Achieving Environmental Excellence:
An Environmental Management Systems (EMS)
Handbook for Wastewater Utilities
August 2004
'v.
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Environmental Management Systems
(EMS) Handbook for Wastewater Utilities
Table of Contents
Foreword 1
Introduction 4
Section 1:
What is an EMS and Why Would a Wastewater Facility Implement One? . . .9
Section 2:
Getting Ready to Implement an EMS 23
Section 3:
Phase II Planning 43
Environmental Policy 45
Legal and Other Requirements 53
Environmental Aspects and Impacts 61
Objectives and Targets and Environmental Management Programs 75
Phase III Implementing 91
Training Awareness & Competence 93
Communication - Internal and External 101
EMS Documents and Records 109
Operational Control 117
Emergency Preparedness and Response 123
Phase IV Checking and Corrective Action 133
Monitoring and Measurement 135
Internal Auditing 145
Nonconformance and Corrective/Preventative Action 155
Phase V Management Review 163
Management Review 165
Section 4:
Third-party Registration 171
Section 5:
Maintaining Your EMS 181
Section 6:
Conclusion 183
Appendix A: EMS Sample Documentation 185
Appendix B: EMS Implementation Toolbox 345
Appendix C: Additional Sources of Information 414
Appendix D: EMS Glossary 420
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EMS Handbook for Wastewater Organizations
Foreword
Dear Colleagues:
Water and wastewater utility managers are facing
unprecedented challenges today as they address a
wide array of issues ranging from increased public
expectations for service levels, improved
environmental performance and compliance,
sustainable infrastructure expectations/needs,
changing work force demographics, and more
stringent regulatory standards. To help them address
these challenges on an ongoing basis, a number of
utilities are developing environmental management
systems (EMS) for their operations.
Environmental management systems, first used in
the private sector, provide organizations of all types
with a structured framework for 1) assessing the
organization's environmental impacts, 2) establishing
policies along with measurable, goals, objectives,
and programs for reducing these impacts, 3)
checking and taking corrective action to ensure the
EMS is meeting its goals, and 4) periodically having
top management review the system to ensure
continual improvement. An EMS is not a substitute
for meeting regulatory requirements, but can enable
an organization to both perform at levels beyond the
minimum levels established for compliance and
address environmental impacts, such as noise and
odor, that may not be regulated. Finally, an EMS
provides a way for an organization to continually
manage and integrate its environmental obligations
for all its programs and projects.
Development of this Wastewater EMS Handbook was
funded through a cooperative agreement between
the Office of Wastewater Management (OWM) at the
U.S. Environmental Protection Agency (EPA) and the
Global Environment and Technology Foundation
(GETF). In order to reflect the real life experiences of
wastewater organizations that have implemented
EMSs, EPA and GETF asked a small group of
utilities and other professionals to serve on a
Steering Committee for this project.
Throughout the Handbook, you will see numerous
examples from our organizations that we hope will
make it easier for you to develop your own EMS. We
are also providing sample documents from all phases
of the EMS process, including information on the
time and cost of developing an EMS.
Based on our own experiences as well as those of
many other public agencies, it is clear that EMSs
work. They can and do provide a wide array of
benefits to organizations. Our agencies have seen
reduced costs, improved environmental performance,
significantly enhanced internal communication, and
better relations with our communities and regulators.
Examples of these benefits and advice based on our
experiences are included throughout the Handbook.
Successfully implementing an EMS requires both a
sustained commitment of time and resources and
sustained top management support. However, we
believe the benefits of the system far outweigh
the costs.
EMSs also provide an excellent framework for
integrating other important utility management
programs like asset management, CMOM, the
Balanced Scorecard, QualServe, and others. Many of
us have used our EMSs in conjunction with these
other programs. In conclusion, we appreciate the
opportunity to help produce this Handbook and share
our experiences with our colleagues. It fills an
important need for our industry and will hopefully
encourage an increasing number of utilities to
develop their own EMSs and realize the benefits we
have witnessed.
Introduction
Wastewater EMS Handbook
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EMS Wastewater Steering Committee
Donna J. Adams
Environmental Health & Safety
Coordinator
Wastewater Division
Department of Public Works
City of Eugene, Oregon
Ellen R. Barrett
President, The Barrett Group
Fort Mill, South Carolina
Richard E. Bickerstaff, Jr.
Assistant Superintendent
Wastewater Collection Department
Commissioners of Public Works
Charleston, South Carolina
Beth Eckert
EMS Coordinator
City of Gastonia, North Carolina
David James
Texas Natural Resources
Conservation Commission
Department: SBEA
Austin, Texas
James Naber
Buncombe County
Metropolitan Sewerage District
Asheville, North Carolina
Jim Newton, P.E., DEE
Environmental Program Manager
Kent County Public Works Department
Dover, Delaware
' /
Eileen O'Neill
Director of Training and
Technical Services
Water Environment Federation (WEF)
Alexandria, Virginia
Chris Toth, PE.
Deputy Director
Wastewater Collection Division
City of San Diego, California
Introduction
Wastewater EMS Handbook
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Acknowledgements
This Environmental Management System (EMS)
Handbook for Wastewater Organizations was
developed under Cooperative Agreement Number
82895101 awarded by the U.S. Environmental
Protection Agency (U.S. EPA). In preparing this
Handbook, the authors solicited input from a variety
of wastewater facilities and wastewater industry
experts that have been through EMS planning and
implementation activities.
U.S. Environmental Protection Agency
Jim Home - Office of Water
Global Environment & Technology Foundation
Sarah Brachman
Scott Christian
Jeff DuTeau
Ladeene Freimuth
Julia Herron
Faith Leavitt
Nick Martin
George Mocharko
Noeleen Tillman
Peer Group Members
Paula Dannenfeldt
Deputy Executive Director
Association of Metropolitan Sewerage Agencies
(AMSA)
Deann Desai
Project Manager
Center for International Standards & Quality (CISQ)
Georgia Tech University
Ed McCormick
Director of Support Services
East Bay Municipal Utility District
Jay Stowe
Utilities Director
Shelby, North Carolina
Charles Sutfin
Deputy Director, Office of Superfund Remediation
and Technology Innovation
US Environmental Protection Agency
Introduction
Wastewater EMS Handbook
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Where Did the Idea for an
EMS Wastewater Handbook Begin?
On September 23, 2003, the U.S. Environmental Protection Agency and the Global
Environment & Technology Foundation (GETF) brought together an informal
Environmental Management Systems (EMS) Wastewater Steering Committee
comprised of wastewater facility managers with expertise and "hands on" experience in
developing and maintaining EMSs for wastewater operations. Five members of this
Steering Committee manage ISO 14001 registered EMSs within their respective
organizations.
Each had the same thought after reflecting on their individual EMS implementation
experiences: "There's so much we wish we had known before we began our EMS
implementation. Let's capture that information in a handbook to help our colleagues in the
wastewater industry demystify EMS implementation, provide step-by-step guidance, relate
our lessons learned, and provide case study examples, implementation tools and materials
that come from real wastewater facilities." Since the number of wastewater utilities
implementing an EMS has grown considerably over the last several years, the committee
felt that the time was right for a wastewater specific EMS handbook. And so, with the
support and assistance of U.S. ERA'S Office of Wastewater Management, this handbook
was developed.
The Steering Committee agreed to assist GETF and U.S. EPA in developing a
Wastewater EMS Handbook that specifically focuses on EMS implementation by public
wastewater utilities. Each Steering Committee member provided their respective EMS
document samples, implementation cost data, resource savings, case studies and EMS
shortcuts, and agreed to be actively involved throughout the development process to
ensure that the document would meet the needs of wastewater facility employees
tasked with EMS implementation.
How is this Handbook Different from Others?
The EMS Handbook for Wastewater Organizations (referred to hereinafter as the
"Wastewater EMS Handbook" or "Handbook") is written for wastewater facility operators
and managers interested in or already in the process of implementing an EMS based
on the ISO 14001 international standard (ANSI/ISO 14001 - 1996) and looking for guid-
ance from wastewater colleagues who have implemented and maintained EMSs at
their own wastewater treatment facilities. While the implementation guidance could very
well serve other public or private sector facilities, all of the material comes from real life
wastewater operations and is intended to benefit wastewater operators interested in
enhancing their own understanding of EMS through the successful approaches and
practical lessons of their wastewater industry peers.
Wastewater facilities have taken a leadership role in public sector EMS implementation
since the adoption of the ISO 14001 EMS in 1996, so there is a wealth of data and
information available. In fact, the guidance, information and materials collected here
come from well over a dozen wastewater facilities. In addition, care has been taken to
ensure representation from a range of facility sizes (daily average flows from 13 MGD
to 180 MGD) across the United States in order to meet the diverse needs of the
wastewater sector.
The Wastewater EMS Handbook builds on a number of excellent EMS implementation
guidance documents that preceded it (see additional EMS information). These guides
are well worth noting as information resources; they provide excellent contact
Introduction
Wastewater EMS Handbook
-------
information, document samples, web links, and additional information resources across
a wide variety of public sector operations. You will find that their implementation
strategies are reasonably consistent with those in this Handbook. However, this
Handbook focuses exclusively on information, data, tools and materials that come
directly from the wastewater sector, and reflects the most up-to-date information
possible about implementing EMSs in wastewater facilities. As you become involved in
your own EMS implementation, we hope that you will consider sharing your best EMS
practices to keep this Handbook current.
How this Handbook is Organized
This Wastewater EMS Handbook guides you through EMS implementation based on
the Plan-Do-Check-Act model of the ISO 14001 Environmental Management System.
The Handbook is designed primarily for EMS implementers, so the heart of it is a
step-by-step guide that shows you how to build your EMS one element at a time. We
have also added helpful sections to assist you in getting your organization ready to
build its EMS, in understanding more about third-party registration of your EMS, and in
accessing a number of appendices of additional tools, materials, and information
resources.
The Wastewater EMS Handbook is organized into 5 sections:
1. What is an EMS and Why Do I Want One
2. Getting My Facility Ready to Implement an EMS
3. Step-by-Step Implementation Guide
4. Third-Party EMS Registration
5. Appendices
In each of the sections you'll find a list of EMS milestones to complete and a suggested
timeframe for completing them. As you work to complete each of these EMS
milestones, you'll be accomplishing an important step in building your EMS, using an
implementation strategy that has been successful with dozens of utilities over the past
seven years.
This implementation strategy is sequenced so that you can build your EMS one piece
or element at a time. We strongly urge you to focus only on the activities and
milestones described in the section you are working on. You do not have to do
everything at once so there is no need to get ahead of yourself or worry about what is
coming next. In each section and through each milestone, you will be guided and
supported by helpful hints and up-to-date methods from your colleagues in wastewater
facilities who have successfully implemented an EMS in organizations just like yours.
These helpful hints include:
^ An explanation of the intent of each EMS requirement.
^ Step-by-Step guidance on how to complete each EMS requirement.
^ An EMS dictionary that explains the EMS language and terms used in that section.
^ Sample EMS procedures, policies, and other documents.
^ Information about who might perform the tasks and the level of effort required from
EMS leadership, front-line employees, and management.
^ Lessons learned and keys to success from wastewater utilities who have
implemented an EMS in facilities like yours.
^ Case study data and information.
^ How to involve contractors and temporary staff in your EMS activities.
^ Pitfalls to avoid.
Introduction
Wastewater EMS Handbook
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Icons will lead you to the hints, key concepts and tips. You'll find the following icon
symbols in each section:
Coach's Corner emphasizes important concepts and key EMS
requirements or responsibilities.
Keys to Success indicates keys to successful EMS implementation, as
identified by the wastewater practitioners.
Notes highlight a point or concept important to EMS implementation.
Reminders are key points to keep in mind as you implement your EMS.
Stop Signs underscore the things to avoid during your EMS
implementation.
Clip and Save
m(Cut out this section) m
Grey Cutout Boxes are put at the end of each step-by-step
implementation section to reference key information, especially for
Environmental Management Representatives. Think of the cutouts as
quick reference summary sheets for each EMS element.
Documentation Pyramids are placed in the sidebars of specific EMS
step-by-step implementation sections to designate that a documented
(written) procedure is a requirement for the element.
Here's an overview of the sections in this Wastewater EMS Handbook:
Section 1 - What is an EMS and Why Would a
Wastewater Facility Want One?
This section explains what an environmental management system is, describes the
basic elements of an EMS, and provides an overview of the typical costs, roles &
responsibilities and the average timeframe for EMS implementation at wastewater
facilities. It also includes benefits, keys to success, lessons learned, and the drivers
wastewater facilities experience when implementing EMSs at their facilities. It lists
Introduction
Wastewater EMS Handbook
-------
associations and regulators that support EMSs, plus resources and points of contact
that wastewater practitioners have found useful. Finally, it discusses the opportunities
and how well an EMS integrates with other management systems that wastewater
facilities may have in place.
Section 2 - Getting My Facility Ready to Implement an EMS
This section identifies the organizational goals that lead wastewater facilities to
implement an EMS. It provides an overview of the phased approach to an EMS, a
sample EMS timeline, and a list of the tools (e.g., document samples, matrices,
checklists, etc.) that wastewater facilities used during EMS implementation. It
discusses the keys to success in choosing effective EMS leaders and managers and
their roles and responsibilities to drive and communicate the EMS throughout the
organization. Section 2 describes how to conduct a preliminary review of what an
organization already has in place to meet EMS requirements (the Gap Analysis) and
the keys to success, lessons learned and the potential barriers for wastewater
organizations as they prepare to implement an EMS. Section 2 ends by discussing
how wastewater organizations overcame the issues of new EMS language/jargon.
Section 3 - Step-by-Step Implementation Guide
This section describes the sequence of activities or "roadmap" for implementing the
key elements of an EMS and explains why certain elements might need to be
implemented in a certain order. The section also provides detailed guidance on how
each element of an EMS could be designed and implemented and discusses each of
the key elements of an EMS and suggests how to put them in place. Section 3
includes the experiences and relevant tools wastewater facilities used during their
EMS step-by-step implementation.
Section 4 - Third-Party EMS Registration
This section discusses the process of third party registration under the ISO 14001
Standard and includes a discussion of what to look for in selecting a third party to
conduct EMS registration. Section 4 includes the keys, lessons learned and things to
avoid when considering a third party to review an EMS and provides the costs, typical
timeline and third party registration points-of-contact from wastewater organizations
that have chosen to third party register.
Section 5 - Conclusion
This section provides a brief review and point-of-contact information for wastewater
facility personnel who have experience in implementing EMSs, and are willing to
share their knowledge with other wastewater organizations.
Section 6 - Appendices
This section describes sources of EMS information and provides sample EMS
policies, procedures, and other tools that organizations can tailor to fit its EMS needs.
The sample procedures, checklists, tools, etc. are from EMS wastewater facilities that
have implemented EMSs. In addition, Appendix D contains an EMS Glossary with the
terms used throughout the Handbook.
Introduction
Wastewater EMS Handbook
-------
Section 1: What is an EMS and Why
Would a Wastewater Facility Want
One?
What this Section Will Cover:
What is an Environmental Management System (EMS)?
The Drivers and Benefits of Implementing an EMS -
Why Do I Want One?
Support for EMSs from Regulators and Associations
EMS Integration with Other Management Systems
FAQs
What is an Environmental
Management System (EMS)?
An Environmental Management System (EMS) is a set of
management processes and procedures that allows an
organization to analyze, control and reduce the environmental
impact of its activities, products and services, and operate with greater
efficiency and control. An EMS is appropriate for all kinds of
organizations of varying sizes in both the public and private sectors.
This Wastewater EMS Handbook uses the ISO 14001 Standard (1996)
as the EMS model for implementation. The EMS is built on ISO
14001's Plan-Do-Check-Act (P-D-C-A) model and is designed to help
you systematically identify, control and monitor your environmental
issues.
An Environmental Management System includes:
Defining roles and responsibilities
Identifying and prioritizing environmental impacts
Setting measurable objectives and targets
Verifying and establishing operational controls
Monitoring and measuring activities and progress
Seeking continual improvement as part of a review cycle
You will probably find that an EMS does not involve a drastic change
from the way you are conducting business now. In fact, most
organizations find that they have many of the pieces of an EMS already
in place. The EMS builds on what you are doing well now, and provides
a structured approach to improve what you want to do better.
Key Section Terms
ISO 14001 -One of the
Environmental Management
Standards developed by the
International Organization for
Standardization in Geneva,
Switzerland. It is the requirements
document that specifies the 17
elements of an EMS.
Continual Improvement - One of
the three main commitments of the
EMS. After checking their EMS
through monitoring and measuring,
and find, fix, and prevent audits,
organizations apply the lessons they
have learned to improve their
environmental management.
Environmental Management
System (EMS) - A system for
identifying environmental and
organizational issues and
implementing improvements based
on Deming's Plan-Do-Check-Act
model. The EMS has 17 elements
that help organizations achieve
environmental policy commitments
and environmental performance
improvements.
Environmental Management
Representative (EMR) - The
clearly-identified EMS team leader
who has the responsibility and
management authority for
implementing the EMS from start to
finish.
EMS Core Team - A
cross-functional team made up of
individuals within the organization
that helps facilitate EMS
implementation across the
organization. They are the EMS
experts and cheerleaders.
Section I: What is an EMS'
Wastewater EMS Handbook
-------
An EMS:
^ Does not direct an organization
to meet certain discharge or emission
limits. It does describe the internal
framework that should be in place
(e.g., policies, procedures, training,
communication, documentation) to
have a proactive system to manage
environmental issues.
^ Does not tell an organization
how or what to manage. That is up to
the organization. An EMS defines the
critical management elements and
operational controls that must be in
place and followed to control the
impact an organization has on the
environment.
^ Is designed to be applicable to
all types of organizations and facili-
ties: large and small private compa-
nies and public organizations such as
municipalities, federal facilities and
wastewater treatment plants.
