next.  Readers of the Guide can use these worksheets to summarize and evaluate their
existing management processes, to initiate needed improvements and to help  maintain implementation
momentum.

The Guide  continues to  use the  ISO 14001 standard as  one important EMS  model.   ISO  14001,
published in November 1996, is the most widely accepted international standard for EMS. EPA, as part
of its effort to promote the use of EMS's that can help organizations improve environmental performance
(including compliance) and make greater use of  pollution prevention approaches,  is implementing
several  EMS  initiatives that might be  useful  to  some  organizations.   These include the National
Environmental Performance  Track, the  EMS  Initiative for  Local Governments and  the Design  for
Environment EMS Guide.  Information on the National Environmental Performance Track program and
other  Federal and state-level EMS initiatives can be found in Appendix B and other relevant sections of
this Guide.

While this Guide is intended primarily for organizations outside the Federal government, some Federal
agencies are developing EMS's at their facilities.  These agencies may wish to  use this Guide to support
their EMS efforts.

This Guide is not intended for use by registrars (or others) for registration purposes, nor is it intended to
provide specific interpretations of the ISO 14001 Standard.
ฉ 2001 NSF

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                              How this Guide is Organized
Section 1:
Why  Your  Organization
Should Have an EMS

Section 2:
Key EMS Concepts
Section 3:
Initial EMS Planning

Section 4:
Key Elements
of an EMS

Section 5:
Roadmap for
EMS Development

Appendices
Describes the many benefits of an EMS and how such a system can
help your organization to compete and prosper in today's global
marketplace.

Summarizes overall management systems  concepts.   This section
explains what a management system is and what must  be in place for
a successful EMS.

Describes the  initial process for planning an EMS and recommends
some steps in the overall EMS planning effort.

Provides detailed guidance on how each element of your EMS could
be designed and implemented. Discusses each of the key elements of
an EMS and suggests how to put them in place.

Describes a sequence  of events or "roadmap"  for implementing the
key elements  of an EMS  and explains why the implementation of
certain elements might precede others.

Describe sources  of EMS information  and related EPA and state
programs.   Also describe  the process  for registering  an EMS and
selecting and working  with a registrar.  The Tool Kit (Appendix A)
provides sample EMS policies, procedures and other tools that your
organization can tailor to fit its EMS needs.  The sample procedures
are adapted from actual EMS  procedures used  by organizations that
have implemented EMS.
Use of Icons

A variety of icons are used in this Guide to highlight key concepts and suggestions for the reader. The
most frequently used icons include:

  Mfc
 ^=(  )ฃi   The light bulb is used to highlight EMS examples and experiences from various
           organizations.
             The hand is used to point out hints for implementing EMS elements.

            The key is used to indicate keys to successful EMS implementation, as identified by
            various organizations.
ฉ 2001 NSF

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            The speech balloon is used to indicate quotes from representatives of organizations that
            have implemented an EMS, as well as definitions from various sources (such as ISO
            14001).
            The Tool Box icon is used to highlight references to useful examples and other tools
            that are found in Appendix A (the Tool Kit).
            The Links icon is used to summarize critical linkages among EMS elements.
ฉ 2001 NSF

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     Section 1:  Why Your Organization Should Have an EMS

A systematic approach to achieve your environmental and other organizational goals
  Key EMS Benefits

      improved
      environmental
      performance

      reduced liability

      competitive advantage

      improved compliance

      reduced costs

      fewer accidents

      employee involvement

      improved public image

      enhanced customer
      trust

      more favorable credit
      terms

      meet customer
\     ronnir
                                 Does your  organization need an  EMS?  Well, ask
                                   yourself the following questions:
          romontc
J
        "We view the
      establishment of an
      EMS as a process
       that forces us to
      better organize our
        priorities and
       projects and to
       identify problems
       and exposures
      before they occur."
           - K.J. Quinn & Co.,
             a small specialty
           chemical company
                Is  your  organization   required  to   comply
                environmental laws and regulations?
                                           with
               Are   you  looking  for  ways   to   improve   your
               environmental performance?

               Is the  state  of your  organization's environmental
               affairs a significant liability?

               Does a  lack  of time or resources prevent  your
               organization   from   managing   its  environmental
               obligations effectively?

               Is  the   relationship  between   your organization's
               environmental goals and other goals unclear?
 If you answered YES to one or more of the above
 questions, an EMS can help your organization —
 and so will this Guide!

 As one of your organization's leaders, you probably
 know that interest in  environmental protection  and
 sustainable development is growing each year.  You
 might hear about these issues from customers, the
 public or others.  Like  many, your organization  may
 be  increasingly  challenged  to  demonstrate  its
 commitment to the  environment.  Implementing an
 EMS can help you meet this challenge  in several
 important ways.

 First, an effective EMS makes good sense, whether
 your organization is in the public or private sector.
 By helping to identify the causes of environmental
 problems and then eliminate them, an EMS can  help
 you save money. Think of it this way:

:ป  Is it better to make a product  (or provide  a
   service) right the first time or to fix it later?

:ป  Is it cheaper to prevent a spill in the first place or
   to clean it up afterwards?

Iป  Is it more cost-effective to  prevent pollution or to
   manage it after it has been generated?
ฉ 2001 NSF

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       "We found that an
      EMS could improve
      employee retention,
       new hire selection,
       working conditions,
      and the perceptions
       of our customers,
       suppliers, lenders,
        neighbors, and
         regulators."
        Milan Screw Products,
     a 32-person manufacturer
           of precision fittings
 Some reasons that
 municipalities have
 implemented an EMS:

 0  Improved compliance
     performance
 0  Enhanced
     management
     confidence
 0  Increased efficiency
 0  Public image concerns
 0  Growth management
 0  Desire to be seen as
     leaders and innovators
Second, an EMS  can  be an investment in  long-
term viability of your organization.  An EMS can
help  you  to  be  more   effective  in  achieving
environmental goals. And, by helping businesses to
keep existing customers and attract  new ones, an
EMS adds value.

Here's some good news:  Much of what you need for
an EMS may already be in place! The management
system framework described in this Guide includes
many elements that are common to managing  many
organizational processes, such as quality, health &
safety, finance, or human resources.  As you review
this  Guide,   you  will  probably  find  that   your
organization  has  many  EMS  processes in place,
even though they may  have been designed for other
purposes.   Integrating environmental management
with other key organizational processes can improve
financial, quality and environmental performance.

The key to effective environmental management is
the use  of  a systematic  approach to planning,
controlling,    measuring    and    improving    an
organization's     environmental     performance.
Potentially significant  environmental  improvements
(and cost savings) can be achieved by assessing and
improving    your   organization's   management
processes.  Many environmental "problems" can be
solved  without installing  expensive pollution control
equipment.

Of course, there is some work involved in planning,
implementing and maintaining  an EMS.   But  many
organizations have found that the development of an
EMS can be a vehicle for positive change.  Many
organizations have seen that the  benefits of an EMS
far  outweigh the potential  costs.  And while  these
EMS concepts certainly apply to the private sector, a
number of  public sector  organizations (including
municipalities) have found that they can benefit from
an EMS.

In the Total Quality Management (TQM)  world, they
say that "quality is free" — as long as you are willing
to make the investments that  will let you  reap the
rewards.  The  same  holds true for environmental
management.

Want to know more about EMS costs and benefits?
Then read on ...
ฉ 2001 NSF

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       EPA encourages the use
       of EMS that improve
       compliance, pollution
       prevention and other
       forms of environmental
       performance.  The
       Agency is assessing how
       EMS can be used to
       strengthen environmental
       programs and policies.
   "We needed a system to
   manage things that
   came up in a consistent
   way. Ourareaisgrowing
   and an EMS will help us
   handle development
   issues such as
   controlling soil erosion
   and preserving the
   natural features of the
   area. An EMS is a way to
   control environmental
   problems in a rapidly
   growing community."
 Steve Daut, Council Trustee
 Village of Chelsea, Michigan
       Frequently Asked Questions about EMS

  1.  We already have a compliance program - why do
     we need an EMS?

An  EMS can help you to comply with  regulations more
consistently and effectively.   It  also can help you identify
and  capitalize on environmental  opportunities  that  go
beyond compliance.

  2.  How big does an organization need to be to
     successfully implement an EMS?

EMS have been implemented by organizations ranging in
size from a couple of dozen employees to many thousands
of employees.  The elements of an EMS (as described in
this Guide) are flexible by design to accommodate a wide
range of organizational types and sizes.

  3.  Will an EMS  help us to prevent pollution?

A commitment to preventing pollution is a cornerstone of an
effective EMS and should be reflected in an organization's
policy,  objectives  and other EMS elements.  Examples
throughout this Guide show how organizations have used
an EMS to prevent pollution.

  4.  To implement an EMS, do we have to start from
     scratch?

Much of what you have  in place  now  for environmental
management probably can be incorporated into the EMS.
There is no need to "start over".

  5.  How will an EMS  affect my existing compliance
     obligations?

An  EMS will not  result in  more  or less  stringent  legal
compliance obligations.  But an EMS should improve your
efforts to comply with legal obligations, and, in some cases,
may lead to  more  flexible compliance requirements.  (See
discussion of Performance Track in Appendix B.)

  6.  Do we  need to be in 100% compliance in order to
     have an EMS?

No.  The concept  of continual improvement assumes that
no organization is perfect. While an EMS should help your
organization to improve compliance and other measures of
performance,  this does not mean that problems will never
occur.  However, an effective EMS should help you find and
fix these problems  and prevent their recurrence.
ฉ 2001 NSF

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                             EMS Costs and Benefits
             POTENTIAL COSTS

                  Internal

      • Staff (manager) time

      • Other employee time
      (Note: Internal labor costs represent the
        bulk of the EMS resources expended
        by most organizations)


      External

      • Potential consulting assistance

      • Outside training of personnel
                                        POTENTIAL BENEFITS


                                Improved environmental performance

                                Enhanced compliance

                                Prevention of pollution/resource conservation
                                New customers / markets

                                Increased efficiency / reduced costs

                                Enhanced employee morale
                                Enhanced image with public, regulators, lenders,
                                investors

                                Employee awareness of environmental issues and
                                responsibilities
                                          If your organization already has or is
                                          considering a quality management system
                                          (based on ISO 9001, for example), you will
                                          find significant synergy between what you
                                          need for quality management and for
                                          environmental management (see below).

Some Common Aspects of Quality and Environmental Management Systems
                 QMS
          Quality Policy
          Adequate Resources
          Responsibilities and Authorities
          Training
          System Documentation
          Process Controls
          Document Control
          Sstem Audits
 y
M
            anagement Review
         EMS
Environmental Policy
Adequate Resources
Responsibilities and Authorities
Training
System Documentation
Operational Controls
Document Control
System Audits
by
Me
  anagement Review
                                         One  final  note:  Small  and   medium-sized
                                         organizations often have certain  advantages
                                         over larger  organizations in  ensuring effective
                                         environmental   management.      In   smaller
                                         organizations,  lines   of  communication   are
                                         generally shorter,  organizational  structures  are
                                         less complex, people  often  perform  multiple
                                         functions,    processes   are   generally   well
                                         understood,  and  access to  management  is
                                         simpler.   These can  be real  advantages for
                                         effective environmental management.

                                         Are you interested in learning more about how
                                         an EMS can help your organization? If so, let's
                                         look at some key management systems concepts
                                         and how they are applied in the environmental
                                         area.
ฉ 2001 NSF
                               7

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                     Section 2:  Key EMS Concepts

                          The focus on quality principles
            An EMS is
   A continual cycle of planning,
   implementing, reviewing and
   improving the processes and
     actions that an  organization
       undertakes to meet its
     environmental obligations.
                               You have probably heard of Total Quality Management
                               (TQM).  Your organization may apply TQM principles to
                               some of its operations and activities.

                               An effective EMS is built on TQM concepts. To improve
                               environmental management, your organization needs to
                               focus not only on what things happen but also on why
                               they happen.  Over time,  the systematic  identification
                               and correction of system  deficiencies  leads to better
                               environmental (and overall organizational) performance.

                               Most EMS models (including the ISO  14001  standard,
                               which  is described later) are built  on  the "Plan,  Do,
                               Check, Act" model introduced by Shewart and Deming.
                               This  model  endorses the  concept   of continual
                               improvement.
       Continual
     Improvement:
  Enhancing your EMS
  to better your overall
     environmental
      performance
                                       Figure 1
r
Plan | ^
^ ^
^
    I
An effective EMS doesn't just
happen. An effective EMS
needs ongoing and visible
management support
          Top management" is the
          person or group with
          executive responsibility for the
          organization"
In the EMS model described in this Guide, the "Plan, Do,
Check, Act" steps have been expanded into  seventeen
elements that  are linked together.   These  EMS
elements and their linkages are discussed in Section 4.

Some of the keys to a successful EMS include:

Top Management Commitment

Applying TQM principles to the environmental area and
providing adequate  resources  are  the job  of  top
management.  To initiate and sustain the EMS effort,
top  management must communicate  to all  employees
the importance of:

•  making the environment an organizational priority
  (thinking of effective environmental management as
  fundamental to the organization's survival)

•  integrating environmental management
  throughout the organization
  (thinking about the environment as part of
  product/service and process development and
  delivery, among other activities)
ฉ 2001 NSF
                                8

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     Flexible & Simple =
        Adaptable &
       Understandable
        Some organizations have
        found that an effective EMS
        allows them to design pollution
        and other environmental
        impacts out of their products,
        services and operations. This
        can save money and reduce
        liability.
        Employee involvement is
        crucial. An effective
        implementation team is
        pivotal to the success of
        many organizations.
       An EMS should integrate
      ifc environmental
       management into day-to-
       day operations as well as
       strategic decisions.  It can
       make the environment the
       responsibiity of every
       employee.
looking at problems as opportunities
(identifying problems, determining root causes  and
preventing problem recurrence)

Focus on Continual Improvement
No organization is perfect.  The concept of continual
improvement recognizes that problems will occur.  A
committed organization learns from its mistakes and
prevents similar problems from recurring.

Flexibility
An effective EMS must be dynamic to allow your
organization  to  adapt  to  a   quickly  changing
environment.  For this reason, you should keep your
EMS flexible and simple.  This also helps make your
EMS  understandable  for  the people  who must
implement it — your organization's  managers  and
other employees.

Compatibility with Organizational Culture
The  EMS  approach and  an  organization's  culture
should be compatible.  For some  organizations,  this
involves a choice: (1) tailoring the EMS to the  culture,
or (2) changing the culture to be compatible with the
EMS  approach.   Bear in  mind  that changing  an
organization's  culture can be  a  long-term process.
Keeping this compatibility issue in  mind will help  you
ensure  that  the  EMS  meets your  organization's
needs.

Employee Awareness and Involvement
As you design  and implement an EMS, roadblocks
may  be encountered.  Some  people may view an
EMS as bureaucracy or extra  expense.  There  also
may   be  resistance to  change  or fear of  new
responsibilities.   To  overcome potential roadblocks,
make  sure that  everyone  understands why  the
organization needs an effective EMS,  what their  role
is and how an EMS will help to control environmental
impacts  in  a  cost-effective   manner.    Employee
involvement helps to demonstrate the organization's
commitment to the environment and  helps to  ensure
that the EMS is realistic, practical and adds value.

Building or improving an EMS  (with  the  help of  this
Guide) provides an opportunity to assess how your
organization manages environmental  obligations  and
to  find  better (and  more  cost-effective) solutions.
While you  will probably identify some areas where
your current EMS  can  be improved,  this does  not
mean that you should change things that are working
well!   By reviewing what your organization does  and
how well it works, you can ensure  that your EMS will
be viable and effective, both now and in the future.

Don't get discouraged if your system has some bugs
at first — the focus is on continual improvement!
ฉ 2001 NSF

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                 Sections:   READY!  (Initial EMS Planning)
                            Putting the theory of EMS into practice

                                       Building an EMS might sound like an overwhelming task
                                       for a smaller organization, but it need not be. Since time
                                       and other resources are limited in any organization, it is
                                       important that ypu use resources wisely.  One way to do
                                       this is by preparing and following a simple, effective plan.
                                       Fortunately, you can build  on  the  experiences  of other
                                       organizations that  have already implemented an EMS.
                                       Examples are provided throughout this Guide.
Milan Screw Products found
that the use of a cross-
functional team (the
environmental task group)
was the key to progress in
evaluating and implementing
their EMS. Participation of
line managers and
employees is essential in
successfully implementing
an EMS.
      Appendix F has
      information on EMS
      resources
      K.J.Quinn & Company found
      that it could perform an initial
      assessment of its
      environmental programs in
      20-25 hours
      Preliminary Review Tools:
      See the "NSF ISO 14001
      Self Assessment Tool"
      (at www.nsf-isr.org) or
      "Incorporating Design for
      Environment into your Gap
      Analysis"
      (at www.epa.gov/dfe)
Figure 2 illustrates the initial  steps in the EMS planning
process.  The importance of  careful planning cannot be
overemphasized.  Taking  the time to figure out what you
need to do, how you will do it, and who must be involved
will pay big  dividends down the road.

Experience  shows that  using  a  team approach to
planning  and  building  an EMS  is an  excellent  way to
promote  commitment  and  ensure  that your objectives,
procedures  and  other system  elements are realistic,
achievable, and cost-effective.  Ideas for using a team
and involving employees are discussed in this section.

A few hints to  keep in mind as you build your EMS:

  •  Help is available — don't hesitate to use it.
    (See Appendix F for  information on resources.)

  •  Pace yourself. Move quickly enough that employees
    stay  interested and  engaged,  but not  so fast  that
    those  involved are  overloaded  or that the effort
    becomes superficial.

  •  Don't re-invent the wheel  - existing management
    practices should help  you  to meet EMS requirements.

  •  Consultants can help you  evaluate your EMS  and
    suggest approaches  used  successfully elsewhere.
    Explore ways tp hold consulting costs  down.  You
    may  be able to join forces with other organizations to
    hire a consultant or sponsor a training course.
                                          Some Thoughts on Using Consultants

                                       Assess your own in-house resources first.
                                       Ensure  both  parties  understand the  scope
                                       of work.
                                       Get references  and  check them.   Look for
                                       consultants   with   experience   in    small
                                       organizations and your specific industry.
                                       Use consultants to gain insights on approaches
                                       used by other organizations.
                                       An EMS developed by consultants "in isolation"
                                       will  not work.   Your own  people need to be
                                       involved in the EMS development process.
ฉ2001  NSF
                                     10

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    FIGURE 2: INITIAL EMS PLANNING STEPS
        Define Organization's Goals

  Secure
Management
Commitment
     Hold
   Kick-off
   Meeting
  Secure
 Resources,
 Assistance
  Select
   EMS
Champion
 Conduct
Preliminary
  Review
                  Initiate
                 Employee
                Involvement
                                     Build
                                 Implementation
                                     Team
                                    Develop
                                    Project
                                     Plan,
                                   Schedule
                 Monitor &
                Communicate
                  Progress
               READY!
ฉ 2001 NSF
                    11

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                              Laying the Groundwork for an EMS:  Key Steps
      Define
   Organization's
    Secure Top
    Management
    Commitment
       Select
       EMS
     Champion
       Build
   Implementation
       Team
       Hold
      Kick-Off
      Meeting
                         more...
A first step in EMS planning is to decide why you are
pursuing the  development of an EMS.   Are  you
trying to improve your environmental performance (for
example, compliance  with  regulations  or prevent
pollution)?  Are you trying  to promote  involvement
throughout the organization?  Write your goals down
and  refer back to  them frequently  as you  move
forward. As you design and  implement the EMS, ask:
How is this task going to help us achieve our goals?
This also is a good time to define the project scope or
"fenceline" (i.e., what is  the  "organization" that the
EMS will cover?  One  location?   Multiple  locations?
Should  we "pilot"  the  EMS  at  one  location  then
implement the system at other locations later?).

One of the most critical steps in the planning process is
gaining top management's commitment to support
EMS development and implementation.  Management
must first understand the benefits of an EMS and what
it will take  to put an EMS in  place.   Explain  the
strengths and limitations of your current approach  and
how those  limitations  can  affect  the  organization's
financial and  other performance.   Management also
has a role in ensuring that the goals for the EMS (see
above)  are   clear  and   consistent   with  other
organizational  goals.   Management's  commitment
should be communicated across the organization.

Not all small- or medium-sized  organizations have the
luxury of choosing among multiple candidates, but ypur
choice of project champion  is critical.  The  champion
should have the necessary authority, an understanding
of  the  organization, and project management skills.
The  champion  should be a "systems thinker"  (ISO
9000 experience can be a plus, but is not necessary),
should have the time to commit to the EMS-building
process and must have top management support.

A team with  representatives from  key management
functions (such as  engineering,  finance,  human
resources, production and/or service) can identify  and
assess issues, opportunities, and existing processes.
Consider including  contractors, suppliers  or other
external parties as part of  the project team, where
appropriate.   The team will need  to  meet regularly,
especially in the early stages of the project.  A cross-
functional team can help to ensure that procedures are
practical and  effective and can build  commitment to
and "ownership" of the EMS.

Once the team has been selected, hold a kick-off
meeting to discuss the organization's objectives in
implementing an EMS, the steps that need to be taken
initially, and the roles of team members, among other
topics.  If possible, get top management to describe its
    mitment to the EMS at this meeting.  The kick-off
2001 NSF
     12

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                                          Creating Your Own EMS (cont'd.)
       Conduct
      Preliminary
        Review
        Prepare
      Budget and
       Schedule
       Secure
     Resources,
        Involve
      Employees
      Monitor and
     Communicate
       Progress
  Advertise your successes to
  keep management and
  employees aware of your
  EMS efforts. Document
  benefits, no matter how
  small they may seem at the
  time. As this list grows, so
  will EMS support.
meeting also is a good opportunity to provide some
EMS  training  for team  members.   Follow-up this
meeting with a communication to all employees.
The next step is for the team to conduct a preliminary
review  of  your  current  compliance  and  other
environmental  programs/systems  and to  compare
these against the criteria for your EMS (such as ISO
14001).     Evaluate  your  organization's  structure,
procedures,  policies, environmental impacts, training
programs and other factors.  Determine which parts of
your current EMS are in good shape and which need
additional  work.   See the "NSF ISO 14001 Self-
Assessment Tool" (www.nsf-isr.org) or "Incorporating
Design for the Environment into Your Gap Analysis"
(www.epa.gov/dfe) for gap analysis tools.

Based on the results of the preliminary review, prepare
a project plan and budget.  The plan should describe
in detail what key actions  are needed, who will be
responsible, what resources are needed, and when the
work will be completed.  Keep the plan flexible, but set
some stretch goals.  Think about how you will maintain
project focus and momentum over time.   Look for
potential "early successes" that can  help to build
momentum and reinforce the benefits of the EMS.

The   plan  and  budget  should  be  reviewed and
approved by top management.  In some cases, there
may   be  outside  funding  or  other   types   of
assistance that you can use (from a trade association,
a  state  technical  assistance   office,  etc.).    See
Appendix F for more ideas on possible sources of help.

Employees are a  great  source  of  knowledge  on
environmental  and health & safety issues related to
their work areas as well as on  the  effectiveness of
current processes and procedures.  They can help the
project team in drafting  procedures.  Ownership of the
EMS will be greatly enhanced by meaningful employee
involvement in the EMS development process.

As you  build  the EMS, be  sure to regularly monitor
your  progress  against   the  project   plan  and
communicate this  progress within the organization.
Be sure to communicate the accomplishments that
have  been made and describe  what happens next.
Build  on  small successes.  Be  sure to keep  top
management informed and  engaged, especially  if
additional resources might be required.
ฉ 2001 NSF
     13

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               Section  4:  SET!  (Key Elements of an EMS)
              What does an EMS consist of? How are the elements linked together?
As mentioned earlier, your EMS should be built on the "Plan, Do, Check, Act" model to ensure that
environmental matters are systematically identified, controlled, and monitored.  Using this approach
will help to ensure that performance of your EMS improves over time and that you meet your goals for
implementing an EMS in the first place.
This section describes seventeen EMS elements that are common to most EMS models. This section
also notes the  key linkages among these elements.  While there are several good EMS models
available, this Guide generally uses  the ISO 14001 Standard as a starting point for describing EMS
elements. This has been done for several reasons:

                 •  ISO  14001 is a widely accepted international standard for EMS that focuses on
                   continual improvement;
                 •  Companies may be asked to demonstrate conformance with ISO 14001 as a
                   condition of doing business in some markets; and
                 •  The  Standard is consistent with the key elements found in many EMS models,
                   including the European Union's Eco-Management and Audit Scheme, EPAs
                   Performance Track and the Code of Environmental Management Principles for
                   Federal Agencies, among others.
  Figure 3: EMS Model
                        Management   \.
                           Review     /
<                               Environmental
                                  Policy
               Checking /
            Corrective Action
          Monitoring & Measurement
        Nonconformance & Corrective &
             Preventive Action
              •   Records
             •   EMS Audits
       Continual
     Improvement!
      Planning
  Environmental Aspects
Legal & Other Requirements
•   Objectives & Targets
Environmental Management^
       Program
ฉ2001 NSF
     Implementation
    Structure & Responsibility
Training, Awareness, Competence
    •   Communication
   •  EMS Documentation
    •   Document Control
   •  Operational Control
•   Emergency Preparedness /
         Response

-------
                      Key Elements of an EMS: A Snapshot
       •  Environmental policy — Develop a statement of your organization's commitment to the
         environment.  Use this policy as a framework for planning and action.
       •  Environmental aspects— Identify environmental attributes of your products, activities
         and  services.    Determine  those  that  could  have  significant impacts  on the
         environment.
       •  Legal and other requirements — Identify  and ensure access to relevant laws and
         regulations, as well as other requirements to which your organization adheres.
       •  Objectives and targets— Establish environmental goals for your organization, in line
         with  your policy, environmental impacts,  the views of interested  parties  and other
         factors.
       •  Environmental management program —  Plan  actions necessary to achieve your
         objectives and targets.
       •  structure and responsibility — Establish roles and responsibilities for environmental
         management and provide appropriate resources.
       •  Training, awareness and competence — Ensure that your employees are trained and
         capable of carrying out their environmental responsibilities.
       •  Communication — Establish processes for internal and external communications on
         environmental management issues.
       •  EMS documentation — Maintain information on your EMS and related documents.
       •  Document control —  Ensure effective management of procedures  and other system
         documents.
       •  Operational control — Identify, plan and manage your operations and activities in line
         with your policy,  objectives and targets.
       •  Emergency preparedness and response —  Identify potential emergencies and develop
         procedures for preventing and responding to them.
       •  Monitoring and  measurement — Monitor key  activities and  track performance.
         Conduct periodic assessments of compliance with legal requirements.
       •  Nonconformance and corrective and preventive action — Identify and correct problems
         and prevent their recurrence.
       •  Records— Maintain and manage records of EMS performance.
       •  EMS audit — Periodically verify that your EMS  is operating as intended.
       •  Management review— Periodically review your EMS with an eye to continual
         improvement.
ฉ2001 NSF
15

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                              Environmental Policy

                         Communicating your environmental vision
 Key Policy Commitments

 0  Continual improvement

 0  Pollution prevention

 0  Compliance with
     relevant laws and
     reaulations
       Sample environmental
       policies are provided in the
       Tool Kit (see Appendix A).
                 An   environmental   policy  is  top  management's
                 declaration of its commitment to the environment. This
                 policy should serve as the foundation for your EMS
                 and provide a unifying vision of environmental concern
                 by the entire organization. Given  its importance, your
                 policy should be more than just flowery prose.

                 Since  it   serves  as   the   framework   for  setting
                 environmental objectives and targets, the  policy  should
                 be brought to life in your plans and deeds.  Everyone
                 in the organization should  understand the policy and
                 what  is expected  pf them  in order to  achieve  the
                 organization's objectives and targets.

                 Your policy should reflect three key commitments (see
                 box),   including   a   commitment   to   continual
                 improvement. While this does not mean  that you must
                 improve in all areas at once, the policy should drive your
                 organization's   efforts    to   continually   improve
                 environmental  management  (and   the   improved
                 performance that results from these efforts).
   Continual Improvement:

  "Process of enhancing the
  environmental management
  system to achieve
  improvements in overall
  environmental performance
  in line with the organization's
  environmental policy."
                 ISO
D01
Hints:

•  Your organization  probably  has  some  type  of
  environmental  policy now,  even if  it's  not written
  down.  For example,  your organization probably is
  committed  to complying with  the law and avoiding
  major  environmental   problems,  at a  minimum.
  Document  existing  commitments  and  goals  as a
  starting point.

•  The  policy should relate  to your  products  and
  services, as well as supporting activities.   Consider
  the results  of your preliminary review (see Section
  3) and your analysis of the  environmental aspects
  of your  products,  services  and   activities  before
  finalizing the policy.  These two steps  can provide
  insight as to how your organization interacts with the
  environment  and  how  well it   is  meeting  its
  challenges.    For example,  information  obtained
  during the  preliminary review  might help you define
  specific policy commitments.

•  Keep your policy simple and understandable.  Ask
  yourself: What are we trying to  achieve?  How can we
  best communicate this to the rest of the organization?
  One  test  to  use: Could our employees describe the
  intent of our policy in twenty words or less?
ฉ2001 NSF
                    16

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          Environmental
             Policy







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1
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C
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^ j









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           Figure 4:
      Three Pillars of an
    Environmental Policy
            Environmental Aspects
            Objectives & Targets
            Training & Awareness
            Communication
            Management Review
The environmental policy should be  explicit enough
to be audited.  If you choose to use phrases such as
"We  are committed to  excellence and leadership in
protecting the environment", consider how you would
demonstrate that such a commitment is being met.

The  environmental  policy  can  be a  stand-alone
document or it can be integrated with your health &
safety, quality, or other organizational policies.

Consider who should be involved in  developing the
policy and the best process for writing it.  Input from a
range of people  within  your  organization  should
increase commitment and ownership.

Make sure  that  your  employees  understand  the
policy.    Options for  communicating  your  policy
internally include posting it around work sites (e.g., in
lunchrooms), using  paycheck stuffers,  incorporating
the policy  into  training classes and materials,  and
referring to  the policy at staff or  all-hands meetings.
Test awareness and understanding  from time to time
by asking employees what the policy means to them
and how it affects their work.

The policy also should be communicated  externally.
Some options for external communications include
placing the  policy on business cards, in  newspaper
advertisements  and in  annual  reports,  among other
options.  You might choose to communicate the policy
proactively  or in  response to  external requests  (or
both).  This decision should  be factored into your
overall strategy for external communication (see later
discussion under "Communications").

Consider how you would  demonstrate that you  are
living by the commitments laid out in the policy. This
is a good test of whether or not the  policy is a "living
document".
         For EPA's Performance Track program, an organization's policy must
                                       include:


         compliance with legal requirements and voluntary commitments;
         pollution prevention (see Figure 5);
         continuous improvement in environmental performance, including
         areas not subject to regulation, and
         sharing information on environmental performance and their operation
         of the EMS with the community.
                         For more information see Appendix B.
ฉ2001 NSF
  17

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       Commitments to Compliance with Legal Requirements and Pollution Prevention

Compliance with legal  requirements is a critical  consideration  in  EMS development and
  implementation. EMS implementation requires an organization, among other things, to:

•    develop and communicate an environmental policy that includes a commitment to compliance;

•    develop and implement a procedure to identify, analyze and have access to environmental
     laws and regulations;

•    set objectives and targets in line with its environmental policy, which includes a commitment to
     compliance;

•    establish management programs to achieve its objectives;

•    train employees and communicate relevant EMS requirements to them;

•    establish and implement operational control procedures;

•    establish and implement a procedure for periodically evaluating compliance; and

•    establish and implement a procedure to carry out corrective and preventive actions.

While the requirements  noted  above relate directly  to  an organization's management of  legal
requirements,  each of the seventeen EMS elements described in  this Guide can  contribute to
enhanced compliance  (including communication, documentation and  document control, records
management,  EMS audits, and management review). An EMS that includes the elements  described
in this Guide will help your organization improve or maintain its compliance performance and facilitate
the establishment of objectives and targets that go "beyond compliance."
                     Figure 5

          Prevention of Pollution Hierarchy
 \
Source Reduction
                  In-Process Recycling
                    Other Recycling
                     Treatment &
                      Recovery
EMS design and implementation also
should take into account the Pollution
Prevention  (P2)  hierarchy.     In
evaluating     P2     opportunities,
organizations should start at the top of
the pyramid (i.e.,  source  reduction)
and work their way down as needed to
define the most appropriate methods
for  preventing  pollution.    Examples
and best practices of P2  in operation
are provided throughout this Guide.
ฉ2001 NSF
                        18

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                    Capture the Learning:  Environmental Policy Worksheet
  Do we have an existing policy?

  If yes, how was the policy developed?
  When was the policy last reviewed?
  Does the policy reflect the three key
  commitments (commitments to
  compliance, prevention of pollution and
  continual improvement?)

  What other commitments does or
  should our policy contain?
  How does our policy take into account
  the environmental attributes of our
  products, activities and services?
  How would we demonstrate
  conformance to our policy?
  How is the policy communicated to
  our employees?  Do our employees
  understand the critical elements of our
  policy?  How do we know?
  What feedback have we received on
  the policy (from employees, contractors
  or other interested parties)?

  What happens when we receive
  feedback on the policy?
  How do we make our policy available
  to external parties? Is this process
  effective?
  Our next step on environmental
  policy is to...
ฉ2001 NSF
19

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                      Identifying Environmental Aspects

                    How an organization interfaces with the environment
/  Environmental Aspect

      "Element of an
      organization's
   activities, products, or
     services that can
      interact with the
      environment."
                   ISO 14001
   Environmental     Impact  :"

     "Any change to the
   environment, whether
   adverse or beneficial,
      wholly or partially
      resulting from an
   organization's activities,
   products, or services."
         efine
    environmental
       aspects
   Decide if under
   your control and
    dentify relate

    environmental
       impacts
      ecide if th
     impacts are
      significant
To  plan  for  and control  its  environmental  impacts,  an
organization  must know what these  impacts  are.   But
knowing what the impacts are is only part of the challenge
— you also  should know where these impacts come
from.  Stated another way,  how does your organization
(i.e., your products, services and activities) interact with the
environment?

If your organization has undertaken  pollution  prevention
projects, you are probably familiar with this concept — that
is, you must know how and where a waste is generated in
order to  minimize  or eliminate  it.   And  like  pollution
prevention,    the   identification   and   management  of
environmental aspects can (1) have positive impacts on the
bottom  line  and  (2)  provide  significant environmental
improvements.