COACH'S
CORNER
n effective EMS
must be dynamic
to allow your
organization to
-dapt to a quickly
langing
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 employees.
COACH'S CORNER
An EMS should integrate environmental management
* ' 'o your day-to-day operations as well as into your
strategic organizational decisions by providing a
managing your responsibilities. Also, because an
EMS is a not a traditional top down management
approach, the environment becomes the responsibility of
everyone by providing everyone with a voice on the best way
to manage their areas and impacts.
An EMS is made up of 17 elements that are common to most models.
Here's a brief snapshot of what's needed under each one:
Environmental policy Develop a statement of your organization's
commitment to the environment. Use this policy as a framework for
planning and action. The policy is a direct reflection of the fundamental
values of your organization.
Environmental aspects Identify environmental attributes of your
products, activities and services. Determine those that could have sig-
nificant impact on the environment.
Legal and other requirements Identify and ensure access to rele-
vant laws and regulations, as well as other requirements (trade associa-
tion, local government initiatives, etc.) that your organization must meet
and follow.
Objectives and targets Establish environmental goals for your
facility, consistent with your policy, environmental impacts, and the
views of interested parties.
Environmental management program Create plans of action
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 employees are
trained and capable of carrying out their environmental responsibilities
under the EMS.
Communication Establish processes for internal and external com-
munications on environmental management issues.
EMS documentation (EMS Manual) Maintain information on your
organization's EMS. Define, be consistent, and provide an overview of
your EMS's key policies, procedures, and related documents.
Section I: What is an EMS'
Wastewater EMS Handbook
-------
Document control Ensure effective management of procedures and
other system documents.
Operational control Identify, plan and manage your operations and
services in line with your policy, priority environmental issues, and
objectives and targets.
Emergency preparedness and response Identify potential emer-
gencies and develop procedures for preventing and responding to them.
Monitoring and measurement Monitor your key activities and track
performance.
Nonconformance and corrective and preventive action Identify
and correct problems and prevent their recurrence.
Records Maintain and manage (access, retention, disposition) EMS
records (training, audits, performance, etc.).
EMS audit Periodically verify, internally and/or through a third-party,
that your EMS is operating as intended.
Management review Assess your organization's EMS with an eye
toward continual improvement.1
Continual
improvement
This P-D-C-A model will lead to continual improvement based upon:
Planning: identifying the environmental impacts ("footprint") of your
organization's operations and services, tracking and following legal
requirements, setting environmental goals, and establishing programs
(i.e., action plans) to achieve your goals.
Implementing or "Do": defining and communicating EMS roles and
responsibilities, developing operating procedures and written programs
to manage significant environmental aspects, training contractors and
staff, developing methods to manage documents and records, and
establishing emergency response procedures to prevent and respond to
environmental incidents.
' Environmental Management Systems: An Implementation Guide for Small and Medium-Sized Organizations, 2nd Edition, NSF International, January 2001.
Section I: What is an EMS'
Wastewater EMS Handbook
The Benefits of
Implementing an EMS:
What Wastewater Utilities
are Saying
Managing a Changing
Workforce
1 fo nal system of documentation
..ill ...Ip sustain an EMS as staff
turns over and will help diffuse
knowledge about changes as they
occur. The standard operating
procedures (SOPs) provide
'present-tense'guides to
employees; the records created to
track various activities signify 'past-
tense' activities and the evi K
that certain activities have a iual /
occurred.
Ellen Barrett
The Barrett Group
Systematically Managing
Environmental Issues
C ./ p' ..ining has improved
nns lerably. Prior to EMS
te shment, no formal, consistent
structure was available for planning.
Also, our planning is much more
focused, with drivers in place, and
our associates (employees) have a
better understanding of the reasons
behind the planning initiatives.
Additionally, knowledge of our
company's impact on the
environment has been heightene
-
Rick Bickerstaff
Charleston, South Carolina
Commissioners of Public Works
-------
What Wastewater
Utilities are Saying
Communicating Better
In the City of San Diego,
Metropolitan Wastewater
Department's (MWWD) Wastewater
Collection Division (WWCD), major
improvements have been made in
communication, clarification of
organizational goals, and tracking of
these goals. The WWCD currently
has 343 budgeted full-time positions
and an annual operating budget of
$63 million. The actual planning
and implementation of an EMS has
resulted in section leaders within
the WWCD communicating br* ie~'
sections in a more organized < id
frequent manner.
Chris Toth
City of San Diego
Wastewater Collection Division
Improving Employee
Understanding of
Environmental Issues
T iroi /hout the wastewater
i ai ation, there is a better
understanding of the purpose of the
EMS, our legal requirements,
environmental impacts, and each
person's role within these areas.
There is improved organization and
tracking of requirements, training, and
related paperwork. All personnel are
more proactive with looking for and
making suggestions of better ways to
do certain tasks. In addition, staff now
have a better understanding of what
is expected of them and management
has confidence that their expectations
have been communicated to staff
through the training process and
documented procedures.
Beth Eckert
Gastonia, North Carolina
Public Works and Utilities Department
Checking and Corrective Action: monitoring and measuring key envi-
ronmental parameters and your EMS objectives to assess environmen-
tal performance, conducting internal reviews of your EMS, and ensuring
that specified practices are followed.
Management Review and Act: review by top management to ensure
that your EMS is working as intended and is effective in meeting your
environmental goals. Making critical course corrections, resource allo-
cation, and strategic planning to ensure that your organization remains
on the path to continual improvement.2
PHASE 1: Getting Ready
Activities in the Getting Ready Phase focus on adequately preparing
your organization for the task of implementing an EMS. Before diving
head first into implementation, it is critical that your team understands
the EMS implementation strategy and that fundamental building blocks
are in place to position your organization for successful implementation.
Activities for Phase 1 include:
Select your EMS "fenceline" or implementation focus area(s).
Confirm commitment and support throughout the organization,
especially from top management.
Designate an EMS leader and form EMS implementation teams.
Conduct a preliminary review of your EMS components in place
(i.e., a "gap" analysis).
Select an EMS
Fenceline
Phase 1: Getting Ready
Confirm Top Management
Commitment and Support
Designate EMS Leader and
EMS Implementation Teams
Conduct a Gap
Analysis
2 Adapted from Environmental Management Systems: An Implementation Guide for Small and Medium-Sized Organizations,
2nd Edition, NSF International, January 2001.
Section I: What is an EMS'
Wastewater EMS Handbook
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Phase 5
Management
Review (Act)
Phase 2
Environmental
Policy
Phase 4 - Checking and
Corrective Action
Monitoring & Measurement
Nonconformance &
Corrective & Preventive
Action
EMS Audits
Continual
Improvement
Phase 2 - Planning
Environmental Aspects
Legal & Other
Requirements
Objectives & Targets
Environmental
Management Programs
Phase 3 - Implementing
Structure & Responsibility
Training, Awareness, Competence
Communication
EMS Documentation (EMS Manual)
Document and Records Control
Operational Control
Emergency Preparedness/Response
J
:ence
PHASE 2: Planning
Activities in the Planning Phase lay out the foundation for your EMS
with the development of specific EMS elements. Your team will work to
identify how your organization can affect the environment and then
prioritize these issues to focus EMS efforts. Once you have identified
and prioritized your environmental issues or aspects, you will determine
in which areas (your choice!) you want to improve by setting objectives
and targets. You will manage your objectives and targets with environ-
mental management programs (action plans), that will define who on
your staff will help in accomplishing your EMS goals, what tasks will be
accomplished, when (timeframes) the tasks will be accomplished,
and the resources required.
* Adapted from Environmental Management Systems: An Implementation Guide for Small and Medium-Sized Organizations,
2nd Edition, NSF International, January 2001.
Section I: What is an EMS'
Wastewater EMS Handbook
-------
NOTE
An EMS is not
intended to replace
* regulations or an
, organization's
compliance
system. In fact, a
commitment to compliance is a
fundamental principle of an ISO
14001-based EMS. An effective
EMS will help your facility meet
environmental commitments and
allow you to avoid the reactive
approach to regulatory
compliance.
Activities for Phase 2:
Draft and communicate your environmental policy.
Create a procedure for understanding and communicating your legal
and other requirements.
Identify the environmental issues (both regulated and non-
regulated) of your operations and services.
Develop a method for prioritizing your environmental aspects.
Set realistic objectives and targets based on your significant
issues and environmental policy.
Develop action plans (i.e., environmental management programs)
that will help you go from the start to finish line in meeting your
objectives and targets.
Phase 2: Planning
Draft and
Communicate
Environmental
Policy
Identify
Environmental
Aspects and
Impacts
Prioritize
Environmental
Aspects
Establish
nhio^tixmc
and
Targets
Develop
LIIVIIUIIIIItMliai
Management
Programs
Understand and Communicate
Legal and Other Requirements
PHASE 3: Implementing or "Do"
The Implementation Phase of an EMS has two major activities: 1) man-
aging significant aspects that were defined in the Planning Phase; and
2) establishing performance indicators for each of your environmental
targets. Begin by focusing specifically on how you can best manage
and address the significant environmental issues within your organiza-
tion. Manage these significant environmental issues by refining, and in
some cases creating, standard operating procedures and work
instructions. Phase 3 includes defining implementation team roles and
responsibilities and establishing internal and external lines of
communication. This is an opportunity to take a more focused look at
the specific operations and services that you decided were most
significant for your wastewater facility.
In Phase 3 you will also define how your organization will achieve better
environmental performance in relation to your defined objectives and
targets. To accomplish this, you will need to define a series of perform-
ance indicators to assess and promote improvement. Many of these
indicators will be obvious (e.g., environmental regulations), whereas
others, especially those involving your organization's objectives and tar-
gets, may be a little more challenging to define at first.
I4
Section I: What is an EMS'
Wastewater EMS Handbook
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Activities for Phase 3:
Clearly define roles and responsibilities, particularly in regard to
significant environmental issues.
Identify EMS training and awareness needs for all staff.
Establish effective internal communication methods for information to
flow top-down, bottom-up, and across your entire operational fence-
line.
Establish ways to communicate effectively with external stakeholders
about your EMS.
Establish operational controls, including a review of existing standard
operating procedures and other documentation (e.g., work instruc-
tions, manuals, etc.) for your operations that you determined were
significant.
Establish a system ensuring documents and records are current,
accessible, and archived when appropriate.
Identify potential emergency situations that could arise from
day-to-day activities and operations, and review or create procedures
or plans to address potential incidents.
Establish normalized baseline data for operations with environmental
targets so that the targets can be measured and goals met
or improved on.
Phase 3: Implementing
Organizational
Accountability
Capabilities &
Communications
Structure &
Responsibility
Training,
Awareness and
Competence
Communication
Controls
EMS
Documentation
Document &
Records Control
Operational
Control
Emergency
Preparedness &
Response
COACH'S CORNER
Don't get discouraged
~^ if you need to work
Jr your EM Sat first. It
does not have to be
perfectthe focus is
on continual improvement!
Section I: What is an EMS'
Wastewater EMS Handbook
-------
COACH'S CORNER
/"-., Keep your EMS internal
audits positive.
,, Remember, this is a
approach that looks at
your system and not a
review of a particular
employee's performance. For
example, if someone does not
know that you have an
environmental policy during
your initial EMS internal audit,
make sure you let them know
that it was a training failure of
the system and not their lack of
knowledge. Also make sure to
note what you are doing well
when you conduct your EMS
internal audits.
Remember, this is a team
effort your facility is trying to
continual improve as an
organization.
PHASE 4: Checking and Corrective Action
In Phase 4 you will define and document methods that your organiza-
tion will use to verify that your EMS is effective and functioning as you
intended. The check, an EMS audit or review, is a tool that you will use
to periodically use to identify any flaws or weaknesses in your EMS.
Remember, this is a "find, fix, and prevent" system, and this information
can help you assess how well your EMS is functioning and put you on
the road to continual improvement. As part of the audit process, your
organization will take corrective actions on any "findings" (nonconfor-
mances concerns or deviations from planned activities) to make sure
that non-conformances are examined for their root cause, corrected,
and prevented from reoccurring.
Activities for Phase 4:
Monitor and measure key characteristics of your management
system.
Determine compliance status.
Ensure that instruments used for monitoring and measuring are
calibrated.
Develop and implementing procedures for handling EMS non-
conformances.
Conduct internal EMS audits.
Maintain EMS records.
Phase 4: Checking and Corrective Action
Ongoing
Monitoring and
Measuring; Check
Calibration and
Compliance
si
Nonconformance,
Corrective and
Preventive Action
Internal EMS Audits
Section I: What is an EMS'
Wastewater EMS Handbook
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PHASE 5: Management Review (Act)
The Management Review is the final element in the EMS cycle. It's an
opportunity for top management to review and fine-tune your EMS and
make course corrections, if needed. Top management will determine
whether the EMS is functioning as you intended, where additional
resources may need to be allocated, if your environmental policy is
appropriate or needs to be revised, and if your organization's objectives
and targets are on track.
Activities for Phase 5:
Judge the suitability, adequacy, and effectiveness of the EMS.
Consider new organizational goals.
Apply lessons learned for continual improvement.
Phase 5: Management Review (Act)
Take account of:
EMS audit findings
progress in meeting objectives &
targets
changes in operations and services
changes in technology
concerns of stakeholders
To assess the:
> suitability,
> adequacy, and
> effectiveness of the EMS
To determine the need for
change or improvement to:
> the environmental policy
> objectives & targets
> other EMS elements
Why Do I Want an EMS?
As public entities, wastewater utilities serve the public well-being, and
public interest in environmental health and safety is high. Wastewater
utilities have increasingly begun turning to Environmental Management
Systems to improve their environmental performance and operational
control and efficiency. These improvements usually mean avoided costs
and dollars saved. In fact, over 50 wastewater utilities are in the
process of implementing an EMS under the National Biosolids
Partnerships program, with many more having implemented, or are in
the process of implementing, an EMS through federal, state and local
government sponsored programs.
What about your organization? Can an EMS bring you benefits?
Here's a quick survey that may help you:
Is your organization required to comply with environmental laws
and regulations?
Would you appreciate opportunities to improve how you manage
your environmental responsibilities?
NOTE
It's important
to keep your
managers
updated
frequently on your
EMS and its progress. Don't wait
until the Management Review to
involve top management and to
report on the performance and
status of your objectives and
targets and the overall progress
of your EMS.
Section I: What is an EMS'
Wastewater EMS Handbook
-------
Why Implement an
EMS?
Organizational Drivers from
Wastewater Facilities
"Improved teamwork, communication,
understanding, and awareness
across divisional functions."
Buncombe County, North Carolina
"Improved relationships with the local
community and regulators."
Charleston, South Carolina
"A better response to sewer overflows
through enhanced operational
controls."
Kent County, Delaware
"Ensured management involvement
and clarified organizational goals."
Eugene, Oregon
"Increased efficiency in manay, g
environmental obligations."
Gastonia, North Carolina
From the United
States
Environmental
Protection Agency
Position Statement
on Environmental
Management Systems
(EMSs), signed on May 15, 2002
by EPA Administrator Whitman:
"EPA will foster continual learning
by supporting research and public
dialogue on EMSs that help
improve our understanding of
circumstances where EMSs can
advance the Nation's
environmental policy goals. We will
strive to collect better information
on the application of EMSs,
including how well EMSs meet
environmental performance
expectations; and the costs and
benefits to organizations and the
environment."
Are you concerned that large portions of your workforce are
retiring and taking undocumented operational knowledge with them?
Would you like to improve your environmental performance?
Would you like to identify and manage your risks effectively
and efficiently?
Are you concerned about your public image?
Do you need better communication channels to capture good
ideas from the frontline for improving your operations?
Would you welcome the opportunity to reduce inefficiencies and
save money?
Would improved teamwork, communication and environmental
understanding be useful in your daily operations?
Would you like to improve competitiveness and reduce the risk of pri-
vatization?
If your answer was yes to any of these questions, then an EMS will
benefit your organization. Wastewater facilities across the country
have success stories about the improvement that resulted from
implementing and maintaining an EMS.
Federal, State and Association Support for EMS
Regulatory agencies, facing increasingly limited financial and human
resources, are recognizing that the promotion of EMS concepts is a way
to further their goals of environmental protection. There are numerous
state and federal programs that support the implementation of EMSs in
the regulated community.
The U.S. Environmental Protection Agency's (U.S. EPA)
support for the voluntary adoption of EMSs has been
evident since the mid-1990s.The Office of Water (OW)
has been the leader in promoting EMS adoption with public agencies.
OW, working with the Global Environment and Technology Foundation
(GETF), has sponsored over 30 public agencies as they have adopted
EMSs since 1997. More recently, OW designated seven organizations
around the country as EMS Local Resource Centers (i.e., PEER
Centers) to meet the EMS needs of public agencies around the country
through training, education, and other forms of technical assistance.
Finally, a national clearinghouse of EMS information geared to the
needs of public agencies has been established. Information on all of
these efforts can be found at www.peercenter.net.
18
Section I: What is an EMS'
Wastewater EMS Handbook
-------
Federal support for EMSs is also demonstrated through U.S. EPA's
Performance Track Program. Performance Track encourages and
recognizes top environmental performance by private and public
facilities across the United States. Performance Track facilities exceed
compliance with regulatory requirements and achieve environmental
improvement and excellence by utilizing an EMS as a fundamental
mechanism. To encourage environmental achievement and continuous
environmental improvement, U.S. EPA offers incentives to Performance
Track members, including:
Recognition - Recognition of member accomplishments by the
U.S. EPA Administrator and other top officials through national and
regional press releases, meetings and other vehicles.
Networking - Promoting exchange of information and creating a
"learning network" for members.