So,  an EMS  should include a procedure tp identify and
assess environmental aspects that the organization:

   •  can control, and
   •  over which it can have an influence.

Your  organization  is  not expected  to  manage issues
outside its  sphere of  influence or control.   For example,
while your  organization probably has  control  over how
much electricity it buys from a supplier, it likely does not
control or  influence the way in  which that electricity is
generated.  Similarly,  if your organization manufactures a
product that  is  subsequently  incorporated  into another
product (for example,  a bumper  that becomes  part of  an
automobile),  your  organization  does  not  control  the
environmental aspects  of that  "finished"  product (the
automobile).  Thus,  your  focus  should   be   on  the
environmental aspects of your products or services.

The relationship between aspects and impacts is often one
of cause and effect.   The term "aspects" (see definition
above) is neutral, so keep  in mind that  your environmental
aspects can be either positive (such as making  a product
out of recycled materials) or negative (such as discharging
toxic materials to a stream). Aspects may result from past
activities, such as spills.

Once you have identified the environmental aspects of ypur
products, activities,  and services,  you should  determine
which  aspects  could   have  significant  impacts on the
environment.  Aspects that have one  or more  significant
impact should be considered  significant environmental
aspects. These significant aspects should be considered
when you  establish  environmental  objectives, define
operational  controls  and  consider  other actions,  as
discussed later.
ฉ2001  NSF
      20

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                                        A multi-step process can be used to make this evaluation.
                                        Keep the resulting information  up-to-date, so that potential
                                        aspects  of new  products, services,  and activities  are
                                        factored into your objectives and controls.
                                        Hints:
'   US Postal Service Assesses
     Its Environmental Aspects
 The US Postal Service examined
 environmental aspects related to the
 vehicles it operates, the chemicals it
 uses to maintain equipment, the solid
 wastes it generates, and the products
 (stamps) that it sells.
   "Products" are tangible
  results of a process that
  transforms inputs into outputs
  (for example, cars or
  computers). "Services"also
  result from processes, but are
  intangible in thatyou cannot
  "hold" them (such as dry
  cleaning or equipment
  maintenance at a customer
  site). "Activities" may relate
  directly or indirectly to the
  provision of products or
  services to customers (such
  as purchasing or product
  design).
        Milan Screw Products set up
        an internal task group to
        identify environmental
        aspects. As part of this
        process, external
        stakeholders were identified
        and interviewed to
        understand their
        environmental concerns.
        These stakeholder concerns
        were added to the list of
        environmental aspects.
   In  identifying   aspects   and  impacts,   look  beyond
   activities  covered by  laws  and  regulations.    But
   because   many  of  your   aspects/impacts  may  be
   addressed  by  legal  requirements, your compliance
   program might yield some valuable information. Permits,
   audit  reports,  and monitoring  records  can be  useful
   inputs.   Beyond  regulated aspects,   consider  land,
   energy, and natural resource use, for example.

   Once  you have identified  environmental  aspects and
   related significant impacts, use this information in setting
   your objectives and targets.   This does  not mean that
   you need to address all  of your impacts at once.
   There may be good reasons (such as cost, availability of
   technology or scientific uncertainty) for addressing some
   impacts  now while deferring action  on others.  Keep in
   mind  that managing  environmental aspects  can have
   positive impacts on the organization.

   Remember to look at services  as well  as  products.
   While  the  need to  examine on-site operations might be
   obvious, you also should  consider the potential impacts
   of  what you  might do  "off-site"  (such  as servicing
   equipment   at   customer   sites).      Similarly,   the
   environmental  aspects  of the  products, vendors, and
   contractors you use may be less obvious, but should still
   be considered.

   Identifying significant environmental aspects  is one of
   the most critical steps in EMS implementation.  It can be
   one of the most challenging - as  well as one of the
   most  rewarding.   Decisions you make in  this step can
   affect  many  other system  elements (such as, setting
   objectives and targets, establishing  operational controls
   and defining  monitoring needs).  Careful  planning of this
   activity will pay dividends in  later steps.
Getting Started

• To understand  your environmental aspects,  it helps to
  understand  the  processes  by  which  you   generate
  products and services.    Flow  charting  your  major
  processes can  help you  understand the process inputs
  and outputs as well as how materials are used.  A sample
  flow chart is provided  in the Tool Kit (see  Appendix C).
  You might also want to consider the views of interested
  parties (e.g., neighbors, civic groups, regulators, etc.) in
  this process.   Some organizations have found external
  parties to be a good resource in identifying environmental
  aspects.
 ฉ2001 NSF
      21

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     In evaluating your
     environmental
     aspects and impacts,
     consider both normal
     and abnormal (such
     as start-up and
     shutdown) operating
     conditions.
       Use visual tools. As a
       starting point, some
       organizations prepare
       maps of their site and
       building(s), along with
       surrounding land uses.
       The implementation
       team uses these maps
       to "audit" the site and
       identify potential
       environmental aspects.
             Objectives & Targets

             Training & Awareness
             Communications
             Operational Controls
             Monitoring & Measurement
You  can use many sources of information to help you
identify  and assess your environmental aspects.  For
starters, look at your permits, the regulations that apply
to your operations, EPCRA reports, Material  Safety
Data   Sheets  and  monitoring   records.     Trade
associations,  regulatory  agencies,   customers  and
suppliers  also  might  provide  useful  information  to
support the assessment

Your team should define the criteria that will be used to
determine significance.  Such criteria often  include the
types of impact; the magnitude, frequency and duration
of the  impact; regulatory  status,  and  other  factors.
Consider the questions on the following page  for
identifying and characterizing aspects and impacts.

Various approaches exist for evaluating environmental
aspects and  impacts.   Select one  that can be  readily
adapted for your  use  and  that  makes sense for ypur
organization.   Examples of approaches for evaluating
environmental aspects and  impacts can be found in the
Tool Kit (see Appendix A).

Once you've  found a  process that works for your
organization, describe  the  process in the  form of a
written procedure.  A sample procedure for performing
the assessment is provided  in the Tool Kit.


You can start put with a simple process for identifying
aspects and impacts, then refine  the  process in the
future as needed.  You  also can identify and consider
more obvious environmental impacts  or  "low hanging
fruit" first, then enhance the assessment  process  to
consider more complex environmental impacts later.  As
with  any  element  of   the  EMS,  there is virtue  in
considering  how your process for identifying aspects
and impacts might be improved over time.  Ask yourself:
Is there additional information we should consider in this
process?  Do we have the  right people involved?  Are
we using the results in a meaningful way?
Use the worksheet at the end of this section to capture
some of your ideas.  Using this worksheet will give you
a "jump start" on implementing this EMS element.
ฉ2001  NSF
   22

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                  Identifying Aspects and Impacts: Some Questions to Consider:
             Identifying Aspects
a  Which operations and activities interface with
   the environment in a way that could result (or
   has resulted) in environmental impacts?
a  What materials, energy sources and other
   resources do we use in our work?
a  Do we have emissions to the air, water or
   land?
a  Do we generate wastes, scrap or off-spec
   materials?  If so, does the treatment of
   disposal of these materials have  potential
   environmental impacts?
a  Which characteristics or attributes of our
   products or services could result in impact the
   environment (through their intended  use, end-
   of-life management, etc.)?
a  Does our land or infrastructure (e.g.,
   buildings) interact with the environment?
a  Which activities (for example, chemical
   storage) might lead to accidental releases?
                                    Evaluating Impacts
                       a  Are the impacts actual or potential?
                       a  Are the impacts beneficial or damaging to the
                          environment?
                       a  What is the magnitude or degree of these
                          impacts?
                       a  What is the freguency or likelihood of these
                          impacts?
                       a  What is the duration and geographic area of
                          these impacts?
                       a  Which parts of the environment might be
                          affected (e.g., air, water, land, flora, fauna)?
                       a  Is the impact regulated in some manner?
                       a  Have our interested parties expressed
                          concerns about these impacts?
           The Link Between Aspects and Impacts (some examples from a real company)
Aspects
Emissions of volatile organic
compounds
Discharges to stream
Spills and leaks
Electricity use
Use of recycled paper
Potential Impacts
Increase in ground level ozone
Degradation of aquatic habitat and drinking
water supply
Soil and groundwater contamination
Air pollution, global warming
Conservation of natural resources
         Air Emissions
      •  Solid and Hazardous Wastes

      •  Contamination of Land
Some Potential Environmental Aspect Categories:

                   •  Water Discharges

                   •  Energy Use
      •  Local Issues
         (e.g. noise, odor, dust, traffic, etc.)
                      Raw Material and Resource Use
                      (water, energy, etc.)

                      Hazardous Material Storage and Handling
ฉ2001  NSF
                    23

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                    Capture the Learning: Environmental Aspects Worksheet
  Do we have an existing process for
  identifying aspects and/or impacts?

  If yes, does that process need to be
  revised? In what way?
  Who needs to be involved in this
  process within our organization?
  Should any outside parties be
  involved?
  When is the best time for us to
  implement this process?  Can it be
  linked to an existing organizational
  process (such as our budget, annual
  planning or auditing cycles?)
  What are some obvious
  environmental aspects of our:
  ^  Operations and activities?
  ^  Products?
  ^  Services?
  What sources of information can we
  use to identify environmental aspects?
  What sources of information can be
  used to determine the environmental
  impacts of these aspects?
  What significance criteria might make
  sense for our organization?
  How will we keep this information up-
  to-date?
  Our next step on environmental
  aspects is to ...
ฉ2001 NSF
24

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                        Legal  and Other Requirements

                          Setting the legal framework for your EMS
Legal requirements include:

 •  Federal requirements

 •  State and local requirements

• Standards in locations where
   you sell products/services

• Permit conditions


  Other requirements might
     include (for example):

 •  Company-specific codes

 •  International Chamber of
   Commerce (ICC) Charter
   for Sustainable
   Development

 •  American Chemistry
   Council's (ACC)
   Responsible Care

 •  American Petroleum
   Institute's Strategies for
   Today's Environmental
   Partnership (API STEP)

 •  Other industry codes or
   programs to which your
   organization voluntarily
   subscribes.
           KEY STEPS
           Analyze Impacts

           Communicate
In order to comply with laws and regulations that apply to
your organization, you must first know what the rules
are ana how they affect what you do.  As discussed
earlier, compliance with legal requirements is one of the
"three  pillars"  upon  which  your  environmental  policy
should be based.  The potential costs of non-compliance
(possible damage to the environment, revenue loss and
impact on public image, for example) can be very high.

Thus, an effective EMS should includes processes to:
  • identify and communicate  applicable  legal and
    other requirements, and;

  • ensure that these requirements are factored into the
    organization's management efforts.

New  or  revised  legal  requirements  might   require
modification  of your  environmental objectives or other
EMS elements. By anticipating new requirements and
making changes to your operations,  you might avoid
some future compliance obligations and their  costs.
Getting Started

Your EMS should include a procedure for  identifying,
having access to and analyzing applicable legal and
other requirements.  "Other requirements" might include
industry codes pf practice or similar requirements  to
which your organization might subscribe.

Identifying applicable regulations, interpreting them, and
determining their  impacts on your operations can  be a
time-consuming task.   Fortunately,  there  are many
methods for obtaining information about applicable  laws
or regulations.  These methods include:

 • commercial services (with updates offered on-line, on
   CD-ROM or in  paper form);
  regulatory agencies (federal, state and local);
  trade groups / associations;
  the Internet (see USEPA web site at www.epa.gov);
  public libraries;
  seminars and courses;
  newsletters / magazines;
  consultants and attorneys; and
  customers, vendors and other companies.
                                        Small business assistance programs exist in every state.
                                        Under the Clean Air Amendments of 1990,  each state
                                        environmental regulatory agency has established
ฉ2001 NSF
    25

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       For more information on EMS
       and compliance, see "Improving
       Environmental Performance and
       Compliance: Ten Elements of
       Effective Environmental
       Management Systems" (see
       Appendix F for details)
             Environmental Policy

             Objectives & Targets

             Training & Awareness

             Communication

             Operational Controls
       See Appendix A for information
       on resources for tracking
       environmental laws and
       regulations.
technical and compliance  assistance programs  to help
companies comply with air quality rules.  In some cases,
these programs have expanded into other environmental
"media",  such as  water and waste  management.   In
addition,  National Compliance Assistance Centers  can
provide  compliance  assistance  for certain  industry
sectors (see Appendix F for more information).

Once applicable requirements have been identified  and
analyzed  for potential  impacts,  communicate  these
requirements  (and  plans for complying with  them) to
employees, on-site  contractors and others, as needed.
Communicating "other applicable requirements" (as  well
as their impacts on the organization) is an important but
often overlooked step. Keep in mind that different people
may have different information needs.

As _with many EMS elements, this is  not a "one time"
activity.   Since legal and other  requirements change
over time, your process  should  ensure that you  are
working with up-to-date information.

Resources to identify and track environmental laws  and
regulations are described in the Tool Kit (Appendix A).
                   Commonly Applicable Federal Environmental Laws in the US
Clean Air Act (CAA)
[40 CFR Parts 50-99]
Clean Water Act (CWA)
[40 CFR Parts 100-145, 220-232, 410-471]
Federal Insecticide, Fungicide and
Rodenticide Act (FIFRA)
[40 CFR Parts 150-1 89]
Resource Conservation and Recovery
Act (RCRA)
[40 CFR Parts 240-299]
Toxic Substances Control Act (TSCA)
[40 CFR Parts 700-799]
Comprehensive Environmental
Response, Compensation and Liability
Act (CERCLA, also known as "Superfund")
[40 CFR Parts 300-311]
Emergency Planning and Community
Right-To-Know Act (EPCRA)
[40 CFR Parts 350-374]
Hazardous Materials Transportation Act
(HMTA) [49 CFR Parts 100-180]
Establishes ambient and source emission standards and permit
requirements for conventional and hazardous air pollutants.
Establishes ambient and point source effluent standards and
permit requirements for water pollutants, including sources that
discharge directly to a waterbody or to a public sewer system.
Establishes a program for Federal review of, registration and
control of pesticides.
Establishes regulations and permit requirements for hazardous
waste management. Also, creates standards for underground
storage tanks that hold oil or hazardous substances.
Regulates the use, development, manufacture, distribution and
disposal of chemicals. Certain chemicals (such as PCB's) are
subject to specific management standards.
Establishes a program for cleaning up contaminated waste sites
and establishes liability for clean-up costs. Also, provides
reporting requirements for releases of hazardous substances
Establishes a program (also known as the "Toxic Release
Inventory") to inform the public about releases of hazardous and
toxic chemicals. Reporting requirements apply to companies that
use, process or store specific chemicals over specified quantities.
Establishes standards for the safe transportation of hazardous
materials.
ฉ2001  NSF
    26

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                  Capture the Learning: Legal & Other Requirements Worksheet
 Do we have an existing process for
 identifying applicable legal and other
 requirements?

 If yes, does that process need to be
 revised? In what way?
 Who needs to be involved in this
 process within our organization? What
 should their responsibilities be?
 What sources of information do we
 use to identify applicable legal and
 other requirements?

 Are these sources adequate and
 effective? How often do we review
 these sources for possible changes?
 How do we ensure that we have
 access to legal and other
 requirements?  (List any methods
 used, such as on-site library, use of
 web sites, commercial services, etc.)
 How do we communicate information
 on legal and other requirements to
 people within the organization who
 need such information?
 Who is responsible for analyzing new
 or modified legal requirements to
 determine how we might be affected?
 How will we keep information on legal
 and other requirements up-to-date?
 Our next step on legal and other
 requirements is to...
ฉ2001 NSF
27

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                              Objectives and Targets
                      Establishing goals for environmental management
 Environmental Objective:

 "Overall environmental
 goal, arising from the
 environmental policy,
 that an organization sets
 itself to achieve, and
 which is quantified
 where practicable."
                    ISO 14001
        Objectives and targets help an organization translate
        purpose into action.   These environmental  goals
        should be factored into your strategic plans.  This can
        facilitate    the    integration    of    environmental
        management   with   your   organization's   other
        management processes.

         You determine  what  objectives  and targets  are
         appropriate for your prganization.   These goals  can
         be applied organization-wide or to individual units,
         departments or functions - depending on where the
         implementing actions will be needed.

         In   setting   objectives,    keep   in    mind   your
         environmental  policy,  including its  three  "pillars."
         You   should   also   consider   your   significant
         environmental aspects, applicable legal and  other
         requirements, the views of interested parties, your
         technological options, and financial, operational,
         and other organizational considerations.
 Environmental Target:
 "Detailed performance
 requirement, quantified
  where practicable,
   applicable to the
  organization or parts
thereof, that arises from
  the environmental
  objectives and that
needs to be set and met
  in order to achieve
  those objectives?
                                        Figure 6
                 I    Policy   I
Environmental!     f
  Aspects   I     I
Legal / Other
Requirements

   Views of    1
nterested Parties
            X       I         /
                    Objectives
                        and
                      Targets
                                     fTechnology 1   f  Finance 1  fOperations!
                                               There are no "standard" environmental objectives that
                                               make sense for all organizations. Your objectives and
                                               targets  should reflect what your organization does,
                                               how well it is performing and what it wants to achieve.
ฉ2001 NSF
      28

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  Factors to consider
  in setting objectives
      and targets

  0  ability to control

  0  ability to track /
     measure

  0  cost to track/
     measure

  0  progress reporting

  0  links to policy
     commitments
      A sample process tool and
      procedure for setting
      objectives and targets are
      included in the Tool Kit
      (Appendix A).
       Environmental Policy
       Environmental Aspects
       Legal & Other
       Requirements
       Structure &
       Responsibility
       Operational Control
       Monitoring &
       Measurement
       Management Review
Hints:

• Setting objectives and targets should involve  people  in
  the relevant functional area(s).  These people should be
  well positioned to establish,  plan for, and  achieve  these
  goals. Involving people helps to build commitment.

• Get top management buy-in for your objectives.  This
  should help to ensure that adequate resources are applied
  and  that   the   objectives  are  integrated  with  other
  organizational goals.

• In communicating objectives to employees, try to link
  the   objectives   to   the   actual   environmental
  improvements  being sought.   This  should  give people
  something tangible to work towards.

• Objectives should be consistent with your overall mission
  and plan and the key commitments  established in your
  policy (pollution  prevention,  continual improvement, and
  compliance).   Targets  should  be  sufficiently clear  to
  answer the question: "Did we achieve our objectives?"

• Be flexible in your objectives.   Define a  desired result,
  then let the people responsible determine how to achieve
  the result.

• Objectives can be established to maintain current levels
  of performance as well as to improve performance. For
  some   environmental  aspects  you  might   have  both
  maintenance and improvement objectives.

• Communicate your progress in achieving  objectives and
  targets across the organization.  Consider a regular report
  on this progress at staff meetings.

• To obtain  the views of interested parties,  consider
  holding an open  house or establishing a focus group with
  people in the community. These activities can have other
  payoffs as well.

• How many objectives and targets should an  organization
  have? Various EMS implementation projects for small and
  medium-sized organizations indicate that it  is best to start
  with a limited number of  objectives (say, three to five) and
  then  expand the list  over time.   Keep your objectives
  simple initially, gain some early successes, and then build
  on them.

• Make  sure your objectives  and targets  are realistic.
  Determine  how  you will  measure  progress towards
  achieving them.

• Keep in mind that your suppliers (of service or materials)
  can help you in  meeting  your objectives and targets (e.g.,
  by providing more "environmentally friendly" products).
ฉ2001 NSF
   29

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                 Comparing Objectives and Targets - Some Examples
Objectives
Reduce energy usage
Reduce usage of hazardous chemicals
Improve employee awareness of
environmental issues
Improve compliance with wastewater
discharge permit limits
Targets
• Reduce electricity use by 10% in 2001
• Reduce natural gas use by 15% in 2001
• Eliminate use of CFCs by 2002
• Reduce use of high-VOC paints by 25%
• Hold monthly awareness training courses
• Train 100% of employees by end of year
• Zero permit limit violations by the end of
2001
                               POLLUTION PREVENTION

         Pfizer Global Research & Development (formerly Warner-Lambert Parke-Davis) has
         a pollution prevention program that shows that improving the environment and the
         bottom line can go hand-in-hand. For example:

          By replacing chillers and redesigning chilling systems to be more efficient,  the
          company has realized $250,000 in energy savings.  Also, because the company is
          more energy efficient, it has reduced emissions from its local power supplier.

          By redesigning and modifying its dust collection system, the company replaced its
          100-hp motors with 40 hp motors, without compromising the effectiveness of the
          dust collection system.  This project lowered the company's operating costs and
          reduced emissions at the local power plant.
                                POLLUTION PREVENTION

         Some Motorola manufacturing sites have  reduced  their water consumption and
         wastewater discharges by greater than 95% by installing ion exchange technology
         and employing better operating techniques.  These changes have lowered usage of
         water treatment chemicals and have resulted in considerable cost savings.
       EPA's Performance Track program requires organizations to consider the
            following factors in setting measurable objectives and targets:
       • Prevention of noncompliance,
       • Prevention of pollution at the source
       • Minimization of cross-media pollutant transfers, and
       • Environmental performance improvement.

       Participating organizations also must show continued improvement in specific
       environmental categories, such as energy use, water discharges, or waste
       generation, among others.
                           See Appendix B for more information.
ฉ2001 NSF
30

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               Capture the Learning:  Objectives and Targets Worksheet
   Do we have an existing process for
   setting and reviewing environmental
   objectives and targets?

   If so, does that process need to be
   revised? In what way(s)?
  Who needs to be involved in this
  process within our organization?
  Should any outside parties be
  involved?
  When is the best time for us to
  implement this process?  Can it be
  linked to another existing
  organizational process (like our annual
  or strategic planning process?)
  What are our existing environmental
  goals?  How were these developed?
  Who was involved?

  What factors were considered in
  setting these goals?
  Who are our interested parties?
  How do we obtain their views?

  How effective has our process been?
   How can we effectively and efficiently
   track our progress and communicate
   the results?

   Who is in the best position to do this?
   Our next step on environmental
   objectives and targets is to ...
ฉ2001 NSF
31

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                  Environmental Management Program(s)
                     A road map for achieving environmental goals
     Objectives and
        Targets
      Established
          T
     Environmental
 Management Program
        Defined
          T
     Monitoring and
     Measurement

      At St. Joseph's Mercy
      Hospital (in Michigan),
      mercury was in widespread
      use. The Hospital had a
      contract with a professional
      environmental response
      company to clean up and
      dispose of any discarded
      equipment and waste that
      resulted from mercury spills.
      Mercury was identified as
      an environmental aspect
      during EMS implementation,
      leading to the development
      of a Mercury Reduction
      Initiative.  This Initiative is
      expected to save the
      Hospital as much as
      $20,000 per year.
So far, this Guide has focused on the foundations of an
EMS - the planning elements.  An  important part of this
planning effort is defining what your organization intends to
achieve in the  environmental  area.   To  achieve  your
objectives  and targets,  you need an action  plan  - also
known  as an environmental management program.

Your environmental management program should be linked
directly to your objectives and targets — that is, the
program should describe how the organization will translate
its goals and policy commitments into concrete actions
so that environmental objectives and targets are achieved.

To   ensure   its   effectiveness,    your  environmental
management program should define:
•  the responsibilities for achieving goals (who will do it?)
•  the means for achieving goals (how will they do it?)
•  the time frame for achieving those goals (when?)

Keep in mind  that your program should be a dynamic one.
For example, consider modifying your program when:
  •  objectives and targets are modified or added;
  •  relevant legal requirements are introduced or changed;
  •  substantial progress in  achieving your objectives  and
    targets has been made (or has not been made); or
  •  your products, services, processes,  or facilities change
    or  other issues arise.

Your action  plan need not  be compiled  into a  single
document.  A "road map" to several action plans is an
acceptable alternative, as  long as the key  responsibilities,
tactical steps,  resource needs and  schedules are defined
adequately in these other documents.

This program  should not be developed in a vacuum — it
should   be  coordinated  or  integrated   with   other
organizational  plans,  strategies,   and  budgets.    For
example, if you are planning for a major expansion in one of
your service operations, then it makes sense to look at the
possible   environmental   issues  associated  with   this
operational expansion at the same time.

Hints:

•  Build  on  the plans and  programs  you have  now for
   compliance, health & safety or quality management.
•  Involve your employees  early  in establishing  and
   carrying out the program.
•  Clearly   communicate    the    expectations    and
ฉ2001 NSF
       32

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 "Before, we focused on
 compliance issues without
 the benefit of an EMS.
 Now, we have a strategic
 plan in place to look beyond
 legal requirements and save
 money. It makes my job
 easier when I can prove my
 department does not have
 to be a cost center."
 Charlie Saunders, EMS Manager,
        Pfizer Global Research &
                 Development
             Objectives & Targets
             Structure &
             Responsibility
             Communication
             Operational Control
             Monitoring &
             Measurement
responsibilities defined in the program to those who need
to know.
In  some   cases,  your  environmental  management
program   may   encompass  a  number  of  existing
operating  procedures  or  work  instructions  for
particular operations or activities.  In  other cases, new
operating  procedures or work instructions  might be
required to implement the program.
Re-evaluate your action  plan when you are considering
changes   to  your products,   processes,  facilities  or
materials.  Make this re-evaluation part of your  change
management process.
Keep it simple (see sample tool, below) and focus on
 continual improvement of  the program overtime.
There may be real opportunities here!  Coordinating
your environmental program with your overall plans and
strategies  may position your organization to exploit some
significant cost-saving opportunities.
                Figure 7: Environmental Management Program (Sample Form)
      A full-size copy of
      this form and
      another sample
      form are provided in
      the Tool Kit (see
      Appendix A).
Objective / Tar
Action
Items

Priority

Responsibilities

get #1 :

Schedule

Resources
Needed


Comments

                                 POLLUTION PREVENTION **

         March Coatings operated a de-ionization unit to purify water for its coating process.
         While effective, the unit required  39,000  pounds of hydrochloric acid  to operate.
         Concerns about potential spills and worker health & safety impacts led the company
         to replace the de-ionizer with a reverse osmosis unit, which completely eliminated the
         use of hydrochloric acid.
ฉ2001  NSF
    33

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      Capture the Learning:  Environmental Management Programs Worksheet
   Do we have an existing process for
   establishing environmental
   management programs?

   If yes, does that process need to be
   revised?  In what way?
  What environmental management
  programs do we have in place nov/?
  What is the basis for our
  environmental management programs
  (for example, do they consider our
  environmental objectives, our
  environmental policy commitments and
  other organizational priorities)?
  Who needs to be involved in the
  design and implementation of these
  programs within our organization?
  When is the best time for us to
  establish and review such programs?
  Can this effort be linked to an existing
  organization process (such as our
  budget, planning or auditing cycles?)
   How do we ensure that changes to
   products, processes, equipment and
   infrastructure are considered in our
   programs?
   How will we otherwise keep our
   programs up-to-date?
   Our next step on environmental
   management programs is to ...
ฉ2001 NSF
34

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                      Structure and Responsibility

                         Aligning your resources to succeed
    "Resources include human
    resources and specialized
      skills, technology, and
      financial resources."
               -ISO 14001
     Characteristics of a
     good management
       representative:

      • Knowledgeable
        • Assertive
       • Independent

For an EMS to be effective, roles and responsibilities
must  be  clearly  defined  and communicated.    The
commitment of all employees is needed for an EMS to
live up to its full potential.

Top  management plays  a  key  role by  providing
resources needed to implement the EMS.  This is one of
the most important jobs of top management (see "Finding
Resources" on next page).  In some organizatipns, "top
management" might be a single individual, while in others
it  might  be  a group of people (such as a board  of
directors).

An effective management system needs an advocate.
Thus, top management should appoint a management
representative.   This representative  (1)  ensures that
the EMS is established and implemented; (2) reports on
its performance over time; and (3) works with others to
modify  the  EMS as  needed.   The  management
representative can be the same perspn who serves as
the project champion (as discussed in Section 3),  but
this is not mandatory. A business owner, plant or shop
manager, or any number of other people might serve as
an effective EMS management representative.
(     More organizational
  advantages of small business:

  0 shorter lines of
    communication

  0 less complex organization

  0 limited delegation

  0 simpler access to
    management
      Getting Started

  Look at:

  0 Program Scope

  0 Environmental
       Aspects

  0 Objectives

  0 Previous audits

   j Other systems
Small  and  medium-sized  organizations  may  have
advantages  over larger  ones  in  structuring  their
resources for environmental management.   Because
personnel and  other  resources  are generally  more
limited in smaller organizations, people often "wear more
than  one hat"  and  have  experience  in  performing
multiple  functions.    An  individual  responsible  for
environmental management in  a smaller  organization
also might be responsible for quality, health & safety,
facilities,  or other functions.  In such cases, integrating
environmental responsibilities with other functions can
be greatly simplified.	
Getting Started:

The following questions can help you determine the right
organizational structure for environmental management:

• What  is   the  scope  of  our  environmental
  management program? What  capabilities  do  we
  need?  Who will help to make  the  EMS effective?
  What training or other resources do we need?

• What are  our significant environmental aspects
  and compliance needs? What operations / activities
  need to be controlled? Who needs to be involved to
  ensure that controls are implemented?
  ฉ 2001 NSF
    35

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 Consider integrating EMS
    with your existing:

 0  information systems

 0  purchasing controls

 0  quality procedures

 0  work instructions

 0  training programs

 0  communication efforts

 0  reporting systems

 0  recruitment, appraisal
    and disciplinary
    processes
  See Appendix C for information
  on process mapping
   What are the results of previous audits or other
   assessments?  What  does this information tell  us
   about the effectiveness of our organizational structure
   and how it might be improved?

 •  What   are  the   current  responsibilities  for
   environmental  management?    How  can  we
   enhance ownership  of  environmental management
   across the organization?  How can other functions
   support the EMS? (See next page.)

 •  What are  our objectives and targets, including
   those  related to  compliance   and pollution
   prevention?  How will  the organizational structure
   help up achieve these goals?

 •  What quality management and / or other existing
   management  systems  exist?  What  roles and
   responsibilities exist in these management systems?
   Do opportunities for system integration exist?

 Consider flow charting  your existing environmental
 management activities. This  can  help you understand
 how these processes work and the final product can be
 a great communication and training tool.   Flow  charts
 also  can  be  useful to look  at  processes such  as
 chemical   purchasing   and   distribution,   employee
 training, and preventive  maintenance,  among  others.
 Appendix C provides information on process mapping.
                                   Hints:
  Appendix A provides a sample
  responsibility matrix
  More information on resources
  is found in Appendix F of this
  Guide
        Objectives & Targets
        Training & Awareness
        Communication
        Management Review
  Build flexibility into  your organizational  structure.
  Recognize   that    environmental    (and    other)
  management needs will change overtime.

  Communicate to people what their roles are (as well
  as the roles of  others).  One tool for communicating
  these  responsibilities is a  responsibility matrix.
  (See the Tool Kit  in Appendix A for an example of
  such a matrix.)
                Finding Resources

In most cases, developing and maintaining an EMS will
not require large  capital  outlays.   What an  EMS will
require is time.  Many smaller prganizations find they
can  make  effective  use  of  interns or  temporary
employees  to perform potentially time-consuming  EMS
development  tasks  (such  as collecting data, drafting
procedures, etc.).  This allows  in-house personnel to
focus on more complex EMS development tasks.  Also,
look for areas where  environmental management can
support other organizational functions (and vice-versa —
see next page).
ฉ 2001  NSF
    36

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           How Various Functions Can Support Your EMS
Functions
Purchasing
Human Resources
Maintenance
Finance
Engineering
Top Management
Quality
Line Workers
How They Can Help (Possible Roles)
• Develop and implement controls for chemical / other material
purchases
• Define competency requirements and job descriptions for
various EMS roles
• Train temporary workers and contractors; maintain training
records
• Integrate environmental management into reward, discipline
and appraisal systems
• Implement preventive maintenance program for key
equipment
• Support identification of environmental aspects
• Track data on environmental-related costs (such as
resource, material and energy costs, waste disposal costs,
etc.)
• Prepare budgets for environmental management program
• Evaluate economic feasibility of environmental projects
• Consider environmental impacts of new or modified products
and processes
• Identify pollution prevention opportunities
• Communicate importance of EMS throughout organization
• Provide necessary resources
• Track and review EMS performance
• Support document control, records management and
employee training efforts
• Support integration of environmental and quality
management systems
• Provide first-hand knowledge of environmental aspects of
their operations
• Support training for new employees
         For EPA's Performance Track program, organizations must provide
          appropriate incentives for personnel to meet EMS requirements.
                     See Appendix B for more information.
        See the EPA/NSF project report, Implementing an EMS in Community-Based
        Organizations for more ideas on how organizations with limited resources can
        implement an EMS.  Download the report free of charge at www.nsf-isr.org or
        www.epa.gov.
ฉ 2001 NSF
37

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                Capture the Learning: Structure & Responsibility Worksheet
How do we define roles,
responsibilities and authorities for
environmental management now?

Is this process effective?
Who is / should be our EMS
Management Representative? Does
this individual have the necessary
authority to carry out the
responsibilities of this job?
Are our key roles and responsibilities
for environmental management
documented in some manner? If so,
how (e.g., job descriptions,
organizational charts, responsibility
matrix, etc.)?
How are EMS roles and responsibilities
communicated within our
organization?
How do we ensure that adequate
resources have been allocated for
environmental management? How is
this process integrated with our overall
budgeting process?

How are environmental expenditures
tracked?
How will we keep this information up-
to-date?
Our next step on structure and
responsibility is to ...
      ฉ 2001 NSF
38

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              Training. Awareness and Competency

                           Building internal capabilities
  Implementing and
  maintaining an EMS
  involves everyone
    Reasons for
     Training:
     motivation

     awareness

     commitment

     skills/
     capability
     compliance

     performance
    An example of a trainin log
    is provided in the Tool Kit
    (see Appendix A)
        Environmental Aspects
        Legal/Other
        Requirements
        Structure &
        Responsibility
        Operational Control
        Records
Here are two excellent reasons for training employees
about environmental management and your EMS:

  • Every employee can have potential impacts on the
   environment, and

  • Any employee can have  good ideas about how to
   improve environmental management efforts.

Each person and function within your organization can
play  a  role  in environmental management.   For this
reason, your training program should cast a  wide net.
Every employee and manager should be  aware of the
environmental  policy,  the  significant  environmental
impacts of their work activities, key EMS  roles  and
responsibilities, procedures that apply to their work and
the importance of conformance with EMS requirements.
Employees  also  should understand  the   potential
consequences of not  following EMS  requirements
(such as spill, releases, fines or other penalties).

All personnel should receive  appropriate training.  Such
training should be tailored  to  the different  needs of
various   levels  or  functions  in   the  organization.
However,  training  is just one element  of establishing
competence, which is typically based on a combination
of education, training, and experience.  For certain jobs
(particularly   tasks   that   can   cause  significant
environmental impacts), you  should establish  criteria to
measure   the competence  of  individuals performing
those tasks.

Getting Started:

  •  A  critical first step in  developing your training
    program  is assessing  your training  and skill
    needs.   In assessing  these needs, you should
    consider both general and specific needs  (e.g.,
    "What EMS procedures  affect Joe's daily work and
    what  happens if  they  aren't  followed?"   "What
    environmental impacts might Joe's work cause?"
    "What  broader  understanding  of  environmental
    issues and our EMS does Joe need?")

   • Look  at the training you conduct  already, for
    compliance  with  environmental  and health  and
    safety regulations  and other purposes.   You may
    find that your existing training efforts go a lonq way
    towards satisfying  the requirements for the EMS.
    Competence might be established on the basis of
    regulatory-required training, in some instances.
ฉ 2001 NSF
     39

-------
  Milan Screw Products found
  that it could provide a great
  deal of its training during
  "brown bag" lunches, during
  which employees bring their
  lunches, participate in a
  training session, and remain
  "on the clock" for the lunch
  period.
    Key Steps in Developing a Training Program

  Step •/:   Assess training needs & requirements
  Step 2:   Define training objectives
  Step 3:   Select suitable methods and materials
  Step 4:   Prepare training  plan  (who, what, when,
           where, how)
  Step 5:   Conduct training
  Step 6:   Track training (and maintain records)
  Step 7:   Evaluate training effectiveness
  Step 8:   Improve training program (as needed)
   Training Resources

   internal trainers / experts

   consultants

   community colleges

   vendors / suppliers

   customers

   technical / trade /
   business associations

   self-study or study
   groups

   training consortia
   (teaming with other local
   companies)

   computer-based training
Hints:

• Because of the level of effort involved in training, this
  is one EMS  element where you  don't want to start
  from scratch.  Many employees may be qualified on
  the basis of  their experience and previous training.
  (Keep   in  mind  that   all  training   should   be
  documented.) Since some employees might require
  training on how to operate equipment safely, on-the-
  job training  certainly can  play  an important role.
  Computer-based training also may be an  option,
  especially for employees  who spend much of their
  time in the field.

• Plan and schedule training opportunities carefully.
  While  finding enough time for training can  be  a
  challenge,  you  might  find creative ways to  make
  "more  time"  (see  "tip",  above  left).   Use   safety
  meetings, staff meetings,  and tool  box meetings to
  provide training and reinforce key messages.

• New  employees  can pose a   significant  training
  challenge.   Consider  developing  an  EMS  training
  package for  new employee  orientation.   Even
  better,  videotape one  of your current  EMS training
  courses to show to new employees.

• In reviewing training needs, dpn't forget to consider
  the  qualifications  and   training   needs  of  your
  environmental   manager   and   your  trainers.
  Professional   certification   programs  may   be
  appropriate for certain functions.

• If the  organization  uses  temporary  or contract
  workers, assess their training needs as well.

• Factor EMS skills requirements into your recruiting,
  selection,   and   new   employee   orientation
  processes.
ฉ 2001 NSF
     40

-------
        When Training
      Might Be Needed:

     New employee is hired

     Employee is transferred to a
     new job

     Individual doesn't follow
     procedure / instruction

     Procedures are changed

     New process, material or
     equipment is  introduces
     Company changes objectives
     and/or targets
     New regulation affects
     organization's activities

     Job performance must be
     improved
 Establishing competency for various tasks can be a
challenge.   Competency criteria  for jobs that  can
cause significant environmental impacts should be as
objective as possible.

One informal method for assessing competency is to
question employees in critical functions as  to how
they perform  various  aspects  of their jobs (e.g.,
"Show me how you..."). Use responses to determine
whether  they  have  the   requisite   skills   and
understanding  to perform the job safely.  This  can
help you gauge whether additional training might be
needed.

Consider visual "job aids" to supplement training or
help establish  competence.   Examples of job aids
include  written or pictorial job procedures, decision
tables or flow charts posted at the workstation.

Finally,  some organizations have been  successful in
blending  environmental awareness training into
existing safety training  programs.   This  can  be
particularly  effective   where  safety   training  is
mandated (i.e., by regulation or other organizational
requirements)  and has strong management support.
                    A Few Thoughts About Adult Learning

   Adults need the opportunity to integrate new ideas with what they already know.

   Information that conflicts  sharply with existing beliefs or has  little  conceptual
   overlap with what is already known is acquired more slowly.

   Adults prefer self-directed learning and want to  have a hand in shaping the
   training program.

   Adults have expectations.  It is important to clarify these up-front.

   Adults prefer active participation to straight lecture.
               - Adapted from "Adults Learning: What Do We Know For Sure"
                                            (Training Magazine, June 1995)
                                     J
    For EPA's Performance Track, organizations must provide specific training for
 employees whose responsibilities relate directly to achieving objectives and targets
                               and legal compliance.
                       See Appendix B for more information.
ฉ 2001 NSF
   41

-------
        Capture the Learning: Training, Awareness & Competence Worksheet
Do we have an existing process for
environmental training?

If so, does that process need to be
revised?  In whatway(s)?
What types of training do we provide
now (e.g., new employee orientation,
contractor training, safety training)?

How would EMS-related training fit with
our existing training program?
Who is responsible for training
now? Who else might need to be
involved within our organization?
How do we determine training needs
now?  (List methods used) Are these
processes effective?
Who is responsible for ensuring that
employees receive appropriate
training? How do we track training to
ensure we are on target?
How do we evaluate training
effectiveness?  (List methods used,
such as course evaluation, post-
training testing, behavior observation)
How do we establish competency,
where needed? (List methods used,
such as professional certifications)

What are the key job functions and
activities where we need to ensure
environmental competency?
Our next step on training,
awareness & competence is to ...
   ฉ 2001 NSF
42

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                             Communications

                        Maintaining the flow of information
  Consider
  communication
  strategies for:

  0 neighbors
  0 community groups
  0 other interest groups
  0 local officials
  0 regulatory agencies
  0 emergency
     responders
 Pfizer Global Research &
 Development (formerly
 Warner-Lambert Parke-
 Davis) has hosted local
 community leaders, state
 agencies, and federal
 agencies, to share its
 environmental activities and
 programs and to obtain
 feedback.
The  importance  of employee involvement in developing
and implementing your EMS has been discussed earlier.
In addition, there may be parties with an  interest in your
environmental  performance  and  management  efforts
outside   the   organization.     Effective   environmental
management   requires effective communications,  both
internally and externally.

Effective communications will help you:
 • motivate your workforce;
 • gain acceptance for your plans and efforts;
 • explain  your environmental policy and  EMS and how
   they relate to the overall organizational vision;
 • ensure understanding of roles and expectations;
 • demonstrate management commitment;
 • monitor and evaluate performance; and,
 • identify potential system improvements.

Effective internal communication requires mechanisms for
information to  flow  top-down,   bottom-up and  across
functional lines.  Since employees are on the "front lines,"
they can be an  excellent  source of information,  issues,
concerns and ideas.

Proactive, two way communication with external parties is
also important for an effective environmental management
system. Taking steps to obtain the views of these
stakeholders, which can include neighbors, customers,
community  groups,  and regulators, will help you better
understand how your organization is perceived by others.
These stakeholders can also bring important
environmental issues to your attention that should be
addressed in your EMS. Your should also condiser ways
to get specific advice from these stakeholders when
developing  critical elements of your EMS such as setting
objectives and targets. Involving  these parties, however,
does not_mean you should cede control of your EMS to
them, but rather use their input to make your EMS
stronger and more responsive to  community concerns.
Doing so will usually provide long-term benefits to your
organization.

Thus, an effective EMS should include procedures for:
 • communicating   internally   (between   levels   and
   functions within the organization), and
  • soliciting, receiving, documenting and  responding  to
   external communications.
ฉ 2001  NSF
       43

-------
 Milan Screw Products' staff
 interviewed neighbors,
 customers, suppliers, and
 employees' family members to
 obtain the views of external
 parties.

 A sample procedure for
 external communication is
 provided in the Tool Kit (see
 Appendix A)
      Getting Started:

      The first step in designing a communications program  is
      determining your key audiences.  Make a list of internal
      and external audiences.

      Once you have identified the audiences, determine  what
      you need to communicate to them. (What do they need to
      know  about your products,  operations  or management
      efforts? What are their concerns?)
      Next, decide how you can best reach them.  Appropriate
      communication  methods  might vary from  audience to
      audience.  Start by looking at your existing  methods for
      communicating, both  internally  and  externally.   These
      might include:
    Environmental Policy
    Environmental
    Aspects
    Objectives & Targets
    Structure &
    Responsibility
    Monitoring &
    Measurement
    Management Review
                                   Internal Methods
                                   •  newsletters
                                   •  intranet
                                   •  staff meetings
                                   •  employee meetings
                                   •  bulletin boards
                                   •  brown bag lunches
                                   •  training	
                                 External Methods
                                 •  open houses
                                 •  focus or advisory groups
                                 •  web site ore-mail list
                                 •  press releases
                                 •  annual reports
                                 •  advertising
                                 •  informal discussions
Hints:
•  Determine how proactive your external communications strategy
  should  be.  Select an approach  that fits your organization's
  culture  and strategy.  Consider,  for example, whether reporting
  on environmental  performance and progress might give you a
  competitive edge.

•  While a proactive external communications program may require
  some  resources,  many  organizations find  that  a  proactive
  communication strategy can be beneficial.  Weigh the costs and
  benefits for yourself, but keep in  mind that you might have many
  interested audiences.

•  In communicating with employees, it is helpful to explain not only
  what they need to do but also  why they need to  do it.   For
  example, when describing a requirement based on a regulation,
  explain the purpose behind the rule and why it is important.  Also,
  make a clear connection  between the requirement  and how it
  applies to each person's job.

•  Keep the message simple, clear, concise, and accurate.

•  Managing  responses to external inquiries  does not  have to  be
  burdensome.  Use a simple method, such  as stapling an inquiry
  to its written response and  then filing them together.  The key is
  to be able  to demonstrate that the organization has a process  for
  gathering and  responding to external inquiries.
ฉ 2001  NSF
             44

-------
                               POLLUTION PREVENTION **
                                and Public Involvement

Motorola has conducted Household Waste Electronics Recycling Days for local residents.
Working in collaboration with local solid waste authorities, the Company has collected for
recycle a variety of home electronic and entertainment equipment, small appliances and other
products. At one of these events, over 21 tons of materials were collected and over 95% of
these materials were recycled.
       For EPA's Performance Track, organizations must commit to public outreach and
       performance reporting. Specifically, participating organizations must prepare an
      annual report on their EMS, a summary of progress on performance commitments,
                           and of their public outreach activities.
                           See Appendix B for more information.
                            The community as part of the solution.
     In an effort to involve stakeholders in the EMS process the Town of Londonderry, NH and
     the City of Lowell, MA engaged residents to collect information pertaining to environmental
     issues that affect their communities. For example, the Town of Londonderry, NH in
     conjunction with its household hazardous waste collection day, asked residents to complete
     a survey to prioritize community related environmental issues. The residents identified the
     fast pace at which the small community is growing as their top-priority issue. The City of
     Lowell, MA's wastewater treatment plant asked local residents to assist with efforts to
     address the plant's odor issues. A number of residents throughout the surrounding area
     recorded weather information on days the odor was prevalent. This information identified
     odor patterns which would aid the City's efforts to identify a solution to this problem.
     ฉ 2001 NSF
45

-------
                 Capture the Learning: Communications Worksheet
Who are our key external
stakeholders?

How were these stakeholders
identified?
With regard to our organization, what
are the key concerns of these
stakeholders?

How do we know this?
What community outreach efforts
are we making now (or have we made
in the recent past)?

How successful have these efforts
been?
What methods do we use for external
communications? Which appear to be
the most effective?

Who has primary responsibility for
external communications?
How do we gather and analyze
information to be communicated?

Who has responsibility for this?
How do we communicate internally
(as well as with our suppliers and
contractors)? What processes do we
have to respond to internal inquiries,
concerns and suggestions?

How effective are these methods?
Our next step on communication
is to...
    ฉ 2001 NSF
46

-------
    Rule of thumb:

  Try to keep the EMS
     description
     document (or
  manual) to no more
  than one page per
     EMS element
ฃ Easy to read and understand
          equals
     easy to implement
                          EMS Documentation

                Describing the EMS and how the pieces fit together
To ensure that your EMS is well understood and operating
as designed, you must provide adequate information to the
people doing the work. There also may be external parties
that want to understand how your EMS is designed and
implemented,  such  as customers,  regulators,  lending
institutions,  registrars and the public. For these reasons,
the various  processes that make up your EMS should  be
documented.

The EMS Manual (or description document)
A  "road map"  or  description  that summarizes  how the
pieces of the EMS fit together can be a very useful tool.
This roadmap generally takes the form of an EMS manual.

An  EMS manual  is  a series  of explanations of the
processes your organization implements to conform to the
EMS  criteria (such as  the  elements  discussed in the
Guide).   While you  don't need  to  maintain  a  single
"manual" that contains all of your EMS documentation, you
should maintain a summary of the EMS that:

• describes  the system's core elements (and  how the
 elements relate to each other), and
• provides direction to related documentation.
        Figure 8:
    Hierarchy of EMS
     Documentation
       EMS Manual
        Procedures
   Forms, Drawings, etc.
Other EMS Documentation
In addition to the EMS manual,  your organization should
maintain other documentation of its EMS.

First, you should document the  processes used tp  meet
the EMS criteria.   (For example, "How do we  identify
environmental  aspects?"    "How  do  we  implement
corrective actions? )  This documentation generally takes
the form of system procedures. In addition, you might
maintain area-or activity-specific documentation (such as
work instructions) that instructs employees on how to carry
out certain operations or activities.

EMS documentation is related  to (but  not the same as)
EMS records.    EMS  documentation  describes  what
your system consists of (i.e., what you do and how you do
it), while EMS records demonstrate that you are doing
what the documentation said you would do.  Document
control and records  management are discussed later in
this Guide.

One way to think about your EMS documentation is to use
the figure  shown at left, which also can be applied to
quality or other management system documents.
 ฉ 2001 NSF
      47

-------
 Use flow charts or other
 graphics where they help
 explain the linkages from one
 system element to another
      Environmental Policy

      Environmental
      Management
      Programs
      Document Control
      Operational Control
You can maintain EMS documentation either on paper or
electronically.   There  may be  some  advantages to
maintaining  documents electronically, such  as ease of
updating, controlling access, and ensuring that all readers
are using the most up-to-date versions of documents.


Hints:

•  Keep EMS documentation simple.  Choose  a format
   that  works best  for your organization.  Your manual
   does not need to describe every  detail of your EMS.
   Instead, the manual can provide  references to other
   documents or procedures.

•  Use  the  results  of your preliminary assessment to
   prepare your EMS documentation.  In  the  course of
   conducting this assessment, you should  have collected
   or prepared useful material on how your  organization
   satisfies  the selected  EMS criteria.   The  box below
   illustrates what constitutes EMS  documentation.

•  The  usefulness of your EMS manual can be improved
   by including the organization's mission statement, vision
   or guiding principles (if these exist). These will improve
   understanding of the organization  and  how the EMS
   supports its overall goals.

•  An EMS manual can be a useful tool for explaining your
   EMS to  new employees,  customers and  others.   A
   sample outline for an  EMS manual is provided in  the
   Tool Kit  (see Appendix A).

•  EMS documentation  should  be updated  as needed,
   based on any system  improvements you put in place.
   However,  if you put too much detail in an EMS manual,
   you  might need to update the  manual frequently (see
   first hint, above).
               What Constitutes EMS Documentation? Consider the following:

            your environmental policy

            your organizational structure and key responsibilities

            a description or summary of how your organization satisfies EMS requirements
            (e.g., "How do we identify environmental aspects?". "How do we control
            documents?" How do we comply with legal requirements?")

          system-level procedures (e.g., procedure for corrective action)

            activity- or process-specific procedures /work instructions

            other EMS-related documents (such as emergency response plans, training
            plans, etc.)
ฉ 2001 NSF
       48

-------
               Capture the Learning: EMS Documentation Worksheet
Do we have existing documentation
of our EMS?

If yes, how is this EMS documentation
maintained (electronically?  In paper
form?)
Who is responsible for maintaining
EMS documentation within our
organization?
Do we have an EMS manual or other
summary document that describes the
key elements of the EMS?

If so, does this document describe the
linkages among system elements?
What does our EMS documentation
consist of? (List components such as
environmental policy, EMS manual,
activity-level procedures or work
instructions, emergency plans, etc.)
Is our EMS documentation integrated
with other organizational
documentation (such as human
resource plans or quality procedures)?

If so, how do we ensure proper
coordination between environmental
and these other functions?
How will we keep our EMS
documentation up-to-date?
Our next step on EMS
documentation is to ...
   ฉ 2001 NSF
49

-------
                            Document Control

                 Ensuring that everyone works with the right tools
   Suggested elements
   of document control

  0 issue / revision date
  0 effective date
  0 approval
     (i.e., signature)
  0 revision number
  0 document number
     (or other identifier
  0 copy number

  0 cross references
       Document control
       should address:
  Preparation
  Issuance / distribution
  Revision
  Periodic review
  Disposition of obsolete
  documents
People  in   your  organization  probably  use  various
documents   (procedures,   work  instructions,   forms,
drawings and the  like) as they perform their duties.  To
ensure that personnel are consistently performing  their
jobs in the right way, the organization must provide them
with the proper tools. In the context of an EMS, the "tools"
needed  are   correct  and   up-to-date   procedures,
instructions and other documents. Without a mechanism
to manage these EMS documents, the organization cannot
be sure that people are working with the right tools.

To ensure that everyone is working with the proper EMS
documents, your organization should  have a procedure
that describes  how  such  documents  are  controlled.
Implementation of this procedure should ensure that:

•  EMS documents can be located (we know where to
  find them),

•  they are periodically  reviewed (we check to make sure
  they are still valid),

•  current versions are available where needed (we make
  sure the right people have access to them), and

•  obsolete documents are removed (people don't use the
  wrong documents by mistake).

Your  procedure  should designate  responsibility  and
authority for  preparing documents, making  changes  to
them and keeping them up-to-date.  In other words, you
need to make it clear   who can actually  generate and
change documents and the process for doing so.
   Key Questions:

Is everyone working with
    the same set of
     documents?

  Do people who need
  access have access?
Getting Started:

• EMS document control requirements are almost  a
  mirror  image  of  the   ISO  9001   requirements.
  Organizations that have or are developing an ISO 9001
  management system can enjoy some advantages here.

• Even if your organization doesn't have  an ISO 9001
  system, you might be  better off than you think.  Your
  organization probably has  document controls  in place
  for other purposes (such as finance, human resources
  or purchasing).  Assess how well these controls work
  and if they can be adapted for your EMS.
 ฉ 2001 NSF
      50

-------
        EMS Documentation
        Operational Control
        Records
  The Tool Kit contains a sample
  index of EMS-controlled
  documents (see Appendix A).
Hints:

• Don't make  your procedure more complicated than it
  needs  to be.  While larger organizations often  have
  complex  processes  for  document  control,  smaller
  organizations can use simpler processes.

• Limiting distribution can make the job easier.  Could
  everyone  have  access  to  one  or  a  few copies?
  Determine how many  copies you really need and
  where they should be maintained for ease of access.

• If  the  people that  need  access to  documents are
  connected to a local area network or have  access to
  the organization's internal web site, consider using a
  paperless system.  Such systems can facilitate control
  and  revision  of documents considerably.  There also
  are a number of commercial software packages that
  can simplify the document control effort.

• Prepare a  document control index that shows  all of
  your EMS documents and the history  of their revision.
  Include this  index  in your manual.   Also,  if multiple
  paper copies of documents are available at the facility,
  prepare a distribution list, showing who has each copy
  and where the copies are located.

• As your procedures or other  documents are revised,
  highlight the changes (by underlining, boldface,  etc.).
  This will make it easier for readers to find the changes.
                 What EMS documents should be controlled?
                            Consider the following:

                 Environmental policy
                 Objectives and targets
                 Roles, responsibilities and authorities
                 EMS description document ("manual")
                 System-level procedures
                 Process- or activity-level procedures /work instructions
                 Related plans (such as emergency response plans)
ฉ 2001 NSF
      51

-------
                Capture the Learning:  Document Control Worksheet
Do we have an existing process for
controlling EMS documents?

If yes, does that process need to be
revised? In what way?
Who needs to be involved in this
process within our organization?
Who needs access to controlled
copies of EMS documents? How do
we ensure that they have access?
How do we ensure that EMS
documents are periodically reviewed
and updated as necessary?
Who has authority to generate new
documents or modify existing ones?
How is this process managed?
How are users alerted to the
existence of new EMS documents or
revisions to existing ones?
How do we ensure that obsolete
documents are not used?
Is our EMS document control process
integrated with other organizational
functions (such as quality)?

If so, how do we ensure proper
coordination between environmental
and other functions?
Our next step on document
control is to...
    ฉ 2001 NSF
52

-------
                            Operational  Control

          Building environmental performance into operations and activities
          Figure 9
                   Significant
                  Environmental
Environmental

   Policy
        Operational
          Controls
                 Legal & Other
                 Requirements
 Objectives &
   Targets
To  ensure that you  satisfy  the  commitments in ypur
environmental  policy,  certain  operations  and activities
must  be controlled.  Where operations  or activities are
complex and/or the potential  environmental impacts are
significant,   controls    should    include   documented
procedures.   Procedures can  help your organization to
manage its significant environmental aspe9ts,  ensure
regulatory  compliance  and  achieve  environmental
objectives.  Procedures can also play a prominent role in
employee training.

Documented procedures should be established where the
absence of procedures could lead to deviations from the
environmental  policy  (including the  commitments to
compliance  and  pollution  prevention)  or  from  your
objectives and targets.  Determining which operations
should be covered by documented procedures and how
those operations should be controlled is  a  critical step in
designing an effective EMS. Keep in mind  that you might
need  operational controls in order to manage significant
aspects or legal requirements,  regardless of whether you
established objectives and targets for each of them.

In determining which operations and activities need to be
controlled, look beyond  routine  production  or service.
Activities such as equipment maintenance, management
of  on-site   contractors,   and  services  provided  by
suppliers or vendors  could  affect your  organization's
environmental performance significantly.
  Examples of activities and
operations that might require
    operational controls:

0 management / disposal of
   wastes

0 approval of new chemicals

0 storage & handling of raw
   materials and chemicals

0 equipment servicing

0 wastewater treatment

0 operation of paint line

0 operation of plating system

   management of contractors
                                     Getting Started:

                                     • Start by  looking at the environmental aspects and
                                      legal requirements that you identified earlier.  Identify
                                      the operations and other activities  that are related to
                                      these significant impacts  and legal  requirements,  then
                                      consider  what types of controls might  be needed  to
                                      manage these aspects and compliance requirements. If
                                      you  have flow  charts  of these processes (or can
                                      develop them), this may simplify the  identification of the
                                      process steps where  some type of control might be
                                      appropriate.

                                     • Prepare draft  procedures and  review them  with  the
                                      people who will need to implement them.  This will help
                                      to  ensure that the procedures are appropriate, realistic
                                      and practical.  Don't be surprised if reviewers come up
                                      with a simpler way to achieve the same results!
ฉ 2001 NSF
                                         53

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                                        Hints:

                                        • Review procedures you already have in place to comply
                                          with environmental and health  & safety  regulations.
                                          Some of these may be adequate  to control significant
                                          impacts (or could be modified to do so). Develop a chart
                                          to keep track of what controls are needed, such as:
Operation or
Activity
1
2
3
4
Procedure is
needed (none
exists)
X



Procedure
exists, but is not
documented

X
X

Procedure
exists and is
documented



X
No procedure
is needed




                              Rules of Thumb: In general, the  more highly skilled and trained
                              your employees are, the less critical documented work instructions
                              become.  As work  becomes more  complex or as the potential
                              impact on the environment increases, the more important these
                              documented work instruction will be.

                              Once you have identified operations that require control, consider
                              what kinds of maintenance and  calibration may be appropriate.
                              Maintenance   of   equipment   that   could   have   significant
                              environmental  impacts  or result  in  non-compliance should  be
                              considered, and the need for a plan to manage  such maintenance
                              should  not be overlooked.  An elaborate  preventive  or predictive
                              maintenance program is not  needed in all cases.  Assess your
                              existing maintenance program and its effectiveness before making
                              significant changes.
/Factors that could affect
 the need for documented
       procedures
     risk of activity

     complexity of activity /
     methods

     degree of supervision

     skills/training of
     workforce
          Hints on Writing Procedures


Understand  the existing process.  Start  with  a flow
chart, if one is available. Build on informal procedures
where possible.
Focus on steps needed for consistent implementation.
Use a consistent format and approach.
Review draft procedures with employees that will have
to implement them.  (Better yet,  enlist employees to
help write them.)
Keep procedures simple and concise.  Excessive detail
does not provide  better control and can  confuse the
user.
     ฉ 2001 NSF
     54

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                             Some of your identified environmental aspects may relate
                             to the chemicals,  raw  materials, or  other goods and
                             services you obtain from  vendors/suppliers.   Likewise,
                             the  activities  of your contractors  can  affect  your
                             environmental   performance.      Communicate   your
                             expectations (including any relevant  procedures) to these
                             business partners.
       Policy
       Environmental
       Aspects
       Legal/Other
       Requirements
       Objectives &
       Targets
       Training
       Monitoring &
       Measurement
While  the  development  of  procedures  can  be  time-
consuming, organizations have come up with  creative
ways to reduce the burden. For example, consider using a
college  intern  or  temporary   employee  to   interview
employees  "on  the  line",  collecting information on what
employees do and how they do it.
If your organization uses a "work team" concept, ask the
work teams to draft procedures for their work areas (or to
modify existing procedures for EMS purposes).
                          POLLUTION PREVENTION
         Rochester Midland Corporation, a manufacturer of cleaning and
         other chemical products, formed a partnership with a cleaning
         contractor that uses Rochester Midland's products, the owners of a
         building where the products are used, and building tenants, to lessen
         the risks associated with cleaning products. The partners began by
         developing common goals, identifying alternative cleaning products and
         processes, and identifying opportunities to reduce risks to building
         occupants and cleaning staff. Over a two-month period, they were able
         to: reduce chemical exposures; improve tenant satisfaction; improve
         communication, awareness,  and training; achieve a 50% reduction in
         cleaning products; and achieve measurable cost savings.
   For EPA's Performance Track program, organizations must have operation and
 maintenance programs for equipment and operations that relate to legal compliance
                      and significant environmental aspects.
                      See Appendix B for more information.
ฉ 2001 NSF
          55

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                Capture the Learning: Operational Controls Worksheet
Have we identified operations and
activities associated with significant
environmental aspects, legal
requirements and environmental
objectives?

If not how will this be accomplished?
Who should be involved?
What operations and activities are
associated with significant
environmental aspects?
What operations and activities are
associated with legal requirements?
What operations and activities are
associated with environmental
objectives and targets?
How are the above operations and
activities controlled?  (list methods)
How do we know whether these
controls are adequate (i.e., to
manage significant aspects, to ensure
compliance, to achieve objectives?
How do we train employees and
contractors on relevant operating
controls?
If new controls are needed (or
existing ones need to be revised),
what is our process for doing so?

Who needs to be involved in this
process?	
Our next step on operational
control is to...
    ฉ 2001 NSF
56

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               Emergency Preparedness and Response

                     Minimizing the impacts of uncontrolled events
^^^^—a


 I
Don't think only about
response - focus on how
to prevent accidents in the
first place
     Review prior accidents
     and incidents as one
     guide to where future
     incidents may occur.
Despite an organization's best efforts, the possibility of
accidents and other emergency situations still exists.
Effective  preparation  and  response  can  reduce
injuries, prevent  or minimize environmental  impacts,
protect employees and neighbors, reduce asset losses
and minimize downtime.

An effective emergency preparedness and response
program should include provisions for:

•  assessing  the  potential  for  accidents  and
  emergencies;

•  preventing    incidents   and   their    associated
  environmental  impacts;

•  plans / procedures for responding to incidents;

•  periodic testing of emergency plans / procedures;
  and,

•  mitigating impacts associated with these incidents.

Consistent with the focus on continual improvement, it
is  important to  review your  emergency response
performance after an incident has occurred.  Use this
review to determine if more training is needed  or if
emergency plans / procedures should be revised.
      USEFUL INFORMATION
           SOURCES:

     • Material safety data sheets
     • Plant layout
     • Process flow diagrams
     • Engineering drawings
     • Design codes and
       standards
     • Specifications on safety
       systems (alarms,
       sprinklers, etc.)
                                Getting Started:

                                •  This is another area where you should not have to start
                                  from scratch.  Several environmental and  health and
                                  safety regulatory programs require emergency  plans
                                  and/or procedures.  Look at what you have now and
                                  assess how well it satisfies the items discussed above.

                                •  Two planning components  that many  organizations
                                  overlook are how they  identify the  potential for
                                  accidents and emergencies  and how they  mitigate
                                  the  impacts of  such incideriTs"  A cross-functional
                                  team   (with  representatives  from   engineering,
                                  maintenance and environmental health  & safety,  for
                                  example) can identify most potential emergencies by
                                  asking  a  series  of  "what  if" questions  related to
                                  hazardous   materials,   activities,   and  processes
                                  employed at the site.  In addition to normal operations,
                                  the team should consider start-up and shutdown of
                                  process equipment,  and other abnormal operating
                                  conditions.
   ฉ 2001 NSF
                                    57

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        Environmental Aspects
        Legal/Other
        Requirements
        Training & Awareness
        Communication
        Document Control
 Ask  yourself:   Does   everyone  (including   new
employees) know what to dp in an emergency?  How
would contractors or site visitors know what to do in an
emergency situation?
Communicate with local officials (fire  department,
hospital, etc.) about potential emergencies at your site
and how they can support your response efforts.
                                   Hints:
                                     Mock  drills  can be  an excellent way to  reinforce
                                     training and get feedback on the effectiveness of your
                                     plans / procedures.
                                     Post copies of the plan (or at least  critical contact
                                     names and  phone numbers) around  the  site and
                                     especially in areas where high hazards exist.  Include
                                     phone    numbers   for   your  on-site   emergency
                                     coordinator, local fire department, local police, hospitaf,
                                     rescue squad, and others as appropriate.
                                     Revise and improve  your plan  as  you learn  from
                                     mock drills, training or actual emergencies.
         Checklist for Emergency Preparedness and Response Plans
Does your plan describe the following:
0 potential emergency situations (such as fires, explosions, spills or releases of hazardous
   materials, and natural disasters)?
0 hazardous materials used on-site (and their locations)?
0 key organizational responsibilities (including emergency coordinator)?
0 arrangements with local emergency support providers?
0 emergency response procedures, including emergency communication procedures?
0 locations and types of emergency response equipment?
0 maintenance of emergency response equipment?
0 training / testing of personnel, including the on-site emergency response team (if
   applicable)?
0 testing of alarm / public address systems?
0 evacuation  routes and exits (map), and assembly points?
ฉ 2001 NSF
  58

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       Capture the Learning:  Emergency Preparedness & Response Worksheet
Have we reviewed our operations
and activities for potential emergency
situations?

If not how will this be accomplished?
Who should be involved?
Do our existing emergency plans
describe how we will prevent incidents
and associated environmental
impacts?

If not how will this be accomplished?
Who should be involved?
Have we trained personnel on their
roles and responsibilities during
emergencies?
What emergency equipment do we
maintain? How do we know that this
equipment is adequate for our needs?
How do contractors and other
visitors know what to do in an
emergency situation?
When was our last emergency drill? Is
there a plan / schedule for conducting
future drills?
Have we established a feedback loop
so we can learn from our experiences?
Our next step on emergency
preparedness & response is to ...
    ฉ 2001 NSF
59

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                        Monitoring and Measurement

                       Assessing how well the system is performing
  "If you can't
 measure it, you
can't manage it."
               Peter Drucker
         Management Expert
     Which operations and
      activities can have
    significant environmental
          impacts?
       What are the key
    characteristics of these
    operations and activities?
     How do we measure
     these characteristics?
]
    /    Attributes of effective
       measurement programs

       J simple

       I flexible

        consistent
        ongoing

        produce reliable data

        communicate results
             An EMS without effective  monitoring and measurement
             processes is like driving at night without the headlights on
             —you know that you are moving but you can't tell where
             you are going!  Monitoring  and measurement enables an
             organization to:

             •  evaluate environmental performance;
             •  analyze root causes of  problems;
             •  assess compliance with legal requirements;
             •  identify areas requiring corrective action, and,
             •  improve performance and increase efficiency

             In  short,  monitoring  helps  you  manage  your
             organization better.   Pollution prevention  and  other
             strategic opportunities are  identified more readily when
             current and reliable data is available.
Your organization should develop procedures to:

• monitor  key  characteristics  of  operations  and
  activities  that  can  have  significant environmental
  impacts and/or compliance consequences;
• track  performance  (including  your  progress  in
  achieving objectives and targets);
• calibrate and maintain monitoring equipment; and,
• through  internal audits,  periodically  evaluate your
  compliance with applicable laws and regulations.
             Getting Started:

             •  Monitoring and measuring can be a resource-intensive
                effort.  One of the most important steps you can take is
                to  clearly define  your needs.   While  collecting
                meaningful information is clearly important, resist the
                urge to collect data "for data's sake."

             •  Review  the  kinds  of monitoring  you  do  now  for
                regulatory compliance and other purposes (such as
                quality or health and safety  management).  How well
                does this serve your EMS purposes? What additional
                monitoring or measuring might be needed?