Lower Priority for Routine Inspections - Establishing Performance
Track members as a lower inspection priority since a performance- and
compliance-focused EMS, coupled with periodic auditing, should
prevent non-compliance at Performance Track facilities.
Regulatory and Administrative Incentives - Regulatory and
administrative actions that only apply to participating Performance
Track facilities (e.g., flexible permits that will reduce permitting costs
and uncertainty).
As of November 2003, there were more than 300 members in
Performance Track from around the United States, including numerous
municipalities and 15 federal facilities participating in the program. For
more information about Performance Track, go to
http://www.epa.gov/performancetrack.
State Support for EMSs
States are increasingly strong supporters of EMSs. For example,
Virginia's Department of Environmental Quality's (DEQ) Environmental
Excellence Program (VEEP) (http://www.deq.state.va.us/veep/) will
grant regulatory incentives in exchange for "actions that are shown to
provide greater environmental protection than are provided through
current practices" (e.g., those that exist under the current regulatory
requirements or program structure). Additional information on state
EMS programs and regulatory incentives can be found on the Multi-
State Working Group's Website (http://www.mswg.org). MSWG is an
organization formed by several state representatives who have
successfully formed an alliance with U.S. EPA to encourage
implementation of EMSs. Also check the National Technical Assistance
Providers (TAP) Directory (www.peercenter.net/taps) and your own
states policies and incentives on EMSs.
Increased Community
Confidence and
Willingness to Pay
We are integrating and implementing
environmental management systems
based upon strategic planning and
continual improvement. This has
increased our customer's
understanding, support, and
willingness to invest more
community money into an aged and
obsolete infrastructure and has
increased customer confidence that
the Department can provide
economical and high quality
services.
Diane Taniguchi-Dennis, RE.
Director of Public Works
City of Albany, Oregon
Section I: What is an EMS'
Wastewater EMS Handbook
-------
Increased Investor
Confidence
f jr c janization's achievement of
e/ ident standards of excellence,
wrougn our EMS based on ISO
14001, has provided a level of
confidence to credit rating agencies
that the utility is being run as a
business and as efficiently as
possible. When we went to the
market for a bond needed to
rehabilitate decaying tunnels,
helped our utility to receive a
favorable credit rating.
John Cook
Assistant General Manager
City of Charleston
Commissioners of Public Works
fit of implementing an EMS is
ability to incorporate other
initiatives, such as asset
management and CMOM.
Jim Newton. P.E., DEE
Kent County, Delaware
Levy Court Public Works
Association Support for EMSs
A number of associations that interact with wastewater organizations
support EMSs, including the American Water Works Association
(AWWA) - http://www.awwa.org, the Environmental Council of the States
(ECOS) - http://www.sso.org/ecos, the International City/County
Management Association (ICMA) - http://www1.icma.org. the National
Association of Counties (NACO) - http://www.naco.org. and the Water
Environment Federation (WEF) - http://www.wef.org, among others.
Many of these organizations have funded specific EMS initiatives and
research. For more information on the association above and their
support of EMS, visit their Websites.
EMSs Are an Ideal Tool to Integrate Other
Important Utility Management Programs
Wastewater utilities are facing a number of pressing management
challenges and there are many different programs to help them improve
in a variety of areas. EMSs do not in any way detract from these other
management tools. Rather, an EMS is one of the best ways to
integrate many other utility management programs.
In fact, effective asset management can be an essential part of a
wastewater EMS. For example, effective asset management could be
reflected in an organization's policy statement, and should be an
important consideration as wastewater organizations determine their
significant environmental aspects, objectives and targets, and develop
environmental management programs to help achieve their objectives
and targets.
Asset management is one of the most important challenges facing
wastewater utilities. Improperly managed and maintained capital assets
not only have major negative impacts on the environment, but can
substantially increase the cost of providing basic wastewater services.
For more information on managing wastewater assets, the Association
of Metropolitan Sewerage Agencies (AMSA) developed a guidebook
titled "Managing Public Infrastructure Assets."
Implementing an EMS can also prepare utilities to face new or
expanded regulatory requirements. For example, many utilities are now
being asked to implement Capacity, Management, Operations, and
Maintenance (CMOM) programs to better manage their wastewater
collection systems. Developing an EMS forces a utility to consider
many of the more specific requirements of an effective CMOM program.
The Charleston, South Carolina Commissioners of Public Works (CPW)
found that having an EMS in place made it much easier to implement
an effective CMOM program because many of the steps for doing so
had already been taken as part of developing their EMS.
20
Section I: What is an EMS'
Wastewater EMS Handbook
-------
Finally, an increasing number of utilities are realizing the need to
develop a comprehensive management system that will help address
many different outcomes including, but not limited to, environmental
outcomes. To address this need, EPA, the Water Environment
Federation (WEF), and AMSA cooperated on an important guide to help
utilities understand how to integrate various management initiatives
under the umbrella of a comprehensive management system. This
guide, titled "Continual Improvement in Utility Management: A
Framework for Integration," can be found at www.epa.aov/ems.
www.peercenter.net, www.amsa-cleanwater.ora. and www.wef.oracan.
This Handbook contains several useful case studies from existing
utilities, most of which used their EMS as the starting point for
developing a more comprehensive system.
For those agencies that wish to implement an EMS that initially focuses
only on biosolids, the National Biosolids Partnership (NBP), has
developed an EMS program that is similar in structure to ISO 14001.
The NBP program requires a more proactive public participation
program, along with regular public reporting. Also, participating
agencies must undergo an independent 3rd party audit before receiving
a certificate from the NBP. This auditing program is similar to the 3rd
party auditing program under ISO described later in this document.
More information on the NBP program can be found at
www.biosolids.org.
Section I: What is an EMS'
Wastewater EMS Handbook
21
-------
Frequently Asked Questions about Environmental Management Systems
Q. We already have a compliance program-why do
we need an EMS?
A. 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.
Q. How big does an organization need to be to
successfully implement an EMS?
A. EMSs have been implemented by organizations
ranging in size from a couple of dozen
many thousands of employees. The eleme-
EMS (as described in this Handbook) ar ^ oy
design to accommodate a wide range
organizational types and sizes.
Q. Wll an EMS help us to prevent pollution and to
minimize wastes?
A. 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
Handbook show how organizations have used an
EMS to prevent pollution.
Q. How will an EMS affect my existing compliance
obligations?
A. 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.
Q. Do we need to be in 100% compliance in order to
have an EMS?
A. 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, fix,
and prevent" these problems and prevent them from
recurring.
Q. What is ISO 14001?
A. ISO 14001 is an internationally recognized
standard for the environment. It provides a systems
approach patterned after a model of plan, do, check
and act. ISO 14001 is one of a series of
Environmental Standards developed by the
International Organization for Standardization.
The ISO 14001 standard includes all of the elements
needed to develop an environmental management
system in an organization.
Q. What are the benefits of an EMS?
A. An EMS provides tools to help manage your
organization's environmental impacts efficiently and
effectively and to improve the impact of an
organization's environmental "footprint." Public
Cations who have implemented an EMS have
following benefits:
gs
>k to the environment and employee
perational efficiency
.ernal relations and public image
communication
j public relations
at are the hurdles to implementing an EMS?
c is important to realize that developing and
iplementing an EMS requires an investment of
e and effort. Along the way there can be hurdles
uch as: difficulty managing organizational change,
lack of top management visibility and involvement,
lack of public awareness and understanding,
maintaining momentum (especially at the frontline),
and political uncertainties.
Q. Is EMS compatible with other management
system approaches?
A. Yes. Whether you have a quality management
system, asset management system, or participate in
the National Biosolids Partnership, an EMS is
compatible and can be integrated with any systems
type approach. For example, procedural methods for
handling operational and environmental records and
providing training are universal and should integrate
well. Furthermore, the process of identifying
environmental and operational priorities, setting
targets and checking progress on those targets will
be very similar in any management systems
approach.
22
Section I: What is an EMS'
Wastewater EMS Handbook
-------
Section 2: Getting My Facility Ready
to Implement an EMS
In previous sections, we've reviewed the benefits you can expect from
your EMS, briefly described the 17 key elements in the EMS, and
graphed and explained the five phases of EMS implementation.
You're probably eager to plunge directly into building your EMS, but
before you do, it's critical that you prepare your organization for the
taskwhat's been called the warm-up and soak-in period. The Getting
Ready Phase should take your organization about three months, and its
importance cannot be overstated.
=>
=>
=>
=>
=>
=>
=>
=>
What this Section Will Cover:
O Choosing Your EMS "Fenceline"
Understanding Your Organizational Goals
Top Management Commitment, Involvement, and Visibility
EMS Program Leadership
Securing and Maintaining Employee Buy-in
Conducting an EMS Gap Analysis or Preliminary Review
Managing Change
Understanding the Implementation Strategy
EMS Information Sources and Resources
Choosing Your EMS Fenceline
When you decide to implement an EMS, one of the first decisions will
be where it will apply. Where you apply your EMS is commonly referred
to as the EMS "fenceline." An EMS can be applied to any operation or
activity, to an entire division or within one department.
Experience from public organizations has shown that starting small is
the way to go. Select one operation or department as a pilot, gaining
confidence and experience as you build your EMS. Consider starting
with a smaller or more manageable operation, then expanding and
transferring the lessons learned and knowledge to other departments.
Personnel in the original fencelines can then be EMS mentors, trainers
or champions as new areas of the organization are added. Five out of
six of our wastewater practitioners used an incremental approach for
EMS implementation, choosing a manageable pilot operation or division
first. These EMSs were then expanded out to include other departments
and/or divisions.
Key Section Terms
Environmental Management System
(EMS) - A system for identifying
environmental and organizational
issues and implementing organizational
improvements based on Deming's
Plan-Do-Check-Act model. The EMS
has 17 elements that help organizations
achieve environmental policy
commitments and environmental
performance improvements.
Environmental Management
Representative (EMR) - The clearly-
identified EMS team leader who has
the responsibility and management
authority for implementing the EMS
from start to finish.
EMS Core Team -A cross-functional
team made up of individuals within the
organization that help to facilitate EMS
implementation across the organization.
These are the EMS experts and
cheerleaders.
EMS Implementation Team -
Individuals within the organization who
are closest to the actual workflow and
who assist the Core Team and the
EMR in better understanding
operational activities. Implementation
Teams are generally very involved in
designing operational controls, testing
emergency preparedness and response
plans, and identifying the environmental
aspects of their daily activities.
EMS Fenceline - Operational area or
areas within an organization where the
EMS is implemented.
Gap Analysis - Preliminary
assessment of an organization's
environmental programs and
management practices to see where
they match up with EMS requirements.
Top Management - Person or group
with executive responsibility for the
organization and the EMS.
Section I: Getting Ready
Wastewater EMS Handbook
-------
Questions to Consider
When Selecting Your
Fenceline:
1) Which of our operations has the
most environmental hot-spots? Which
operations give us more headaches?
2) Where do we use the most natural
resources? Energy? Hazardous
materials?
3) Which operations offer the most
transferability and replication to other
wastewater operations?
4) Which of our operations has the
most receptive management? Line
Supervisors? Employees?
5) Which of our operations are NOT
in the middle of a capitol
improvement project or being
restructured or reorganized?
Here are some examples of EMS fencelines in wastewater
organizations across the United States:
Wastewater Organization
Buncombe County,
North Carolina
Metropolitan Sewer District
Charleston, South Carolina
Commissioners of Public Works
Eugene, Oregon
Public Works
Gastonia, North Carolina
Public Works
Kent County, Delaware
Public Works
San Diego, California
Metropolitan Sewer District
Fenceline
Wastewater Treatment Plant;
Operations Department; Electrical
Maintenance; Structural
Maintenance; Mechanical
Maintenance; and WWTP
Administration
Water Distribution Department
Wastewater Collection Department
All Wastewater Operations
Wastewater Treatment Division: 2
WWTPs; a laboratory;
pretreatment; biosolids; and a
resource recovery farm
Wastewater Collections,
Wastewater Treatment, and
Biosolids Treatment
Operations & Maintenance Division
(pilot); Wastewater Collection
Division; Water Operations Divisions
(3 of the 6 Divisions
within San Diego's MWWD)
Once top management has confirmed the fenceline selection, it's time
to pay a visit to the managers and supervisors in the fenceline
divisions. You'll certainly want to include all types of employees (i.e.,
union stewards, contractors, temporary staff) in your discussions right
from the start. You'll want to think about how best to prepare them all
for the EMS implementation experience. It's a fact that the time you
invest now in promoting awareness, understanding, receiving buy-in,
especially among managers and supervisors, will be time saved later in
the process.
One point repeated by wastewater facilities that have implemented
EMSs is to spend extra time with managers and supervisors. One-on-
one conversations can identify their needs, concerns, and problem
areas. The more middle managers involved in the initial stages of the
EMS, the more support and buy-in you will get. An EMS involves all
employees in the fenceline at appropriate points in the implementation
process, including support services like H.R.so get out there and
start the discussions!
There are a number of keys to success for getting buy-in at the
fenceline areas that are worth noting, including:
Invite the fenceline staff to a short EMS awareness meeting.
Senior management should be highly visible and involved in
making the case for EMS and endorsing it as a priority. It needs
to be perfectly clear to everyone that the EMS is a management
commitment.
24
Section 2: Getting Ready
Wastewater EMS Handbook
-------
(Note: An EMS presentations from a waste water organization is
included in Appendix B).
Drop by for brief informal discussions with supervisors, and
managers and union stewards. Ask them what is going really
well in their operation. Ask them where there might be some
opportunities for improvement. It's probable that the EMS can
facilitate some of the improvements in later implementation
activities.
Hang EMS posters and other informal awareness information on
bulletin boards and in lunch rooms. One example of an
interactive, fun tool, produced by MGMT Alliance, Inc., is
available at http://www.mgmt14k.com/014kpizza.htm.
We'll be talking more about employee buy-in in later sections of the
Handbook.
Understanding Your Organizational Goals
It's clear that implementing an EMS can lead to better environmental
performance in your fenceline areas, as well as other important
business benefits. Here are some of the organizational goals described
by wastewater facilities we've talked to:
Improve documentation and communications
Develop and/or update standard operating procedures
for field activities
Improve morale and teamwork
Increase efficiency of operations
Reduce energy consumption
Enhance the public image of the City or Agency
Develop a process that would put us into a proactive role with regard
to compliance instead of reactive
Become more competitive
Become "best in class" for wastewater
While there are some remarkable similarities among wastewater
facilities, no two are exactly alike. An important first step in EMS
readiness is understanding why your organization is implementing an
EMS. Are you concerned about environmental performance? Do you
want to improve your public image? Are you planning for succession
issues as portions of your staff retire and new personnel must be
trained and ready? Do you want better communication across your
organization? Are you interested in green purchasing and product
substitution options? Are you having problems meeting the expectations
of the public?
" jp r anagers should attend training
ss is on EMS implementation. A
racility EMS Steering Committee was
formed with top management
involvement. This committee was
instrumental in developing and
approving the EMS Policy and _
level-one procedures.
id
id_ fc
Rick Bickerstaff
Charleston, South Carolina
Commissioners of Public Works
5" ,iiic management, as represented
"tr Dublic Works Director, has
'6., Jrectly involved with the EMS
process by participating on the Core
Team in the development of the EMS.
In addition, he has kept the County
Commissioners and the Sewer
Advisory Board informed of the EMS
progress with periodic briefings. He
has attended EMS workshops and
training and has reviewed all EMS
documents, as they have been
prepared and has talked to pla
employees about the EMS.
"J
Jim Newton, P.E., DEE
Kent County, Delaware
Levy Court Public Works
T jisi' ,\ management directed that an
*O- "001 EMS be established and
fjioviued the economic resources to
obtain necessary consultant support.
Management created an
environmental management
representative position within the
division and made the position
comparable to other senior staff
positions. Management heads up the
EMS Steering Committee which
meets on a regular (quarterly) basis
and directs the production of a
monthly division-wide activity report
which highlights EMS activities.
Management tracked the progress of
EMS development on a continual
basis over a two-year period until the
EMS became registered.
Chris Toth
City of San Diego
Wastewater Collection Division
Section 2: Getting Ready
Wastewater EMS Handbook
25
-------
NOTE
Write your goals
v down and refer
back to them
frequently as you
move forward.
REMEMBER
The goals of
management and the
, frontline employees may
be different, and
therefore, the way you
obtain support and buy-in from
management and employees
may be different.
7 ie C jneral Manager introduced the
ic .' of the EMS at a MSD board
meeting. From there, the General
Manager held organizational team
meetings to discuss the goals of the
organization (EMS was one of the
goals discussed). During these
meetings, the General Manager, along
with the EMR, introduced the EMS
and how it will merge into the business
plan of the organization. The General
Manager also approved a Steering
Committee which consists of top
management. Each member of the
Steering Committee meets with their
staff on a regular basis and reviews
the concept and focus of the EMS.
James Naber
Buncombe County, North Carolina
Metropolitan Sewer District
It's extremely useful and informative to spend some time with various
levels of staff and functions in your organization, particularly in your
fenceline divisions, discussing what improvements each would like to
realize in its respective areas of responsibility. The responses you get
from senior management will be considerably different than those from
the frontline folks, but all are important. Keep track of these
organizational goals. Document them, and refer to them often as you
build your EMS. Frequently ask yourself whether your EMS plans
include activities that will help you reach your goals.
You'll secure enthusiasm and buy-in at all levels in your fenceline
areas as employees across your organization see that the EMS is
accomplishing improvements they have suggested. You'll also
encourage employees to communicate fresh ideas about how your
operations might continue to be improved.
Here are some examples of goals that managers from wastewater
facilities considered important:
ซ Establish your organization as a leader within the
wastewater sector
ซ Instill a proactive instead of reactive culture
ซ Improve communications internally and externally
ซ Enhance public image
ซ Capture and document institutional knowledge
Here are some examples of goals that frontline employees from
wastewater facilities considered important:
Enhance the environmental impact of operations by doing some-
thing good for the environment in everyday work
Improve communication between divisions and across functions
Increase the use of best practicesperforming activities better than
industry standards
Ensure that the organization is doing the right thing (i.e., complying
with the law, etc.)
Standardize procedures so that everyone is consistent and
working together
As we've discussed in a previous section, the EMS integrates well
with, and is also an excellent delivery vehicle for, other voluntary and
required systems (e.g, Asset Management, CMOM, ISO 9000,
Balanced Scorecard, QualServe, NBP, etc.) that your organization
already endorses, so if your organization intends to adopt one or more
of them, be sure to include that in your organizational goals as well.
26
Section 2: Getting Ready
Wastewater EMS Handbook
-------
Management Commitment, Involvement,
and Visibility
One of the most important steps in the planning process is to gain top
management's commitment and support to EMS development and
implementation. It is critical that EMS commitment and support comes
from both local (municipal) leadership and your organization's top
management. In fact, experience has shown that public organizations
who attempt to implement an EMS without top management support are
unsuccessful.
Don't assume that top managers know all they need to know about an
EMS. Just like the rest of your employees, senior managers need
training. Short, frequent sessions that address managers' concerns and
goals have been the most successful ways to keep management up to
date on your EMS.
If your city managers or your wastewater management do not
understand the potential benefits of an EMS, they probably will not
have the incentive to follow through with implementation. During your
preliminary discussions about the EMS, you'll want them to clarify
management's specific goals for the EMS at your facility. You'll want
to confirm that they understand the EMS implementation strategy and
schedule you are using, the estimated direct labor commitment
involved, and when, how, and what to communicate to employees on a
regular basis. Every organization implementing an EMS has come to
the same conclusion about managementvisibility, commitment, and
involvement are the #1 keys to success. Be sure your EMS plans
include regular and frequent dialogue with management.
NA. NOTE
On the political side, top management could include: the
v mayor, city manager, town board, city council or city
commissioners. Top management on the facility side
could include the division director, department head, or
frontline managers.
Employees will react to management's actions far more than their
words, so be sure that management understands their role in EMS
development and implementation and that it involves being visible and
involved, particularly in the beginning stages. Here's what wastewater
facilities reported as management's most important roles and
responsibilities:
Providing input and approving the environmental policy statement
Appointing the EMS Management Representative
Approving EMS plans and programs
Tracking EMS performance
Being visible and involved in the EMS (e.g., showing up at team
meetings and employee presentations)
Communicating support of the EMS across the organization
Regularly meeting with the Environmental Management
Representative
Section 2: Getting Ready
Wastewater EMS Handbook
CASE STUDY
Top Management from the City
of Lowell, Massachusetts
showed its support for EMS
implementation by providing a
financial incentive to
employees within the
wastewater facility when they
successfully completed
their EMS.
Initial commitment was by the
Assistant Superintendent of
Wastewater Treatment and the
Director of Public Works and Utilities.
They saw the potential benefits to the
organization and asked staff to
investigate the program and then to
begin development and
implementation. Support also came
through approval of the time for staff
to develop and implement the
program and then by the City Council
through approval of the policy. The
City Council and City Manager
approve the EMS policy each year if
the Management Review Boa/7
determines that a change is needed.
Beth Eckert
Gastonia, North Carolina
27
-------
NOTE
It is critical to
. select the
right EMR.
Not everyone can
do the job
NOTE
All of the
wastewater
facilities
consulted for
this Handbook have
successfully implemented an
EMS by using a full-time EMR
or designated an EMR with
other organizational
responsibilities. The decision
you make for an EMR will
depend on the size of your
facility and available
resources.
Frequently asking employees at various levels and functions how
the EMS is going
Expressing personal goals for the EMS to the EMS leadership
Using the "bully pulpit" carefully and only when needed to move the
program forward
Providing human as well as financial resources
Helping your EMS teams to manage change
Rewarding, acknowledging, and reinforcing the benefits that the
EMS brings and the people who are making it happen
Another management key to success is to send three or four "good
news" bullets to senior management on a monthly basis. This keeps the
EMS on their agenda, and provides information for them to report at
their management meetings and through other outreach activities (e.g.,
conferences, newsletters, civic meetings, etc.).
EMS Program Leadership: the EMR, Core
and Site (Implementation) Teams
As you've probably gathered by now, the EMS is not a program that
one person can put into place. In fact, every employee in your fenceline
will be involved in some way in building and maintaining your EMS. One
of the first responsibilities that you as top management face is to
appoint an EMS champion. That person is the EMS program manager
and in EMS terms is called the Environmental Management
Representative, or EMR. The EMR, sometimes with recommendations
from top management, will appoint a cross-functional team of EMS
program leaders called the Core Team. These are the employees from
various levels and functions in the fenceline who will become additional
EMS experts, and assist the EMR in designing, delegating, and
evaluating EMS activities. A third level of EMS leadership are the
Implementation Teams. These are the employees and staff who are
closest to the actual work in the operations of your fenceline. They have
a huge amount of institutional know how and operational experience
that is critical to a strong EMS.
In some cases, organizations decide to add a Steering Committee.
Members of the Steering Committee often include City Commissioners,
City Managers, Mayors, Council Members, and Directors of other
municipal utilities and services. The Steering Committee's job is to
ensure that the EMS plans are consistent with the strategic vision of
the city and to ensure that appropriate resources are allocated for
the EMS.
Selecting an EMS Champion:
The Environmental Management Representative
The Environmental Management Representative (EMR) is the clearly-
identified EMS team leader who has responsibility and authority for
implementing and maintaining the EMS. The EMR has the designated
authority from management to get the job done and is pivotal to the
success of your program. The fact that the EMR represents top
management and speaks with its authority should be clearly stated and
28
Section 2: Getting Ready
Wastewater EMS Handbook
-------
regularly repeated throughout the EMS implementation, particularly in
organizations where the EMS hierarchy doesn't mesh with the
organizational hierarchy.
It's a good idea to make sure that your EMR gets sufficient EMS
training before beginning to build your EMS. This Handbook will be
extremely useful for making contact with other wastewater facilities
(or any relevant organization for that matter) who have implemented
an EMSEMRs are always happy to share their experience and
keys to success.
To locate additional information, or contact any of the Steering
Committee members that contributed to this Handbook, visit
www. peercenter. net.
In addition to being the EMS expert and champion, it's also useful if the
EMR has a good knowledge of the overall operations, strong project
management and organizational skills, and is a good communicator up
and down the organizational hierarchy. The most successful EMRs are
enthusiastic team players who are trusted and respected by all levels of
staff. A sense of humor is always an added bonus.
The EMR typically assumes the new EMS responsibilities in addition to
their existing responsibilities. In four out of the six wastewater facilities
contributing to this Handbook this was the case. Be sure management
understands the number of hours involved and is willing at times to
redistribute some responsibilities to others in the organization. Charts
have been included within this section for the EMS roles and number of
hours the wastewater facilities that consulted for this guide spent in
implementing their EMSs.
Typical EMR Responsibilities
The EMR is the project leader for the EMS and is essential to
successful implementation as the EMS driver and key communicator. In
addition to typical project manager responsibilities, the EMR can
anticipate the following activities:
Build and lead the EMS Core Team
Plan the EMS project and implementation schedule
Gather, organize, and disseminate information
Delegate tasks and establish deadlines
Facilitate top management visibility and involvement
Obtain cross-functional support and buy-in
Regularly meet and communicate with top management about the
benefits and status of implementation
EMR Qualifications
<ป Knowledge of organization's
business and management
practices and core opera-
tions
<ป Environmental background
<ป Leadership and project
management skillsteam
builder
<ป Systems thinker
<ป Good communicator up and
down the ladderrelates to
all levels of staff
NOTE
Vv Experience with
public organizations
\ that have
r implemented an
EMS has shown
that EMS Core Teams have
2-12 members, with an
average of 7 people.
Consider including
contractors, suppliers or
other external parties as part
of the Team, as appropriate.
The Teams definitely need to be
cross-functional, have buy-in into the
program, and have the time to
perform the tasks that were assigned
to them. I think if we had to do it over
again, and what we have done since
initial development, is to create an
EMS Team that is composed of a
more diverse level of staff. Initially, all
members were supervisors and now
our group includes laboratory
technicians, operators, assistant
managers, and supervisory level staff.
The buy-in from the frontline
employees comes easier the more
they are involved in the process.
Beth Eckert
Gastonia, North Carolina
Public Works and Utilities Department
Section I: Getting Ready
Wastewater EMS Handbook
29
-------
NOTE
Of the six wastewater facilities
that assisted with
this Handbook,
four had Core or
Site Team
members that
were not
supportive of their
EMSs (at I east at first).
Do you have any potential
EMS saboteurs in your
organization? Many public
organizations that have
implemented EMSs have
included saboteurs on their
Core and Site Teams and
turned them into supporters
of the EMS.
OACH'S
CORNER
f An EMS Core Team
ihould include cross-
jnctional (e.g.,
engineering, finance,
human resources,
operations, etc.)
representation and include
members from top to
bottom of the organization
(i.e., management to the
frontline). Members can
even be pulled in from
operations outside the
scope of the EMS fenceline.
A cross-functional team can
help to ensure that
procedures are practical
and effective and can build
commitment to and
"ownership" of the EMS.
The Core Team
The EMS Core Team plays an important leadership role in planning the
EMS project, delegating the tasks, establishing deadlines, collecting and
evaluating work, and providing training, guidance and assistance as
needed. The EMR heads the Core Team, and its members are an
organization's EMS experts and champions.
Some organizations enlist volunteers for their team; others delegate and
assign members to the Core Team. Keep in mind that the Core Team
also needs the authority as well as responsibility to drive the EMS.
If your organization cannot get enough volunteers on the Core Team,
consider making membership on the Team a prestigious honor. Get Top
Management to recognize your EMS Core Team members.
"Congratulations, you've just been selected to our EMS Core Team!"
Wastewater Organization
Buncombe County, North Carolina
Metropolitan Sewer District
Gastonia, North Carolina Public Works
San Diego, California
Metropolitan Sewer District
Kent County, Delaware Public Works
Eugene, Oregon Public Works
Charleston, South Carolina Public Works
Establish a
Core Team?
Yes
Yes
Yes
Yes
Yes
Yes
# of Members *
7
8
10
8
8
12
* The size of your Core Team will depend on your organizational structure,
specific employee skills and expertise, and your organization's available
resources.
REMEMBER
It takes time for the EMS Core Team to develop a team
dynamic. Give yourselves time to "gel" and work together as
a team. At first, have team meetings with some simple and
non-threatening EMS activities. For example, work together
on issues such as clarifying the meaning of key EMS terms
and EMS jargon.
30
Section 2: Getting Ready
Wastewater EMS Handbook
-------
EMS Core Team Qualifications:
"In the know" in their operational and functional areas
Good communicators and listeners
Enthusiastic and committed
Respected and trusted by employees and managers
Implementation or Site Team(s)
The majority of public organizations that have implemented an EMS
have also chosen to assemble an EMS implementation or site teamor
several teamsto help with the development of various EMS elements.
The make-up of the implementation teams typically consists of
personnel from the frontlinepersonnel that are responsible for the
activities and operations that generate potential significant
environmental impacts.
View the establishment of an Site Team as an opportunity to secure
buy-in at all levels of your organization. By involving staff in the EMS
Implementation Team activities (e.g., environmental analysis), you can
have greater assurance of their support and assistance.
Wastewater Organization
Buncombe County, North Carolina
Metropolitan Sewer District
Gastonia, North Carolina Public Works
San Diego, California
Metropolitan Sewer District
Kent County, Delaware Public Works
Eugene, Oregon Public Works
Charleston, South Carolina Public Works
Establish a
Site Team?
# of Members
Same as the Core Team
Yes
No
8
Same as the Core Team
Same as the Core Team
Yes
8
Typical Site Team Responsibilities:
Documenting the organizational activities/operations as process
flow diagrams
Assisting with the identification of environmental impacts
Providing input on environmental objectives
Developing work instructions and/or standard operating procedures
for activities or operations that were identified as significant
Disseminating information and good news about the EMS effort
acting as EMS champions for their area of operation
NOTE
Based on your wastewater facility size, you may not
need both an EMS Core and Site Team. For three of
the six of the wastewater facilities that consulted for
this Handbook, the Core and Site Teams were the same.
a i i/i
If //a.r jefinitely a plus to have a
s: ~3ctional representation
d on EMS Team(s).The EMS
Team members selected brought forth
knowledge and expertise from their
departments. The members were
willing to learn and grow, and they
also wanted to be involved with
be part of creating a culture sh...
(TQM, EMS) affecting the
organization.
i iiiey
'ith ="ld
sh...
//
James Naber
Buncombe County, North Carolina
Metropolitan Sewer District
EMS Core and Site
Team Keys to Success
Ask for volunteersif there
are none, have section
managers make appoint-
ments. They know the leaders.
Make responsibilities clear
to employees and to their
managers.
Reward/recognize their
involvement.
Secure their time commitment
from managementbe aware
of peak operational times.
Sometimes include the "bad
apples" on the implementation
team as a way to alleviate
dissension at the pass.
Section 2: Getting Ready
Wastewater EMS Handbook
31
-------
COACH'S CORNER
training for employees
_ up front. This will
' contribute to the
EMR's ability to
facilitate and direct the
EMS development effort.
./a//, frontline employees were not
)l- I. They slowly became
volved as the EMS implementation
moved along. Based on initial
discussions with many of these staff
members, their initial reaction to the
program was that it be put up on a
shelf and forgotten about. However,
discussions with staff as the
implementation progressed revealed
that many of the employees were
seeing potential benefits to personally
and professionally and discoverinq
how they can use the program.. he.
them do their job better.
Beth Eckert
Gastonia, North Carolina
Public Works and Utilities Department
CASE STUDY
An Associate Recognition
Program is in place for
employees at the Charleston,
South Carolina CPW. Under
the Program, employees are
nominated by other
employees and management,
based on productivity,
contributing to goals, and
being team-oriented and
positive. Awards include peer
recognition, cash, and parking
privileges. A copy of
Charleston's Associate
Recognition Program is
attached in Appendix B.
Lessons Learned Regarding Core and Site Teams
(from wastewater facilities):
ป Don't pressure anyone not willing to serve.
ป Be clear that each team member understands their role.
ป LISTEN to concerns and try to address, don't dismiss, concerns
early-catch and try to alleviate these concerns before they get back
to the frontline.
ป Let team members know that their opinions matter.
ป Conduct team-building exercises to build a team dynamic.
Securing and Maintaining Employee Buy-in
The same concepts that you used for enlisting the support of your
fenceline managers, supervisors, and union stewards can be applied to
getting employee buy-in. Some employees may view an EMS as
bureaucracy, the "flavor of the month," or added work or expense. There
also may be resistance to change or fear of new responsibilities. To
overcome these potential barriers, 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 (and safety)
impacts in their areas and in day-to-day operations.
Get key employees involved in the EMS early and often. While the EMS
is not technically challenging, the introduction of new ideas can be
threatening for employees. Therefore it's important to get employee
support from the beginning through ongoing, consistent, open dialogue
on your EMS. Employees should understand what the organization
wants the EMS to accomplish. This can go a long way toward gaining
that support and answering the question of "what's in it for me?"
CASE STUDY
An EMS Commitment Statement was prepared and signed by all
employees at the Charleston, South Carolina CPW (a copy is
attached in Appendix B).
Communicate and ask employees for their EMS goals during the
planning stages and throughout EMS implementation. Open employee
dialogue, buy-in, and involvement will help ensure that the EMS is
realistic, practical and adds value.
NOTE
3 of 5 = number of wastewater treatment facilities from
. the Wastewater Steering Committee that involved
. frontline employees during the initial stages of EMS
planning and development.
32
Section 2: Getting Ready
Wastewater EMS Handbook
-------
EMS implementation requires participation by more than a single
individual to be successful. Ultimately, your organization will want to
institutionalize the EMS and create an atmosphere or culture where
environmental management becomes business as usual across all
day-to-day activities. Therefore, involving cross-sectional employees
early in the planning of the EMS is the best way to promote short- and
long-term commitment throughout the organization. Plus, it's a great
way to gain support and ensure buy-in for the EMS.
Ideas for building a team approach to the EMS
and involving employees from the very beginning
include:
Holding a kick-off meeting and invite top management; this helps
everyone see the EMS as a priority.
Talking the EMS up with employees, union stewards, middle
managers, 2nd shifters, etc.
Spending time talking with middle management and line supervisors.
One-on-one conversations can identify their needs, concerns, and
problem areas. The more your middle managers are involved in the
initial stages of the EMS, the more support and buy-in you will get.
Asking employees on the front-line what changes they would like to
see in their operations as a result of the EMS (See Appendix B for a
list of questions that a public works organization used in getting
support and buy-in fromfrontline employees). However, don't over-
whelm them with EMS "jargon."
Posting EMS signs on bulletin boards, lunch-rooms, and near
coffee and copy machines to familiarize staff with EMS words
and the ideas.
Advertising early successes to keep management and employees
aware of EMS efforts.
CASE STUDY
At the Buncombe County, North Carolina MSD, employees from the
very beginning were asked for their operational expertise and what
they wanted to get from an EMS. Buncombe employees soon realized
their ideas and efforts could make a difference.
Conducting an EMS Gap Analysis
Of all of the activities in the Getting Ready Phase, the Gap Analysis is
your EMS leadership team's first foray into the actual world of EMS
jargon and the requirements of a formal EMS. The Gap Analysis
provides a current baseline assessment of the degree of conformance
of existing policies, procedures and practices to standard EMS
requirements.
Your EMS Gap Analysis will probably show that you have a number
of EMS elements in place. Rememberyou don't have to start
from scratch!