             •  You can start with a relatively simple monitoring and
                measurement process, then build on  it as you gain
                experience with your EMS.
    ฉ 2001 NSF
                   60

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  EPA policies provide
  incentives for effective
  compliance management
  programs. See "Incentives for
  Self-Policing: Discovery,
  Disclosure,  Correction and
  Prevention of Violations"
  (http://es. epa.go v/oeca/finalpo
  lstate.pdf) and "Small
  Business Compliance Policy"
  (http://es. epa.gov/oeca/sbcp
  2000.pdf)
  Employees should have a
  mechanism to report
  regulatory violations (or other
  EMS issues)  without fear of
  retaliation by their employer
  Focus on things that you
  can do something about
Hints:
• Monitoring  key   process   characteristics:   Many
  management theorists endorse the concept of the 'Vital
  feW — that is, that a limited number of factors can have
  a substantial impact on the outcome of a process.  The
  key is to figure out what those factors are and how to
  measure  them.   Process  mapping  can  help  you
  determine what those factors might be.

• Most effective  environmental  measurement systems
  use a combination of process and outcome measures.
  Outcome  measures  look at  results  of a process  or
  activity, such as the  amount of waste generated or the
  number of spills that took place.  Process  measures
  look at "upstream" factors, such as the amount of paint
  used per  unit of product or the number of employees
  trained on a topic.  Select a combination of process and
  outcome measures that are right for your organization.

• Equipment calibration:  Identify process  equipment
  and  activities  that  truly affect  your  environmental
  performance.  As  a starting point, look at those  key
  process characteristics you identified earlier.  Some
  organizations place critical monitoring equipment under
  a   special  calibration   and   preventive  maintenance
  program.  This  can help to ensure accurate monitoring
  and make employees aware of which instruments  are
  most critical for  environmental  monitoring  purposes.
  Some organizations find it  is  more  cost-effective  to
  subcontract calibration and maintenance  of monitoring
  equipment than to perform these functions internally.

• Regulatory compliance: Determining your compliance
  status on a regular basis is very important. You should
  have a procedure  to systematically  identify, correct,
  and  prevent   violations.    Effectiveness   of   the
  compliance assessment process should be considered
  during EMS management review.   EPA encourages
  "systematic discovery" of regulatory violations, which
  means    detecting   potential   violations    through
  environmental  audits   or compliance   management
  systems  that  show  due  diligence  in  preventing,
  detecting and correcting violations.

. Operational performance: Consider what information
  you  will   need to  determine  if  the  company  is
  implementing operational controls as intended.   The
  example on Page 62 illustrates the relationship among
  monitoring and  measurement,  operational controls and
  significant environmental aspects.

. Progress on meeting objectives: You should measure
  progress  on achieving  objectives and targets  on a
  regular basis and  communicate  the results of such
  measurement  to  top   management.    To   measure
  progress  in meeting  objectives,  select appropriate
  performance indicators (see below).
ฉ 2001 NSF
      61

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            Environmental Aspects
            Legal/Other
            Requirements
            Objectives & Targets
            Operational Control
            Corrective Action
            Management Review
..vlii
kg_ The value of periodic monitoring:

   St. Joseph's Mercy Hospital
   noticed an increase in its
   discharge of silver to the local
   wastewater treatment plant. They
   investigated what had changed at
   the Hospital and found that a new
   x-ray processor had been installed
   without a silver recovery system.
   Once the recovery system was
   installed, silver discharge levels
   returned to permitted levels.
Selecting  performance  indicators:  Performance
indicators can  help you  to understand how well your
EMS is working.  Start by identifying a few performance
indicators that are:
  - simple and understandable;
  - objective;
  - measurable; and
  - relevant to what your organization is  trying to
    achieve (i.e., its objectives and targets)

 Data collected on performance indicators can  be quite
 helpful  during  management  reviews.   So,  select
 indicators that  will provide top management  with the
 information it needs to make decisions about the EMS.

 Make sure you can commit the necessary resources
 to track performance information over time.  It is OK to
 start small and build over time as you gain experience
 in evaluating your performance.  Keep in mind that no
 single measurement will tell your organization how it
 is doing in the environmental area.

  Communicating performance: People respond  best
  to  information  that is  meaningful  to "their world."
  Putting  environmental information in  a form that is
  relevant to their function increases the likelihood
  they will act on the  information.  Be sure to  link your
  measurement program  with  your communications
  program and  other elements of  the  EMS (such as
  management reviews, as discussed later).

  Compliance auditing  guidance: The USEPA  has
  prepared  guidance documents  and  protocols for
  conducting environmental compliance audits under a
  number  of its  regulatory  programs.   For more
  information,   check   the   EPA   web    site   at
  www.epa.gov/oeca/index.html.
                               POLLUTION PREVENTION **

          A Pitney Bowes Inc. facility formed a Zero Discharge Task Team to design
          projects to reduce emissions over a five-year period.  Wastes were ranked
          ordered in terms of their potential risks to the environment and employee
          safety. Those with high rankings were evaluated on a priority basis.
          Through the implementation of many projects, the facility has reduced
          hazardous waste generation  by 69%, EPCRA 313 air emissions by 98%
          and treated wastewater by 93%. Projects included finding substitutes for
          parts cleaning and degreasing, replacement of all cyanide processes, and
          installation  of fume scrubbers on plating lines, among others.
     ฉ 2001 NSF
    62

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                                       Figure 10:
          Linking Monitoring Processes to Operational Controls:  One Example
Operation with
  Significant
Environmental
   Aspect

Surface
Coating
Operation

(significant
aspect is VOC
emissions)
 Liquid
 Waste
 Storage

 (significant
 aspect is
 potential for
 spills)
Key Characteristics
Operational of Operation
Controls or Activity
• Approved list 	 ^.
of coatings
• Coating work — ^
instruction
• Permit report — ^
procedure
• Generator — ^
• procedure
• Storage — ^
area procedure
• Type of 	 ^.
coating
• Rate of — ^
application
• Frequency — ^-
of
application
• Emissions — ^
ofVOCs
• Use of proper — ^
containers
• Segregation — ^
of
incompatibles
• Availability of — ^
spill equipment
Monitoring or
Measurement
Methods
• Compare to —
approved list
• Measure —
quantity applied
• Use coating —
log book
• Calculate —
based on use
• Inspections of —
storage area
• Inspections of —
storage area
• Inspections of —
storage area
                                   Equipment
                                   Calibration
                                     Needs
                                    None



                                    Flow meter

                                    None
                                                                               Flow meter
                                    None

                                    None



                                    None
                        Examples of EMS Performance Indicators

                      Pounds of VOC emitted per unit of production

                      Pounds of hazardous waste generated per year

                      Percentage of employees completing environmental training

                      Average time for resolving nonconformities

                      Energy use per unit of production

                      Percentage of solid waste recycled / reused
     ฉ 2001 NSF
63

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           Capture the Learning:  Monitoring and Measurement Worksheet
Have we identified operations and
activities associated with significant
environmental aspects, legal
requirements and environmental
objectives?  If, not how will this be
accomplished?
What type(s) of monitoring and
measurement do we need to ensure
that operational controls are being
implemented correctly?
What type(s) of monitoring and
measurement do we need to ensure
that we are complying with applicable
legal requirements?
What type(s) of monitoring and
measurement do we need to ensure
that we are achieving our
environmental objectives & targets?
How do we identify the equipment
used for any of the monitoring or
measurement listed above? If not how
will this be accomplished?
How will we ensure that monitoring and
measurement equipment is properly
calibrated and maintained?
What process do we have to
periodically evaluate compliance with
legal requirements? How effective is
this process?
Our next step on monitoring and
measurement is to ...
    ฉ 2001 NSF
64

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     Nonconformance and  Corrective / Preventive Action

              Fixing EMS problems - and avoiding them in the future
     Key Steps

   identify the problem

   investigate to identify
   the root cause

   come up with solution

   implement solution

   document solution

   communicate solution

   evaluate effectiveness
   of solution
"Nonconformance"
means...

•  system does not meet
   the EMS criteria

        ~ or —

•  implementation is not
   consistent with the
   EMS description
No EMS is perfect.  You will probably identify problems
with your system (especially in the early phases) through
audits, measurement, or other activities.  In addition, your
EMS will need to change as your organization changes
and  grows.   To  deal  with system  deficiencies,  your
organization needs a process to ensure that:

  •  problems (including nonconformities) are identified
    and investigated;
  •  root causes are identified;
  •  corrective and preventive actions are identified and
    implemented; and,
  •  actions are tracked and  their effectiveness is
    verified.

EMS  nonconformities  and  other  system deficiencies
(such as  legal noncompliance) should be analyzed to
detect patterns or trends.  Identifying trends  allows you
to anticipate and prevent future problems.

Focus on   correcting  and    preventing   problems.
Preventing  problems is generally  cheaper than fixing
them  after they  occur  (or after they  reoccur).   Start
thinking about problems as opportunities to improve!
         Management
            Review
      Figure 11:

= System Improvement
                                 Hints:

                                 • If  your  organization has  an ISO  9001 management
                                  system, you  should  already  have a  corrective and
                                  preventive action process for quality purposes.  Use
                                  this as a model (or integrate with it) for EMS purposes.

                                 • Some organizations find that they can  combine some
                                  elements of their management review and corrective
                                  action processes.  These organizations use a portion of
                                  their  management  review  meetings   to   review
                                  nonconformities, discuss  causes and  trends,  identify
                                  corrective actions and assign responsibilities.
ฉ 2001 NSF
      65

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 Why do EMS problems
 occur?
 Typical causes include:

0 poor communication

0 faulty or missing procedures

0 equipment malfunction
   (or lack of maintenance)

0 lack or training

0 lack of understanding
   (of requirements)
0 failure to enforce rules

0 corrective actions fail to
   address root causes of
   problems
               Legal & Other
               Requirements
               Operational
               Control
               Monitoring &
               Measurement
               EMS Audits
               Management Review
The amount of planning and documentation needed for
corrective & preventive  actions  will vary  with  the
severity of the problem and its potential environmental
impacts.   Dont go  overboard with bureaucracy —
simple methods often work quite effectively.

Once you document  a problem, the organization must
be committed to resolving it in a timely manner. Be
sure that your corrective & preventive action process
specifies   responsibilities    and    schedules  for
completion.  Review your progress regularly and follow
up to ensure that actions taken are effective.

Make sure your actions are based on good information
and analysis of causes.  While  many corrective actions
may be "common sense," you  need to  look beneath
the surface to determine why problems occur.  Many
organizations use  the  term  "root  cause"  in their
corrective and preventive action processes.  While this
term can be used  to describe a very formal  analysis
process, it can also mean something simpler - looking
past  the  obvious   or  immediate  reason   for  a
nonconformance to determine why the nonconformance
occurred.

Rule of thumb: Corrective actipns should (1) resolve
the immediate problem (2) consider whether the same
or similar problems exist elsewhere in the organization,
and  (3)  prevent the problem  from recurring.   The
corrective  action   process   also  should  define  the
responsibilities and schedules associated with  these
three steps.

Initially,  most EMS  problems  may be identified by your
internal  auditors.   However,  over  the long  run,  many
problems and good  ideas  may be  identified  by the
people doing the work. This should be encouraged.
Find ways  to get  employees  involved  in the system
improvement process  (for example,  via  suggestion
boxes, contests or incentive programs).
    ฉ 2001 NSF
     66

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 People doing the
 work are often in
 the best position
 to see problems
 and suggest
 solutions
 The Tool Kit
 contains a sample
 corrective action
 procedure and
 tracking log
 (see Appendix A)
   Sources
  of change
Investigate and
 recommend
   solutions
Institutionalize
   Change
Corrective
  Action
 Process
                   Figure 12
                        ** POLLUTION PREVENTION **

          By switching from a solvent-based paint that contained lead to a no
          lead, low-solvent, water-based paint, March Coatings dramatically
          decreased its volatile organic compound (VOC) air emissions from over
          19 tons in 1995 to less than 6 tons in 1999 while simultaneously
          increasing production. The company went from being a large quantity
          generator of hazardous waste to small quantity generator status under
          RCRA. March  Coatings accomplished this by working closely with its
          paint supplier to find a formula  that met their needs.
ฉ 2001 NSF
                 67

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            Capture the Learning:  Corrective & Preventive Action Worksheet
Do we have an existing process for
corrective and preventive action?

If yes, does that process need to be
revised? In what way?
Who needs to be involved in this
process within our organization?
How are nonconformities and other
potential system deficiencies
identified? (List methods such as
audits, employee suggestions, ongoing
monitoring, etc.)
How do we determine the causes of
nonconformities and other system
deficiencies? How is this information
used?
How do we track the status of our
corrective and preventive actions?
How is / can information on
nonconformities and corrective actions
be used within the EMS (for example,
in management review meetings, in
employee training sessions, in review
of procedures, etc.)
How do we ensure the effectiveness
of our corrective and preventive
actions?
Our next step on corrective and
preventive action is to ...
     ฉ 2001 NSF
68

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                                   Records

                   Evidence that the EMS is working as intended
   What are "records"?

 Records provide evidence
   that the processes that
   make up your EMS are
   being implemented as
.        described.
 >*	^
The value of records management is fairly simple — you
should be able to demonstrate that your organization is
actually  implementing  the  EMS as  designed.   While
records have value internally, over time you may need to
provide evidence  of EMS implementation to external
parties (such as customers, a  registrar, or the  public).
Records   management   is   sometimes   seen  as
bureaucratic,  but  it is difficult  to  imagine  a  system
operating consistently without accurate records.

The basics  of records  management are straightforward:
you need to decide what records you will keep, how you
will keep them and for how long. You should also think
about how  you  will  dispose of records  once you no
longer need them.

If  your   organization  has  an   ISO  9001  (or  other)
management system, you should  have a process in place
for managing records. This process could be adapted for
EMS purposes.
       Records should be
       important to the operation
       of the EMS, including your
    ""*"  regulatory compliance
       efforts.
Hints:

• Start by identifying what EMS records are required. Look
 at your other procedures and work instructions to determine
 what evidence is needed to demonstrate implementation.
 Also consider records that are required by various legal
 requirements.

• Focus on records that add value — avoid bureaucracy.  If
 records have no  value or are not specifically required, don't
 collect them.  The records  you choose to  keep  should be
 accurate and complete.

• You may need  to  generate  certain  forms in  order  to
 implement your EMS.  When these forms are filled out, they
 become  records.     Forms  should   be  simple and
 understandable  for the users.

• Establish a records retentipn policy and stick to it.   Make sure
 that your policy takes  into  account  records  retention
 requirements specified  in  applicable  environmental
 regulations.

• In designing your records management process,  be sure to
 consider:
 - who needs access?
 - to what records?
 - in what circumstances?
 ฉ 2001 NSF
      69

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           Key Questions

         what records are kept?
         who keeps them?
         where are they kept?
         how are they kept?
         how long are they kept?
         how are they accessed?
         how are they disposed?
        Virtually every element
        of an EMS can result in
        the generation of
        records
      The Tool Kit contains a tool
      for organizing your filing
      system (see Appendix A).
      You can copy the pages, cut
      out the tabs, and use them to
      set up your filing system.
 If your organization uses computers extensively,
 consider using an electronic EMS records management
 system. Maintaining records electronically can provide
 an excellent means for rapid retrieval of records as well
 as controlling  access to sensitive records.

 Think about  which   records might  require  additional
 security.   Do  you need to restrict  access  to certain
 records?  Should a back-up copy of critical records be
 maintained at  another location?
Types of Records You Might Maintain (Examples):

 •  legal, regulatory and other code requirements
 •  results of environmental aspects identification
 •  reports of progress towards meeting  objectives  and
   targets
 •  permits, licenses and other approvals
 •  job descriptions and performance evaluations
 •  training records
 •  EMS audit and regulatory compliance audit reports
 •  reports of  identified  nonconformities,  corrective
   action plans and corrective action tracking data
 •  hazardous material spill / other incident reports
 •  communications    with    customers,   suppliers,
   contractors and other external parties
 •  results of management reviews
 •  sampling and monitoring data
 •  maintenance records
 •  equipment calibration records
                Capture the Learning: Records Management Worksheet
Have we identified what records
need to be maintained? Where is this
defined?
Have we determined records retention
times?  Where is this defined?
Have we established an effective
storage and retrieval system?
Our next step on records is to
    ฉ2001  NSF
      70

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                                EMS Auditing

              Objective evidence of conformance with EMS requirements

                                  Once your organization has established its EMS, verifying
                                  the implementation  of the system will be critical.  To
                                  identify and resolve  EMS deficiencies you must actively
                                  seek them out.

                                  In  a  smaller  organization,  periodic  audits can be
                                  particularly valuable.  Managers are often so close to the
                                  work performed that they may not see problems or bad
                                  habits  that have developed.  Periodic EMS  audits will
                                  help determine whether  all of the requirements of the
                                  EMS are being carried out in the specified manner.
    Audits are vital to
        continual
       improvement
f      EMS Audit

    "A systematic and
 documented verification
  process of objectively
 obtaining and evaluating
  evidence to determine
 whether an organization's
      environmental
   management system
     conforms to the
      environmental
   management system
  audit criteria set by the
   organization, and for
  communication of the
 results of this process to
      management.
                      - ISO 14001
For your EMS audit program to be effective, you should:

• develop audit procedures and protocols;
• determine an appropriate audit frequency;
• select and train your auditors; and,
• maintain audit records.

Results of your EMS audits  should  be linked  to the
corrective and preventive  action process, as described
earlier.

While  they can be time-consuming,  EMS  audits are
critical  to EMS  effectiveness.   Systematic identification
and  reporting  of  EMS deficiencies  to  management
provides a great opportunity to:

• maintain management focus on the environment,
• improve the EMS and its  performance, and
• ensure the system's cost-effectiveness.
Getting Started:

• How  frequently   do   we   need   to   audit?
  To  determine an appropriate frequency  of your EMS
  audits, consider the following factors:

  - the nature of your operations and activities,
  - your significant  environmental aspects /  impacts
    (which you identified earlier),
  - the results of your monitoring processes, and
  - the results of previous audits.

As a rule of thumb, all parts of the EMS should be audited
at least annually.  You can  audit the entire EMS at one
time or break it down  into  discrete elements for  more
frequent  audits.    (There   may  be   advantages   to
conducting frequent audits, but the decision  is up to you).
 ฉ2001 NSF
      71

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  Audit procedures should
         describe:

  3  audit planning

  3  audit scope (areas and
    activities covered)

  3  audit frequency

  3  audit methods

  3  key responsibilities

  3  reporting mechanisms

  3  recordkeeping
   Traits of a good
      auditor:

  J Independent
    (of the activity
    being audited
  J Objective

  J Impartial

  1 Tactful

  J Attentive to detail
 1 l/Mrio i/y/// perform the audits? You should select and
  train  EMS auditors.  Auditor training should be bpth
  initial and ongoing.  Commercial EMS auditor training
  is available, but it might be more cost-effective to link up
  with  businesses  or other  organizations  in your area
  (perhaps  through  a trade  association) to sponsor  an
  auditor training course. Some local community colleges
  also offer EMS auditor training courses.

  Auditors should be trained in auditing techniques and
  management  system  concepts.    Familiarity  with
  environmental  regulations,  facility  operations,  and
  environmental science can be a big plus, and in some
  cases may be essential to adequately assess the EMS.

  Some auditor training  can  be  obtained  on-the-job.
  Your organization's  first  few EMS audits  can  be
  considered part of auditor training, but make  sure that
  an experienced  auditor leads or takes part in those
  "training" audits.

  Auditors should  be  independent  of the  activities
  being audited.   This can be a challenge  for small
  organizations. See the box on next page for ideas.

  If your company is registered under ISO 9001, consider
  using your  internal quality auditors as  EMS auditors.
  While some additional training  might be needed  for
  EMS auditing, many of the required skills are the same.

 How should management use audit results?
  Management  can use EMS audit  results to identify
  trends  or  patterns in  EMS  deficiencies.    The
  organization also should ensure that identified system
  gaps or deficiencies are  corrected in a timely fashion
  and that corrective actions are documented.
 Sources of Evidence

 0  interviews
 0  document review
 0  observation of
     work practices
Hints:

•  Your EMS audits should focus on objective evidence
  of  conformance.   During an audit, auditors  should
  resist the temptation to evaluate, for example,  why a
  procedure was not followed — that step comes later.

•  During  an audit, auditors should  review  identified
  deficiencies with people who work  in  the relevant
  area(s).   This will help the auditors verify that their
  audit findings are correct.   This  also can reinforce
  employee awareness of EMS requirements.

•  If possible,  train  at least  two  people as  internal
  auditors.  This will allow  your auditors to  work as a
  team.   It also allows audits to take  place  when one
  auditor  has   a  schedule  cpnflict,  which  is  often
  unavoidable in a smaller organization!
ฉ2001  NSF
      72

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  Results of regulatory
  compliance audits are often
  good indicators of EMS
  deficiencies.  Use
  compliance audit findings to
  guide your EMS efforts
  The Tool Kit includes a sample
  EMS audit procedure, sample
  EMS audit questions, and a
  number of sample audit forms
  (see Appendix A)
        Structure & Responsibility
        Training & Awareness
        Corrective Action
        Management Review
       Options for Auditor Independence
Barter for audit services with other small organizations
in your area
Use external auditors
Have office personnel audit production areas
(and vice versa)
Before you start an audit, be sure to communicate
the audit scope, criteria,  schedule, and other pertinent
information to the people in the affected area(s).  This
helps to  avoid  confusion  and facilitate  the  audit
process.

Consider  integrating   your  EMS  and  regulatory
compliance audit  processes, but keep in mind  that
these audit processes have different purposes.  While
you might want to communicate the results of EMS
audits widely within your organization,  the results of
compliance audits might  need to  be communicated in a
more limited fashion.

Final thought: An  EMS audit is  a check on how well
your  system  meets  your  own  established   EMS
requirements.  An EMS audit is not an assessment of
how well  employees do their jobs.   Auditors should
avoid the "gotcha" mentality.  Audits should be judged
on the quality of findings, rather than on the number of
findings.
                                                    Figure 13:
                                Linkages among EMS audits, corrective action and
                                              management reviews
  Even if you have an
  effective internal audit
  program, consider periodic
  external audits to ensure
  objectivity
                  Periodic
                EMS Audits
                                  EMS
                               Established
                                 Corrective Action
                                     Process
                                                    Management
                                                      Reviews
ฉ2001  NSF
    73

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                 Capture the Learning:  EMS Auditing Worksheet
Have we developed an EMS audit
program? If not, how will this be
accomplished?

Who need to be involved in the audit
process?
Is there another audit program with
which our EMS audits could be linked
(for example, our quality or health &
safety management system audits)?
Have we determined an appropriate
audit frequency? What is the basis
for the existing frequency? Should the
frequency of audits be modified?
Have we selected EMS auditors?
What are the qualifications of our
auditors?
What training has been conducted or
is planned for our EMS auditors?
Have we conducted EMS audits as
described in the audit program?
Where are the results of such audits
described?
How are the results of EMS audits
communicated to top management?
How are the records of these audits
maintained?
Our next step on EMS auditing
 is to...
  ฉ2001 NSF
74

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f  An effective EMS
      is one that:

  2 meets the
    organization's
    needs

  2 produces results

  2 conforms to EMS
    criteria

  Zl Aias staying power
     Management Review

Closing the continual improvement loop

            Just as a person should have periodic physical exams,
            your  EMS  must be  reviewed  periodically  by  top
            management to stay "healthy". Management reviews are
            one key to continual improvement and for ensuring that
            the EMS will continue to meet your organization's needs
            over time.

            Management reviews also offer a great opportunity  to
            keep your EMS efficient  and  cost-effective.   For
            example,  some  organizations have  found  that certain
            procedures and processes initially  put in place were not
            needed to achieve their environmental objectives or  to
            control key processes.  If EMS procedures and other
            activities don't add value, eliminate them.

            The key question that  a  management review seeks  to
            answer:

               "Is the system working?" (i.e., is it suitable,
               adequate and effective, given our needs?)
'  "Many of the benefits
  of an EMS cannot be
  anticipated
  beforehand.  You will
  have to discover them
  as pleasant surprises
  at some point after
  implementation. They
  will be there.
             Milan ScreJ? Products
   The Tool Kit contains a
   sample Management Review
   procedure.
   (See Appendix A)
            Hints:

            • Two kinds  of  people should  be  involved  in the
             management review process:

             - people who have the right information / knowledge,
             -  people  who  can  make   decisions  about the
               organization and its resources (top management).

            • Determine management review frequency that will
             work best for your organization.  Some  organizations
             combine these reviews with other  meetings (such as
             director  meetings).  Other organizations hold "stand-
             alone" reviews.   At a minimum, consider  conducting
             management reviews at least once per year.

            • During management review meetings, make sure that
             someone records what  issues were discussed, what
             decisions were arrived at, and what action  items were
             selected.  Results of management reviews should be
             documented.

            • Management reviews  should  assess  how changing
             circumstances   might   influence  the   suitability,
             effectiveness  or adequacy of your EMS.   Changing
             circumstances might be internal to ypur organization
             (such as new facilities, new raw materials,  changes  in
             products or services, new customers, etc.) or might be
             external  factors  (such as new laws,  new scientific
             information or changes in adjacent land use).
 ฉ2001 NSF
                 75

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Information sources to
      consider:
  Audit results
  Internal suggestions
  External communications
  Progress on objectives
  and targets
  Other environmental
  performance measures
  Reports of emergencies,
  spills, other incidents
  New or modified
  legislation and
  regulations
  New scientific / technical
  data on materials and
  processes  used by the
  organization
    Consider holding
  jf^ management review meetings
    "after hours" to minimize
    disruption of work.
         All elements of the
         EMS should be
         considered as part
         of Management
         Review
• After  documenting the action items arising from your
 management review, be sure that someone follows-up.
 Progress  on  action  items  should  be tracked  to
 completion.

• As you assess potential changes to your EMS, consider
 other organizational plans and goals.  In this way,
 environmental  decision-making can  be integrated into
 your overall management and strategy.

    Management Review: Questions to Ponder
. Did we achieve our objectives and targets? If not,
 why not? Should we modify our objectives?
. Is our environmental policy still relevant to what we do?
. Are roles and responsibilities clear, do they make
 sense and are they communicated effectively?
. Are we applying resources appropriately?
. Are our procedures clear and adequate? Do we need
 other  controls? Should we eliminate some of them?
. Are we fixing problems when we find them?
. Are we monitoring our EMS (e.g., via system audits)?
 What  do the results of those audits tell us?
. What  effects have changes in materials, products, or
 services had on our EMS and its effectiveness?
. Do changes in  laws or regulations require us to
 change some of our approaches?
. What  other changes are coming in the near term?
 What  impacts (if any) will these have on our EMS?
. What  stakeholder concerns have been raised since
 our last review? How are concerns being addressed?
. Is there a better way?  What can we do to improve?
       Smaller organizations often favor employee experience over written procedures and
       documented systems. However, personnel turnover without documented systems can
       stall progress. When the manager of the Washtenaw County Home Toxics Reduction
       Program took over his position, there had been a six-month gap since his predecessor
       had left and very little in place to tell him what to do, whom to contact,  or what the
       history of the program was. Having an EMS can facilitate a smooth transfer of
       responsibilities for environmental management.
                  YOU SHOULD NOW UNDERSTAND ALL OF
                  THE ELEMENTS OF AN EFFECTIVE  EMS !!

              NOW YOU'RE READY TO "GO"! (See next section)
         NSF
      76

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               Capture the Learning:  Management Review Worksheet
Do we have an existing process for
conducting management reviews?

If yes, does that process need to be
revised? In what way?
Who needs to be involved in this
process within our organization?
When is the best time for us to
implement this process?  Can this
effort be linked to an existing
organization process (such as our
budget, annual planning or auditing
cycles?)
How frequently are management
reviews?  What is the basis for this
frequency?

Should we conduct reviews more or
less frequently?
Who is responsible for gathering the
information needed to conduct
management reviews? Who is
responsible for presenting this
information?
How do we ensure that changing
circumstances (both internal and
external to the organization) are
considered I this process?
How do we ensure that the
recommendations of management
reviews are tracked and acted upon?
Our next step on management
review is to...
    ฉ2001 NSF
77

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          Section 5  :  GO!  (Roadmap for EMS Development)
              A sequence of activities for building an EMS from the ground up

                                    Once you gain an understanding the individual elements of
                                    an EMS, you can begin the process of putting these
                                    elements in place. Each of the individual EMS elements
                                    is described in detail in Section 4. Also, several "up front"
                                    EMS planning tasks (such as gaining top management
                                    commitment) were described in Section 3.
      Ford Motor Company
    if conducted I SO 14001
      implementation
      workshops for its
      suppliers.  Part of these
      workshops was devoted
      to a discussion of how to
      "launch" the EMS effort
      through a set of
      implementation steps.
      The Washtenaw County
     : Home Toxics Reduction
^W8- Program (HTRP)
      successfully linked its
      management review
      process with its new
      Business Improvement
      Process (BIP). HTRP used
      its environmental objectives
      as input to the BIP and
      reviewed progress annually
      to determine what worked
      and to make adjustments,
      where needed. The output
      of BIP will feed into the
      County's budgeting
      process.
Experience of many organizations shows that the order in
which EMS implementation activities should take place is
not always obvious or intuitive.  Further, the optimal
sequence of implementation activities does not
necessarily follow the order in which elements are
described in various EMS models, such as ISO 14001.
Using a logical sequence can save time and money and
minimize the "false starts" an organization might make.

This section provides a step by step action plan for
developing and implementing the elements of an EMS. It
describes a logical sequence or "roadmap" for planning
and implementing EMS elements and explains how this
sequence can be important in building an effective EMS.

Keep in mind that this is just one way to do the job- you
might find other approaches that work just as well.

Figure  14  illustrates  the suggested  implementation
process flow.  Each of the steps (and a rationale for their
sequence) is discussed below.

A few hints to keep in mind as you build your EMS:

   •  You may already have some  EMS  elements in
      place, as indicated by the preliminary review that
      you  performed earlier (see Section  3 for more
      details).
   •   Make sure to build in the links between elements.
      Refer back to Section 4  for information on the key
      links.  The effectiveness of your EMS depends as
      much on the strength of its links as it does on the
      strength of the individual elements themselves.
   •   For many EMS elements, you will need to design
      and implement a process.   In these cases,  you
      also should consider  documenting the process in
      the form of a procedure.
    ฉ 2001 NSF
       78

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          Identify
       Legal & Other
       Requirements
                                                            _\Sec.
    Identify & Evaluate
     Environmental
    Aspects, Related
  Operations & Activities
        Define Views
        of Interested
          Parties
         Prepare
      Environmental
          Policy
            T
         Define Key
         Roles and
       Responsibilities
          Establish
          Objectives
          & Targets
          Establish
         Operational
         Controls &
         Monitoring
         Processes
         Establish
      Procedures for
        Corrective/
        Preventive
          Action,
        Document
         Control &
         Records
       Management
 Environmental
  Management
   Programs
   Identify
Monitoring &
Measurement
   Needs
          Identify
        Operational
         Controls
                              Define
                            Job-Specific
                             Roles and
                          Responsibilities
               K
    Initial
  Employee
 Awareness
                             Establish
                               Other
                           System-Level
                            Procedures
   Prepare
     EMS
Documentation
   (manual)
                          Conduct Specific
                         Employee Training
                                                      T
                             Conduct
                              Internal
                            EMS Audits
   Conduct
 Management
   Reviews
              Figure 14:   GO!
ฉ 2001 NSF
       79

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       Identify
      Legal and
        Other
    Requirements
       Identify
   Environmental
    Aspects and
  Related Products,
   Operations and
      Activities
           Creating Your EMS: Step by Step

A first step in the EMS-building process is understanding the
legal and other requirements that apply to what you do (i.e.,
that apply to your products, activities and services). This step is
important for understanding compliance obligations and  how
these obligations affect the overall EMS design.  For example,
you might have an operation  that is covered by an air quality
permit or might provide a service that results in the generation
of regulated wastes.   Your EMS should include processes to
ensure that such  legal requirements are addressed when you
conduct these operations (or when they are modified).

Your EMS should be designed  to help you accomplish more that
just compliance with applicable laws and  regulations, but these
compliance requirements should be a major consideration.
Performing this step first allows you to understand how legal
requirements might relate to the environmental aspects and
impacts of your products, activities and services, as discussed
next.

Once you understand what "rules" apply,  you should assess
how your organization interacts with the environment. This
is accomplished by identifying your environmental aspects and
impacts and determining which of them are significant.  Some
of your environmental aspects may be regulated, while others
may not be.

As you identify and assess your aspects,  you also should
identify specific products, operations and activities from
which these aspects / impacts arise.  Likewise, you can identify
any monitoring that is performed of these operations or
activities for environmental purposes.  For example, if you
identify the generation of a particular air emission as a
significant environmental aspect, it would help to know which
operation(s) generate such air emissions. It might also help to
know whether these air emissions are monitored or otherwise
measured in some manner.

Collecting this information at an early stage will help you
implement subsequent EMS elements. You can use a form
(such as Figure 15) to capture  this information.  One caveat -
just because you  identify an existing control and/or monitoring
activity related  to a particular operation or activity, don't
automatically  assume that these controls are adequate for
EMS purposes. The adequacy of these controls will depend on
several factors, including your objectives  and targets.
ฉ 2001 NSF
            80

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  Figure 15:  Linking Operations, Aspects, Controls and Monitoring (example)
Source
Operations
Parts painting
Parts plating
Other Activities
Raw material
storage
Fleet maintenance
Products
Pumps
Services
Equipment servicing
at customer sites
Significant Aspect(s)
• Air emissions
(VOCs)
• Solvent waste
generation
• Waste generation
• Water discharges
• Potential spills
• Waste oil generation
• Potential spills
• Energy Use
• Chromium content
• Waste generation
• Fuel use
Regulated?
• Yes
• Yes
• Yes
• Yes
• Yes
• Yes
• Yes
• A/o
• A/o
• A/o
• A/o
Associated Controls
• Limits on VOC
content in paints
and operating hours
• SOP for HW
generation
• SOP for HW
generation
• Notification to site
effluent treatment
plant
• Stormwater
Pollution Prevention
Plan
• SOP for HW
generation
• Stormwater
Pollution Prevention
Plan
• None
• None
• SOP for equipment
service
• None
Associated
Monitoring
or Measurement
• Paint use records,
log of operating
hours
• Waste tracking
sheet
• Waste tracking
sheet
• Pre-discharge
sampling
• Weekly
inspections of
storage area
• Waste tracking
sheet
• Weekly
inspections of
storage area
• None
• None
• Waste tracking
sheet
• Fuel dispensing
records
ฉ 2001 NSF
81

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        Define
       Views of
      Interested
        Parties
Armed  with  information  on  applicable  legal  and   other
requirements as well  as the  environmental attributes of your
products,   activities   and  services,   you   should   gather
information  of  the  views   of your  "stakeholders"  (or
interested parties). Stakeholders might  include, for example,
your neighbors, interest groups,  regulators and  others.   Their
views  might  address  how  your  organization  affects the
environment, how well  you are meeting your  environmental
obligations, and whether your organization is a "good neighbor",
among other topics. There are many ways to collect information
on  stakeholder  views,   as  discussed  in   Section  4  (See
"Communication").