' /e > orked to provide employees with
' e cessary tools (e.g., standard
updating procedures) to successfully
and consistently complete their work.
With communication and
documentation in place, change
became easier and smoother. Allow
time for employees to absorb
information and adapt to chang .
Chris Toth
City of San Diego
Wastewater Collection Division
COACH'S CORNER
Use your EMS Gap
L Analysis as a project
planning and a
7 communication tool.
The Analysis will allow
you to scope and budget
the EMS effort by
identifying your EMS gaps
and by providing a
preliminary level of effort to
fill the gaps. Since this is
typically the first exposure
personnel have to the
EMS, the EMR and Core
Team, use the Gap
Analysis to increase
employee EMS awareness,
communicate useful
information about
environmental issues to top
management and frontline
employees, and teach
everyone about the basic
EMS elements.
Section I: Getting Ready
Wastewater EMS Handbook
33
-------
COACH'S CORNER
A few things to keep in
your EMS:
*~ Help is available from
your wastewater peers and
from other public organiza-
tions don't hesitate to use it.
(See Appendix C for a list of
your wastewater peers and
other EMS resources.)
*~ Pace yourselves and do not
stall in your EMS planning and
implementation. Move quickly
enough that your employees
stay interested and engaged,
but not so fast that those
involved are overloaded.
Don't re-invent the wheel
existing environmental
programs and management
practices should help you meet
EMS requirements.
*~ Consultants can help you
evaluate your EMS and
suggest approaches used
successfully elsewhere, but
use them as facilitators. Your
organization must manage the
EMS, not the consultants.
NOTE
Personnel that conduct the gap
analysis should have
a basic
. understanding of
X your EMS. The
EMR and EMS
Core Team
members are typically
responsible for conducting the
analysis. It involves reviewing
documentation and interviewing
personnel, through an
established protocol.
It's recommended that the EMR, and some members of the Core and
Implementation Teams conduct the Gap Analysis, and that these team
members have a basic understanding of the EMS before they begin. It's
also a good idea for top management to communicate to managers,
directors, union stewards and supervisorswell in advancewhat the
gap analysis is, the reasons for doing it, and when it will take place.
Schedule the Gap Analysis at a time convenient to fenceline managers
if possible.
Conducting the Gap Analysis in-house rather than hiring an outside
consultant is preferable for several reasons. First, it's a great tool to
familiarize your Core Team and your EMR with the language of the
EMS and the 17 requirements that make up the Plan-Do-Check-Act
cycle. Second, it's an activity that allows the EMR to delegate some of
the responsibility to several Core Team members, and to evaluate the
skill set of the Core Team. Third, it's a good opportunity for the Core
Team to work together for the first time to accomplish an important EMS
milestone; and fourth, it's a great tool to open a dialogue between the
Core Team and the Implementation Teams about the plans, procedures,
SOPs, and records that currently exist in operational areas.
Finally, once you have completed your Gap Analysis, you'll have a good
idea of how much work your organization needs to do to complete the
EMS, and that will help you to allocate human and financial resources
appropriately.
At the end of the Gap Analysis you'll have improved your Core Team
dynamic, increased employee EMS awareness, communicated useful
information about environmental issues to your senior management,
and learned a lot about EMS elements and the scale of the
implementation effort.
Wastewater
Organization
Buncombe County, North
Carolina Metropolitan
Sewer District
Charleston, South
Carolina Public Works
Eugene, Oregon
Public Works
Gastonia, North Carolina
Public Works
Kent County, Delaware
Public Works
San Diego, California
Metropolitan Sewer
District
Was a Gap
Analysis
Conducted?
No
Yes
Yes
Yes
Yes
Yes
Did you Use
a Checklist?
No
Yes
Yes
Yes
Yes
Yes
% of EMS
Elements
in Place
20%
40%
40%
15%
60%
10%
Typical EMS
Elements that
were in Place
> Legal & Other
Requirements
> Monitoring and
Measurement
> Operational
Controls
> Standard
Operating
Procedures
> Environmental,
Health & Safety
(EH&S) Training
> Emergency
Response
Various EH&S
Records
> Management
Review
34
Section 2: Getting Ready
Wastewater EMS Handbook
-------
What to Look for in the Gap Analysis
The protocol (or checklist) that you can use for the Gap Analysis will direct
you in your efforts. You will review documentation, interview personnel,
and assess whether you have documented procedures for internal and
external communication, training, and management review, etc.
See Appendix B for an example EMS Gap Analysis Checklist.
The information you capture from the gap analysis will save you
time further down the road and eliminate duplicating what already
exists. Develop a gap report based on your findings and report to
top management.
Managing Change: It's NOT Easy!
As you move forward with your EMS, you'll begin to realize that the
challenge is not with technical issues but rather with organizational
change. Most organizations don't like change. Managers, directors, and
employees all are quite comfortable with the status quo.
"Change is good...but you go first!"
Managing change is an important factor in EMS implementation, and
the entire EMS leadership must be involved. The Steering Committee
and top management facilitate change by clearly showing through
frequent communication and through their involvement early on in EMS
awareness activities that the EMS is a priority for the organization and
one that has their personal attention. The EMR, Core Team, and
Implementation Teams are the change agents that are closest to the
workforce. They must be ready to listen and respond to concerns and
fears that the workforce expresses, for these issues are not ones to be
swept aside or discounted. Ideally the EMS teams that you have
selected will be staffed by people who have earned the trust and
respect of their peers and colleagues. That is an important key to
success in change management.
^ NOTE
. As new elected officials (e.g., City Managers or Council) or
senior managers at your facilitiy come on board, there
may be the perception that the EMS is not "their"
initiative. This can result in reduced support and resources for
the implementation effort. It's very important to educate the new
leaders early on about the associated benefits of your EMS to secure
their buy-in and support.
Brainstorm with your Core Team and Site Teams about the times when
change went really well in your organization. What lessons can you
learn from that experience that you can apply to the EMS program?
Then recall a time when change went really badly in your organization.
Apply these lessons to the EMS program as well.
Wastewater and
Other Public
Organizations' Keys
to Success for
Managing Change
Secure active support/
interaction from manage-
ment
Establish early dialogue
and lines of communication
Define opportunities for
ownership and empower-
ment (e.g., incentive pro-
grams, etc.)
Maintain consistency
keep EMS on the radar/visi-
ble
Promote activity and
involvement (e.g., an EMS
comment box)
Our organization learned that change
could be a good thing and not
something to be afraid of. We also
learned that communication (two-way
communication) with all relevant
levels of staff can help to make
changes smoother and more positive.
It is amazing the different
perspectives the various levels of
staff have about what management
may consider to be the most minor
change and that if given the
opportunity to be heard, how e:
staff is to share their opinion.
^Pr4
Beth Eckert
Gastonia, North Carolina
Public Works and Utilities Department
Section 2: Getting Ready
Wastewater EMS Handbook
35
-------
A Few Words About
EMS Language/Jargon
The language/jargon of an EMS is
typically a hurdle at the beginning of
the EMS process. Words like
"aspect," "significance," "target," etc.
have a specific meaning that is not
necessarily intuitive or consistent
when you begin your EMS
implementation.
REMEMBER
,| Spend time with your EMS
*-- Core Team unlocking
EMS termsthis will
ave you hours down the
iad. Also, pass these
language lessons on to
managers and employees while
conducting the gap analysis or
during monthly all-hands
meetings, etc.
Begin
Phase 1:
Getting Ready
(~3 months)
You've conducted your Gap Analysis, obtained commitment and support
from management, formed your EMS leadership teams, and given
some thought to change management. Your Getting Ready Phase of
EMS implementation is almost completed. Two more tasks await you:
becoming acquainted with the strategy you'll use to implement the EMS
and finding information resources and materials that will help you
prepare your organization to build the EMS.
Understanding the EMS Implementation
Strategy
The strategy used in this Wastewater EMS Handbook is one used
successfully by over 50 organizations across the United States. It's a
dynamic strategy, because it reflects the most current lessons learned,
improvements, tools and materials that many different public agencies
have gathered from the experiences of wastewater utilities and other
public facilities like yours.
One way to describe the strategy is "just-in-time" implementation.
As previously mentioned, when you are involved in a particular phase of
EMS activity, there is no need to look ahead to what will happen in the
next phase. We urge you to stay focused on the EMS milestones in the
current phase. As you complete each milestone, you are one step
closer to a complete and thorough EMS. The activities in each phase
are designed to sequentially build a strong and thorough EMS.
While the EMS that you are building can certainly apply to any EMS
based on the Plan-Do-Check-Act approach, this Handbook and
implementation strategy are based on the ISO 14001 Environmental
Management System. Should you determine at a later date that 3rd-
party verification of your EMS is a sound business decision, you will
have addressed all the elements described in the ISO 14001 EMS.
Here's an example program plan that describes the five phases of
EMS implementation:
End
Phase 2:
Planning
(~6 months)
Phase 3:
Implementing
(~9 months)
Phase 4:
Checking & Corrective
Action
(~5 months)
Phase 5:
Management Review
(~1 month)
* Commitment
* Awareness
* ID Goals
ป EMR & Team
Selection
* Gap Analysis
Game Plan
-
* Policy
ป Legal & Other
Requirements
* Significant Aspects
ID
* Objectives & Targets
ป EMPs
* Managing Significant Aspects
(Operational Controls)
* Training
* Documents & Records
(SOPs, WIs, etc.)
* Emergency Preparedness &
Response
* Communication
* Roles & Responsibilities
* Monitoring & Measurement
* Compliance Status
* Internal & External
Reviews
* Corrective Actions
* Preventative Actions
* Judge the suitability, ade-
quacy, and effectiveness
of the EMS
* Consider new organiza-
tional goals
* Apply lessons learned for
continual improvement
36
Section 2: Getting Ready
Wastewater EMS Handbook
-------
One question often asked is how long the implementation will take and
how much direct labor and other resources your organization will
commit. The timeline for waste utilities that have successfully
implemented an EMS has averaged 12 - 24 months. Less time than
that for implementation would require a huge amount of resources;
longer than that detracts from the motivation and energy of the process.
The time it takes your facility to implement an EMS will vary, depending
on the length of the time for each phase of activity, operational and
business realities that intrude on your normal workflow, and many other
change issues that wastewater facilities are faced with each day. The
timeline provides an average time of each phase. Here's some
additional information from wastewater facilities around the country:
REMEMBER
t Implementing an EMS is
~S not a race to see who
gets there first. Make
sure that you devote
sufficient time and
resources to the EMS
and get employee buy-in and
support early and often.
Wastewater Organization
Buncombe, North Carolina Wastewater
Plant
Buncombe County, North Carolina
Metropolitan Sewer District
Charleston, South Carolina Wastewater
Collection System Department
Charleston, South Carolina
Environmental Resources
City of Eugene, Oregon Wastewater
Gastonia, North Carolina Wastewater -
2 treatment plants (includes a
laboratory, the pretreatment program
and a biosolids program)
Kent County, Delaware Wastewater
San Diego, California Operation &
Maintenance Division
San Diego, California Metropolitan
Wastewater Collection Division
Size of Facility
(in Millions of Gallons/Day = MGD)
40MGD
20 MGD
40 - 74 MGD
< 40 MGD
49 - 75 MGD
6 MGD
16 MGD
15 MGD
> 75 MGD
> 75 MGD
Time in Months
(from EMS Project Start to 1st
Management Review)
22 Months
13 Months
18 Months
24 Months
18 Months
18 Months
Currently implementing an EMS
18 Months
30 Months
These implementation averages will help you guide your organization through the EMS process. While they
are specific to each organization, they should help you plan your program structure and prevent you from
spending too much time on any one phase.
Another question asked by top management concerns the amount of direct labor support the EMS
implementation will require. A rough average is 12 hours of time per year for each employee in your
organization. Certainly your receptionist will probably not spend as much time on the EMS as your EMR or
Core Team members, but over each year the total hours expended has held to this average. Direct labor
costs to maintain your EMS will shrink considerably as the EMS becomes business as usual.
Section I: Getting Ready
Wastewater EMS Handbook
37
-------
Here's some information about the resource commitment of wastewater facilities interviewed for this
Handbook:
Wastewater Organization
Buncombe, North Carolina
Wastewater Plant
Charleston, South Carolina
Wastewater Collection
System Department
Charleston, South Carolina
Environmental Resources
City of Eugene, Oregon
Wastewater
Gastonia, North Carolina
Wastewater (2 treatment
plants, a laboratory, the
pretreatment program and a
biosolids program
San Diego, California
Metropolitan Wastewater
Collection Division
San Diego, California
Operation & Maintenance
Division
Total Labor Cost
$50,000
Not Available
Not Available
$85,000
$51,800
$211,000
$200,000
Total Consultant
Cost
(if applicable)
$35,000
Not Available
Not Available
$21,000
Not Applicable
$90,000
$160,000
Total Cost to
Implement
(Labor, travel, materials,
and consultants)
$94,000
Not Available
Not Available
$120,000
$53,800
$308,000
$365,000
Wastewater Average
Staff Time
(EMS Project Start to 1st
Management Review)
3,300 hours
1,675 hours
1,675 hours
4,300 hours
Not Available
6,200 hours
Not Available
Discuss with your management, your Core Team, and your Implementation Team a timeline that you feel is
appropriate for your organization. Refer to your Gap Analysis to get a general sense of how much work
needs to be done and the anticipated size of the program.
A list of key EMS implementation activities and the month they were completed by the wastewater facilities
that contributed to this Handbook is attached at the end of this section.
EMS Roles and Hours Dedicated to EMS Implementation
Roles
Environmental Management Representative (EMR)
Senior Management
EMS Core Team
Consultant(s)
Hours
(from project start to completion of
first management review)
Average hours = 2,100
Range of hours = 1,000 to 3,000
Average hours = 30
Range of hours = 8 to 100
Average hours = 2,050
Range of hours = 1,800 to 2,500
Average hours = 315
Range of hours = 100 to 500
38
Section 2: Getting Ready
Wastewater EMS Handbook
-------
EMS Information Sources and Resources
The Getting Ready Phase involves educating many levels of employees
in your facility: managers, the EMR, EMS leadership teams, and
employees. This process of learning more about an EMS doesn't end in
this phase, but continues throughout each of the subsequent phases.
Assembled in this Handbook are excellent lists of information resources,
some of which are contained in Appendix C of this Handbook; others
are available on the Internet.
Some additional EMS Implementation Guides that have served
wastewater utilities and other pubic entities over the past seven years
include:
EMS: An Implementation Guide Small and Medium-Sized
Organizations, Second Edition, NSF International, Ann Arbor, Michigan,
January 2001.
An EMS Troubleshooters' Guide for Local Governments, Global
Environment & Technology Foundation, Arlington, Virginia, October
2002.
The Internet is an excellent source of EMS information. One site that
caters specifically to public entities implementing an EMS is the Public
Entity EMS Resource Center the PEER Center Website at
www. peercenter. net. Linked from the PEER Center are seven Local
Resource Centers across the United States. Each has experience and
expertise in facilitating EMSs in public entities.
Moving to the Next Phase
Congratulations! You have brought your organization through its first
phase of EMS implementation. Here's a checklist of the EMS
Milestones you've accomplished:
S Choosing your EMS "fenceline"
S Understanding your organizational goals
V Confirming top management commitment, involvement, visibility
V Selecting an EMS champion
V Building EMS teams
S Securing employee buy-in
S Conducting a Gap Analysis
S Managing change
S Understanding the implementation strategy
S Accessing EMS tools and information
Things to Avoid
1. Overburdening employees with
EMS implementation tasks during
peak operational periods.
2. Using EMS "jargon" when
communicating with employees
(e.g., instead of environmental
aspect/impact, try cause/affect).
3. Waiting until the EMS
management review to involve
management in the EMS. Provide
brief monthly reports/updates on
the status of implementation to get
management involved early on.
4. Stalling during your EMS
planningstick to a regular pace
so that your employees remain
engaged and interested in the
EMS process.
5. Establishing implementation
time frames that are
unreasonabledon't bite off more
than you can chew.
NOTE
Additional sources of
EMS information
that the Wastewater
Steering
V Committee
found useful are
in Appendix C.
Section I: Getting Ready
Wastewater EMS Handbook
39
-------
COACH'S
ORNER
..To increase your
' chances of continued
management support for
the EMS:
*~ Enlist the aid of top man-
agement frequently, and ask
them to regularly be visible,
provide resources, and make
the EMS a priority (i.e., "wave
the flag"). If your managers
take a hands-on part in the
EMS you will have an easier
time with change and also
have greater success in your
EMS implementation.
*~ Clearly define who your top
management is for the EMS
and what goals are driving
their interest in the EMS.
*~ Provide management at all
levels with specifically
designed training to help them
understand EMS activities and
milestones, the scope and
timeframe of the program, and
their role in the EMS process.
*~ Collect and record EMS per-
formance and benefits through-
out your EMS implementation.
How are you improving your
efficiency, saving money,
avoiding accidents and spills,
increasing environmental
awareness and understanding,
reaching out to stakeholders,
etc. This information needs to
be passed on to employees
and to management (in the
Management Review). In other
words, document and celebrate
your EMS successes as you
go along!
As you complete this phase, it might be useful to document the lessons
your EMR, Core Team and Implementation Teams have learned. What
barriers did you experience? What benefits have you seen?
Some of the documents that you will have generated in the Getting
Ready Phase include:
An EMS organizational chart showing the functions of those who
serve as your EMR, your Core Team and Implementation Teams
and, on your Steering Committee, if you have one.
A gap analysis showing what you already have in place that
conforms to an EMS, and the areas that provide opportunities for
improvement.
A list of organizational goals at the various levels and functions of
your fenceline.
A tentative timeline of EMS implementation that is appropriate for
your organization.
A list of wastewater facility contacts who have implemented an
EMS in their own organizations.