Gathering  this  information  now   allows  you  to  consider
stakeholder  input  in  the development  of your  environmental
policy.  Since you have  already assessed your legal and other
requirements and  your environmental aspects,  you should be in
a  good  position  to   have meaningful   dialogues with   these
stakeholders.
       Prepare
   Environmental
        Policy
At this point, you should have a sound basis for developing (or
possibly amending) your  environmental  policy.   Using  the
information developed in the previous three steps allows your
organization  to  prepare  a policy  that   is   relevant  to   the
organization and the key issues that it faces.  For example, you
will have  information on the views  of your  stakeholders  that
might be valuable in developing an environmental policy.

Keep in mind that you  evaluated your current  environmental
programs  when  you performed  the preliminary review (see
Section  3), so you  should  understand  how (and  how well) you
are currently managing these key issues.
        Define
       Key Roles
          and
    Responsibilities
Once the environmental policy has been written, you can begin
to define key roles and  responsibilities within the EMS.  At
this   stage   of  implementation,   focus   on   "higher-level"
responsibilities, such  as the roles and responsibilities of senior
management, key functional leaders and environmental staff (if
one  exists).   EMS responsibilities for  other  specific jobs  or
functions will  be identified in a later step. Once the key roles
and responsibilities have been defined, obtain the input of these
individuals  in  the  next   step of the process -  establishing
objectives and targets.
ฉ 2001 NSF
            82

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      Establish
     Objectives
        And
         Figure 16
            Develop
         Environmental
          Management
           Programs
    Identify
 Monitoring and
 Measurement
    Needs
  Identify
Operational
 Controls
        At this  point  you  are  ready  to  establish  environmental
        objectives and targets for your organization.  These objectives
        should be consistent with your environmental  policy.  Each of
        your objectives also should reflect the analyses you carried out
        on legal  and other requirements, environmental aspects and
        impacts, and the views of interested parties (as well as the other
        factors discussed in Section 4).

        You  identified the  operations  and  activities  related  to  your
        significant aspects and impacts in  an  earlier step. Also, you
        defined certain key roles and responsibilities.  This information
        will help you to determine the relevant levels and functions
        within the organization for achieving objectives and targets.  For
        example, if you set an objective to reduce hazardous waste
        generation by 10% this year, you also should know which parts
        of the organization must  be involved  in order  to meet this
        objective.
This brings  us to  one of the most challenging  (and
potentially most valuable) steps in the overall process.
Armed with  an understanding of legal requirements,
your significant environmental aspects and impacts,
and  your objectives and targets, your are  ready  to
tackle  several  EMS  elements  simultaneously.
These elements include the design of environmental
management  programs,  the initial identification  of
necessary  operational  controls,   and  the  initial
identification of monitoring and measurement needs.
One reason combining these  steps is that they can
often  overlap  significantly.    For  example,   your
environmental  management program  for achieving a
certain objective (such as maintaining compliance with
regulations)  might consist  of a  number  of  existing
operational  controls  (procedures)  and  monitoring
activities.   Similarly,  achieving   an  objective might
require  a feasibility study  or the implementation  of
certain   "new"  operational   controls.     Likewise,
determining  progress  on  achieving objectives  often
requires some  form of monitoring or measurement.
ฉ 2001 NSF
                   83

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  An example of a form for
  describing environmental
  management programs that
  shows the links between
  programs and operational
  controls is provided in the
  Tool Kit (Appendix A)
One important  caveat:  Keep in mind that operational
controls and monitoring / measurement processes might
be  needed  even  if no objective  (or  corresponding
management program) exists for a particular operation or
activity.   For  example,  controls might be needed for
certain  operations  to  ensure  compliance  with  legal
requirements or to control a  significant  environmental
aspect,  even where no specific objective  has been set.
The initial identification of operational control needs at this
point in  the process should be supplemented by a more
detailed design  of  operational controls and monitoring
processes, as described in a subsequent process step.

Also keep in mind that this process is usually iterative.
That is, you might  need to "re-visit"  your management
programs, operational controls and monitoring processes
overtime to ensure they are consistent and up-to-date.
                                   You should already have a head start on this step, since
                                   you identified operations  and activities related to your
                                   significant  environmental  aspects  (as well as existing
                                   control  and  monitoring processes) several  steps ago.
                                   Remember how we said this was a good idea?

                                   Your don't  need to  fully  develop  these  operational
                                   controls and  monitoring activities yet - that step comes
                                   later  (see  "Design Operational Controls  &  Monitoring
                                   Processes").  What you need to do now is compile a list
                                   of your operational control and monitoring needs. As
                                   you develop  your environmental management programs,
                                   ask yourself the following questions:

                                   •   How do we control this operation or activity now?
                                   •   Are these controls  adequate to meet our objectives
                                      and to ensure compliance?
                                   •   If additional controls  are needed,  what  types  of
                                      controls make sense?
                                   •   What type of monitoring / measurement is needed to
                                      track our progress in  achieving  objectives  and to
                                      ensure that operational controls are  implemented as
                                      designed?
ฉ 2001  NSF
     84

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         Establish
     Corrective Action,
    Document Control &
   Records Management
        Processes
At this stage  of implementation, your EMS will begin to
generate some documents  (such  as procedures and
forms)  and  records  (that  demonstrate  that  various
processes are being carried out).  For this reason, it is a
good    time    to    establish     procedures    for
corrective/preventive action, document control, and
records  management.    These three processes  are
essentially  "system  maintenance" functions.  As you
develop and  implement  other system-level  procedures,
work  instructions for various activities, and  other EMS
documents, you need  a  process  for controlling  the
generation  and  modification   of   these   documents.
Likewise, you  will need a process to ensure that you can
fix (or correct) problems when  they  occur.  In addition,
many of these processes (such as monitoring activities)
will generate  records,  so you need an effective way to
manage the records that your EMS generates.
          Establish
         Operational
         Controls &
         Monitoring
Once the system maintenance functions are in place, you
can start in earnest the  establishment of activity-  or
area-specific  operational  controls  and monitoring
processes.  As a starting point, refer back to the list of
operational control  and  monitoring  needs  that you
generated in preparing your environmental management
programs  (see earlier step).  Also, you  should  have a
template for the development of these work  instructions
(or standard operating procedures), since your document
control  process  was  established  in the  prior  step.
Remember that you might need operational controls and
monitoring processes to meet your policy commitments
and control significant environmental aspects,  even
where   no   specific   objectives   or   environmental
management programs have been established.

Employees that work in relevant operations or activities
can provide a lot of support here.  Also, note that these
operational controls and monitoring processes can play
an important role in employee training, as discussed later.

Also keep in  mind that you  also need a  procedure for
conducting periodic compliance evaluations.
ฉ 2001 NSF
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          Define
       Job-Specific
        Roles and
      Responsibilities
        Plan and
        Conduct
          Initial
        Employee
       Awareness
         Establish
          Other
       System-Level
        Procedures
           Prepare
             EMS
        Documentation
           (manual)
As  part of the process  described above,  you should
define job-specific roles and responsibilities.  Such
roles  and responsibilities  should  address the specific
operational controls and monitoring processes discussed
above.     You   might  want   to   document  these
responsibilities in  a responsibility matrix or in some
other form that is easily communicated to employees.

Initial  employee  awareness   training   should   be
conducted to promote understanding of the organization's
EMS efforts  and the  progress made to-date.  As a  first
step, train employees on the environmental policy  and
other elements of the EMS.  Discuss the environmental
impacts of their activities, any new / modified procedures,
the organization's  objectives and targets,  as well as their
EMS responsibilities.  If you have contractors or others at
your site who are not employees of your organization,
consider  whether  these  other individuals should  be
included in these EMS awareness sessions.

Some system-level procedures (such as  the procedures
for identification of environmental aspects and  access to
legal and other requirements) were developed at earlier
stages of the process. At this point,  you can  establish
any other procedures required for the EMS.  These
other system-level procedures might include, for example:
 •  employee training  and  awareness,
 •  internal and external communication,
 •  emergency preparedness and response,
 •  EMS auditing, and
 •  management review.

Once you have established roles and responsibilities  and
defined all of your system-level  procedures, preparing
the EMS manual should  be a relatively simple matter.
The manual should summarize the results of your efforts
so far (that is,  it should describe the processes you have
developed, the roles and responsibilities you have defined
as well as other EMS elements).  Also, it is important to
describe the links among system elements and  provide
direction to other system  documents.  Keep the  manual
simple - there is no need to  provide great detail on  any
particular system  process. Readers can  be referred to
the detailed procedures if more information is needed.
ฉ 2001 NSF
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          Plan and
          Conduct
          Specific
         Employee
          Training
Once the  procedures and other system  documentation
have been prepared, you are ready to conduct specific
employee EMS training.  As a first step, identify specific
training needs. Employee training should be designed to
ensure understanding of:
•  key system processes,
•  operational controls related to their specific jobs, and
•  any  monitoring  or measurement  for which they are
   responsible.

Job-specific  training should also  cover topics such as
EMS  auditing for  those  employees that  will  conduct
internal EMS audits.
          Conduct
          Internal
           EMS
          Audits
Once internal auditors have been selected and trained,
you should design and initiate the  internal auditing
process.  At this  point, you should  have sufficient EMS
processes in place to conduct meaningful  audits.  Many
organizations find  that it is easier to  start with smaller,
more frequent audits that to audit the entire EMS at once.
These early audits can serve  as a  learning tool for the
auditors.

Once the audit results are known, use the corrective and
preventive action process you developed  earlier to
address any identified problems.  Audit records should be
managed  in accordance with  the records management
process.
         Conduct
       Management
         Reviews
Use the results of your internal audits (along with other
information on  the  EMS)  to  conduct  management
reviews.  Management should consider the need for any
changes to the  EMS and  make  assignments  for any
changes  needed.     Such  assignments   should  be
consistent with the  roles and responsibilities  established
previously.
ฉ 2001 NSF
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                    Appendix A:  TOOLKIT
Sample Environmental Policies	89
Environmental Impact Identification and Evaluation:  Techniques .and Data Sources..96
Sample Procedure:  Instructions for Environmental Aspects Identification Form	98
Environmental Aspects Identification Form	103
Sample Environmental Aspect Evaluation and Scoring Tools	104
Resources for Tracking Environmental  Laws and Regulations	106
Sample Process Tool:  Setting Objectives & Targets	108
Sample Procedure:  Setting Objectives & Targets	111
Sample Tools: Environmental Management Program	113
Sample Responsibility Matrix	117
Sample Environmental Training Log	120
Sample Procedure: Communications with External Parties	123
Sample Document Index	125
Outline of Sample EMS Manual and Other EMS Documents	127
Sample Records Management Form (supplied courtesy of	130
General Oil Company)	132
Sample Procedure:  Corrective and Preventive Action	134
(includes tracking log)	134
Sample Environmental Records Organizer	136
Sample Procedure: EMS Audits	136
Sample EMS Audit Forms	141
Sample EMS Audit Questions	143
Sample Procedure: Management Review	149

Note: The examples in the Tool Kit are drawn from many different sources. They are not
designed to be used together in EMS development.
                                                                            \
ฉ2001 NSF                            88

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                                            \
                  Sample
               Environmental
                  Policies
ฉ2001 NSF                89

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  Sample policy - Actual policy reproduced with permission. Policy is not in original format.
                                            \
                               NEO INDUSTRIES
              HEALTH, SAFETY AND ENVIRONMENTAL POLICY
Neo  Industries is committed to managing health, safety and environmental (HS&E) matters as an
integral part of our business. In particular, it is our policy to assure the HS&E integrity of our processes
and facilities at all times and at all places. We will do so by adhering to the following principles:
                                   Compliance
We will comply with all applicable laws and regulations and will implement programs and procedures
to assure compliance.  Strict compliance with HS&E standards will be a key ingredient in the training,
performance reviews and incentives of all employees.

Where existing laws and regulations  are not adequate to  assure protection of human health, safety
and the environment, we will establish and meet our own HS&E quality standards.
                                    Prevention
We will employ management systems and procedures specifically designed to prevent activities and /
or conditions that pose a threat to human health, safety or the environment. We will minimize risk and
protect our employees and the communities in which we operate by employing safe technologies and
operating procedures, as well as being prepared for emergencies.

We will strive to prevent releases to the atmosphere, land or water. We will minimize the amount and
toxicity of waste generated and will ensure the safe treatment and disposal of waste.
                                Communication
We will communicate our commitment to HS&E quality to our employees, vendors and customers.  We
will solicit their input in meeting our HS&E goals and in turn will offer assistance to meet their goals.
                              Continuous Improvement
We will  continuously  seek  opportunities  to improve our adherence to these principles, and  will
periodically report progress to our stakeholders.
{Signature}
Neil K. Holt
President
                       March 1995
  ฉ 2001 NSF
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 Sample policy - Actual policy reproduced with permission. Policy is not in original format.
                                                                       \
Pacific Gas and Electric Company
Environmental  Quality
                                                          statement
PG&E is committed to a
clean, healthy environment.
We will provide our
customers with safe,
reliable, and responsive
 utility service in an
environmentally sensitive
and responsible manner
We believe that sound
environmental policy
contributes to our
competitive strength and
benefits our customers,
shareholders, and
employees  by contributing
to the overall well-being
and economic health  of the
communities we serve.
September 1995
(Actual policy is printed on recycled paper)
                                   We will:

                                   Comply fully with the letter and spirit of
                                   environmental laws and regulations, and
                                   strive to secure fundamental reforms that will
                                   improve their environmental effectiveness
                                   and reduce the cost of compliance.

                                   Consider environmental factors and the full
                                   acquisition, use, and disposal costs when
                                   making planning, purchasing, and operating
                                   decisions.

                                   Work continuously to improve the
                                   effectiveness of our environmental
                                   management.

                                   Provide appropriate environmental training
                                   and educate employees to be environmentally
                                   responsible on the job and at home.

                                   Monitor our environmental performance
                                   regularly through rigorous evaluations.

                                   Seek to prevent pollution before it is
                                   produced, reduce the amount of waste at our
                                   facilities, and support pollution prevention by
                                   our customers and suppliers.

                                   Manage land, water, wildlife, and timber
                                   resources in an environmentally sensitive
                                   manner.

                                   Use energy efficiently throughout our
                                   operations, and support the efficient use of
                                   gas and electricity  by our customers and
                                   suppliers.

                                   Re-use and recycle whenever possible.

                                   Use environmentally preferred materials.

                                   Clean up residual pollution from past
                                   operations in a cost-effective manner.

                                   Work cooperatively with others to further
                                   common environmental objectives.

                                   Communicate and reinforce this policy
                                   throughout the company.	
 ฉ 2001 NSF
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Sample policy - Actual policy reproduced with permission. Policy is not in original format.
             CAMPBELL & CO.  ENVIRONMENTAL POLICY
                  Campbells Go's commitment to improve the
                  environment is an expression of our Guiding
                Principles, and a demonstration of "thinkglobally
                         and act locally" sensibilities.

                   We strengthen this commitment by
                  employing Quality Operating System
                 methodology as the framework to identify
                objectives and targets for addressing areas
                     of environmental significance.

                Campbell & Co. is improving thecondition of
                  ourenvironment by preventing pollution,
                 specifically through the reduction of natural
                  resource usage. We are also helping to
                  preserve the environment by promoting
                  recycling as well as continuing to make
                 responsibleenvironmental choices when
                         purchasing products.

                  Campbells Co. will comply with allfederal,
                  state and local legislation and regulatory
                requirements, as well as those requirements
                  adopted through the Michigan Business
                  Pollution Prevention Partnership Policy.

                 Aboveall,Campbell&Co. employees will
                strive to continuously improve our efforts to
                 create a cleanerandsaferenvironment.
\
                   David Scheinberg, Presidents CEO
Created: June 6, 2000
Revised: Octobers, 2000
ฉ 2001 NSF                             92

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Sample policy - Actual policy reproduced with permission.  Policy is not in original format.
                       Village Of Chelsea, Michigan

                   Statement Of Environmental Policy

The Village of Chelsea is committed to continual improvement of its Environmental
Management System and is in compliance with all relevant federal, state, and local
environmental legislation and regulations.  The Village of Chelsea will meet and
strive to exceed all environmental requirements and will seek to prevent pollution
before it is produced. To sustain this commitment, the requirements of the
Environmental Management System described in this Manual apply to all activities
and employees. The Village's Department Superintendents are the Village's
Management Representatives who have the responsibility and authority to plan,
enforce, and maintain the Village's Environmental Management System.  This
responsibility also includes stoppage of activities that deviate from the
 requirements of this Manual. The EMS Management Representative may
delegate some of this authority downward  through the organization in order to
implement the system effectively. We will  continuously seek opportunities to
improve our adherence to the principles of environmental management.
Policy adopted by Village Council on March 11, 1997.
\
Village President
Village Clerk
[Signatures included in original policy.]
ฉ 2001 NSF                              93

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Sample policy - Actual policy reproduced with permission. Policy is not in original format.


Saint Joseph Mercy Hospital (in Michigan) demonstrated that an environmental policy can
be written in the form of a procedure. One advantage of this approach is that hospital staff can
make a direct connection between the policy and their departmental responsibilities for
implementing the policy.  The hospital includes its policy in the Administrative Policy Manual
because that manual was already well established and widely distributed. Integrating EMS
requirements with existing manuals, procedures, training, and responsibilities was a key
implementation strategy for the hospital.

                        Saint Joseph  Mercy Hospital

                    Administrative Policy and  Procedure

  Subject:                                     Environmental Compliance Policy
  Effective Date:                               September 14, 1998
  Revised Date:
  Approved By:                                President and CEO

  POLICY
  It is the policy of St. Joseph Mercy Hospital (SJMH), which includes all SJMH owned and
  operated buildings and services, to conduct all of its operations in an environmentally
  responsible and sensitive manner. St. Joseph Mercy Hospital will fully comply with both
  the letter and the spirit of all applicable federal, state and local regulatory requirements
  governing hazardous materials and wastes, pollution  prevention and environmental
  protection. It is recognized that the health and well being of the environment contributes to
  the health and well being of the communities and populations we serve. St. Joseph Mercy
  Hospital will strive to continuously improve its systems and procedures related to
  environmental protection and pollution prevention activities. St. Joseph Mercy Hospital will
  manage its facilities and properties in an environmentally responsible manner.  St. Joseph
  Mercy  Hospital will participate as appropriate in community, industry, and/or governmental
  sponsored groups addressing environmental issues affecting the communities we serve.

  NARRATIVE
  Environmental protection is the responsibility of all SJMH departments and employees. As a
  health  care organization, SJMH must handle and manage a wide variety of potentially
  hazardous or polluting materials including medical wastes, radioactive materials and
  hazardous chemicals and wastes.  Many of our processes present potential water and air
  quality issues that demand continuous monitoring and control. Proper and responsible
  handling of these materials and processes is imperative to prevent pollution, reduce waste
  and protect our environment.  A host of federal, state and local regulatory requirements are in
  place to guide this organization in achieving environmental compliance.

  PROCEDURE
  I.        Each department will continuously assess its operations to identify potential safety
           hazards and  pollution risks.  Each department is responsible for establishing and
           maintaining department specific policies and procedures designed to reduce or
           eliminate environmental hazards and minimize any negative environmental impact
           when applicable.
           A.       Potential risks will be minimized to the extent possible by seeking  out less
                   environmentally hazardous products, equipment or procedures.
           B.       Appropriate engineering controls will be implemented when it is not
                   possible to eliminate an environmentally hazardous material or


ฉ 2001 NSF                               94
\

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Sample policy - Actual policy reproduced with permission. Policy is not in original format.


                   procedure.
           C.       All departments and employees will strive to reduce all types of wastes
                   through identifying and eliminating wasteful practices and products and
                   participate in organizational recycling and waste reduction programs.

           D.       Departments will educate and communicate organizational and
                   department specific environmental policies, goals and objectives to
                   employees as required.
           E.       Departments will consider using products that have recycled content
                   taking economic and quality factors into account.
  II-       The Safety Steering Committee is responsible for monitoring environmental
           compliance issues recommending and assuring that corrective action is
           implemented as warranted to correct deficiencies.
           A.       Objectives and targets will be established to assure continuous
                   improvement in organizational environmental performance. Safety
                   Committee structure is responsible for establishing goals and
                   implementing programs to meet targets. The Safety Steering Committee
                   is responsible for monitoring  progress and reporting activities to
                   Executive Management.


  REFERENCES
    Safety Steering Committee
    Hazardous Material and Waste Committee
    Product Value Analysis Committee
    Safety Policy Manual Section lll_300 - "Hazardous Materials and Waste"
    Departmental Specific Hazardous Material/Pollution Prevention Policies and Procedures
\
ฉ 2001  NSF                               95

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                                            \
           Environmental Impact
        Identification and Evaluation:
              Techniques and
               Data Sources
ฉ 2001 NSF               96

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                                                                                       \
             SOME TECHNIQUES AND DATA SOURCES FOR IDENTIFYING AND
                         EVALUATING ENVIRONMENTAL IMPACTS
Process Hazard
Analyses
Used to identify and assess potential impacts associated
with unplanned releases of hazardous materials.
Methodology in common use due to OSHA Process Safety
Management regulations.  Typically employs team approach
to identify and rank hazards.
Failure Mode and
Effects Analyses
Commonly used in quality field to identify and prioritize
potential equipment and process failures as well as to
identify potential corrective actions.  Often used as a
precursor to formal root cause analyses.
Process Mapping
See Appendix C for details of this technique.
Environmental Impact
Assessments
Used to satisfy requirements of National Environmental
Policy Act (NEPA) regarding the evaluation of environmental
impacts associated with proposed projects.  Methodology in
common use, but not typically used to assess environmental
impacts associated with existing operations.
Life Cycle
Assessments
Used to assess full range of impacts from products, from
raw material procurement through product disposal.
Methodologies somewhat subjective and can be resource
intensive.  Described in ISO 14040-14048.
Risk Assessments
Used to assess potential health and/or environment risks
typically associated with chemical exposure. Variety of
qualitative and quantitative methodologies in common use.
Project Safety / Hazard
Reviews
Used to assess and mitigate potential safety hazards
associated with new or modified projects. Methodologies in
common use. Typically do not focus on environmental
issues.
Emission Inventories
Used to quantify emissions of pollutants to the air.  Some
data may already by available to the organization, based on
EPCRA requirements and CAA Title V permitting program.
Pollution Prevention
or Waste Minimization
Audits
Used to identify opportunities to reduce or eliminate pollution
at the source and to identify recycling options. Requires
fairly rigorous assessment of facility operations.  Typically
does not examine off-site impacts.
Environmental
Property Assessments
Used to assess pptential environmental liabilities associated
with facility or business acquisitions or divestitures. Scope
and level of detail is variable. Typically do not assess
impacts associated with products or services.
Environmental Cost
Accounting
Used to assess full environmental costs associated with
activities and/or products.  Emerging protocols require
comprehensive assessment to quantify costs.
Environmental
Compliance Audits
Used to assess compliance with federal, state and local
environmental regulations. Methodologies in common use.
Scope and detail vary.  Not typically directed at examining
environmental impacts (particularly for products).
ฉ 2001 NSF
                 97

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                                            \
            Sample Procedure:
   Instructions for Environmental Aspects
            Identification Form
      (courtesy ofZEXEL Corporation)
ฉ 2001 NSF               98

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                                                                                      \
OPERATIONAL PROCEDURE
Number: 1 Author:
OP-EV0100.R06 | Ronda Moore
Title:
Environmental Aspects & Impacts
Issue Date:
August 04, 2000
Approval:
Vice President Operations
Reviewed By:
Waste Water Group Leader
1.0   Purpose
      The purpose of this procedure is to provide a system and instructions to identify
      environmental aspects of ZEXEL's activities, products, and services in order to
      determine those which may have a significant impact on the environment.

2.0   Scope
      This procedure covers all activities, products, and services associated with ZEXEL.  For
      purposes of evaluation, activities, products, and services with similar characteristics may
      be grouped together.
3.0    Reference Documents

            Document Name
Objectives and Targets
Management Review
Aspect/Impact Evaluation Form
Aspect/Impact Listing - Decatur
Aspect/Impact Listing - Arcola
Initial Production Control
Contract Review
          Document Number
OP-EV0103
OP-ZX006
WF-ES002
WF-ES008
WF-ES058
OP-ZX001
OP-SA001
4.0    Procedure
4.1     The procedure consists of an initial screening of activities, products, and services, based
       on data submitted to the ISO 14000 Task Force by the Area Managers. The Task Force
       assesses the aspects, determines associated impacts, and assigns an impact rating.
       The Task Force will review the evaluation results, and up-date as needed.

4.2     Area Managers are responsible for developing a flowchart for their department(s)
       showing all inputs and outputs to their processes. Inputs into the process may include
       supplies, raw materials, chemicals, packaging, and energy consumption. Outputs from
       the process may include products, solid wastes, liquid wastes, emissions, noise, and
       odor.  The flowcharts shall also include the current method of handling generated
       wastes.

4.3     The Task Force shall evaluate the information submitted on the flowcharts.  The Task
       Force may call upon other ZEXEL Team Members to assist, as needed. Each activity,
       product, and service shall be evaluated from the time the material is accepted on site
       through the time of sale, at the sale location. If a waste is being evaluated, the timeline
       to consider is the time the material is accepted on site through ultimate disposal, as
       displayed by the diagram below.
ฉ 2001 NSF
99

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                                                                                          \
                    Accept Material

                    |	Product—
                    I	Waste—
             Sale Location
                  Ultimate Disposal
                  -I
4.4    The Task Force shall assign an impact rating according to the scales described below,
       while considering each of the following stages: raw material storage, production
       (accidents, start up, and normal operation), product and waste storage, transportation,
       and ultimate disposal.

4.5    The Task Force shall ask for each aspect / impact evaluation:
                  a) Is it in our permits / permittable?
                  b) Is it regulated by law?
                  c) Do we have control over it?

If the answer to a and/or b is "yes", the impact must be included on the list of significant
impacts.  If the answer to c is "no", the impact shall not be included on the list of significant
impacts.  The following table explains  the different possible answers.
Possible Answer
Yes
Wo
Permitted /
Permittable
must include
may include
Regulated by Law
must include
may include
Do we have
Control
may include
shall not include
4.6    When evaluating the "frequency", the number shall be determined from the following
       scale, based on documented evidence, by asking the following questions to determine
       frequency of use and of accidents:  (1). How often does the process occur? and (2).
       How often has a problem occurred?
Frequency
Continuously
once per shift
once per day
Weekly
Monthly
Quarterly
semi-annually
Annually
once every 1 to 5 years
over 5 years
Never
Scale
10
9
8
7
6
5
4
3
2
1
0
ฉ 2001 NSF
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                                                                                       \
4.7
4.8
4.9
4.10
When evaluating the "severity" the task force shall assign an impact number by selecting
the highest evaluated rate from the scale below, based on documented evidence.  When
considering human impact, it is important to include contractors, neighbors, customers,
etc., as well as team members.
Severity
Scale
10
9
8
7
6
5
4
3
2
1
Human Impact
multiple deaths
single death
disabling injury
long term health
effects
lost time
Injury/Illness
restricted duty
medical only
first aid treatment
Discomfort
None
Animal / Plant
Effect
widespread
permanent
destruction
on-site permanent
destruction
widespread genetic
impact
on site genetic
impact
wide spread
disfigurement
on-site disfigurement
wide spread
appearance
reduction of natural
beauty
on-site appearance
none
Public Relations
plant closure
permanent public
disfavor
interrupted
operations
loss of historical
assets
state or national
protest
city or county protest
employee protest
public inconvenience
public disfavor
none
 Impact ratings shall be determined by multiplying the frequency and severity numbers.
 The Task Force shall determine an appropriate cutoff level for significant impacts.

 The Environmental Manager shall work closely with ZEXEL's Plant Management to
 ensure that the identified significant environmental aspects are considered in
 establishing environmental objectives and targets forZEXEL, as stated in the Objectives
 and Targets OP.

 The results of the most recent environment aspect / impact identification is reviewed as
 part of the Management Review process, as specified in the Management Review OP.
 From this review ZEXEL Management determines the need to update the environmental
 impact evaluation. Factors considered in the determination to update the assessment
 include improved methodologies, and major changes in ZEXEL's policies,  products, or
 processes. Aspect reviews may also be triggered from the Initial Production Control
 (IPC) and Contract Review process. Environmental impact evaluations shall be
 conducted at least, on an annual basis, by the end of each calendar year, even if none
 of the  factors listed above dictate a review.
ฉ 2001 NSF
                                   101

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ASPECT/IMPACTEVALUATION

Aspect/Impact/Activity:
                       Date:

Category
Air Quality
Water
Quality
Land Quality
Consumption




Stages
Raw Material
Storage
Production
(Start-Up)
Production
(Normal)
Product/
Waste Storage
Transportation
Ultimate
Disposal

Freq
Use







uency
Incident







Severity
Human
Impact







Animal/Plant






Public






Overall Rating

Impact
Rating







Please note: Significant Impact if
                    - permittable
                    - required by law
                    - over the establish cut off

Frequency
continuously
1 per shift
1 per day
weekly
monthly
quarterly
semi-annually
annually
1 every 1 - 5 yrs
over 5 yrs
never (Use Only)
Severity
Human Impact
multiple deaths
single death
disabling injury
long term health
effects
lost time injury/
illness
restricted duty
medical only
first aid
treatment
discomfort
none

Animal/ Plant Effect
widespread perm.
destruction
on-site permanent
destruction
widespread genetic
impact
on-site genetic impact
widespread
disfigurement
on-site disfigurement
widespread appearance
reduction of natural
beauty
on-site appearance
none

Public Relations
plant closure
permanent public
disfavor
interrupted
operations
loss of historical
assets
state or national
protest
city or county
protest
employee protest
public
inconvenience
public disfavor
none


Scale
10
9
8
7
6
5
4
3
2
1
0
                                                                                  \
ฉ 2001 NSF
102

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                                                       \
  Environmental Aspects Identification Form
      (courtesy of Johnson Controls, Inc. -
          Automotive Systems Group)
Note: The instructions and form were developed within the context of a comprehensive
EMS. References are made to processes outside of the instructions.

This is intended as an example, not a stand-alone document.
ฉ 2001 NSF                    103

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                                                                                      \
Provided courtesy of Johnson Controls, Inc., Automotive Systems Group
Instructions for Environmental Aspect Identification  Form


Responsibilities

The facility Cross Functional Team (CFT) led by the Management Representative (MR) is
responsible for completing this form for each Core Process and Supporting Activity within a
facility. If possible, members of the CFT must conduct a physical  inspection when completing
this form. The completed form is a material balance of a process  or activity and is used to
identify Environmental Aspects. The facility CFT compares the resulting material balance and
list of facility-specific aspects to any information available in the form of generic "HSE Process
Profiles" produced for similar type processes or activities.

At a minimum, the CFT will review and revise the completed forms, by means of physical
inspection, as necessary at issuance,  annually, prior to and immediately following
implementation of new or modified processes/activities.

All environmental aspects are evaluated for significance and managed as defined in the
Environmental Aspects Control Plan form.

Conducting a Material Balance

The material balance consists of identifying all raw  materials, chemicals, and utilities used as
input along with their relative  usage rates, and all output as product and by-products produced.
The latter is all wastes produced, all recycled materials, water discharges, and air emissions
known for the process(es), and any available rates  of production.

1.0     Record the Plant Name, Process/Activity Name, and Location.

2.0     Provide a description  of the process/activity.

3.0     Determine and record if the Process/Activity is a Contracted Process/Activity.

4.0     Record Material Inputs and Outputs. If the Process/Activity is installed or in place,
       conduct the identification by means of physical inspection.

       Raw material inputs

         •  Parts: Enter the major, non-chemical parts/supplies used in the process.
         •  Chemical: Enter any chemical materials used in the process.
         •  Energy: Enter energy type and usage. (Levels are relative to the facility.)
         •  Other Input: Enter inputs that are not covered clearly in other categories,  (e.g.
             packaging, containers)
         •  Water Use: Enter water type (e.g. city, well, storm, process, chilled) and usage.
             (Levels are relative to the facility.)
ฉ 2001 NSF                              104

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                                                                                         \
     Provided courtesy of Johnson Controls, Inc., Automotive Systems Group


       Process Output

          •  List all products produced by the process specifically produced for sale.
             Recyclable and Chemical By-Product (e.g. Rebond) outputs are entered in the
             waste section.
          •  List all air emissions whether they are drawn directly through a stack or are
             discharged into the room and escape as fugitive emissions. Include noise and
             odor as an  air emission if potentially noticeable outside the facility.
          •  Enter wastes.  Wastes are any materials intended to be discarded or disposed of,
             whether regulated or not, and include liquids, solids, and gases. Also include
             recycled materials, returnable containers and chemical by-products under this
             category
          •  Check the recycled box if the material is currently recycled, internally or
             externally.  It does not include materials that go directly back into the process
             (i.e., Calibration shots returned to day tanks, etc.)
          •  Include containerized wastewater transported off-site.
          •  Enter all wastewater streams that discharge directly to storm or sanitary sewer
             systems or surface waters. Containerized wastewater should be included in the
             waste section. In the bottom portion of the wastewater section, list any treatment
             that occurs before the water is discharged.

5.0    Compare the completed form to any information available in the form of generic "HSE
       Process Profiles" produced for similar type processes or activities.