A list of public and private organization contacts in your area
who have implemented an EMS.
Your favorite Websites for EMS tools, materials, and information.
Barriers you have experienced in this phase.
Benefits you have experienced in this phase.
Lessons learned about implementing an EMS in your organization.
In the next Section of this Wastewater EMS Handbook, you'll find
step-by-step guidance to help you and your EMS Leadership Teams
accomplish the EMS milestones in each of the subsequent EMS
phases. We hope you will take the time to share your experiences,
data, case studies, lessons learned and keys to success with other
wastewater facilities who will consider EMS implementation in the
future.
Best of luck!
// /vaf earned early on that a phased approach to our EMS implmentation
i j > iinable and suitable to the needs of our organization. We die
want to bite off more than we could chew.
mentation
:
James Naber
Buncombe County, North Carolina
Metropolitan Sewer District
40
Section 2: Getting Ready
Wastewater EMS Handbook
-------
COACH'S CORNER
Methods used by other EMS Wastewater Practitioners to
Promote Familiarity/Awareness of their EMSsLet's borrow
from their EMS Playbook!
. Post EMS awareness signs and aspect/impact lists,
objectives and targets, etc. on bulletin boards and
throughout buildings, access areas, lunchrooms, and break
rooms.
2. Use brochures, EMS videos, and EMS awareness reference
cards.
3. Conduct EMS awareness training and hold face-to-face
meetings.
4. Develop an EMS newsletter and monthly activity reports.
5. Create EMS information Websites.
6. Send emails on EMS basics that go out to all employees.
7. Hold an EMS slogan contest with a day of vacation as a prize to
the winner.
8. Create an EMS character, catchy EMS acronym, and a simple
message to inform employees about the EMS.
9. Develop creative and fun ways to present the EMSkitchen
magnets, screen savers, etc. with the EMS
logo/character/acronym.
Lessons Learned
1. Keep EMS staff and core team
meetings focused and efficient
(provide food as an incentive!).
2. Implement a document control
system for your procedures,
documents and records early on
in the EMS implementation
process.
3. Contact other wastewater
treatment facilities and other
public organizations that have
implemented an EMS to benefit
from their knowledge. They are
eager to share their insights.
4. Communicate implementation
successes early on to help
motivate management and all
employees to the benefits of an
EMS.
5. Make the EMS "system"
dependent and not "person"
dependent.
Section I: Getting Ready
Wastewater EMS Handbook
41
-------
Frequently Asked Questions about Environmental Management Systems
Q. Where in my operations would an EMS be
appropriate?
A. An EMS can be applied in one or more
departments or operations across an organization.
You should examine the organization's activities and
services and determine where the EMS would best
serve needs and organizational goals. The
department(s) or facility(ies) to which
EMS is called the "fenceline".
you
Q. To implement an EMS, do we hav
scratch?
A. Much of what you have in place now for
environmental management probably can be
incorporated into an EMS. There is no need to "start
over" and re-invent the wheel for environmental and
other organizational programs that are in place. A
gap analysis is a great way to determine what parts
of an EMS may already exist. See Appendix Bforai
Gap Analysis Checklist.
Q. What is the purpose of an EMS Gap Analysis?
A. The requirements of an EMS are compared to an
organization's current management and
environmental programs. The gap analysis is used to
determine EMS program priorities and for planning
the path ahead for implementation.
Q. What is it going to cost to implement an EMS at
my wastewater facility?
A. The cost of implementing your wastewater EMS
will vary depending on the size of your facility
(fenceline), if you use consultants, and the number of
policies, procedures, work instructions, etc. you
have in place that meet the requirements of
Note the dollar and human resources spent
Cementation from wastewater facilities on
s Section. Use the lessons learned and
s from other wastewater organizations
mented an EMS and to use this
Handbc a resource.
.plement an EMS without consultants?
ilthough your current consultants can be a
resource for reviewing environmental
.ipliance and assisting with other EMS tasks, we
/commend you use them only as needed for the
EMS. Remember, this is your EMS. Take ownership
of your EMS by involving your own management and
staff in implementation activities.
Q. Where can I find additional help on EMSs,
especially in the wastewater sector?
A. The Wastewater Steering Committee that
contributed their knowledge to this Handbook are
providing you with a support network as you
implement an EMS at your wastewater facility. Their
POC information is listed in the front of this
Handbook.
Appendix C contains EMS Websites and other
excellent resources, some specifically tailored for
wastewater and/or public organizations.
In addition, the Peer Center Website
(www.peercenter.net) is specifically customized for
the public wastewater industry, and therefore, will
contain EMS tools, case studies, references, POCs,
etc... for wastewater managers.
42
Section 2: Getting Ready
Wastewater EMS Handbook
-------
Phase II: PLANNING
You are now ready to begin the
Planning phase of the EMS cycle.
Each section of this Handbook will
guide you step-by-step through each of
the EMS activities. Refer to the icons for
case studies, sample documents, keys to
success and other implementation assis-
tance. At the end of each sec-
tion, two handy reference
sheets review the
Purpose of each
requirement,
describe the
Results you'll be
developing, dis-
cuss how to
Prepare to do the
work, and show
how the element
links to other EMS
requirements.
In this phase, you will be developing
a formal environmental policy, essentially
a vision and mission statement that
describes your organization's commit-
ment to the environment and is the foun-
dation for your EMS planning and action.
Next you'll conduct a thorough assess-
ment of how the operations in your fence-
line impact the environment, and identify
which of those impacts is most significant.
You will review how you stay current with
the laws and other requirements that
guide your operations and how you com-
municate this information to the
employees who need the
information to do their
jobs effectively.
Finally, you will be
setting environmen-
tal performance
improvement objec-
tives and measura-
ble targets, and then
establishing pro-
grams to accomplish
your goals. If you are
using a two-year imple-
mentation strategy, the activi-
ties in this phase can be comfortably
accomplished in about six months.
Here's a checklist of requirements in this
Phase:
Phase II EMS Requirements (6 months)
Environmental Policy
Legal and Other Requirements
Aspects and Impacts
Objectives and Targets
Environmental Management Programs
^
^
^
^
^
-------
Section 3: Environmental Policy:
Setting the Stage
An environmental policy is your organization's statement of its
commitment to the environment. It is signed by top management
and serves as a foundation document for your EMS and provides
a vision for your entire organization. Everyone in the organization
should understand the policy and what is expected of them in order to
achieve your environmental goals. Use your policy as a framework for
planning, action, and continual improvementall else that follows will
be based on your policy.
As you develop your EMS policy, it is critically important that the policy
be consistent with other strategic environmental priorities you may have
established through organization-wide strategic plans or other similar
efforts. Don't make the mistake of having your EMS policy "exist in a
vacuum." For example, you may have already embarked on major
effort to improve the management of your capital assets through a for-
mal assets management program. Make sure this commitment is
reflected in your EMS policy and made part of your EMS throughout.
ISO 14001 Environmental Policy Commitments:
Continual Improvement
Pollution Prevention
Compliance with Relevant Laws and Regulations
Step-by-Step Guide to Developing
an Environmental Policy
i
Step 1) Review Current Policies
Step 2) Draft an Environmental Policy
Step 3) Check Your Environmental Policy for
EMS Conformance
Step 4) Finalize Your Environmental Policy
Step 5) Communicate Your Policy
Step 6) Review Your Environmental Policy for Effectiveness
Step 1) Review Current Policies
You probably have some type of environmental or other organizational
policies in place, even if they are not written down. For example,
your organization is most likely committed to complying with
environmental laws. Document what you have in place as a starting
point. Leverage your current policies, build on them, and develop
your environmental policy.
If no policy or language exists, you will need to draft a policy from
scratch. There are plenty of examples your team can review to get
Key Section Terms
Continual Improvement - The
process of enhancing an
organization's EMS to achieve
improvement in overall environmental
performance in line with the
organization's environmental policy.
The basic principle of the plan, do,
check, act approach.
EMS Core Team -A cross-functional
team made up of individuals within
the organization that helps facilitate
EMS implementation across the
organization. Team members are the
EMS experts and cheerleaders.
Environmental Management
Representative (EMR) - The clearly
identified EMS team leader who has
the responsibility and management
authority for implementing the EMS
from start to finish.
Environmental Performance -
Measurable results of the EMS
related to an organization's control of
its environmental aspects, based on
its environmental policy, objectives
and targets.
Environmental Policy -An
organization's formal statement
defining its intentions and principles in
relation to its overall environmental
performance. It provides a framework
for action and setting environmental
objectives and targets.
Pollution Prevention - The
development, implementation, and
evaluation of efforts to avoid,
eliminate, or reduce pollution at the
source. Any activity that reduces or
eliminates pollutants prior to
recycling, treatment, control
or disposal.
Section 3: Environmental Policy (Phase I)
Wastewater EMS Handbook
45
-------
Methods Used to
Internally
Communicate
Environmental
Policies:
^ Posting the policy at various
sites throughout the work place
(e.g., in lunchrooms) so there is
a visual reminder of the state-
ment and its importance
^ Using paycheck stuffers,
identification badges, wallet
cards, etc. so that employees
can carry the environmental
policy with them
^ Incorporating the policy into
training classes and materials
^ Referring to the policy at staff
or all-hands meetings
^ Posting the environmental poli-
cy on the facility's Internet
f jll t> gether a representative, cross-
id tal group from your
organization when developing the
policy and you'll have more bu)
your EMS policy from every lev
f
Beth Eckert
Gastonia, North Carolina
Public Works and Utilities Department
Involving Contractors
and Temporary Staff
Contractors and temporary staff that
work within your EMS fenceline are
required to be trained on and
understand your environmental
policy. Most wastewater facilities
that have an EMS conduct a shorter
version of their EMS awareness
training for their contractors and
temporary staff that includes a site
safety review and an overview of
the EMS and the environmental
policy.
started, including an example policy at the end of this section and
examples from wastewater organizations are included in Appendix A.
Avoid developing a policy that is vague or could apply to any
organization. Your policy should be specific to the goals you want to
accomplish.
Step 2) Draft an Environmental Policy
Once you have your EMR and EMS Core Team in place, create a draft
environmental policy based on any current business commitments
and/or organizational and environmental goals. Remember that
conformance to ISO 14001 must include statements regarding the three
key commitments noted above.
Designate a couple of EMS Core Team members to be responsible
for your draft policy. Get input from top management and seek input
from employees. It is important that your policy reflect your
organizational culture and that it is appropriate to all levels of your
operations and services.
A sample Environmental Policy is attached at the end of
this section. Additional sample policies from wastewater facilities are
attached in Appendix A.
NOTE
Before you finalize your environmental policy, consider
2* . sitting down and brainstorming how your facility impacts
\ the environment (your "footprint") and draft a few goals
Sfck that you would like to achieve with your EMS.
. Identifying a few environmental goals before you
finalize your policy will allow you to see how your
wastewater facility considers environmental goals in line with business
objectives. This approach will result in a policy that is specific to your
organization and what you want to accomplish, rather than a "cookie
cutter" policy.
Step 3) Check Your Environmental Policy for
EMS Conformance
Check
-------
Step 4) Finalize Your Environmental Policy
Once you have considered what you want to accomplish
environmentally as an organization and checked your policy for
conformance, finalize your policy by having top management sign, date,
post, and communicate it. This shows commitment from the top.
COACH'S CORNER
\?\> ,, Keep your environmental policy simple, understandable,
- J* and to the point. One quick test: Could your employees
" ' describe your policy statement in a few words?
Step 5) Communicate Your Policy
Once your policy is signed and approved, communicate it to your
employees. Make sure that all employees understand the policy and
how it relates to their work.
Conduct training to introduce the environmental policy to your
employees, explain its purpose, and answer any questions. This can be
done in separate training sessions and/or by incorporating training on
the policy into other ongoing training (e.g., health & safety,
environmental refreshers, etc.).
Case Study
Kent County Levy Court Public Works Wastewater wrote their policy
to reflect an acronym that all employees could remember. They also
added a symbol to help remember the acronym. In addition, they
gave every fenceline employee a kitchen magnet with the policy
information on it, and are considering placing the information on
insulated mugs and mouse pads made from recycled materials. Kent
County's Policy mascot, abbreviated policy, and acronym (CHIRP)
nvironmental/Biosolids Policy
Comply with regulations and NBP Code
f Good Practice
ave an environmental/biosolids vision
nprove continuously
eadily share information
ractice pollution prevention
Three Lessons Learned
(from wastewater facilities):
1. Keep your policy simple. A simple
policy written with specific
expectations provides employees
with a straight-forward and realistic
view of your environmental and EMS
purpose.
2. Include employees from across
your wastewater facility when drafting
your policy. Have a couple of Core
Team members and management
representatives draft your statement,
then refine and finalize your policy
based on feedback from the entire
Core Team and staff at all levels. This
will help secure employee buy-in.
3. Make sure your policy uses key
words from the ISO 14001 Standard
(e.g., pollution prevention, continual
improvement, and compliance),
especially if you are working
toward third-party certification.
Three Things to Avoid
(from wastewater facilities):
1. Creating a policy that is too long.
A lengthy policy makes it difficult for
employees to identify the most
important points. Make it one page or
less.
2. Not defining your wastewater
fenceline (core operations and
services) before drafting your
environmental policy.
3. Rushing your drafting process.
Spend time drafting your policy
since it really defines management's
commitment to the EMS and sets
the framework for development of
your EMS.
Section 3: Environmental Policy (Phase 2)
Wastewater EMS Handbook
47
-------
Three Keys to
Success
(from wastewater facilities):
1. Don't start from scratch. Use
existing policies and
organizational goals to
document and expand your
environmental policy. This will
lead to positive, organization-
wide acceptance.
2. When training your
employees on the basics of the
EMS policy, make sure they
understand they do not have to
memorize the policy. They do
need to understand what your
environmental commitments are
related to the policy and be able
to express that in their own
words. Consider laminating and
using badge/wallet size policy
cards that employees can keep
with them and that contain the
basics of your wastewater
environmental policy.
3. When developing your
environmental policy (and your
EMS), it is critical that top
management listen to the
working conditions and
concerns of all employees.
Common Questions to Ask Employees about Your
Environmental Policy Include:
Can you describe the environmental policy in your own words?
What does the environmental policy mean to you?
How does your job contribute to your organization achieving the
goals of the environmental policy?
The policy also needs to be communicated externally and made
available to the public. Some options for external communications
include placing your policy on business cards, in newspaper
advertisements, in annual reports, and posting it on your organization's
public Internet site.
Step 6) Review Your Environmental Policy
for Effectiveness
Once your policy is in place, consider how you will demonstrate that
your organization is implementing the commitments you laid out in the
policy. This is a good test of whether or not the policy is a "living,"
working document and not just a hard copy document that will
collect dust.
Review your policy during EMS Management Reviews (See the
Management Review section later in this Handbook). These meetings
are times when management, the EMR and other staff can determine
whether the EMS is functioning consistent with your policy
commitments, and that your environmental goals are being met.
/ we four Environmental Policy readily
iil e to the public. Provide the front
office with copies of the policy so they can
hand it out to inquirers. Also consider
posting it on your Internet and at the local
library and/or local public offices.
James Naber
Buncombe County, North Carolina
Metropolitan Sewer District
noment of our Environmental
jlk, enhanced Senior Management's
ability to have open dialogue and
constructed a message that coincided
across the entire Metropolitan
Wastewater District's mission.
Chris Toth
City of San Diego
Wastewater Collection Division
Section 3: Environmental Policy (Phase I)
Wastewater EMS Handbook
-------
Environmental Policy
(Cut out this section for handy reference)
The Purpose of this EMS element is to:
o Ensure that your organization's management establishes an environmental policy that defines
your wastewater facility's environmental vision and goals, and that the policy is communicated
and understood by all employees and applicable contractors and vendors.
The Results of this EMS element are:
o An approved environmental policy (EMS Document) that is implemented and understood
throughout your organization.
o Firm management commitment to EMS implementation.
o Communication of the environmental policy throughout your wastewater organization, and
its availability to the public.
Before you Begin this EMS element:
o Determine where your EMS will be applied ("fenceline").
o Consider defining your organization's impact on the environment and setting your environmental
goals before finalizing your environmental policy.
Section 3: Environmental Policy (Phase 2) 49
Wastewater EMS Handbook
-------
ISO 14001
Requirements
Key Links to Other
EMS Elements
Required Documents
& Records
Optional Documents
& Records
Environmental Policy
Top management shall
define the organization's
environmental policy and
ensure that it:
a) Is appropriate to the
nature, scale and
environmental impacts of
its activities, products or
services;
b) Includes a commitment
to continual improvement
and prevention of
pollution;
c) Includes a commitment
to comply with relevant
environmental legislation
and regulations, and with
other requirements to
which the organization
subscribes;
d) Provides the framework
for setting and reviewing
environmental objectives
and targets;
e) Is documented,
implemented, maintained,
and communicated to all
employees;
f) Is available to the public.
Environmental Aspects -
Conduct your aspect/impact
analysis to determine envi-
ronmental management pri-
orities in order to finalize
your environmental policy.
Objectives & Targets -
Consider setting goals
before you finalize your
environmental policy. This
will set the framework and
vision for environmental
improvement.
Training & Awareness -
Every employee within the
EMS fenceline needs to
understand the basics and
purpose of the EMS and the
environmental policy, espe-
cially as it relates to their
job.
Communication -
Communicate the environ-
mental policy throughout
your organization and make
it available to the public.
Management Review -
Regularly review the effec-
tiveness of the policy with
top management.
A Documented
Environmental Policy
Other Environmental
Commitments (e.g., EPA's
Green Lights, etc.)