6.0    Sign and date the form with the date the form was completed or revised.

7.0    Collect all completed Aspect Identification forms and enter data into the supporting
       Environmental Aspect Control Plan form.
ฉ 2001 NSF                               105

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                                                                                                       \
                           Environmental Aspects Identification
                                       Process Overview
                                            Establish Cross
                                            Functional Team
                                                (CFT)
                                            Determine Core
                                            Processes and
                                          Supporting Activities
                                             Inspect each
                                          Process/Activity and
                                            conduct material
                                               blanace
                                           Identify and record
                                               aspects
                                          Compare to available
                                               profiles
                                              Proceed to
                                             Environmental
                                               Aspects
                                             Analysis and
                                            . Control Form/
ฉ 2001  NSF
106

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                                                                                                                       \
          Plant.
 ENVIRONMENTAL ASPECTS IDENTIFICATION
	  Process/Activity:	
         Contracted?
         RAW MATERIAL INPUTS
                                                Process/Activity Location:
PARTS



CHEMICAL MATERIAL



Ifflfe
BedrtJy
MutfOee
Stem
Compresed M
Hydraulcs
EHERCY USE:
USAGE
High Medium










Low





OTHER INPUT:



TYPE:





WATER USt:
USAGE
High Medium










Low






MATER


Provkis toef descrifrticn of
Optional AtmcnivMaidepholo.sthemgtc,
stetiii drawing, delated desoijton







On s(e Ttealinert (Type)




                                                                               PRODUCT OUTPUTS
                                                                                 AHEMSSIOH5
                                                                                (T>cludซ DOS* b odoi]
                                                                           WASTE (ซ BYPRODUCTS)
ฉ 2001  NSF
                              107

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                                         \
          Sample Environmental
          Aspect Evaluation and
              Scoring Tools
ฉ2001 NSF              108

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                                                                                 \
     Sample 1: Environmental Aspect/Impact Scoring Worksheet

A company identified "Spills from Unloading Trucks" as an environmental aspect of its
operations. The company used the following worksheet and rating criteria to determine
whether the environmental impacts (on water quality and/or soil contamination) of this
aspect should be considered significant.

First, the company determined that the LIKELIHOOD of a spill was low, since it had not
experienced any spills of this type in the prior three years. Second, they determined that the
MAGNITUDE (or SEVERITY) of the environmental impact would be moderate for most of
the types of materials that they unload from trucks at the  loading dock.  The company noted,
however, that certain chemicals are regulated and that spills of such materials in reportable
quantities would require an appropriate response to regulatory agencies.

Using the "Key to Impact Rating"  (see below), an environmental impact with a Low
Likelihood and a Moderate Magnitude received an overall score of "low impact
significance". Thus, "spills from unloading trucks" was not considered a significant
environmental aspect.
Area or
Activity
Shipping
Dock









Aspect
Spills from
Unloading
Trucks








Impacts
Water Quality

and

Soil
Contamination





Impact Scoring
(see below)
Likelihood is
low

Magnitude
is moderate
A
OVERALL \
IMPACT / \
SCORE IS / \
LOW \
Significance
Not
Significant

(Note: spills
of
reportable
quantities of
certain
chemicals
\mustbe
\ Veported)
                        Key to Impact Rating
Likelihood of
Occurrence
or Impact(s)

High
Medium
Low
Magnitude
(severity of impacts, actual or pc
Severe
High
Significance
High
Significance
Medium
Significance
Moderate /
High
Significance
Medium
Significance
Low
Significance
-^ I
J

ential
Low
Medium
Significance
Low
Significance
Low
Significance
Excerpted from "Environmental Management Systems: A Guide for Metal Finishers"
(NSF International), available for free download at www.nsf-isr.org.
ฉ 2001 NSF
109

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                                                                                        \
       Sample 2:  Environmental Aspect/Impact Scoring Worksheet

       Approach
       For each product, service or activity (or group of products, services or activities), each
       element in the table is assigned two scores, based on (1) the degree of impact and (2)
       frequency or likelihood of the associated environmental impacts.

       Degree of Impact
       4 = serious (likely to result in severe or widespread damage to human health or the
          environment)
       3 = moderate
       2 = minor
       1 = no impact (unlikely to have an adverse impact on human health or the environment)

       Frequency/Likelihood of Impact
       4 = continuous (impact occurs on an on-going basis)
       3 = frequent (impact occurs more than once / month)
       2 = infrequent (impact occurs more than once / year but less than once / month)
       1 = improbable / never (impact has never occurred or is highly unlikely to occur)

       Scores are added for each indicator across the relevant life cycle stages (as shown in the
       example below) to generate a total impact score.
Category
Human Health
Environment
Resource Use
  Indicator

Employees

Surrounding
Community

  Global


Air Quality

  Surface
  Water
  Ground
  Water
Land / Soil

Ecosystem
  Effects
   Noise


   Fuels
  Water
   Raw
 Materials
                                Pre-
                             Production
                                  3/2

                                  2/2


                                  1/2
                         Manufact-  Production/   Use/  Waste
                           uring    Distribution  Service   Mgt
2/2

2/3


1/2
2/1

2/2


1/3
4/2

1/2


1/2
2/2

2/2


1/3
                                     TOTAL
                                     SCORE
22

20


17
       ฉ 2001 NSF
                             110

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                                          \
   Resources for Tracking Environmental
          Laws and Regulations
ฉ 2001 NSF              111

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                                                                               \
   Resources for Tracking Environmental Laws and Regulations

Over the last few years, the Internet has emerged as a tremendous tool for tracking and
obtaining information  on environmental laws and regulations.  For example, the USEPA
home page (see address below) in one quite useful Internet source. See Appendix Ffor
additional information  on resources.

This table describes a variety of commercial and non-commercial sources of information on
federal  and state environmental  laws  and regulations.  This list is  not  intended to be
comprehensive.  Appearance on  this list should  not be construed as  an endorsement by
EPA or NSF of any commercial products listed here.
Source
USEPA
Small Business Ombudsman
(1-800-368-5888)
USEPA Web Site
Small Business Assistance
Programs (various states)
US Small Business
Administration
US Government Printing Office
(202-512-1800)
Trade and Professional
Associations (various)
Counterpoint Publishing
(1-800-998-4515)
Bureau of National Affairs
(1-800-372-1033)
Thompson Publishing Group
(1-800-677-3789)
Business & Legal Reports, Inc.
(1-800-727-5257)
Aspen Law and Business
(1-800-638-8437)
Description
Regulatory explanations and guidance, research, case
studies, contacts for additional information. Variety of hotlines
available for particular statutes (such as RCRA). Internet
access also available (http://www.epa.gov).
Provides a variety of information of environmental laws and
regulations as well as tools and compliance guidance.
(http://www.epa.gov).
Guidance on regulations and compliance issues. Initially
focused on clean Air Act requirements, but expanding into
other environmental media.
Various services available to small businesses in the US.
Federal Register published daily with all federal proposed and
final rules. (Also available on line via GPO Access)
Provide a variety of services related to environmental laws
and regulations, including regulatory updates and training.
Contact individual associations for details.
CD-ROM and Internet dial-up access to legal / regulatory
information for federal government and all 50 states, updated
daily.
Information on EHS laws, regulations and activities at
international, national and state level. Paper and electronic
access available.
Manuals on a variety of federal and state environmental
programs with monthly updates and newsletters.
Access to federal and state regulations with monthly, updates
on available on CD-ROM.
Publishes compliance manuals with regular update service for
RCRA and Clean Air Act.
ฉ 2001 NSF
112

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                                            \
           Sample Process Tool:
        Setting Objectives & Targets
ฉ2001 NSF               113

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                                                                                   \
             Sample Process Tool for Setting Objectives & Targets
Step 1: A cross-functional team is a good way for your organization to set realistic objectives
       and targets. List here who needs to be involved on the team:
                  Name
                   Contacted?
Step 2: Think about what information sources your team will need to establish objectives and
        targets.  Pull together information sources such as:
            Information Sources

 • process maps
 • waste, and emission data
 • site maps
 • compliance audit reports
 • list of identified environmental aspects and
  impacts
 • communications from interested parties
 • others??
 (you may also want to do a plant tour or "walk
 through" to identify other issues)	
                How they will help
                      e.g.,
    • identify process steps with environmental
    aspects
    • determine current wastes and sources
    •etc.
Step 3: Is there other information that might be helpful to the team?
         Other Information Needed
               Where we will get it
 ฉ 2001 NSF
114

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                                                                                      \
Step 4:  List the significant environmental impacts (you identified these earlier). You can
        categorize these impacts by type:
Energy
Use

Raw
Materials

Air
Impacts
Water
Impacts
Waste
Impacts
Land
Issues

Other
(specify)
Step 5: Look at processes (such as plating or assembly) and activities (such as shipping or
       purchasing). Are there any other issues the team should consider, in addition to those
       listed above as significant impacts? (For example, you might want to establish an
       objective to reduce spills of hazardous materials at the loading dock, even if this was not
       identified as a  potentially significant environmental impact.)
    Process or activity
Issues
Possible Objectives & Targets
Step 6: List any new regulatory requirements that affect the facility (or other regulations for
       which the need for additional actions has been identified).
     Regulations, other requirements
               Possible Objectives & Targets
Step 7: Consider inputs from interested parties.  Any need for additional objectives related to
        views of neighbors, community groups or other parties?
        Inputs from Interested Parties
                Possible Objectives & Targets
 ฉ 2001 NSF
      115

-------
                                                                                      \
 Step 8: Look at the lists of possible objectives developed in Steps 4 -7.  Brainstorm
         with the team on whether these objectives are:
                     • reasonable,
                     • technologically feasible,
                     • consistent with other organizational plans/goals, and
                     • affordable.
          List preliminary objectives and targets based on this exercise:
                           Selected Preliminary Objectives
Step 9:  Determine how you will measure each of the selected preliminary objectives.  (If you
         cannot establish an effective way to measure it, put that objective "on-hold" for later
         consideration).
           Selected Objectives
           Performance Indicator(s)
Step 10: For each objective that you selected, determine who is going to develop the action plan
          (who, what, when, where, how). List these names below:
           Selected Objectives
         Responsibility for Action Plan
 ฉ 2001 NSF
116

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                                            \
            Sample Procedure:
        Setting Objectives & Targets
ฉ2001 NSF               117

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                                                                                     \
        EMS PROCEDURE:  SETTING AND TRACKING OF ENVIRONMENTAL
                           OBJECTIVES AND TARGETS
I. Purpose

The purpose of this procedure is to ensure that the organization establishes and maintains
documented environmental objectives and targets.

II Scope

This procedure applies to environmental objectives and targets set at all relevant levels
within the organization.

III. Definitions

Environmental (or environmental) objective- A site goal that is consistent with the
environmental  policies and considers significant environmental impacts and applicable laws
and regulations. Objectives are quantified wherever practicable.

Environmental (environmental) target- A detailed performance requirement (quantified
wherever practicable) based on an environmental objective. A target should be met in order
for the underlying objective to be achieved.

IV. General

The organization establishes environmental objectives and targets in order to implement the
environmental  policies.  Objectives and  targets also provide a means for the organization to
measure the effectiveness of its environmental efforts and improve the performance of the
environmental  management system.  In establishing environmental objectives, the
organization considers:

  • applicable laws and regulations (and requirements of other programs, such as ...);

  • environmental aspects of the organization's activities and products;

  •technological, financial, operational,  and other organizational  requirements; and,

  • the views of employees and  other interested parties.
Based on the organization 's environmental objectives, targets are established for different
functions within the organization and for different areas of the plant.  For example, the
organization may establish an environmental objective to "reduce waste generation by 10%
per year".  Based on this objective, different areas of the plant might set targets for reducing
individual waste streams in order to ensure that the organization's objective was achieved.
An organization-wide environmental objective might also be translated into individual
projects (such as changes in production processes,  materials or pollution control equipment)
in different plant areas.
ฉ2001 NSF                             118

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                                                                                     \
V. Procedure

A. The organization's top management is responsible for establishing environmental
   objectives on an annual basis.  To initiate the process, the Plant Manager holds a
   meeting of all staff members to discuss the development of environmental objectives.

B. Objectives are action- and prevention-oriented and are intended to result in meaningful
   improvements in the organization 's environmental performance.

C. Each plant area or functional manager is responsible for providing input from his / her
   own function (Finance, Engineering, etc.) or shop area (Fabrication, Assembly, Shipping /
   Receiving, etc.). The organization's environmental manager is responsible for providing
   input on applicable laws and regulations, significant site environmental impacts, and the
   views of interested parties.  (These inputs are obtained from the separate analyses
   required by Procedure #'s).

D. As a starting point, the organization's management evaluates its performance against
   environmental objectives for the current year. As part of this effort, management
   examines the results of its environmental performance evaluations.

E. Preliminary environmental objectives are developed for further discussion and evaluation.
   Each manager is responsible for evaluating the potential impacts within his / her
   functional or shop area (if any) of the proposed environmental objectives. The
   organization's environmental manager reviews proposed objectives to ensure
   consistency with the overall  environmental policy.

F. Environmental objectives  are finalized, based on review comments from site managers
   and employees. Each manager identifies the impacts of the objectives in his / her
   function or shop area, establishes targets to achieve the objectives, and develops
   appropriate measures to track progress towards meeting the objectives and targets.

G. Each manager is responsible for communicating objectives and targets (and the means
   for achieving them) to others in his / her part of the organization.

H. Progress  towards the objectives and targets is reviewed on a regular basis at
   management meetings. The progress is also communicated to plant employees via
   bulletin boards and other  similar means.

I. At the end  of each calendar year, the organization's management reviews its performance
   with regard to achieving the objectives and targets.  This information is used as  input to
   setting objectives and targets for the succeeding year.
ฉ2001 NSF                              119

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                                        \
             Sample Tools:
   Environmental Management Program
ฉ2001 NSF             120

-------
          Sample Environmental Management Program Form
                                                                              \
(Note: Use one form per objective)
Date
                  Individual Responsible:
Environmental Objective:
Related Target(s):
Related Significant Environmental Aspect(s):
Specific Function and/or Department:
Target Date (Month/Year):  (_
                Environmental Management Program: Action Plan
How will this objective be met? (attach additional pages as necessary)
What operational controls might support the achievement of this objective?
How will this objective be tracked? (attach additional pages as necessary)
What resources will be required to achieve this objective? (attach additional
pages as necessary)
Adapted from the EPA/NSF guide "Environmental Management Systems: A Guide for Metal
Finishers" (December 1998). Available for free download at www.nsf-isr.org.
ฉ 2001 NSF
                                    121

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                                              \
Environmental Management Program - Sample Tool
Objective / Target #1
Action Items

Priority

Respon-
sibilities

•
•

Schedule

Resources
Needed


Comments

ฉ 2001 NSF
122

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                                             \
        Sample Responsibility Matrix
ฉ2001 NSF                123

-------
  Legend:
  L = Lead Role
  S = Supporting Role
                                Responsibility Matrix
                                               \

Communicate importance of
environmental management
Coordinate auditing efforts
Track / analyze new
regulations (and maintain
library)
Obtain permits and develop
compliance plans
Prepare reports required by
regulations
Coordinate communications
with interested parties
Train employees
Integrate environmental into
recruiting practices
Integrate environmental into
performance appraisal
process
Communicate with
contractors on
environmental expectations
Comply with applicable
regulatory requirements
Conform with organization's
EMS requirements
Maintain equipment /tools
to control environmental
impact
Monitor key processes
Coordinate emergency
response efforts
Identify environmental
aspects of products,
activities, or services
Establish environmental
objectives and targets
Develop budget for
environmental management
Maintain EMS records
(training, etc.)
Coordinate EMS document
control efforts
Plant
M'gr
L









L
L


L
S
L



EHS
M'gr
S
L
L
L
L

S



L
L

S
S
L
S
S
L

HR
M'gr





L

L
L

S
S



S




Maintenance

S








S
S
L


S




Purchasing /
Materials









L
S
S



S



S
Engineering



S






S
S



S




Production
Supervisor(s)
S
S




L



S
S

L

S
S



Finance










S
S



S

L


EMS
Mg't Rep.










S
S



S



L
Employees










S
S








ฉ 2001 NSF
124

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                                          \
    Sample Environmental Training Log
ฉ2001 NSF               125

-------
                                                                                         \
                                  EMS Training Log (Sample)
Training Topic
EMS Awareness
Supervisor EHS Training
Hazardous Waste
Management
Hazardous Waste
Operations
Spill Prevention &
Response
Chemical Management
Emergency Response
Accident Investigation
Hazardous Materials
Transport
Hazard Communication
Personal Protective
Equipment
Fire Safety
Electrical Safety
Hearing Conservation
Confined Space Entry
Lock-out/Tag-out
Bloodborne Pathogens
Job-Specific Training (list)
Attendees*


















Frequency


















Course Length


















Course
Method


















Comments


















Date
Completed


















Attendees Code
1:  All Employees
2:  Supervisors / Managers
3:  Operators
4:  Maintenance
5:  Material Handlers
6:  Engineering
        ฉ 2001 NSF
126

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                                           \
            Sample Procedure:
       Communications with External
                 Parties
ฉ2001 NSF               127

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                                                                               \
                   EMS PROCEDURE: COMMUNICATIONS
                          WITH EXTERNAL PARTIES
I. Purpose
This procedure is intended to establish a process for outreach and communication
with external parties regarding the organization's environmental management system
(Note: the organization should also consider external communication regarding its
significant environmental aspects).

II. Scope

This procedure describes how the organization receives, documents, and responds to
communications from external parties. In addition, it discusses proactive steps that
the organization takes to maintain a meaningful dialogue with external parties on
environmental matters.

III. Definitions

Interested Parties- Individuals or groups with an interest in the environmental impacts
of the organization's products, activities or services. These parties include regulators,
local residents, employees, stockholders, insurers, customers, environmental groups
and the general public (adapted from ISO 14001).

IV. General

The organization uses a number of mechanisms to ensure effective communication
with interested parties. These mechanisms include regulatory filings (such as permit
applications and reports), open houses, the media, and informal discussions with
regulators, community representatives, and local business  leaders.

To solicit the views of interested parties,  the organization may use additional
techniques, including (but not limited to) surveys, community advisory panels,
newsletters, or informal meetings with representatives of external groups.

General rules for external communications require that the  information provided by the
organization:

   • be understandable and adequately explained to the recipient(s); and

   • present an accurate and verifiable picture of the organization and its
    environmental management system, its environmental performance, or other
    related matters.
ฉ2001 NSF                            128

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                                                                              \
V. Procedure

A. Management of Communications from External Parties

       1. Inquiries and other communications (received by mail, fax, telephone, or in
         person) from external parties concerning the organization's EMS or
         environmental performance may be received by a number of the
         organization's representatives, including the Plant Manager, the
         environmental manager, and the human resources manager, among others.
         All such communications are reviewed by the Plant Manager or his / her
         designee to determine the appropriate response.

       2. Communication with representatives of regulatory agencies is delegated to
         the organization's environmental manager, who maintains records of all
         such communications (both incoming and outgoing). In the absence of the
         environmental manager, communications with regulatory officials are
         delegated to the human resources manager.

       3. Copies of all other written communications on environmental matters are
         maintained by the human resources manager. All non-written
         communications from external parties are documented using telephone logs
         or similar means. All records of external communications are maintained as
         discussed in Procedure # (Records Management).

       4. A record of the responses to all communications from external parties is
         maintained by the human resources manager in files designated for that
         purpose.

B. Outreach to Interested Parties

       1. The organization solicits the views of interested parties on its environmental
         management system, its environmental performance, and other related
         matters. In particular, such outreach is conducted when significant changes
         at the facility are being considered, such as facility expansion or other
         actions that might affect the actual or potential environmental impacts of the
         organization's products, activities,  or services.

       2. As part of the Management Review process, the team designated to
         conduct the Review evaluates proactive efforts to communicate with
         external parties.  Based on this evaluation and other factors, the
         organization's management determines the need for outreach with external
         parties in the coming year and how such communications can be carried
         out most effectively.

External Hazard and Emergency Communication

Note: All external communications regarding emergency response are addressed in
Procedure #.

ฉ2001 NSF                            129

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                                        \
         Sample Document Index
ฉ2001 NSF              130

-------
                             Sample Document Index
 (sample indicates individual that revised document, his/her position/deoartment and dateCs) of revision)
                                                 Revision Number
                                              \
Document
Environmental Policy
Environmental Manual
Procedure 1 :
Environmental Aspects
Identification
Procedure 2: Access to
Laws and Regulations
Procedure 3: Setting
Objectives & Targets
Procedure 4:
Environmental Training
Procedure 5: External
Communications
Procedure 6: Internal
Communications
Procedure 7: Document
Control
Procedure 8:
Emergency
Preparedness
Procedure 9: Corrective
Action
Procedure 10: Records
Management
Procedure 11: EMS
Audits
Procedure 12:
Management Reviews
Procedures 13-X (list
individually)
EMS Audit Checklist
Other plans &
documents related to
above procedures (list
separately, e.g. SPCC
Plan, Emergency
Response Plan, etc.).
Other forms and
checklists (list)
1
John Smith
Plant Manager
1/1/98

















2
John Smith
Plant Manager
1/1/99

















3


















4


















5


















6


















ฉ 2001 NSF
131

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                                      \
           Outline of Sample
            EMS Manual and
         Other EMS Documents
ฉ 2001 NSF              132

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                                                                              \
     Outline of Sample EMS Manual and Other EMS Documents

                              Basic EMS Manual
• Index / Revision History / Distribution List
• Environmental Policy
• Description of How Our EMS Addresses Each of the EMS Elements (and linkages
 among these elements)
     - How We Identify Significant Environmental Aspects
     - How We Access and Analyze Legal and Other Requirements
     - How We Establish and Maintain Objectives and Targets
     - How the Organizational Structure Supports EMS (organization charts, key
      responsibilities)
     - How We Train our Employees and Ensure Competence
     - How We Communicate (internally and externally)
     - How We Control EMS Documents
     - How We Identify Key Processes and Develop Controls for them
     - How We Prepare for and Respond to Emergencies
     - How We Monitor Key Characteristics of Operations and Activities
     - How We Identify, Investigate and Correct Nonconformance
     - etc.

                Environmental Management Program Description
• Annual Objectives and Targets
• Action Plans (to achieve objectives and targets)
• Tracking and Measuring Progress

                              EMS Procedures
• Index / Revision History / Distribution List
• Organization-wide Procedures (for some  EMS elements there might be more than
 one procedure)
      -  Environmental Aspects Identification
      - Access to Legal and Other Requirements
      - Training, Awareness and Competence
      -  Internal Communication
      -  External Communication
      -  Document Control
      - Change Management Process(es)
      -  Management of Suppliers / Vendors
      -  Emergency Preparedness and Response
      -  Monitoring and Measurement
      - Calibration and Maintenance of Monitoring Equipment
      - Compliance Evaluation
      - Corrective and Preventive Action
      -  Records Management
      -  EMS Auditing
      - Management Review
• Procedures / Work Instructions for Specific Operations or Activities
      - Waste Management
      - Wastewater Treatment             (These are examples only)
      - Operation of the Paint Line

              Other EMS Documentation (Emergency Response Plans, etc.)

ฉ2001 NSF                           133

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                                        \
    Sample Records Management Form
          (supplied courtesy of
          General Oil Company)
ฉ 2001 NSF             134

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                                                                            \
Title: EMS RECORDS MANAGEMENT TABLE
Revision Date:November?, 2000
Print Date: January 29, 2001 (Uncontrolled document if
printed)	
             Doc. No.: EMF-4.5.3
             Approval by:
             Page 135 of 1
                      EMS Records Management Table

The following table lists records related to the Environmental Management System, in
accordance with EMP-4.5.3 (Record keeping procedure).
Record Type
ADMINISTRATION
Records on costs - purchasing,
operations, and disposal
Utility bills
Record of annual waste quantity
received
Certificates of Insurance
Waste Analysis Sheets
Waste Manifests - outgoing
ENVIRONMENTAL
Incident Reports
Complaint Reports
EMS Communications with external
parties
Decision regarding external
communication of significant
environmental aspects
Major Source Determination Records
Title V Permit Exemption
Correspondence regarding Air Notices
Odor Control System Permit
Air Emission Reports
Records on waste disposal sites used
EMS Monitoring Inspection reports
Person Responsible

Office Manager
Office Manager
Office Manager
Office Manager
Office Manager
Office Manager

Env. Dept.
Env. Dept.
Env. Dept.
Env. Dept.
Env. Dept.
Env. Dept.
Env. Dept.
Env. Dept.
Env. Dept.
Env. Dept.
Env. Dept.
Location

Admin. Office
Admin. Office
Admin. Office
Admin. Office
Admin. Office
Admin. Office

Env. Office
Env. Office
Env. Office
Env. Office
Env. Office
Env. Office
Env. Office
Env. Office
Env. Office
Env. Office
Env. Office
File
Method

Date order
Date order
Date order
Date order
Customer
name
Date order

Date order
Date order
Issue
Date order
Date order
Date order
Date order
Date order
Date order
Site name
Date order
Retention
minimum

3 years
3 years
Life of Co.
Life of
Company
3 years
3 years

3 years
3 years
3 years
3 years
Life of Co.
Life of
Company
5 years
5 years or
per Permit
5 years
Life of Co.
5 years
ฉ 2001 NSF
135

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                                           \
            Sample Procedure:
      Corrective and Preventive Action
          (includes tracking log)
ฉ 2001 NSF               136

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                                                                                    \
         EMS PROCEDURE:  PREVENTIVE AND CORRECTIVE ACTION


I. Purpose

The purpose of this procedure is to establish and outline the process for identifying,
documenting, analyzing, and implementing preventive and corrective actions.

II. Scope

Preventive or corrective actions may be initiated using this procedure for any environmental
problem affecting the organization.

III. General

A. Corrective action is generally a reactive process used to address problems after they
  have occurred.  Corrective action is initiated using the Corrective Action Notice (CAN)
  document as the primary vehicle for communication. Corrective action may be triggered
  by a variety of events, including internal audits and management reviews. Other items
  that might result in a CAN include neighbor complaints or results of monitoring and
  measurement.

B. Preventive action is generally a proactive process intended to prevent potential problems
  before they occur or become more severe. Preventive action is initiated using the
  Preventive Action Notice (PAN).  Preventive action focuses on identifying negative trends
  and addressing them before they become significant. Events that might trigger a PAN
  include monitoring and measurement, trends analysis, tracking of progress on achieving
  objectives and targets, response to emergencies and near misses, and customer or
  neighbor complaints, among other events.

C. Preventive and corrective action notices are prepared, managed and tracked using the
  preventive  and corrective action database.

D. The ISO Management Representative (or designee) is responsible for reviewing issues
  affecting the EMS, the application and maintenance of this procedure, and any updates to
  EMS documents affected by the preventive and corrective actions.

E. The ISO Management Representative is responsible for logging the PAN or CAN into the
  database, and tracking and recording submission of solutions in the database. The
  requester and recipient of the CAN or PAN are responsible for verifying the effectiveness
  of the solution.  The ISO Management Representative is responsible for overall tracking
  and reporting on preventive and corrective actions.

F. Personnel receiving  PAN's and CAN'S are responsible for instituting the required
  corrective or preventive action, reporting completion of the required action to the ISO
  Management Representative, and assuring sustained effectiveness.
ฉ2001  NSF                             137

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                                                                                     \
///. General (cont'd.)


G. Completed records of PAN's and CAN'S are maintained in the database for at least two
   years after completion of the corrective or preventive action.

IV. Procedure

A. Issuing a CAN or PAN

    1. Any employee may request a CAN or PAN.  The employee requesting the CAN or
       PAN is responsible for bringing the problem to the attention of the ISO Management
       Representative.  The ISO Management Representative is responsible for
       determining whether a CAN or PAN is appropriate and enters the appropriate
       information into the corrective and preventive action database.  Responsibility for
       resolving the problem is assigned to a specific individual ("the recipient").

    2. The ISO Management Representative, working with the recipient, determines an
       appropriate due date for resolving the CAN or PAN.

B. Determining and Implementing Corrective and Preventive Actions

    1. The CAN or PAN is issued to the recipient, who is responsible for investigation and
       resolution of the problem. The recipient is also responsible for communicating the
       corrective or preventive action taken.

    2. If the recipient cannot resolve the  problem by the specified due date, he / she is
       responsible for determining an acceptable alternate due date with the ISO
       Management Representative.

C. Tracking CAN'S and PAN's

    1.  CAN'S or PAN's whose resolution dates are overdue appear on the Overdue
       Solutions report. The ISO Management Representative is responsible for issuing
       this report on a weekly basis to the Plant Manager and the recipients of any
       overdue CANs or PANs.
    2. Records of PANs and CANs are maintained in the database for at least two years
      after completion of the corrective or preventive action.

D. Tracking Effectiveness of Solutions

    1. The recipient of a CAN or PAN, in conjunction with the requester, are responsible for
      verifying the effectiveness of the solution. If the solution is deemed not effective, the
      CAN or PAN will be reissued to the original recipient.
ฉ2001  NSF                             138

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                 SAMPLE CORRECTIVE ACTION NOTICE
    CAN Number:               Issue Date:         Solution Due Date:
                        Name       Location            Phone:
    Requested By:
    Issued To:
    Problem Statement (completed by ISO Management Representative):
    Most Likely Causes (completed by ISO Management Representative):
    Implemented Solutions (completed by recipient - include dates as applicable):
    Results (confirming effectiveness):
                        Closed by:                     Closing Date:
ฉ2001 NSF                           139
                                                                             \

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                                                        \
             CORRECTIVE ACTION TRACKING LOG
CAN
Number































Requested
By































Issued
To































Plan
Due
(Date)































Plan
Completed
(Date)































Corrective
Action
Completed
(Date)































Effectiveness
Verified
(Date)































CAN
Closed
(Date)































ฉ 2001 NSF
140

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                                         \
          Sample Environmental
            Records Organizer
ฉ2001 NSF              141

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                                                                             \
                  Environmental Records Organizer (SAMPLE)
     Air Emissions Regulations




     Air Emissions Fees




     Air Emissions Inventories




     Air Emissions Permits




     Air Permit Applications




     Air Permit(s): Historical




     Annual Licenses & Fees




     Compliance Reporting




     Compliance Plans




     Community Right-to-Know




     EPCRA Regulations




     EPCRA Reporting




     Hazardous Waste Regulations




     Hazardous Waste Permit/ID Number




     Hazardous Waste Fees




     Hazardous Waste Biennial Report




     Hazardous Waste: Open Manifests




     Hazardous Waste: Closed Manifests




     Historical Data




     Indoor Air Quality
         Loss Prevention Information




         Other Permits & Permit Applications




         Pollution Prevention (P2) Regulations




         Pollution Prevention Fees




         Pollution Prevention Reporting




         Recycling Information




         Recycling Projects




         Special Wastes




         Solid Waste Permit




         Solid Waste Fees




         Spill Reports




         Spill Response Actions




         Stormwater Regulations




         Stormwater Permit




         VOC/HAPs Reporting




         VOC Annual Analysis




         Wastewater Regulations




         Waste water Fees




         Wastewater Permit




         Wastewater: Semi-Annual Reporting
ฉ 2001 NSF
142

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                                         \
      Sample Procedure:  EMS Audits
ฉ2001 NSF              143

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                                                                                    \
            EMS Procedure: Environmental Management System Audits

I. Purpose

To define the process for conducting periodic audits of the environmental management
system (EMS). The procedure defines the process for scheduling, conducting, and
reporting of EMS audits.


II.  Scope

This procedure applies to all internal EMS audits conducted at the site.

The scope of EMS audits may coverall activities and processes comprising the EMS or
selected elements thereof.


III.  General

Internal EMS audits help to ensure the proper implementation and maintenance of the EMS
by verifying that activities conform with documented procedures and that corrective actions
are undertaken and are effective.

All audits are conducted by trained auditors.  Auditor training is defined by Procedure #.
Records of auditor training are maintained in accordance with Procedure #.

When a candidate for EMS auditor is assigned to an audit team, the Lead Auditor will
prepare an evaluation of the candidate auditor's performance following the audit.

The ISO Management Representative is responsible for maintaining EMS audit records,
including a list of trained auditors, auditor training records, audit schedules and protocols,
and audit reports.

EMS audits are scheduled to ensure that all EMS elements and plant functions are audited
at least once each year.

The ISO Management Representative is responsible for notifying EMS auditors of any
upcoming audits a reasonable time  prior to the scheduled audit date.  Plant areas and
functions subject to the EMS audit will also be notified a reasonable time prior to the audit.

The Lead Auditor is responsible for  ensuring that the audit, audit report and any feedback to
the plant areas or functions covered by the audit is completed per the  audit schedule.

The ISO Management Representative, in conjunction with the Lead Auditor, is responsible
for ensuring that Corrective Action Notices are prepared for audit findings, as appropriate.
ฉ2001 NSF                             144

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                                                                                       \
IV.  Procedure

A. Audit Team Selection - One or more auditors comprise an audit team. When the team
  consists of more than one auditor, a Lead Auditor will be designated.  The Lead Auditor is
  responsible for audit team orientation, coordinating the audit process, and coordinating
  the preparation of the audit report.

B. Audit Team Orientation - The Lead Auditor will assure that the team is adequately
  prepared to initiate the  audit.  Pertinent policies, procedures, standards, regulatory
  requirements and prior audit reports are made available for review by the audit team.
  Each auditor will have appropriate audit training, as defined by Procedure #.

C. Written Audit Plan - The  Lead Auditor is responsible for ensuring the preparation of a
  written plan for the audit.  The Internal  EMS Audit Checklist may be used as a guide for
  this plan.

D. Prior Notification - The plant areas and / or functions to be audited are to be notified a
  reasonable time prior to the audit.

E. Conducting the Audit

    1. A pre-audit conference is held with appropriate personnel to review the scope,  plan
       and schedule for the audit.

    2. Auditors are at liberty to modify the audit scope and plan if conditions warrant.

    3. Objective evidence is examined to verify conformance to EMS requirements,
       including operating procedures. All audit findings must be documented.

    4. Specific attention is given to corrective actions for audit findings from previous audits.

    5. A post-audit conference is held to  present audit findings, clarify any
       misunderstandings, and summarize the audit results.

F. Reporting Audit Results

    1. The Team  Leader  prepares the audit report, which summarizes the audit scope,
       identifies the audit team, describes sources of evidence used, and summarizes the
       audit results.

    2. Findings requiring  corrective action are entered into the corrective action database.
ฉ2001 NSF                              145

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                                                                                    \
IV. Procedure (cont'd.)

G. Audit Report Distribution

    1. The ISO Management Representative is responsible for communicating the audit
      results to responsible area and / or functional management.  Copies of the audit
      report are made available by the ISO Management Representative.

    2. The ISO Management Representative is responsible for ensuring availability of audit
      reports for purposes of the annual Management review (see Procedure #).

H. Audit Follow-up

    1. Management in the affected areas and / or functions is responsible for any follow-up
      actions needed as a result of the audit.

    2. The ISO Management Representative is responsible for tracking the completion and
      effectiveness of corrective actions.

I. Record keeping

    1. Audit reports are retained for at least two years from the date of audit completion.
      The ISO Management Representative is responsible for maintaining such records.
ฉ2001 NSF                             146

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                                                                              \
                                 Audit Plan
Area or
Function to be
Audited
• Purchasing






Lead
Auditor
• Jim H.