City/County Environmental
Policies
Business/Technical
Objectives
50
Section 3: Environmental Policy (Phase 2)
Wastewater EMS Handbook
-------
File/Retrieval ID (Optional):
Record Schedule No./Retention Period: 03603A/Permanent
Originator: P2 Team
Commissioners of Public Works
4.2 - Environmental Management System - Environmental Policy Statement
The Charleston Commissioners of Public Works (CPW) is committed to the improve-
ment of the environment for present and future generations through:
The treatment and delivery of safe potable water.
The collection, treatment, and proper disposal of wastewater.
The responsible impact of its activities, products and services on
the environment.
The continual environmental improvement and the prevention of pollution.
Compliance with all applicable federal, state, and local laws, regulations,
statutes and other environmentally related requirements to which the
organization subscribes.
The establishment of environmental objectives and targets that are peri
odically reviewed to ensure success.
And communication of its Environmental Management System to CPW
associates and to other interested parties.
CPW will establish and maintain an Environmental Management System (EMS) that
corresponds to the ISO 14001 Standard and the mission, vision, strategic business
plan and core values adopted by CPW.
William Koopman, Jr.,
General Manager
John Cook, PE,
Assistant General Manger
Kin Hill, PE,
Director of Operations
Dorothy G Harrison,
Director of Administrative Services
Document No.: P2-4.2
(11/15/2002)
Page 1 of 1
Document Distribution
Controlled Original - Chairman, P2 Team
All other copies are uncontrolled
Section 3: Environmental Policy (Phase 2)
Wastewater EMS Handbook
SI
-------
Section 3: Legal and Other
Requirements
Due to its potential impacts on the environment and public health,
wastewater utilities are heavily regulated. A key requirement of
the EMS and your environmental policy is a commitment to legal
(regulatory) and other compliance requirements. To fulfill those
commitments, you need to be up-to-date on the local, state, and federal
requirements that apply to your operations, activities and services as
well as any other relevant requirements. How these regulations and
other commitments affect what you can do within your organization is a
critical part of managing your environmental issues. Additionally, you'll
want to verify that these requirements are communicated to employees
whose work function is governed by these regulations in language that
they can understand.
LEGAL Requirements Typically Include:
Federal requirements
(e.g., Emergency Release NotificationEPCRA; Clean Water Act
CWA; Spill Prevention, Control and Countermeasure, SPCC Rule, etc.)
State and local requirements
(e.g., Coastal Zone Management; Resource Conservation and
Recovery ActRCRA; Pretreatment Requirements; Biosolids Land
Application)
OTHER Requirements Might Include:
Trade Association commitments or agreements
(e.g., American Water Works Association Standards, National
Biosolids Partnership Code of Good Practice, APWA Management
Accreditation Guidelines)
Local/regional environmental and community initiatives
(e.g., Regional Stormwater Education Partnership)
Voluntarily programs in which your organization participates
(e.g., EPA's Performance Track, Energy Star)
Step-by-Step Guide to Legal
and Other Requirements
Step 1) Identify and Maintain Compliance with
Your Legal and Other Requirements
Step 2) Develop a System Procedure for
Identifying Your Legal and Other
Requirements
Step 3) Check the Legal and Other Requirements
Procedure for EMS Conformance
Step 4) Communicate Your Legal and Other
Requirements
Key Section Terms
EMS Fenceline - Project scope
and/or operational areas within an
organization in which the EMS is
implemented.
Legal Requirements - The set of
rules and legal regulations that apply
to the operations and services of an
organization, including local, state,
and federal laws.
Other requirements - The rules
and guidelines an organization
follows that are not legally binding
under existing environmental laws,
but to which an organization is
committed (e.g., industry standards or
voluntary guidelines). Under an EMS,
these requirements require the
same commitment as legally
binding requirements.
System Procedure -An EMS
(ISO 14001) required document that
establishes purpose, scope, roles &
responsibilities, the tasks to be
completed, and where and how the
associated records and documents
are maintained.
REMEMBER
A commitment to
compliance with legal
requirements is one of
the three commitments
of your environmental
policy.
Section 3: Legal and Other Requirements (Phase I)
Wastewater EMS Handbook
53
-------
Three Keys to
Success
(from wastewater facilities):
1. Document a summary of all
your legal and other
requirements in one easy-to-
follow database or
spreadsheetshowing the
requirements and to which
operation or area they apply.
2. Inform regulators of your
efforts to implement an EMS at
your wastewater facility in
order to encourage an active
dialogue about the value of an
EMS approach.
3. Provide training and
communicate your
requirements to employees in
regulated areasin language
they can easily understand.
NOTE
EMS software and/or a
database tracking tool and an
j-mail notification
system can help
your organization
v comply with
' legal and other
requirements.
Research has shown
that a large number of a
public organization's
environmental violations
result from missing permit
reporting deadlines. An easy
and proactive way to manage
these compliance obligations
(and to manage your EMS
project) is to consider using a
software tool. See Appendix
B for a review of available
EMS software tools.
Step 1) Identify and Maintain Your Legal and
Other Requirements
A good place to start is to review how your organization currently
identifies and maintains its legal and other requirements. Ask yourself:
ป Who on your staff is responsible for this? Perhaps you outsource it.
ป What information sources do you find most useful and user-friendly?
ป If outsourcing, you need to be confident that regulatory updates and
requirements are updated and current.
ป Where do you store the information and in what form?
ป Is there an electronic database of your laws and other require-
ments? Perhaps it's a paper copy?
ป Do your employees know how to access the information as
necessary?
ป How often do you check to see whether information is current?
ป Who on your staff is responsible for communicating legal and
other requirements clearly and simply to employees?
Case Study
In King County, Washington, the EMS Team surveyed their EMS
fenceline (Solid Waste Operations) to identify their current
regulations and permits that affect that area. King County started
by putting together a list of the environmental regulations and then
creating one clear, manageable reference document and list. The
EMS Team identified the current and outdated regulations during
the review.
Perhaps your current system is working well and your review confirms
that your process is complete, current and efficient. Most importantly,
you have verified roles and responsibilities, including communicating
information to employees whose work is governed by the requirements.
In either case, once you've identified any gaps between what the EMS
requires and what you currently do, you and your Core Team can
plan ways to implement any necessary changes to make your process
for determining legal and other requirements conform to the
EMS requirements.
f urir i our EMS development process
it d an external consultant to conduct an
environmental requirements baseline which
included an assessment of facility operations
to determine which rules and regulations and
other relevant industry standards apf.
our wastewater facilities.
Donna Adams
Eugene, Oregon
Wastewater Division
54
Section 3: Legal and Other Requirements (Phase I)
Wastewater EMS Handbook
-------
-2 REMEMBER
You may find that an informal process for identifying and
tracking information on your legal and other requirements
exists already. Now it is simply a matter of developing a formal
procedure.
Sources for Legal and Other Requirements
There are many sources of information to identify and track your
environmental regulations and other requirements, including: federal,
state, and local regulatory agencies; trade groups/associations;
environmental journals; consultants; and commercial services (e.g.,
legal reports on CD-ROM). Identify the sources that suit your needs and
incorporate them into your legal and other requirements procedure.
Many wastewater facilities have found it useful to collect a common list
of information sources and key contacts and to post this list in their
EMS documents. In many cases this activity has brought some
duplication of effort and inefficiencies to light and expedited the process
of staying current with legal requirements.
One legal information source that many wastewater and
public organizations have found very useful is the Local
Government Environmental Assistance Network
(LGEAN), which provides environmental management,
planning, funding, and regulatory information for local
governments. LGEAN enables local officials to interact
with their peers and others online.
The International City/County Management Association (ICMA) is
responsible for the management of LGEAN, but the strength of the
LGEAN network is in the partnership that has been formed by the
various organizations that comprise it, including trade associations,
regional and state non-profits such as the Environmental Council of the
States (ECOS), and government agencies, such as the U.S. EPA.
Through the membership of these partners, the network is able
to reach more than 100,000 local government officials and
environmental professionals.
'OTE
Many organizations use a consultant to do a compliance
status check of the entire fenceline. At the same time
the consultant can help develop a list or database of
the local, state, and federal laws that apply to your
jcility.
Legal Sources
Wastewater facilities that were
consulted for this Handbook
considered the following sources of
regulatory and other requirements
information the most important and
useful:
1) EPA Website (www.epa.gov)
2) Local Government Environmental
Assistance Network
(www.lgean.org)
3) Federal Register Notices
4) Trade Associations (e.g., The
Association of Metropolitan
Sewerage Agencies (AMSA), Water
Environment Federation (WEF),
National Rural Water Association
(NRWA), etc.)
5) State Agency Internet sites and
Information Sources
Involving Contractors
and Temporary Staff
It is important to train and
communicate legal and other
requirements to your temporary
employees if they work in areas
that are regulated, have significant
aspects, or are related to your
objectives and targets.
Remember to communicate and
provide training in language they
can understand. For example, for
temporary staff for whom English is
not their primary language, consider
using illustrations (e.g., a circle with
a line through it to indicate no). For
example you could create a sign to
designate for employees to not
throw their oily rags in the general
trash.
If on-site contractors are within your
EMS fenceline, they also need to
understand their responsibilities to
comply with environmental, legal,
and organizational requirements.
Section 3: Legal and Other Requirements (Phase I)
Wastewater EMS Handbook
55
-------
F ivie
-------
Step 4) Communicate Your Legal and Other
Requirements
Identifying your legal and other requirements is an important first step.
But what good is the information if it's not communicated to employees,
on-site contractors, and others who need to understand it?
It's important that employees whose work is affected by these laws
understand what the requirements mean, and how they affect their
job. Communication about your legal and other requirements should
be in plain English rather than "legalese."
> NO!According to the Clean Water Act, section 5.3.3 and our
Stormwater Management Plan, it is illegal to dump hazardous
waste in anything other than its proper, labeled container.
> YES! We should not dump our hazardous waste in the floor
drain because the drain leads to the local stream where we
like to fish.
f REMEMBER
Not everyone in every area needs to know all the legal
requirements that apply to your organization. Keep in mind
that different people may have different informational needs.
Three Lessons Learned
(from wastewater facilities):
1. Include clearly-defined roles and
responsibilities in your methods to
track requirements.
2. Consider using a third-party to
document your baseline of legal
requirements.
3. Conduct more frequent reviews of
your legal requirements than other
EMS elements. The wastewater
industry is heavily regulated and
changes can occur often.
Three Things to Avoid
(from wastewater facilities):
1. Making your legal and other
requirements review a one-time only
activity. You must keep up-to-date
with with changing requirements.
2. Overlooking the communication of
applicable requirements to front-line
floor employees.
3. Treating "other" requirements and
voluntary initiatives as "minor"
agreements.
Section 3: Legal and Other Requirements (Phase I)
Wastewater EMS Handbook
57
-------
Legal and Other Requirements
(Cut out this section for handy reference)
The Purpose of this EMS element is to:
o Identify, track, and communicate your organization's legal and other requirements.
The Results of this EMS element are:
o A system procedure (EMS document) that identifies, tracks, and communicates your Legal
and Other Requirements.
o A list (EMS record) of applicable environmental laws and other requirements.
Before you Begin this EMS element:
o Identify environmental regulatory information relevant to your
organization.
o Obtain information regarding other environmental requirements relevant
to your organization.
"" "
58 Section 3: Legal and Other Requirements (Phase 2)
Wastewater EMS Handbook
-------
ISO 14001
Requirements
Key Links to Other
EMS Elements
Required Documents
& Records
Optional
Documents &
Records
Legal and Other
Requirements
The organization shall
establish and maintain a
procedure to identify and
have access to legal and
other requirements to
which the organization
subscribes and that are
applicable to the
environmental aspects of
its activities, products or
services.
Environmental Policy -
Your policy requires
commitment to all
applicable environmental
laws and organizational
requirements. Compliance
with environmental laws is
one of the three major
policy commitments.
Objectives & Targets -
Consider your legal
commitments and
requirements as you
identify possible areas for
measurable environmental
performance improvements.
Training & Awareness -
Employees whose work is
governed by regulations
need to understand the
laws that affect their daily
work and the operational
controls that are needed to
maintain compliance.
Communication -
Talk to employees about
how environmental laws
and other requirements
affect their work, and how
their roles and
responsibilities ensure
compliance.
Operational Control -
Procedures, work
instructions, manuals, etc.
need to be documented or
established for
environmental priority areas
and regulated areas.
Legal and Other
Requirements
Procedure
List of Legal and Other
Requirements
Compliance Plans
Relevant Code of Federal
Regulations (CFRs),
State and Local
Regulations, Permits, etc.
Section 3: Legal and Other Requirements (Phase 2)
Wastewater EMS Handbook
59
-------
Section 3: Environmental Aspects
and Impacts
(Defining the Impact Your Organization Has on the Environment)
Identifying how your organization's operations and services affect the
environment is a critical element of your EMS. It is here that you will begin
the first step of defining your organization's environmental "footprint" (i.e.,
how your operations and services affect the environment), leading to
measurable goals for improving your environmental performance through
your EMS.
The step-by-step tasks described in the following sections will guide your
organization in identifying its environmental footprint. This process is one of
the most challenging portions of EMS implementation and requires focus
and teamwork. However, this is the opportunity for your organization to stop,
take a hard look at your individual operations and activities, and identify how
these positively and negatively affect the environment.
You are about to embark on a process of organizational "discovery" that will
help everyone involved better understand your operations and the unique
role that each of you, individually and collectively, play in managing your
wastewater facility's environmental impacts. The result of this effort will be a
list of environmental aspects and impacts, and the processes/activities that
potentially create them. From this list, your team will develop a means to
prioritize those that are most significant and those that require your
organization's most immediate attention. This may seem daunting, but if you
follow the step-by-step approach it will be manageable and you will quickly
realize the benefits of this effort.
Step-by-Step Guide to Identify
and Prioritize Environmental
Aspects
Step 1) Clarify EMS Jargon with Your Team
Step 2) Determine Your Core Operations - -
and Supporting ActivitiesYour EMS
"Fenceline"
Step 3) Construct Input/Process/Output
Diagrams
Step 4) Develop a List or Matrix of Environmental
Aspects and Impacts
Step 5) Prioritize Your Environmental Aspects
and Impacts
a. What Criteria will you Use to Prioritize?
b. How Will the Criteria be Used?
Step 6) Develop a System Procedure for Identifying Your
Environmental Aspects/Impacts
Step 7) Check Your Environmental Aspect Identification
Procedure for EMS Conformance
Step 8) Review and Revise Your Environmental Aspects/Impacts
Key Section Terms
EMS Core Team - A cross-functional
team made up of individuals within
the organization that helps facilitate
EMS implementation across the
organization. Team members are the
EMS experts and cheerleaders.
Environment - Surroundings in
which an organization or facility
operates, including air, water, land,
natural resources, flora, fauna,
humans and their interrelation.
Environmental Aspect - Element of
an organization's activities, products
or services that can interact with the
environment. Aspects = Causes
Environmental Impact - Any
change to the environment, whether
adverse or beneficial, that results
from an organization's activities,
products or services.
Impacts = Effects
EMS Fenceline - Project scope
and/or operational areas in an
organization in which the EMS is
implemented. For example, for
wastewater operations, this could
include the pretreatment and the
laboratory operations.
"Footprint" - The environmental
impact of your facility; how your
operations and services interact with
the air, water, land, resources, local
and regional community, etc.
Stakeholders - Groups and
organizations having an interest or
stake in an organization's EMS (e.g.,
regulators, shareholders, customers,
suppliers, special interest groups,
residents, etc.).
Section 3: Environmental Aspects and Impacts (Phase 2)
Wastewater EMS Handbook
61
-------
Test your Knowledge!
It's a good idea to be sure you
have a clear understanding of the
difference between activities,
aspects, and impacts. Here's a
short quiz to use with your EMS
Core Team (the answers are
below). Indicate which of the
following terms is an activity,
aspect, impact, or none?
Aspect, Impact, Activity, or None
1) Air pollution/degradation
2) Burning diesel fuel
3) Digester
4) (Electrical) energy consumption
5) Water consumption
6) Degradation of a stream/creek
7) Burning bio-diesel fuel
8) Spilled Solvent
9) Recycling Program
10) Cleaning Spills
(Ol> ^l!A!PV (6 pedwj
UB ijos/jajBM 01 uojjBpBjBap
PUB UOUBUjlUBJUOO J8>|JOM IpadSB
UB s| |||ds - padsy (8 padsy
(l pBdwi (9 padsy (9 padsy
(^ auoN (C AJJAJPB au.} s| >pnjj
am BujAup - padsy (z pBdwi (|,
Before we jump directly into the next steps, the aspect/impact analysis
presents a terrific opportunity for you to involve not only the Core Team, but
also your front-line employees. In fact, their participation is often referred to
as a fundamental key to successful EMS implementation. These are the
employees who have hands-on knowledge and experience of all of the
activities you are preparing to evaluate and who are the closest to the actual
operations. Their involvement will also help instill an understanding and
appreciation for the interaction between the environment and their daily work
activities. Involve them early, because it will reap wonderful rewards
throughout implementation. Talk about getting buy-in for your EMS!
Step 1) Clarify EMS Jargon with Your Team
One of the first hurdles that you will likely encounter is having your
Team(s) achieve a comfort level with the EMS "jargon" involved in this
phase of activities. Therefore, take a look at two terms that you or your
employees may not have seen beforeaspect and impact.
Environmental aspects are the parts of your operations and activities
that interact with the environment. Environmental impacts are the
changes to the environment, positive or negative, resulting from your
organization's operations and activities. Still a little unclear?
Well, try thinking about it this way: the aspects are the causes and the
impacts are the effects.
Aspects = Causes and Impacts = Effects
For example, the burning of gasoline in your car
can cause air emissions which affect the air quality.