Audit Team
Members
• Linda B.
• Joe S.






Target
Date
• 11/10/00






Special Instructions
- Verify corrective actions
from previous audit
- Interview new employee
in department






ฉ 2001 NSF
147

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                                                                                        \
                       Sample Communications to Audit Team

                  ENVIRONMENTAL MANAGEMENT SYSTEM AUDIT
Lead Auditor:

Audit Team Members:
Audit Area:
       Target Due Date:
Listed above is the area to be audited. The due date given is the target to have the entire audit
completed, including the report and follow-up meeting with the responsible area management.  Listed
below are the areas of environmental management systems criteria that you are to assess.  If you
have any questions, please call me.  Special instructions, if any, are listed below.  Thank you for your
help.  Effective audits help make an effective environmental management system.
    Policy

   Environmental Aspect identification

   Environmental Management Program

   Training, Awareness, Competence

   EMS Documentation

   Operational Controls

   Monitoring and Measurement


    Records

   Management Review
       	Legal and Other Requirements

       	Objectives and Targets

       	Structure and  Responsibility

       	Communication

       	Document Control

       	Emergency Preparedness

       	Nonconformance / Corrective Action



       	 Management System Audits
Special Instructions:
ISO Representative (signature)
ฉ 2001 NSF
148

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                                       \
        Sample EMS Audit Forms
ฉ2001 NSF             149

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                                                                \
               EMS AUDIT SUMMARY SHEET
Organization Audited:,



Lead Auditor:	
                  Date:
ELEMENT NUMBER AND DESCRIPTION

4.2
4.3
4.3.1
4.3.2
4.3.3
Environmental Policy
Planning
Environmental Aspects
Legal and Other Requirements
Objectives and Targets
4.3.4 || Environmental Management Program(s)
AUDIT RESULTS
No. of Majors / No. of Minors





A, N,orX*





II
4.4 || Implementation and Operation \\ \\
4.4.1 || Structure and Responsibility || ||
4.4.2 || Training, Awareness, and Competence
II
4.4.3 || Communication || ||
4.4.4 || EMS Documentation || ||
4.4.5 || Document Control
4.4.6 || Operational Control
II
II
4.4.7 || Emergency Preparedness and Response || ||
4.5
4.5.1
4.5.2
4.5.3
4.5.4
4.6
Checking and
Corrective Action
Monitoring and Measurement
Corrective and Preventive Action
Records
EMS Audit
Management Review
TOTAL
Legend:
A = Acceptable: Interviews and other objective
evidence indicate that the EMS meets all the
requirements of that section of the standard.










I
I
N = Not Acceptable: The auditor has made
the judgment that, based on the number and
type of nonconformances, the requirements
of that the section of the standard are not
being met.
X = Not Audited
ฉ 2001 NSF
150

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                                                                            \
                   EMS AUDIT FINDINGS FORM
 Type of Finding (circle one):

 Nonconformance:  Major     Minor      Positive Practice  Recommendation

 Description (include where in the organization the finding was identified):
 ISO 14001 (or other EMS criteria)
 Reference:
   Date:
Finding Number:
Auditor:
   Auditee's Rep.
 Corrective Action Plan (including time frames):
 Preventive Action Taken:
 Individual Responsible for Completion of the
 Corrective Action:
         Date Corrective Action Completed:
 Corrective Action Verified By:
                                                      Date:
ฉ 2001 NSF
151

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                                                   \
         Sample EMS Audit Questions
            (by organizational function)
      The following questions are excerpted from a
  comprehensive list of EMS audit questions contained in
 the NSF-ISR project report, "Implementing Environmental
       Management Systems in Community-Based
                Organizations: Part 2".

  For a complete list of EMS audit questions by function,
  download Part 2 of the project report from the NSF web
                site (www.nsf-isr.org)
ฉ 2001 NSF                  152

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                                                                     \
                     Function: TOP MANAGEMENT
4.2 Environmental Policy
Top Management
a. Describe your role in the development of the
environmental policy.
b. How do you know that your policy is
appropriate for your activities, products, and
services?
c. What is management's role in the review and
revision of the policy?
d. How does management ensure continued
adherence to the policy throughout the
company?
e. How does the policy help guide organizational
decisions?
f. How are employees made aware of the
environmental policy?
g. How is the policy made available to the public?
[Auditor Note: Is there evidence that the policy was
issued by top management? (e.g., Is the policy signed?
By whom? At what level in the organization are they?)]
Objective Evidence








Notes:
ฉ 2001 NSF
153

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                                                                    \
                     Function: TOP MANAGEMENT
4.3.3 Objectives and targets
Top Management
a. What are the environmental objectives and
targets for your organization? What is your role
in approving them?
What are the relevant functions and levels within
your organization that support the attainment
each of the objectives and targets?
b. How are the environmental objectives linked to
other organizational goals (and vice versa)?
c. Are the objectives/targets consistent with the
goals of the environmental policy for prevention
of pollution and continual improvement?
d. How were the objectives and targets developed
by or communicated to management?
e. How does management keep up with progress
in meeting their objectives and targets
throughout the year?
f. How often are you informed of the status of the
objectives and targets?
g. On what basis are the objectives and targets
reviewed and modified?
Objective Evidence







Notes:
ฉ 2001 NSF
154

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                                                                     \
                     Function: TOP MANAGEMENT
4.4.1 Structure and responsibility
Top Management
a. At what level within the organization is the
designated EMS representative placed?
Auditor Note: Is the EMS representative at a level within
the organization to effectively implement an EMS for
his/her organization?]
b. What authority does the EMS representative
have to carry out his/her responsibilities?
c. How does the organization assess its resource
needs for environmental management? How
are these factored into operating and strategic
plans (and vice-versa)?
d. What resources (financial, technical personnel)
has management provided to develop or
maintain the EMS?
e. How are you informed on the performance of
the EMS? Do you receive routine reports?
f. Are responsibilities for the environmental
management of the organization documented?
If so, where?
Is an integrated structure in place in which
accountability and responsibility are defined,
understood, and carried out?
g. How are these responsibilities communicated to
all employees (including managers)?
Objective Evidence







Notes:
ฉ 2001 NSF
155

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                                                                                     \
                          Function: TOP MANAGEMENT
 4.4.3 Communication
 Top Management
                  Objective Evidence
 a.  How are you informed of the environmental
     issues within your organization? How often
     does this take place? Does this include
     compliance issues?
     How are you kept up to date with progress in
     meeting your organization's environmental
     objectives and targets?
     How is this information passed on to your
     managers?
 c.  How do you communicate with the
     organization on environmental issues?

     How is this done? How frequently?
 d.  How does the organization handle inquiries
     from interested parties (e.g., the public,
     regulators, other organizations) on
     environmental matters?
     Who has responsibility for responding to such
     inquiries?
4.6 Management review
Top Management
a. Describe the organization's management
review process.
b. How often are management reviews
performed? How was this frequency
determined?
c. Who is involved in the management review
process? What are their roles in this process?
d. What changes have been made to the EMS as a
result of the last review?
Objective Evidence




Notes:
ฉ 2001  NSF
156

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                                        \
           Sample Procedure:
           Management Review
ฉ2001 NSF              157

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                                                                                   \
                   EMS PROCEDURE: MANAGEMENT REVIEW

I. Purpose

The purpose of this procedure is to document the process and primary agenda of issues to
be included in the Management Review meetings for evaluating the status of the
organization's environmental management system (EMS).

II. Scope

This procedure applies to all Management Review meetings conducted by the organization.

III. General

The Management Review process is intended to provide a forum for discussion and
improvement of the EMS and to provide management with a vehicle for making any
changes to the EMS necessary to achieve the organization's goals.

IV. Procedure

A. The ISO Management Representative is responsible for scheduling and conducting a
  minimum of two Management Review meetings during each 12-month period.  The ISO
  Management Representative is also responsible for ensuring that the necessary data and
  other information are collected prior to the meeting.

B. At a minimum, each Management Review meeting will consider the following:

       • suitability, adequacy and effectiveness of the environmental policy;

       • suitability, adequacy and effectiveness of the environmental objectives (as well as
        the organization's current status in achieving these objectives);

       • overall suitability, adequacy and effectiveness of the EMS;

       • status of corrective and preventive actions;

       • results of any EMS audits conducted since the last Management Review meeting;

       • suitability, adequacy and effectiveness of training efforts; and,

       • results of any action items from the previous Management Review meeting.

C. Minutes of the Management Reviews will be documented and will include, at a minimum
   the list of attendees,  a summary of key  issues discussed and any actions items arising
   from the meeting.

D. A copy of the meeting minutes will be distributed to attendees and any individuals
  assigned action items. A copy of the meeting minutes will also be retained on file.
ฉ2001 NSF                             158

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                                         \
              Appendix B:



 EPA's National Environmental Performance



Track and Other Government EMS Initiatives
ฉ2001 NSF              159

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                                                                                   \
         National Environmental Performance Track Program

The National Environmental Performance Track is designed to recognize and encourage top
environmental performers - those who go beyond compliance with regulatory requirements
to attain levels of environmental performance and management that benefit people,
communities, and the environment. As top environmental performers, participants earn
access to a unique reward package that includes recognition, better information, and
administrative streamlining.

The Performance Track consists of two levels.  The first level, the National Environmental
Achievement Track, is available now and is open to facilities of all types, sizes, and
complexity, public or private, manufacturing or service-oriented.  It is designed to recognize
facilities that consistently meet their legal requirements and have implemented high-quality
environmental management systems, as well as encourage them to even better
achievement by continuously improving their environmental performance and informing and
involving the public. The second level, the National Environmental Stewardship Track, is
designed to recognize and encourage broader and higher levels of voluntary environmental
performance than those expected under the Achievement Track. The Stewardship Track is
still under development, and EPA plans to have it available by May 2001.

Any program for improving environmental performance must aim for participation by small
businesses and other small entities, such as local governments.  EPA is making every effort
to make the Achievement Track accessible for small entities. This effort is  reflected in
several aspects of the design. For example, depending on the nature and extent of a
facility's operations, the EMS for a small facility may be simpler than one for a larger, more
complex facility. For the same reason, a small facility may have fewer environmental
aspects. In addition, a small facility is not asked to make as  many performance
commitments as other participants.

Environmental Management System (EMS) Requirements

Facilities wanting to participate in the Performance Track must meet several requirements.
A facility will certify that it has an EMS in  place.1  The EMS will include the elements listed
below and will have gone through at least one full cycle of implementation (i.e.,  planning,
setting performance objectives, EMS  program implementation, performance evaluation, and
management review). A facility that has adopted systems based on EMS models with a
Plan-Do-Check-Act framework would meet most of these elements.

EPA recognizes that the scope and level of formality of the EMS will vary, depending on the
nature, size, and complexity of the facility.  EPA's experience with a variety of programs
suggests that these EMS elements are within the capability of small facilities and can be met
through a variety of approaches. To help small facilities implement an EMS, EPA will make
guidance documents and assistance materials available.

A facility will certify that it has implemented an EMS that includes these elements:
1 For purposes of the Achievement Track, an EMS represents an organization's systematic
efforts to meet its environmental requirements, including maintaining compliance and
achieving performance objectives that may be related to unregulated aspects of the
organization's activities.
ฉ2001 NSF                            160

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                                                                                     \
Policy

A written environmental policy, defined by top facility management, that includes
commitments to: (1) compliance with both legal requirements and voluntary
commitments; (2) pollution prevention (based on a pollution prevention hierarchy
where source reduction is the first choice); (3) continuous improvement in
environmental performance, including areas not subject to regulations; and (4)
sharing information about environmental performance and the operation of the EMS
with the community.
Planning

•  Identification of significant environmental aspects2 and legal requirements, including
   procedures for integrating anticipated changes to the facility's requirements or
   commitments into the EMS.

•  Measurable objectives and targets to meet policy commitments and legal
   requirements, to reduce the facility's significant environmental impacts, and to
   meet the performance commitments made as part of the facility's participation in
   the program.  In setting objectives and targets, the facility should consider the
   following criteria: preventing non-compliance, preventing pollution at its source,
   minimizing cross-media pollutant transfers, and improving environmental
   performance.

•  Active, documented programs to achieve the objectives, targets, and
   commitments in the EMS, including the means and time-frames for their
   completion
Implementation and Operation

•  Established roles and responsibilities for meeting objectives and targets of the
   overall EMS and compliance with legal requirements, including a top
   management representative with authority and responsibility for the EMS.

•  Defined procedures for: (1) achieving and maintaining compliance and meeting
   performance objectives; (2) communicating relevant information  regarding the
   EMS, including the facility's environmental performance, throughout the
   organization;  (3) providing appropriate incentives for personnel to meet the EMS
   requirements; and (4) document control, including where documents related to
   the EMS will be located and who will maintain them.

•  General environmental training programs for all employees, and specific training
2 An "environmental aspect" is defined as an "element of an organization's activities,
products, or services that can interact with the environment." Facilities are asked to use their
list of significant environmental aspects in selecting performance commitments under this
program.


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                                                                                   \
   for those whose jobs and responsibilities involve activities directly related to
   achieving objectives and targets and to compliance with legal requirements.

•  Documentation of the key EMS elements, including the environmental policy,
   significant environmental aspects, objectives and targets, a top management
   representative, compliance audit program, EMS audit program, and overall EMS
   authority.

•  Operation and maintenance programs for equipment and for other operations
   that are related to legal compliance and other significant environmental aspects.

•  An emergency preparedness program.

Checking and Corrective Action

•  An active program for assessing performance and preventing and detecting non-
   conformance with legal and other requirements of the EMS, including an
   established compliance audit program and an EMS audit program.

•  An active program for prompt, corrective action of any non-conformance with
   legal requirements and other EMS  requirements.
Management Review

•  Documented management review of performance against the established
   objectives and targets and the effectiveness of the EMS in meeting policy
   commitments.
Although a third-party audit of the EMS is not necessary to qualify for the Achievement
Track, a facility is asked in the application form if it has undergone such an audit.  If it has
not, it will have conducted a self-assessment. A facility will retain EMS documentation and
provide a summary of its performance, including performance against objectives and
targets, and a summary of the results of compliance and EMS audits, in its Annual
Performance Report.
For more information about the National Environmental Performance Track, contact the EPA
via:

Web: www.epa.gov/performancetrack
E-Mail: ptrack@indecon.com
Phone: 888-339-PTRK
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                                                                                 \
   The Multi-State Working Group on Environmental Management
      Systems Overview of Organizational and State Activities
MSWG is an organization that convenes government, non-government, business and
academic interests to conduct research, promote dialogue, create networks and establish
partnerships that improve the state of the environment, economy and community through
systems-based public and private policy innovation.  Its quarterly meetings move around the
US to accommodate participation. Meetings are open; everyone is welcome. All have a right
to speak. Decisions are by consensus.  The Council of State Governments (CSG) handles
administration and to accommodate gifts has 501(c)(3) status. Voluntary dues support
MSWG. NGOs do not pay dues. New members are welcome, especially businesses and
NGOs.  All 50 states are enrolled in MSWG and linked by e-mail. About 25 states regularly
participate at quarterly meetings and  30-40 states attend the annual meeting and workshop.
Check www.mswg.org for information.

What activities does MSWG sponsor?

•  Pilot projects: In partnership with the U.S. EPA, the Environmental Law Institute,  and
   University of North Carolina-Chapel Hill, MSWG states sponsor about 75 EMS pilot
   projects that produce data for a national database project funded by the EPAs Office of
   Water.  The purpose of the pilots  is to evaluate the ability of environmental management
   systems to improve the environment. Information is at: www.eli.org/isopilots.htm
•  EMS Research: MSWG held six EMS research roundtables at major universities that led
   to a Research Summit, held in 1999 at The Brookings Institution in cooperation with
   CSG and the National Academy of Public Administration. The Summit produced an EMS
   research agenda. Summit papers are included in a textbook, edited by Harvard
   University and the Massachusetts Institute of Technology, published  in 2001 by
   Resources for the Future. Plans are being made for a second summit.
•  EMS Policy Academy: With funding from The Joyce Foundation to CSG and support of
   business, MSWG has a design team of business, government, academic and NGO
   appointees preparing recommendations for a national EMS Policy Academy. The
   "virtual" Academy will focus on learning about public policy EMSs, not those within the
   confines of a  private organization and will complement and not compete with existing
   services. Public policy EMSs have designed to have credibility with business,
   government,  NGO, consumer and enlightened shareholder interests.
•  Workshops:  Each June or July, MSWG sponsors, with support from  EPA and
   businesses, an annual EMS workshop.  It is a "hands-on" event that hosts EMS
   practitioners from the US and abroad. It has grown from 75 participants in Gary, NC
   1998 to nearly 300 in San Diego,  CA in 1999.
•  Networking:  MSWG provides a networking function between states and EMS  support
   functions, especially those focused on EMSs that fit into a public policy strategy.
   Technical assistance centers in Florida, Georgia, Iowa, Kentucky, Massachusetts and
   South Carolina help MSWG participants.
•  Other activities: MSWG members contribute to numerous public policy-related
   environmental initiatives and discussions including EPAs Performance Track,  ISO
   14001 revisions; Environmental Council of States forums; Global  Environmental
   Management Initiative meetings; professional and trade association programs and
   Commission for Environmental Cooperation.
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MSWG is state-driven. Several states sponsor EMS pilot projects and contribute data to the
UNC-ELI database. They are: AZ, CA, IL, IN, NC, NH, OR, PA VT and Wl.  These states
have or are developing public-policy-related EMS policies, programs, internal EMSs or
environmental laws that recognize EMSs: AZ, CA, CT, FL, IA, IL, IN, LA, MA, ME, MN, NC,
NH, OH, OR, PA, SC, TX, VA, WA, VT and Wl.  Contact Marci Carter, carterm@uni.edu for
state contact information or questions. Many MSWG states participate in EPAs performance
track program, whose businesses use EMSs for public policy purposes.
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                                                                                 \
            Implementing Environmental Management Systems
                          In Government Entities

Fourteen government entities were selected from an applicant pool of 50 to participate in a
pilot  project  designed  to assist public-sector organizations develop and implement an
environmental management system (EMS) based on the  ISO 14001 protocol. The  U.S.
Environmental Protection Agency's (U.S. EPA) Office of Water, Office of Compliance, and
Office of Air and Radiation,  including Regions I and IX, jointly sponsor this initiative which
runs from April 2000 to January 2002.

Each participating organization has selected a facility/organization ("fenceline") in which to
implement the EMS, as noted below.
Public Entity
City of Berkeley, CA
Citv of San Dieao, CA
City of Detroit, Ml
Florida Gulf Coast University - Fort Myers, FL
Port of Houston, TX
Jefferson County, AL
Little Blue Valley Sewer District - Independence, MO
Louisville and Jefferson County Metropolitan Sewer
District Louisville, KY
Wisconsin Department of Natural Resources -
Madison, Wl
Tri-County Metropolitan Transportation District
Portland, OR
King County Solid Waste Division - Seattle, WA
Massachusetts Department of Environmental
Protection Lawrence, MA
University of Massachusetts - Lowell, MA
New Hampshire Department of Transportation
Concord, NH
Fenceline
Solid Waste Management Division
Refuse Disposal Division
Department of Recreation & Public
Lighting
Solid Waste Activities and Services
Container Terminal and the Central
Maintenance Department
General Services Department
Wastewater Treatment Facility
All operations
Wastewater Treatment Facility and
Purchasing Department
Air Management Bureau
Maintenance Facilities
Entire Division - Eight Transfer Stations &
one Regional Landfill
Wall Experiment Station
Analytical Laboratory
Olney Science Building - Laboratory
Bureau of Traffic
In 1997, U.S. EPA sponsored the first two-year EMS project for nine local governments.
Participants experienced compelling environmental and economic benefits over the two-year
project period:

•  Improved Environmental Awareness - "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
   contractors, 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."
ฉ 2001 NSF
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                                                                                     \
•  Improved Efficiency - "Systematically analyzing compliance issues revealed an
   opportunity for cost savings. Fifteen departments were responsible for obtaining their
   own air quality permits - 23 altogether. The implementation team consolidated these
   permits into eight, saving the city $16,000 per year."

•  A Positive Effect on Environmental Compliance and Performance - "With regards 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."

For case study information, see the final report at www.getf.org/projects/muni.cfm.

THE SECOND GOVERNMENT EMS INITIATIVE

Due to the overwhelming success of the first program and local governments' growing
interest in EMSs, U.S. EPA decided to conduct a second EMS initiative to gather additional
data  about the value of EMS tools in government organizations. The Global Environment &
Technology Foundation (GETF) was again selected to lead the effort, providing in-depth
training, coaching and on-site technical assistance to help participants design and
implement their EMS's.

Jim Home, the National Project Manager, from U.S. EPA's Office of Water said,

"The U.S. EPA team was extremely gratified by the level of interest shown by local
governments for this second initiative and the level of sophistication of the applications. It is
clear that public-sector organizations are rapidly becoming aware of the value of
implementing EMS's and the value of working with U.S.  EPA.  We are delighted with the
diverse range of organizations that were selected and expect great things from each of
them."

During the two-year project, participants attend five comprehensive workshops. At each they
receive training, materials, and technical assistance to help them  accomplish EMS
milestones in each of the four implementation phases.

The Houston Port Authority, TX had the following to say about the project:

"This will be an interesting two-year process, learning with and from other organizations who
share our interest in protecting the environment while providing public services.  We plan to
convey all that we learn to our tenants, the city and county, and other port authorities so that
we can all do a better job as stewards of the environment."

 For more information on the Local Government EMS Initiative, please contact Craig Ruberti
  (cruberti@getf.org) at 703-750-6401, Faith Leavitt (fleavitt@earthvision.net) at 941-489-
  1647, or Jim Home (horne.james@epa.gov) at 202-260-5802 or visit the project web site
        (http://www.getf.org/projects/muni.cfm) for regular updates on the project.
ฉ2001  NSF                             166

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                                                                                 \
  NEIC Compliance-Focused Environmental Management System

Since the late 1980s, civil multimedia compliance investigations conducted by the EPA
National Enforcement Investigations Center (NEIC) have increasingly involved identifying
causes of observed noncompliance.  In a significant number of cases, the causes arise from
inadequate environmental management systems (EMSs). NEIC, in response, developed
key elements for a compliance-focused EMS (CFEMS) model, which have been used as the
basis for EMS requirements in several settlement agreements.  The CFEMS, which includes
a guide for using it in settlement agreements, was published in August 1997 and revised in
January 2000.3

The CFEMS elements are as follows:

   1. Environmental Policy                     8.  Environmental Planning and
   2. Organization, Personnel, and                 Organizational Decision-Making
      Oversight of EMS                        9.  Maintenance of Records and
   3. Responsibility and Accountability              Documentation
   4. Environmental Requirements              10. Pollution Prevention Program
   5. Assessment, Prevention and Control        11. Continuing Program Evaluation and
   6. Environmental Incident and                   Improvement
      Noncompliance Investigations              12. Public Involvement/Community
   7. Environmental Training, Awareness,           Outreach
      and Competence

To achieve maximum benefit from the CFEMS elements, the overall EMS in which they are
incorporated should embody the "plan, do, check, and act" model for continuous
improvement. Consequently, the compliance-focused EMS model described here is
intended to supplement, not replace, EMS models developed by voluntary consensus
standards bodies, such as the ISO 14001 EMS standard developed by the International
Organization for Standardization.

Settlement agreements that require an EMS typically include a  requirement that the
organization conduct an initial review of its current EMS, followed by development of a
comprehensive CFEMS that must be documented in a manual. The EMS manual must
contain policies, procedures, and standards for the 12 key elements, at a minimum, and
should also identify other, more detailed procedures and processes (e.g., inspections and
self-monitoring) that may be located elsewhere at the facility. After the organization has
had sufficient time to implement and refine the EMS (usually 2 to 3 years), the agreement
should require at least one EMS audit by an independent third-party auditor, with results
reported to both the organization and EPA. However, additional audits may be required, as
individual circumstances dictate
    3The document is available on NEIC's website.
    http://es.epa.gov/oeca/oceft/neic/12elmenr.pdf
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                                                                                     \
The intended result of this approach is twofold: first, to have the organization develop an
EMS that will both improve its compliance with applicable environmental requirements and,
second, to improve its environmental performance by achieving the organization's
environmental targets and objectives.

The January 2000 revision involved enhancing several of the elements and more completely
incorporating the due diligence provisions of the EPA audit policy.  Refinement continues
through settlement negotiations, and discussions with EPA staff, EMS consultants, and
environmental personnel from several companies with medium-size and large facilities.
ฉ2001  NSF                             168

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              Appendix C:



Information on Process Mapping and Design



             for Environment
ฉ2001 NSF              169

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                     Introduction to Process Mapping
Organizations operate using a collection of processes. A process can be defined as a
method of doing something, generally involving a number of steps or actions.  An EMS is
one example of linked organizational processes that are directed at a specific purpose.
Most organizations employ a variety of processes to carry out their core functions, such as
manufacturing a product or providing a service.

A process typically has four components.  Two of these are inputs (the items to which action
is done) outputs (the results of those actions).  In addition, a process has controls (which
direct the action) and  mechanisms (which are the resources that actually perform the
action). Mechanisms can be people or machines that change the inputs to the outputs.
Other concepts that are important to process mapping are process boundaries (which define
the limits of a particular process from its larger environment), suppliers (who provide the
process inputs) and customers (whoever receives the output of the  process).

Process mapping is a tool that allows an organization to visualize and understand how work
gets accomplished and how its work processes can be improved. It is a simple but powerful
tool through which an organization can focus its efforts where they matter most and
eliminate process inefficiencies.  Used properly, process mapping can help an organization
understand its environmental aspects and reduce wastes and pollution.  It also can help an
organization to reduce operating costs by identifying and eliminating unnecessary activities.

As an EMS tool, process  mapping can help an organization to:

       •   improve its understanding of existing processes, including the key inputs
          (such as chemicals, raw materials and other resources used), outputs (including
          products, wastes, air emissions, etc.) and interactions with other processes.

       •   identify areas for process improvement that can result in environmental
          performance improvements (such as pollution prevention opportunities)

Overtime, processes are often modified many times in seemingly small ways. Overtime,
these process modifications can result in a process that is ineffective. This is  one of the
bases for the concept of "re-engineering" which seeks to examine processes in a holistic
manner to ensure they are effective and necessary to achieve an organization's mission.

Getting Started on Process Mapping
•  Select a process (or set of related processes) to examine.  Processes might be
   prioritized for review based on a number of criteria, such as relevance or importance to
   the organization, prior assessments of the process, existing knowledge of the
   environmental  significance of the process, or history of problems with the  process,
   among others.  Define the process boundaries.

•  Use a team to  understand and map how these existing process(es) work.  At a
   minimum, the team should include the process "owner" as well as individuals that are
   actively involved in carrying out the process. Many organizations use a facilitator that is
   independent of the process under review to manage team meetings. Don't be surprised
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                                                                                    X

   if a diversity of opinions exists among team member exist regarding how the existing
   process works.

•  Clarify the objectives of the process under review. Each process should have a
   primary customer and a primary performer, although additional (secondary) customers
   and performers also might exist.

•  As a team, determine the level of detail needed to accurately map your processes.
   Initially, you might map at a fairly high level, then get into more detail as improvement
   opportunities as identified.

•  Decide on a set of symbols that the team will use to visually describe the process. For
   example, use one symbol for work steps, another symbol for process inputs, a third
   symbol for process outputs, a fourth symbol for decision points, a fifth symbol for
   measurement points, etc.

•  Identify the key steps (or "unit operations") in the process first, then go back and
   analyze each of these steps in more detail.  Use lines or arrows to show the
   relationships among individual process steps. Use  brainstorming and/or storyboarding
   techniques to identify the process steps, then agree upon the sequence of these steps.

•  Start with the preparation of an "as is" map that describes how the process works
   now, including key process inputs to and outputs. For environmental purposes, key
   inputs might include energy and other resources consumed, and raw materials and
   chemicals used.  Outputs might include products or services, air emissions, wastewater
   discharges, solid and hazardous wastes. This "as is" map can be analyzed to identify
   environmental aspects and key opportunities for improvement.

•  Some processes can be extremely complex and might consist of numerous sub-
   processes.  If the team gets bogged down, it might examine and map some of the key
   sub-processes first, rather than trying to tackle the entire process at once.  As a rule of
   thumb: If the process is so complex that it cannot be shown on a single page, then it
   might be a good candidate for re-engineering.

•  Depending on the purpose of the process mapping  exercise, the analysis of the "as is"
   map can lead to the  preparation of a modified map that defines how the re-engineered
   process is intended to function.

•  A variety of tools and materials can be used to prepare process maps. For example, a
   number of commercial software packages exist. However, you can also employ simpler
   methods, such as self-sticking removable ("Post-It") note pads. These are particularly
   useful for moving individual process steps around on a board.

A sample process map for a printing operation is shown at the end of this section.
ฉ2001 NSF                             171

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Conclusion

Process mapping can provide a solid foundation for understanding and continually
improving an organization's processes.

Viewing processes graphically helps an organization to see things that otherwise might not
be apparent. Once a process map has been prepared, it can be used as training tools as
well as for internal and external  communications.

Process mapping has several important benefits for an EMS. First, it allows an organization
to understand its current environmental aspects and impacts as well as the specific
operations and activities from which they arise.  Second, it provides a basis for enhancing
an organization's processes in a manner that can improve both environmental and financial
performance.
ฉ2001  NSF                             172

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         Sample Process Map for Printing Operation
    Packaging

   - skids & pallets
   kraft wraps
  Supplies
- spray powder
shop towels
    Raw
  Materials
  - plates
- paper& ink
water
:  Chemicals
  - cleaning
   solvents
ink preservers
plate gums




1 '
PRODUCTS
brochures
catalogs
art prints
annuals


waste paper *
*
[ recycled ]|

fugitive air 1
emissions 1
|
atmosphere j|
i
distill
1
1
PRINTING PR
^ r
web dryer PI
emissions
II
i

i

thermal PI
oxidizer
II
i

atmosphere
1

"Hi


^


recovered
solvents
F
ation



i







<


ESS ^-
ki__ \^ \^ -ซi —

waste ink

waste solvents

waste solutions

waste plates

waste packaging

waste oil & antifreeze

solvent-containing tc
	 1 	
JL
	 -\
centrifuge ^
^ ^~
r
secondary use in
parts washers


j-*-[ recycled ]

*-*{ fuel blend ]|

-^e^^
	 ป{ sewer ]|
	 >{ recycled ]

r-*{ recycled )

>-^ trash J|


	 ^ recycled )|

)wels

\ '
spun shop
towels
V
commercial laundry
1 r
       recycled back to company
ฉ 2001 NSF
            173

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                 Information on Design for Environment
Every product or service has some impact on the environment.  Such impacts can occur at
many stages of the product or service's life cycle, from raw material acquisition to ultimate
disposal or reuse.  Just as the quality and performance characteristics of a product are
significantly affected by decisions made at the development stage, so are the product's
environment attributes.  Consideration of potential environmental impacts throughout the
product or service development process can improve both environmental and financial
performance.  By looking at each stage of a product or service life cycle, an organization
can better understand and control the potential environmental impacts.

Design for Environment (DFE) is based on techniques for integrating environmental
considerations into an organization's decisions concerning  its products and services, as well
as manner in which these products and services are generated.  In involves an
understanding of materials flows (and the environmental effects of such material flows) as
well as the comparison of alternative approaches to producing a product or service.

DFE is grounded in the use of life cycle assessment to evaluate the full range of impacts
associated with a product or service.  Such life cycle assessments allow an organization to
evaluate potential  environmental impacts and identify opportunities to make improvements.

DFE is based on an assessment of the performance, costs and risks associated with
alternatives.  The technique seeks to  encourage front-end innovation through product or
service redesign, rather than reliance on "end of pipe" controls in order to manage risks to
the environment. As such, use of the technique might result in redesign of a product
formulation, a manufacturing process, or a management practice, among other possibilities.

In general, the earlier that environmental considerations are taken into account in the
product or service development process, the more effective the results will be with respect to
environmental performance. Organizations can use an approach that includes:

     • Evaluating  information on the  environmental attributes of a product or service,
     • Designing specific measures to reduce associated environmental impacts.
     • Testing alternatives that seek  to reduce impacts, while considering other importance
        product characteristics (such as quality and performance), and
     • Applying the resulting  "lessons learned" to subsequent product or service
        development.

While it might be simpler to implement DFE practices on new products or services, an
organization also might find opportunities to apply DFE in their existing products or services.
In conducting such evaluations, an organization could consider a number of goals, such as:
   Minimizing the use of toxic materials
   Minimizing compliance costs
   Avoiding chemicals that are banned or
   restricted by customers / other parties
   Minimizing packaging
           Minimizing energy use
           Minimizing use of water, other resources
           Maximizing reuse potential
ฉ 2001 NSF
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A product or service's environmental impacts are largely based on the inputs used to make
the product (or provide the service) and the outputs generated at various stages of its life
cycle. An organization can start to apply DFE concepts by using a simple matrix to assess
the environmental impacts associated with a product, such as shown below (1).

                                      Potential Environmental Issues
Product Life
Cycle Stages
Premanufacture
(Product design)
Product
Manufacturing
Product
Packaging &
Delivery
Product
Use
Product Disposal
or Reuse
Material
Selection





Energy
Use





Air
Emissions





Water
Discharges





Solid
Wastes





For many organizations, the effective application of DFE concepts involves working closely
with their suppliers and customers. Effective communications with supply chain partners
can be critical in ensuring that an organization's products or services satisfy all their
performance needs (i.e.,  performance, durability, environmental, safety, cost, etc.)

More information on DFE can be obtained from a variety of sources (see Appendix F for
additional information sources). In particular, organizations can access information on DFE
tools and projects on EPA's DFE web site at www.epa.gov/opptintr/dfe.

(1) Adapted from "Best Current Practices: Design for Environment", Lucent Technologies,
  February 1997.
ฉ 2001 NSF
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                                                                                  X
                                                                          V
                                                                  U.S.EPA

           Integrated Environmental Management Systems

What is EPA's DIE Program?

EPA's Design for the Environment Program partners with stakeholders to help businesses
help the environment.  DfE projects help businesses design products, processes, and
management systems that are cost-effective, cleaner, and safer for workers and the public.
The DfE goals are to

       Encourage businesses to incorporate environmental information into their decision
       criteria, and

       Effect behavior change to facilitate continuous environmental improvement.

To accomplish these goals DfE and its partners use several approaches including cleaner
technology and life-cycle assessments, environmental management systems (EMS),
formulation improvement, best practices, and green supply chain initiatives.

To date, the DfE Program has brought environmental leadership to over 2 million workers at
over 170,000 facilities. Small- and medium-sized businesses recognize DfE  as a unique
source of reliable environmental (as well as performance and cost) information.

DIE'S Approach to EMSs

EPA's Design for the Environment (DfE) Program has developed an enhanced EMS
approach called Integrated Environmental Management Systems (IEMS) to help companies
achieve continuous environmental improvement.  I EMSs emphasize reducing risk to
humans and the environment, pollution prevention, and wise resource management.  DfE's
IEMS combines continuous improvement principles and tools with proven environmental
assessment methodologies.

Key IEMS components that might not be included in traditional EMSs are

       Paying close attention to process and material flows,
       Obtaining knowledge of chemicals used and their hazards  and exposures,
       Conducting substitutes assessments that can include full-cost accounting, and
       Considering and selecting cleaner technologies.

I EMSs assist companies in making sound environmental decisions as part of daily business
practices. As a result, I EMSs help companies to

       Reduce cross-media impacts and Use energy and other resources efficiently,
       Better manage the risk associated with using hazardous chemicals (both regulated
       and unregulated),
       Practice extended product and process responsibility,  and
       Integrate environmental and worker safety and health  requirements.

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DfE's IEMS approach was piloted with several small and large screen printing companies
and the Screenprinting & Graphic Imaging Association International.  The pilots
demonstrated that both small and large companies can develop and  implement
sophisticated, action-oriented lEMSs.  Several of the pilot companies are applying for ISO
14001 certification.

What IEMS Materials Are Available?

To help organizations create and document their own  lEMSs, DfE has developed an IEMS
Implementation Guide (EPA 744-R-00-011),  an IEMS  Company Manual Template (EPA
744-R-00-012), and a website. The Implementation Guide walks an organization through
the steps of developing an IEMS.  It provides simple, thorough directions that are clear even
to those unfamiliar with  environmental management planning. The Guide includes
worksheets, examples,  and step-by-step guidance on process mapping, environmental
policy development, risk assessment, and evaluating  cleaner alternatives.

IEMS information and materials may be obtained by visiting the DfE website at
www.epa.gov/dfe or by  contacting EPAs Pollution Prevention Information Clearinghouse via
email (ppic@epa.gov) or phone (202-260-1023).

Possible IEMS Roles for Lead Organizations, Associations,  Technical Assistance
Providers, and Large Companies

A lead organization such as an association, a technical assistance provider, or a large
company can greatly facilitate development of lEMSs among its members, clients, or small
suppliers.  DfE's IEMS experience shows that the IEMS development process can be much
more cost- and time-efficient  and more fun  if a lead organization takes on common
activities, such as developing a basic process map or providing group training, that each
company would otherwise do separately. Some additional ways in which a lead
organization could help companies with lEMSs include

      Adapt the IEMS Implementation Guide and other tools to reflect a given industry
      sector's unique conditions,
      Organize and lead participating companies to develop an IEMS,
      Develop sector-specific pollution prevention and regulatory information,
      Help establish environmental improvement targets and evaluate results, and
      Recognize or certify companies that participate and demonstrate results.

Opportunities For IEMS Partnerships With DfE.  If  you are interested in becoming an
IEMS partner and in leading IEMS efforts for an industry group or supply chain call DfE  at
202-260-1678.
ฉ2001 NSF                            177

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                                         X
                Appendix D:



        Registration of Environmental



            Management Systems
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Registration  of Environmental Management Systems
                                                                                    X
1st Party Audit
Internal Audit

2nd Party Audit
Customer audit of a
supplier

3rd Party Audit
Audit by another party
independent of a
supplier and its
customer
    Registration
        vs.
    Certification

Both terms refer to
describe the third-
party audit process.
Technically speaking,
"registration" applies
to management
systems, while
"certification" applies
to products.
However, in common
usage, they are
synonymous.
      Scope of
   Registration....

..is the activities and
organizations that are
included within the
EMS.

The scope should be
discussed with your
registrar before
Stage 1.	
EMS registration in this appendix refers to the process
whereby a non-biased third-party attests that an
organization's EMS conforms with the requirements of the
ISO 14001 Standard.  ISO 14001 was written to describe the
requirements for registration/self declaration and is the only
one of the ISO series of environmental standards (such as
environmental labeling or environmental performance
evaluation) to which an organization may register.  The third-
party organization that performs the registration services is
called the "registrar," and is selected by the organization that
desires registration services.

An  accredited  registrar  is  one  whose  competence  is
evaluated  by an independent third-party.  Each country of the
world  has its own  accreditation  body established  either
nationally or by  their government.  In the United States, the
accrediting body for both ISO 9000  and ISO 14001  is the
American    National    Standards    Institute/Registrar
Accreditation  Board   (ANSI/RAB).   ANSI/RAB   has
established criteria which registrars  must  meet in  order to
achieve  accreditation.    Accreditation  is  not   a   legal
requirement.  However, accreditation provides organizations
assurance  that  their   registrar  has   met   ANSI/RAB
requirements for things such as impartiality, confidentiality, a
documented  registration  system,  quality  assurance, and
policies to handle complaints and appeals.

The Registration Process

ANSI/RAB has established a two-stage registration approach
for accredited  registrars.  Registrars may have different
registration processes but must follow the basic two stage
process:

Stage 1 Planning for the Audit

The purpose  of Stage 1 is  to determine the organization's
preparedness for the registration audit. This stage includes a
document review as well as on-site visit. A review of the EMS
in light of the  possible significant environmental aspects is a
primary objective of Stage 1.
ฉ 2001 NSF
             179

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                                                                                       X
What does registration
really mean?

Registration to ISO 14001
does not mean that your
organization is a "green"
facility, is environmentally
friendly or that you have
demonstrated superior
environmental
performance.

It means that your
organization can claim it
has a documented EMS
that is fully implemented
and consistently followed.
Major Nonconformance
occurs when	

   One or more of the
   numbered requirements
   of ISO 14001  have not
   been addressed and/or;

   One or more of the
   numbered requirements
   of ISO 14001  have not
   been implemented
   and/or;

-  Several
   nonconformances taken
   together lead  a
   reasonable auditor to
   conclude that one or
   more of the numbered
   requirements  of ISO
   14001 have not been
   addressed or
   implemented
Stage 2: Evaluating Implementation

Stage 2 always takes place at the organization's location.
An  audit team  conducts  an on-site audit to evaluate and
verify through objective evidence  (interviews,  procedures,
records, etc.) that the EMS conforms to the requirements in
the ISO 14001 Standard and is implemented and maintained.

Once you achieve registration, regular surveillance audits by
the registrar are  required  by  ANSI/RAB.  These  may be
conducted once per year (with a re-audit after three years) or
at least twice per year with all 17 elements audited in a three
year period.

To what do you conform?

The answermay surprise you. Naturally you have to conform to
IS014001 Standard requirements butyou also have to conform
to:

•  Your own organization's policies and procedures: The
    EMS an  organization  designs  often goes above and
    beyond  ISO  14001 requirements. Did your environmental
    policy say your organization would promote sustainable
    development? Be an environmental leader? Continually
    improve   environmental  performance?     During  a
    registration audit, your policies and procedures become
    criteria to which you will be audited.

•  The policies and procedures of the registrar:  You will not
    be  audited to the registrar's policies and procedures but
   they will include your responsibilities (such  as timeframes
   for  corrective actions)  and  rights within the registration
    process  (such as auditor approval), and processes you
    should be aware of (such as confidentiality and  dispute
    resolution).

Why Register?

The ISO  14001  Standard  does  not  require third-party
registration.     However,   for  some  industries  such  as
automotive, a registered EMS is a mandated requirement for
thousands of suppliers to the major auto makers.  In addition,
organizations that sell their goods or services internationally
may find that EMS  registration is a strong selling point in the
global marketplace and  may enable them to obtain preferred
supplier status.

Where registration is not a direct market driver, organizations
may pursue registration for many reasons including:
   ฉ 2001 NSF
             180

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                                                                                     X
 "Sufficient data on an
 organization's
 compliance with
 relevant legislation
 and regulations,
 gathered during the
 registration review
 and surveillance, are
 relevant and
 necessary to
 determine whether or
 the organization's
 systems conform to
 the standard."

 -ANSI/RAB Criteria for
     Bodies Operating
        Registration of
        Environmental
 Management Systems
               (E3.2)
 "...while compliance is
 part of the
 management system,
 the registration audit
 is not an audit of full
 compliance with all
 applicable regulatory
 requirements."

   - ANSI/RAB Criteria
  for Bodies Operating
        Registration of
        Environmental
 Management Systems
	(E3.2).
•  Maintenance of current market position;
•  Opportunities for a competitive advantage;
•  Help ensure regulatory compliance;
•  Improve   relationships  with   regulators   and/or   the
   surrounding community; and
•  Support state and Federal regulatory incentive programs.

There  are also  important but often  unrecognized internal
benefits to registration.  Registration is a way to protect the
investment  your  organization has  made  in  your  EMS.
Knowing that you will be audited regularly by  an outside party
helps to keep  management's attention on the  EMS and
ensure that it  has the resources it needs to improve  over
time.

Registration and Compliance

A registration audit is not a compliance audit.  Difference in
the two types of audits are highlighted in Table  1.  An EMS
auditor will not perform a  detailed compliance inspection but
the will  gather data on how your organization manages its
compliance program. Pertinent questions may include;  How
do you stay informed of new requirements?  How are these
communicated  to  employees?     How  do you  evaluate
compliance with regulations?  What process  do you have for
resolving any noncompliances  identified?

Occasionally,  an  EMS  auditor may  identify a  regulatory
noncompliance during the registration  audit.  Does this mean
you automatically fail the audit? No,  it does not. The registrar
must verify that the EMS is set up to handle noncompliances
and that taken together, the noncompliances do not indicate
a major nonconformance.

Accredited  registrars are  required to have a  method for
handling  and reporting regulatory  noncompliance  identified
during a registration audit. Ask your registrar for their policy
or procedure for handling this situation.

Table 1. Difference between EMS and Compliance Audits
EMS Audit
• Focus is on systems
• Information gathered
largely through interviews
and document review
• Corrective action involves
individuals outside of the
environmental staff
Compliance Audit
• Focus is on details of
regulations
• Observation of activities
is important
• Corrective actions
involve only
environmental staff
 ฉ 2001 NSF
             181

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                                           \
               Appendix E:



   Integration of Environmental Management



  Systems and Quality Management Systems
ฉ 2001 NSF               182

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                                                                                         \
                   Integration of Management Systems

Integrating management systems has become an increasingly important  competitive issue.  A
growing body of information  indicates that organizations that  integrate their EMS  and quality
management systems (QMS)  can realize significant benefits, such as streamlined operations and
decision-making,  simplified employee training,  more efficient of resources and reduction in  audit
costs.  Systems for managing health & safety  and other organizational functions can be similarly
integrated.

The two most common models for QMS and EMS (ISO 9001  and  ISO 14001, respectively) share
many common elements. This should be no great surprise, since ISO 9001  was one of the source
documents used  by  the drafters  of ISO 14001.  The two standards are very compatible in their
current forms. The ISO committees responsible for the development and maintenance of these two
standards continue to examine potential opportunities to increase the compatibility or alignment of
the two standards.

Organizations that choose to  implement both of these  standards generally  find that they can use
many common processes to conform.  In general, the elements of a QMS and  an EMS can be
categorized as either (1) essentially the same, (2) similar or (3) unique (see  table  below).  System
elements in both  the "essentially  the same" and "similar" categories can often be addressed by a
common  procedure  (or parallel  procedures),  although some customization may  be  needed to
address the differing  overall purposes of these systems.  Unique elements are typically dealt with in
separate  (EMS  or  QMS) procedures.   Some of  the typical elements for  integration include:
document control, corrective/preventive action, training, records management and management
review.   However,  some organizations  have gone  much further - for  example, some  have
developed common (quality and environmental) policies.  The degree  of system integration varies
widely from organization to organization.

While an  EMS can be readily  integrated with an existing QMS, the overall purposes of these two
systems must be  kept in mind. A  QMS is intended primarily to ensure that an organization satisfies
its customers by assuring the quality of its products.  An EMS generally has a broader context - the
relationship between an organization and the environment in which it operates.  Also, an EMS often
concerns itself with a broader range of stakeholders, such as neighboring communities, customers
and regulatory agencies.

System integration can have environmental benefits.  By linking environmental management more
closely with day-to-day planning  and operation, some  organizations have been able to raise the
visibility of  environmental management  as a core  organizational  issue.  In addition, these
organizations enhance their abilities to address  environmental issues when making modifications to
products or processes for quality purposes.

Organizations that have a QMS in  place generally are better off when implementing an  EMS for
several reasons.  First, employees typically are  already familiar with management system concepts
and are involved in making the system work. Second, many of the  processes needed for the  EMS
might already be in place. Finally (and perhaps most importantly), top management has committed
the use of management systems to achieve organizational goals.
ฉ2001 NSF                               183

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                                                                                  \
A Few Tips on System Integration

For organizations that have an existing QMS and wish to integrate an EMS with it, some
suggestions are provided below.

ฎฐ  Understand the existing QMS,  its effectiveness  and how the workforce perceives the
   system.   Is the existing QMS documentation clear and  workable?   Do employees
   believe that the system  is helping the organization to achieve desired results?

ฎฐ  Ensure that the scope of the two systems will be consistent (i.e., that the systems will
   cover the same facilities, products, activities and/or services). In particular, this will be
   an important issue if third-party registration will be sought.

ฎฐ  Establish  a cross-functional team (including, at  a  minimum, representatives from the
   environmental and  quality functions) to determine the optimal approach to system
   integration.

ฎฐ  As needed, manage resistance to change.  Some  employees and managers may be
   reluctant to change a system that they are already familiar with and/or in which they
   have important roles.

ฎฐ  Understand how  QMS and EMS differ in purpose. While there are many common
   management system elements, there are elements of each system that are  unique (see
   below).   In the case  of EMS, these include  for example, environmental aspects,
   communications, emergency preparedness and response.  These  differences must be
   acknowledged and accommodated within the integrated management system.
         Relationship of EMS Elements to QMS (based on ISO 9001:  1994)

  Elements that are Essentially the Same            Elements that are Similar
ฎฐ Training, Awareness & Competence        ฎฐ  Environmental Policy
ฎฐ Document Control                       ฎฐ  Structure and Responsibility
ฎฐ Nonconformance, Corrective & Preventive   ฎฐ  EMS Documentation
   Action                                  ฎฐ  Operational Control
ฎฐ Calibration  (part  of  the  Monitoring &   ฎฐ  Monitoring & Measurement
   Measurement element)                   ฎฐ  EMS Audit
ฎฐ Records                                ฎฐ  Management Review

        Elements that are Unique
Environmental Aspects
Legal and Other Requirements
Objectives & Targets
Environmental Management Program(s)
Communications
Emergency Preparedness & Response
ฉ 2001 NSF                             184

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                                                                                   \
•  Modify system documentation as  required.   Keep procedures simple and clear for
   users.  Review proposed changes with affected managers and employees.

•  On a procedure-by-procedure basis, consider whether to integrate procedures or keep
   them separate.  While integration can reduce  the total number of procedures or work
   instructions, it also can confuse the overall purpose of such procedures in some cases.

•  Once  the integrated system documentation has been prepared, train managers and
   employees on the integrated system.

•  Audit the integrated system and take actions as necessary.
                        A few final thoughts on system integration:

        •   Can your organization afford to have two or more separate systems?

        •   Are there compelling reasons to keep these systems separate?

        •   What is the optimal approach from a strategic and operational standpoint?

        •   What approach is best suited for the organization's change and growth?
ฉ 2001 NSF
185

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                                              X
                 Appendix F:



      Additional Sources of Information and



                   Contacts
ฉ 2001 NSF                 1 86

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                                                                                         X
             Appendix F: Additional  Sources of Assistance

There are many resources available to help your organization develop and implement an EMS that are
free of charge or relatively inexpensive. The following is a description of some of these resources.

Federal Government Agencies

The U.S.  Environmental Protection  Agency (USEPA) provides information on a number of topics
that can be useful in  the development and implementation of an EMS.  Some of these resources
include:  assistance with interpretation of environmental laws and regulations; information on pollution
prevention technologies (case studies and fact sheets);  and hotlines  to answer questions about
environmental issues.  The  Agency also has  web sites for information on EMS's and  Design for
Environment.  The USEPA's Office of Compliance has established national Compliance  Assistance
Centers for various industry sectors.

The  Small Business Administration  (SBA) provides  assistance  to small  and  medium-sized
organizations.   The  SBA  can provide  information  and assistance related to:   operation and
management of a business; sources of financial assistance; international trade; as well as laws and
regulations.

State Agencies

Your state environmental regulatory agency can provide assistance with the development of an EMS.
Contact your  state  environmental  agency and inquire about  education  and outreach  programs for
organizations  that are developing  an  EMS.  Many state environmental agencies also can provide
publications,  pamphlets, and  on-line  help related  to  state environmental laws, innovative pollution
prevention technologies, waste reduction, and permitting.  Some  states (such as North Carolina,
Wisconsin and Virginia)  have developed programs to  help organizations implement and EMS and/or
seek ISO  14001  registration.  Recently,  several states (including  Texas and Virginia) established
"EnviroMentor" programs within their Small Business Assistance Offices.  These mentoring programs
are intended to help small companies comply with regulations.

Associations

Industry trade associations  can provide  assistance with the  development of  an EMS.  These
organizations can provide information on industry-specific environmental management issues, and can
put you in contact with  other organizations that can  share their experience and expertise in  EMS
implementation.

Colleges and Universities

Some colleges and universities provide EMS-related training or manage EMS demonstration projects.

Chambers of Commerce

Your local or state chamber of commerce might be helpful in providing  information about legislative
and  regulatory issues  that  affect  environmental  management  for  small and medium- sized
organizations. Other services that are commonly offered include handbooks,  workshops, conferences
and seminars.
ฉ 2001 NSF                                187

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                                                                                            X
Non-Profit Organizations

Another resource to consider is the Manufacturing Extension Partnership (MEP), which is a growing
nationwide system of services that provide technical support to businesses interested in assessing and
improving their current manufacturing processes.  The MEP is a partnership of local manufacturing
extension centers  which  typically  involve  federal,  state, and local  governments,  educational
institutions,  and other sources of information and funding support. The MEP can also often provide
assistance with quality management, development of training programs and business systems.

The Industrial Technology Institute (ITI) is a non-profit organization dedicated to expanding technology
access and technology management among U.S. manufacturers.  ITI provides technical assistance to
small  and medium-sized organizations through the Michigan Manufacturing Technology Center.  ITI
also has experience with the development of business performance tools and provides services for
energy,  environment, and manufacturing assessments; as well as, QS 9000 and ISO 14000 training
and implementation.

Other Organizations

Another recommended  source of information and expertise is the organizations with which you do
business. It is likely that your suppliers and customers have experience with many of the aspects of
an EMS, and might be willing to share their experiences and provide advice to your organization.

On-line Resources

There is a wealth of information related to EMS implementation available electronically via the Internet.
Many state, federal, and local agencies have home pages on the Internet containing information that
can be useful to your organization.  Numerous non-governmental  organizations have home pages that
contain  information on  topics such   as  ISO  14000,  pollution prevention, recycling  and  waste
minimization,  environmental laws  and regulations,  innovative manufacturing technologies,  and
materials substitution.  If your organization  does not have Internet access, contact your local library to
see if it provides Internet access to users.
Additional EMS resources and contacts are described on the following table.
ฉ 2001  NSF                                  188

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                                                                                                                                     X
                                                     Appendix F (cont'd.)
                                  Additional Sources of Information and  Contacts
Note: This list is not intended to be comprehensive. Appearance on this list should not be construed as an endorsement by NSF of any products/service.

                                                       FEDERAL AGENCIES
     Organization
 US Environmental
 Protection Agency
          Resource

Small Business Compliance
Assistance Centers:
                       Design for Environment Guide,
                       Fact Sheets and DFE EMS
                       Template
                       Small Business Compliance
                       Policy
                       Compliance-Focused EMS
                       Enforcement Agreement
                       Guidance

                       Environmental Compliance
                       Auditing Protocols
                       Code of Environmental
                       Management Principles
                       Pollution Prevention
                       Clearinghouse
 Telephone Number / Internet Address

202/564-7066 (general information)
                              www.epa.gov/opptintr/dfe/tools/ems/
                              ems.html
                              202/564-7072
                              www.epa.gov/oeca/smbusi.html
                              http://es.epa.gov/oeca/oceft/neic/
                              12elemnr.pdf
                              EPA National Service Center
                              1-800-490-9198
                              www.epa.gov/oeca/ccsmd/profile.html
                              www.epa.gov/oeca/cemp/cemptoc.html
                              202/260-1023
              Description

Centers are Internet Web Sites with
comprehensive environmental compliance,
technical assistance, & pollution prevention
information for various industry sectors.

Website contains information on EMS and
how to incorporate DFE into an EMS.
Provides a how-to manual for implementing
a DFE-based EMS and a set of integration
tools for companies that already have an
EMS.

Effective May 11, 2000, this policy
supercedes the June 1996 version.
Published in the Federal Register on April
11,2000 (65FR19630).

Presents the key elements of a compliance
focused EMS model.
                                     These protocols are intended to guide
                                     regulated entities in the conduct of
                                     compliance audits and to ensure that audits
                                     are conducted in a thorough manner.

                                     Collection of five broad principles and
                                     performance objectives that provide a basis
                                     for environmental management among
                                     Federal agencies.

                                     Technical Information on materials and
                                     processes, including publications related to
                                     waste minimization and pollution prevention.
ฉ 2001 NSF
                                           189

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                                                                                                                                          X
                                                         FEDERAL AGENCIES
 U.S. Small Business
 Administration
 Government Printing
 Office

 US Department of
 Energy
                        Office of Wastewater
                        Management

                        Public Information Center

                        RCRA / Superfund Hotline
                        Technology Transfer and
                        Support Division

                        TSCA Hotline
                        Enviro$en$e
                        US EPA Home Page
SBA Answer Desk
                        SBA Home Page
GPO Superintendent of
Documents
                               www.epa.gov/owm/iso2/htm


                               202/260-7751


                               800/424-9346
                               202/382-3000
                        Small Business and Asbestos     800/368-5888
                        Ombudsman                    202/557-1938
513/569-7562



202/554-1404



http://es.inel.gov





http://www.epa.gov




1-800-8-ASK-SBA



http://www.sbaonline.sba.gov




202/512-1800
Pollution Prevention Information   http://www.er.doe.gov/production/esh/
Clearinghouse                   epic.html
Provides information on various EPA-
sponsored EMS projects.

General information about EPA programs.

Provides information about hazardous waste
regulations and handles requests for federal
documents and laws.

Information and advice on compliance
issues for small quantity generators of
hazardous waste.

Access to the ORD research information and
publications.

Assistance and guidance  on TSCA
regulations.

Solvent alternatives, international, federal
and state programs, other research and
development. Also, environmental profiles
of various industrial categories.

Information about EPA regulations,
initiatives, and links to the home pages of
other agencies and EPA regional offices.

Information about SBA programs, and
telephone numbers for local offices.

Information about business services
available to your organization, with links to
other related  sites.

Information about available documents and
instructions on ordering GPO publications.

Pollution prevention and environmental
design information.
ฉ 2001 NSF
                                             190

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                                                                                                                                           X
      Organization

 State Environmental
 Protection Agencies
          Resource

Environmental Assistance
Programs
                         Small Business Assistance
                         Programs (Mandated under Title
                         V of the Federal Clean Air Act).
    STATE AGENCIES

 Telephone Number / Internet Address

Contact your state's Environmental
Protection Agency
                               Call the EPA Small Business
                               Ombudsman (800/368-5888) for the
                               phone number and address of the Small
                               Business Assistance Program in your
                               state.
              Description

Many state environmental protection
agencies provide  publications, technical
assistance, and information on pollution
prevention technologies, waste reduction,
and regulatory compliance,  at little or no
charge.

Provides information and technical
assistance to small businesses regulated
under the Clean Air Act.
 State Environmental
 Protection Agencies
 (cont'd)
                         State and Local Pollution
                         Prevention Programs
Michigan Department of
Environmental Quality
                               Contact the National Pollution Prevention
                               Roundtable (202/466-7272) for the phone
                               number and address of the pollution
                               prevention program in your state.
http://www.deq.state.mi.us
                                       Provides information and technical
                                       assistance on pollution prevention.
Fact sheets, training, and technical
assistance.
                         Minnesota Technical Assistance
                         Program

                         Ohio Department of
                         Environmental Protection
                               http://es.inel.gov/techinfo/facts/mpca/mpc
                               a.html

                               http://arcboy.epa.ohio.gov
                                       Fact sheets on pollution prevention,
                                       materials substitution.

                                       Fact sheets on pollution prevention,
                                       materials substitution.
                        Wisconsin Department of         http://es.inel.gov/techinfo/facts             Fact sheets on pollution prevention,
                        Natural Resources                                                      materials substitution.
Note: The list shown above represents only a sample of the resources that may be available from state agencies. Contact your state
agency for details of existing programs and other forms of assistance available
ฉ 2001 NSF
                                             191

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                                                                                                                                        X
                                                     EMS SOFTWARE PACKAGES
Organization
Greenware
EMSoft2000
ISOXpert
ISOSoft 14001
Contact Info
1-800-474-0627
www.greenware.com
1-800-241-3618
www.rmtinc.com
1-800-1 SO-EASY
416-679-0119
www.isogroup.simplenet.com/soft14k
Description
Provides ISO 14001 assessment, implementation and audit
software
Software package based on LotusNotes to support EMS
implementation
Built on LotusNotes platform. Customizable document formats.
Provides ISO 14001 assessment, implementation and audit
software. Co-developed with BSI.
             Organization

 Industrial Technology Institute (ITI)
 Manufacturing Extension Partnership
 (MEP)
             NON-PROFIT ORGANIZATI'

            Address                Phone Number
2901 Hubbard Road
P.O. Box 1485
Ann Arbor, Michigan 48106-1485
Building 301, Room C121
National Institute of Standards and
Technology
Gaithersburg, Maryland 20899-
0001
1-800-292-4484
Fax:1-313-769-
4064
1-301-975-5020
1-800-MEP-4MFG
Fax:1-301-963-
6556
              Description

Technical assistance to small and mid-sized
manufacturers. Energy, environment, and
manufacturing assessments, as well as
performance benchmarking, and QS 9000
and ISO 14000 implementation assistance.

Assists manufacturers with assessing
technological needs, and works to help small
manufacturers solve environmental problems
with cost-effective solutions.
 North American Commission on
 Environmental Cooperation

 "Improving Environmental Performance
 and Compliance: 10 Elements of Effective
 Environmental Management Systems"
www.cec.org/pubs_info_resources/
publications/enforce_coop_law/ems
.cfm?varlan=english
514/350-4334        Joint expression from three North American
(Commission)        governments regarding how voluntary EMS's
                    designed for internal management purposes
202/564-7048        can also serve broader public policy goals,
(USEPA)            such as compliance assurance and improved
                    environmental performance.
ฉ 2001 NSF
                             192

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                                                                                                                                             X
                          Resource
 ANSI Online
 Business Resource Center
 Canadian Standards Association
INTERNET RESOURCES

                Internet Address

     http://www.ansi.org




     http://www.kciLink.com/brc



     http://www.csa.ca/isotcs
 Clean Technologies Center (UCLA)                             http://cct.seas.ucla.edu

 Consortium on Green Design and Manufacturing (DC-Berkeley)    http://euler.berkeley.edu/green/cgdm.html

 Environmental Technology Gateway                             http://iridium.nttc.edu/environmental.html
 International Corporate Environmental Reporting Site
 Industrial Technology Institute Home Page
 International Network for Environmental Management
 ISO 14000 Information Center
     www.enviroreporting.com
     http://www.iti.org
     www.inem.org
     http://www.iso14000.com
            Description

Contains information related to the
American National Standards
Institute, including meetings, events,
and standards information databases.
Provides information on a variety of
topics, including tips on management,
recycling, and financing.

A center for information and services
related to ISO 9000 and ISO 14000,
maintained by the Canadian
Standards Association.

Innovative technologies for pollution
prevention.
Environmental design and
sustainable development.
Access to other environmental links
and information, environmental
technologies.

International news about
environmental issues and resources
for environmental reporting.

Information about ITI, how to find
environmental information on the
Internet, and links to other
organizations.

Case studies, publications and how-
to information on environmental
management. Interactive topis for
assessing environmental policies and
reports.
Answers to questions on ISO 14000
ฉ 2001 NSF
             193

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                                                                                                                                        X
                                                       INTERNET RESOURCES
                         Resource
 ISO 14000 Integrated Solutions (ANSI/GETF)
 ISO Online
                 Internet Address
                             Description
                                                                                                   standards.
                                                            http://www.gnet.org
      http://www.iso.ch
 Multi-State Working Group                                    www.mswg.org


 National Environmental Information Resources Center (NEIRC)     http://www.gwu.edu/~greenu/
 NSF-ISR Home Page
      http://www.nsf-isr.org
                                        AUTHORIZED SOURCES OF THE ISO 14000 STANDARDS
                 Will provide training, conferencing,
                 on-line information services and
                 publications on a fee basis.

                 The ISO homepage provides
                 information on ISO, its structure,
                 members, technical committees,
                 meetings, and events.

                 Describes the activities of this group
                 regarding EMS and ISO 14001.

                 Provides  access to a wide variety of
                 information about environmental
                 matters, with links to hundreds of
                 organizations.

                 Contains information on NSF
                 International and its pilot projects in
                 EMS implementation.
 NSF International (NSF)


 American National Standards Institute (ANSI)


 American Society for Quality (ASQ)



 American Society for Testing and Materials (ASTM)
Phone: 1-888-NSF-9000
Fax: 1-734-827-6801

Phone: 1-212-642-4900
Fax:1-212-398-0023

Phone: 1-414-272-8575
Fax: 1-414-272-1734

Phone:1-610-832-9585
Fax: 1-610-832-9555
789 N. Dixboro Road
Ann Arbor, Ml 48105
          ,nd
11 West 42"u Street
New York, NY 10036
Milwaukee, Wl
West Conshohocken, PA
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              194

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                          Glossary of Acronyms

ACC       American Chemistry Council
ANSI       American National Standards Institute
API STEP  American Petroleum Institute's "Strategies for Today's Environmental Partnership"
CAA       Clean Air Act
CEC       Commission for Environmental Cooperation
CERCLA   Comprehensive Environmental Response, Compensation and Liability Act
CERES     Coalition for Environmentally Responsible Economies
CFCs      Chlorofluorocarbons
CM A       Chemical Manufacturers Association
CWA       Clean Water Act
DFE       Design for Environment
EHS       Environment, Health and Safety
EMAS      Eco-Management and Audit Scheme
EMS       Environmental Management System
EPA       (Also USEPA) U.S. Environmental Protection Agency
EPCRA     Emergency Planning and Community Right-to-Know Act
FIFRA      Federal Insecticide, Fungicide and Rodenticide Act
HMTA      Hazardous Materials Transportation Act
ICC        International Chamber of Commerce
ISO        International Organization for Standardization
ITI         Industrial Technology Institute
MEP       Manufacturing Extension Partnership
OSHA      Occupational Safety and Health Administration
PCBs      Polychlorinated Biphenyls
P2         Pollution Prevention
QMS       Quality Management System
RCRA      Resource Conservation and Recovery Act
SBA       U.S. Small Business Administration
SPCC      Spill Prevention Control and Countermeasure
TC 207     Technical Committee 207 (of ISO)
TSCA      Toxic Substances Control Act
TQM       Total Quality Management
USTAG     U.S. Technical Advisory Group (to TC 207)
VOCs      Volatile Organic Compounds
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                                Bibliography
•  Canadian Standards Association, Competing Leaner, Keener and Greener: A Small
  Business Guide to ISO 14000,1995.
•  Cascio, Joseph, editor. The ISO 14000 Handbook.  CEEM Information Services with ASQC
  Quality Press, 1996.
•  Diamond, Craig P., "Voluntary Environmental Management System Standards: Case
  Studies in Implementation."  Total Quality Environmental Management, (Winter 1995/1996),
  pp. 9-23.
•  GETF, The USEPA Environmental Management System Pilot Program for Local
  Government Entities, January 2000.
•  Hillary, Ruth, Evaluation of Study Reports on the Barriers, Opportunities and Drivers for
  Small and Medium Sized Enterprises in the Adoption of Environmental Management
  Systems, October 1999.
•  Institute of Quality Assurance, Quality Systems in the Small Firm: a Guide to the Use of the
  ISO 9000 Series,  March 1995.
•  International Organization for Standardization, ISO 14001: Environmental Management
  Systems - Specification with Guidance for Use. 1996.
•  International Organization for Standardization, ISO 14004: Environmental Management
  Systems - General Guidelines on Principles, Systems, and Supporting Techniques.  1996.
•  Kuhre, W. Lee, ISO 14001 Certification: Environmental Management Systems, 1995.
•  Lucent Technologies, Best Current Practices: Design for Environment, February 1997.
•  Michigan Department of Commerce and Natural Resources, Environmental  Services
  Division, Business Waste Reduction: Creating an Action Plan, November 1994.
•  Northern Environmental, ISO 14001 Guide for Small to Medium-Sized Companies, 2000.
•  NSF-ISR, Implementing Environmental Management Systems in Community-Based
  Organizations,  1998.
•  NSF-ISR, Environmental Management Systems: A Guide for Metal Finishers, 1998.
•  Tibor, Tom with Ira Feldman, ISO 14000: A Guide to the New Environmental Management
  Standards, Irwin Professional Publishing, 1996.
•  United Nations Environment Programme (UNEP), the International Chamber of Commerce
  (ICC), and the International Federation of Consulting Engineers (FIDIC).  Environmental
  Management System Training Resource Kit.  Version 1.0, December 1995.
•  United States Postal Service, Environmental Resources Handbook.  November 1995.
  Us Environmental Protection Agency, Implementation Guide for The Code of Environmental
  Management Principles for Federal Agencies, March 1997.
  Voehl, Frank; Jackson; and Ashton, ISO 9000: An Implementation Guide For Small and Mid-
  Sized Businesses, St. Lucie Press, 1994.
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