Here are some examples from wastewater facilities:
Operation or Service
Activity
Burning of Fuels
Transport of Diesel Fuel
Maintenance of Fleet
Vehicles
Equipment Maintenance
Facility Boilers
Office/Administrative
Activities
Environmental
Aspects
Air Emissions (CO)
Spills and Leaks
Used Oil Recycling
Solid Waste Generation
Electricity Use
(Gas & Diesel)
Recycled Paper
Potential
Environmental
Impacts (Effects)
Degradation of Air
Quality
Soil and Groundwater
Contamination
Conservation of Natural
Resources
Reduction in Landfill
Space
Reduction in Natural
Resources
Conservation of Landfill
Space
Why is this distinction so important? In order for your organization to
build and grow a culture of continual improvement with regard to the
environment, you first need to identify how your organization affects or
impacts its surrounding environment. To ultimately manage the identified
62
Section 3: Environmental Aspects and Impacts (Phase 2)
Wastewater EMS Handbook
-------
impacts, you also need to identify the operations and/or activities that
cause the impacts and the ways these occur. The more clearly your
team can define this relationship, the better able they will be to
understand what needs to be done to control and manage the most
important impacts.
Step 2) Determine Your Core Operations and
Supporting ActivitiesYour EMS "Fenceline"
Once your team has a solid understanding of the terms "aspect" and
"impact," work with your EMS Team(s) and management to define
exactly what operations and supporting activities will be the initial focus
of your EMS efforts. This area or operation is commonly referred to as
the EMS "fenceline." An EMS can be applied to any operation or activity
within your wastewater facility, big or smalla department, division,
operation or your entire facility. Remember, this is YOUR EMS and only
you can decide what makes sense for your organization.
Other wastewater facilities and local organizations that have
implemented EMSs advise: Think Big, Start Small! It may be tempting
at first to include all of your operations and facilities within your EMS
fenceline, but it is usually unrealistic for most organizations to launch
and manage such a large-scale project, considering the human and
financial resources involved. Consider starting with a small section of
your organization, and then add more departments and facilities as
your EMS experience and expertise grows. This way you develop a
solid understanding of the EMS process and a group of internal experts
that can act as mentors as your EMS grows.
Example Fencelines from Wastewater and Public Organizations
that have Implemented EMSs:
Louisville and Jefferson County, KY
Metropolitan Sewer District
Oakland County, Ml
Drain Commissioner's Office
Rivanna, VA
Water and Sewer Authority Complex
Kent County, DE
Department of Public Works
City of Eugene, Oregon
Charleston, South Carolina
San Diego, California
Wastewater Treatment Facility and
Purchasing Department
Wastewater Treatment Plant
Engineering and Construction
Wastewater Treatment Plant
Wastewater Treatment Facility and
Biosolids Operation
Wastewater Division
Entire Wastewater Operation
Wastewater O&M Division
Three Lessons Learned
(from wastewater facilities):
1. Ensure the activities you list for
your aspects/impacts have potential
or direct impacts on the environment.
Do not list activities that have little or
no impact on the environment (i.e.,
you do not have to list every single
thing at your facility).
2. Make your aspect ranking method
simple and easy to understand.
3. Keep your aspect analysis
procedure flexibleremember, this
process is not set in stoneif you do
not feel your aspect analysis is
working, change it! Remember, an
EMS is about continual improvement.
Questions to Consider:
^ What resources do you
have at your disposal for
EMS activities?
^ Where will you get the most
bang for your buck? What
areas give you the most
heartburn at the moment or
are of greatest concern to
your community?
^ Where do you use the most
natural resources? Energy?
Hazardous materials?
^ What areas have the most
support and/or interest?
Have receptive manage-
ment? Line supervisors?
Employees?
Section 3: Environmental Aspects and Impacts (Phase I)
Wastewater EMS Handbook
63
-------
Inputs/Process/Outputs
Overview
One way to visualize the
environmental "footprint" of your
operations and activities is to
construct input/process/output
diagrams. These diagrams will help
you identify what materials and
resources you use (inputs), where
they are used (the process), and how
they are turned into a product or
service (output), re-used as by-
products (output), or become wastes
(output). A simple
input/process/output diagram is
provided below. As you will see in this
section, these diagrams are helpful in
identifying your environmental
aspects.
Waste water
Pretreatment
(Process)
Products, By-
products, and
Wastes (Outputs)
Step 3) Construct Input/Output Diagrams
Once you have defined which operations and activities fall within your
EMS implementation scope, take a closer look inside your fenceline.
To understand your environmental aspects and impacts, it helps to
understand the inputs/processes/outputs that are part of the
operations and activities within your fenceline. At this point you may
be thinking, "okay I can do that, let's sit down and drum up a list. We
pretty much know our impacts on the environment." Although your
team could probably brainstorm a pretty good list, the EMS process
helps you focus your efforts to ensure that you cover all bases and
that nothing slips through the cracks.
One common approach for conducting this assessment is to first
create a flowchart of your EMS fenceline with associated processes
and operations.
A typical wastewater facility-level diagram is presented below as an
example of the common format:
System Operation
& Maintenance
II Municipal
Combined I Separate
Sewer System I stomi Sewer
I System
Biosolids
Management
& Disposal
Materials
Management
Laboratory
For example purposes, let's say that your organization
selected "Treatment" as its EMS fenceline. Based upon the
above example you would then dig a little deeper to look at
the individual operations/activities within this fenceline. To
accomplish this, organizations commonly utilize
input/process/output diagrams (see sidebar) to help
understand and visualize processes as well as how
materials are used, re-used and disposed within each
individual operation or activity. You are probably wondering
why "Laboratory" is highlighted a little differently than the
other operations/activities in the diagram above. The next
few pages will walk through the basics of determining
environmental impact for a laboratory operation.
64
Section 3: Environmental Aspects and Impacts (Phase 2)
Wastewater EMS Handbook
-------
The next step is to construct the input/process/output
diagrams for each of the operations/activities within your
fenceline and laboratory as selected in the sample diagram.
Materials &
Resources"*
(Inputs)
Effluent
Biosolids
Lab Equipment
Chemicals
Gases
Microbiological Media
Energy
Supplies
Laboratory (Process)
Chemical Analysis
Biological Analysis
Physical Analysis
Monitoring
Sampling
Generation of Data
Products"*
(Outputs)
Laboratory Data
By Products"*
(Outputs)
Recyclables (e.g.
Glassware, Packaging,
Paper, etc.)
Wastes
(Outputs)
Analysis (Chemical) Wastes
Glassware
Solid Waste (e.g. Trash, Empty
Containers, etc.)
This process for developing input/process/output diagrams should now
be continued for each of the other operations/activities within your
defined fenceline. For example, if your EMS Team were working from
the example flowchart presented above, you would proceed to develop
diagrams for Chemical Storage/Haz Materials Management, Biosolids
Management and Disposal, Pretreatment Program Compliance, and
NPDES Permit Compliance. Remember, this is only an example. Your
defined fenceline might entail very different operations/activities both in
number and type.
f / fo using on the creation of
ul ocess/output diagrams first in
the determination of our impacts and
aspects, we were able to see the
environmental consequences of our
organization.
San Diego, California
Refuse Disposal Division
REMEMBER
leep in mind as you
brainstorm and generate
your aspect/impact list
that you are not expected
~ to manage environmental
issues outside your
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.
Therefore, your focus as you
develop your list should be on
the environmental aspects of
your own operations and
services within the fenceline that
you define.
COACH'S CORNER
Your EMS Site Team(s)
ซK are terrific at producing
^^^ _i_i _ _ _ / _j_ _j_
diagrams in the areas
in which they work.
Along with the Site Team
member(s), have a Core
Team member and a person
from your environmental staff
when you develop your
diagrams. This is a great
opportunity for operational
and environmental staff to
discuss your facility and
processes, perhaps for the
first time.
Section 3: Environmental Aspects and Impacts (Phase 2)
Wastewater EMS Handbook
65
-------
CH'S CORNER
When you identify your
impacts, you want to
igulated Aspects
air Emissions, Water
Discharges, etc.)
2) Non-Regulated Aspects
(e.g., Electrical/Energy Use,
Land Use, etc.)
3) Emergency Situations/
Conditions (e.g., Spills, Leaks,
etc.)
4) Positive Impacts on the
Environment
(e.g., Recycling Paper, Re-
Use of Water, Using Biogas
as an Energy Source, etc.)
/on' beat your aspect analysis to
a -do the evaluation the best
you can and move on. It is very easy
to get bogged down in this element
and not make any progress. Don't be
afraid to say, 'good enough for now,
let's move on.'
Beth Eckert
Gastonia, North Carolina
Public Works and Utilities Department
Step 4) Develop a List or Matrix of Environmental
Aspects and Impacts
Once you have identified your core fenceline operations and activities and
created diagrams to "visualize" your processes, it's time to create your list
of environmental aspects and impacts. Get together with the employees
from the areas where you have input/process/output diagrams to
brainstorm and work together on your wastewater environmental
aspect/impact list. Start with each process. For instance, look at the
example diagram and text on the previous page and take a closer look at
chemical analysis, then biological analysis, followed by physical analysis
and so on.
The most common approach to developing this list of environmental
aspects and impacts is to develop a matrix for each of your
input/process/output areas to collect relevant information in an
organized and manageable manner.
Referring back to the laboratory example, the first step is to
add the various processes involved in laboratory
operations/activities. The following is an example for the
laboratory:
Operation/Activity
Chemical (Nutrient) Analysis
Biological Analysis
Physical Analysis
Sampling, Analysis & Monitoring
Laboratory/Biosolids Testing
Laboratory/Recycling Program
Next, add the various aspects related to each individual
process. Remember, aspects are how these processes
interact with the environment and are the causes of potential
environmental impacts. Adding some aspects, the example
matrix would now look like this:
Operation/Activity
Chemical (Nutrient) Analysis
Biological Analysis
Physical Analysis
Sampling, Analysis & Monitoring
Laboratory/Biosolids Testing
Laboratory/Recycling Program
Aspects
Hazardous Waste Disposal
Spills, Solid Wastes,
Hazardous Waste
Solid Wastes
Energy Use
Energy Use, Solid Wastes,
Hazardous Waste
Glassware Recycling (+)
66
Section 3: Environmental Aspects and Impacts (Phase I)
Wastewater EMS Handbook
-------
Okay, at this point you have brainstormed with your team and with
the help of your visual diagrams. You've identified the various
processes involved and their associated aspects. Now, let's add
:he potential impacts to the environment of each process. Doing
so would look like:
Operation/Activity
Chemical (Nutrient)
Analysis
Biological Analysis
Physical Analysis
Sampling, Analysis &
Monitoring
Laboratory/Biosolids
Testing
Laboratory/Recycling
Program
Aspects
Hazardous Waste
Disposal
Spills, Solid Wastes,
Hazardous Waste
Solid Wastes
Energy Use
Energy Use, Solid
Wastes, Hazardous
Waste
Glassware
Recycling (+) - see
sidebar on positive
aspects
Impacts
Potential Land and Water
Degradation, Landfill Use
Depletion of Natural
Resources, Landfill Use,
Hazardous Waste Disposal
Landfill Use
Depletion of a Natural
Resource
Depletion of Natural Resource,
Landfill Use, Hazardous Waste
Disposal
Conserving
Landfill Space (+) - see
sidebar on positive aspects
Sample lists of aspects and impacts from wastewater facilities are
provided in Appendix A.
NOTE
As a public organization, you may want to consider
involving external stakeholders (neighbors, local
k community groups, etc.) in identifying potential
environmental aspects and impacts that affect the
local community. For example, you may want to consider
effluent, odor, and light pollution issues.
Step 5) Prioritize Your Environmental Aspects
and Impacts
Whew! At this point you probably have a large list or a number of
individual operation/activity lists of environmental aspects and impacts.
Don't worry! An EMS is structured so that you do not have to manage
all of these aspects and impacts at once. The next step of the process
is to whittle the list down, through a prioritization technique, to a
manageable group of the most "significant" to your organization. So,
how do you narrow your list to focus on what is most significant? First
you need to develop a means to rank and differentiate, or "prioritize,"
the different aspects that you have identified, to determine which of
them are most significant.
REMEMBER
I Don't forget to include your
'V positive aspects! Take a
look at your pollution
prevention plans, reuse
, and recycling initiatives,
Build momentum from
,,ow you are minimizing and
preventing pollution already. For
example, for disposal of
glassware (the activity) used in
your laboratory operations, your
(positive) aspect would be
recycling the glassware and the
(positive) impact would be
conserving landfill space.
COACH'S CORNER
Involving personnel
from the frontline in
.identifying your inputs/
=' processes/outputs and
your aspects/impacts
list is a good way to
ensure buy-in to your EMS.
Besides, employees who are
involved day-to-day with the
front-line operations are
typically the best in identifying
the environmental issues
associated with activities
(working with the environmental
department).
Section 3: Environmental Aspects and Impacts (Phase 2)
Wastewater EMS Handbook
67
-------
"Don't get too far
down in the weeds"
Many wastewater facilities have
reported getting caught up in too
much detail and generating very
large lists of environmental aspects
and impacts. Remember that this is
an iterative processa process that
stresses the importance of
continuous improvement. If you
do not catch every aspect/impact
during your first review, it's okay.
You will most likely catch it during
the next cycle as your EMS is
refined and matures.
NOTE
Vfc ^ When you prioritize
the environmental
impacts at your
\ facility, consider
what is regulated
as one of your key
scoring criteria.
Significant criteria to
consider when
prioritizing your
environmental aspects:
c> Impact to Natural Resources
c> Impacts to Land, Water and Air
c> Cost
c> Probability of Occurrence
c> Volume
>=> Toxicity
c> Regulated
c> Public (Stakeholder) Impact
c> Nuisance
c> Human Health Impacts
The basic process that you will use is to (1) define a group of
selection criteria (e.g., air, water, land), (2) develop a scoring
system, and (3) apply this criteria to each of the listed
environmental aspects to achieve a total rank or number. For
example, looking at the laboratory, the scores come out as follows:
Operation/
Activity
Chemical
(Nutrient)
Analysis
Biological
Analysis
Physical Analysis
Sampling,
Analysis &
Monitoring
Laboratory/
Biosolids Testing
Laboratory/
Recycling
Program
Aspects
Hazardous
Waste
Disposal
Spills, Solid
Wastes,
Hazardous
Waste
Solid
Wastes
Energy Use
Energy Use,
Solid
Wastes,
Hazardous
Waste
Glassware
Recycling
M
Impacts
Hazardous Waste
Disposal
Depletion of Natural
Resources, Use of
Landfill Space,
Hazardous Waste
Disposal
Use of Landfill
Space
Depletion of a
Natural Resource
Depletion of Natural
Resource, Use of
Landfill Space,
Hazardous Waste
Disposal
Conserving
Landfill Space (+)
Changes to
Air
3
1
1
1
1
1
Changes to
Land
5
1
5
1
3
3+
Changes to
Water
5
3
3
1
1
1
Step 5a) What Criteria will you Use to Prioritize?
As with every other part of the EMS, the Keep It Simple, Simple [KISS]
rule applies here. Experience has shown that a simple system for
prioritizing environmental aspects and impacts has generated the same
results as a more complex one, but in a shorter period of time and with
happier EMS team members. There is not a magic number here in
terms of how many criteria you will utilize; it really depends on what
factors are important within your organization and what allows your
organization to simply and effectively rank your identified aspects. The
criteria you use to determine significance will act as a filter to identify
those environmental aspects that your organization will need to
manage. Here's some simple advice: Don't have too many criteria. A
very complicated grading system will confuse and discourage those
involved and make this process much more difficult than necessary.
Remember the KISS rule!
Step 5b) How Will the Criteria be Used?
Once you have selected your criteria for ranking your aspects and
impacts, apply the criteria to each of the entries on your aspects &
impacts list using a quantitative ranking method. A simple 1 - low; 3 -
medium; and 5 - high impact rating system works well and avoids long
discussions about the difference between a 2 and 3 or a 3 and 4.
Section 3: Environmental Aspects and Impacts (Phase I)
Wastewater EMS Handbook
-------
However, if your team can't seem to decide if something should be a 3
or a 5, call it a 4 and move on! Don't let the pursuit of the perfect
become the enemy of the good!
Refer back to the laboratory example, suppose that our teams selects
the following three criteria for prioritizing aspects: Impact to Air, Land,
and Water.
Adding the criteria into our example table and applying our
simplified scoring system, your team would end up with something
like this:
Operation/
Activity
Chemical
(Nutrient)
Analysis
Physical Analysis
Biological
Analysis
Laboratory/
Biosolids Testing
Laboratory/
Recycling
Program
Sampling,
Analysis &
Monitoring
Aspects
Hazardous
Waste
Disposal
Solid
Wastes
Spills, Solid
Wastes,
Hazardous
Waste
Energy
Use, Solid
Wastes,
Hazardous
Waste
Glassware
Recycling
M
Energy Use
Impacts
Hazardous Waste
Disposal
Use of Landfill
Space
Depletion of Natural
Resources, Use of
Landfill Space,
Hazardous Waste
Disposal
Depletion of Natural
Resource, Use of
Landfill Space,
Hazardous Waste
Disposal
Conserving
Landfill Space (+)
Depletion of a
Natural Resource
Air
Impact
3
1
1
1
1
1
Land
Impact
5
5
1
3
3+
1
Water
Impact
5
3
3
1
1
1
Total
Score
13
9
5
5
5
3
NOTE
Every environmental aspect you determine to be
significant will require you to verify current controls
(procedures, work instructions, etc.) or to
fcv implement new controls to show that you are
w managing your significant environmental issues
(for more information, see the Operational Control
section later in this Handbook).
REMEMBER
The number of and
criteria you use for
your wastewater
facility are up to yoi
Involving Contractors
and Temporary Staff
It is important to involve contractors
and temporary employees in this
phase of your EMS, particularly if
they work in areas that can create a
significant impact on the
environment. The wastewater
facilities that have EMSs in place
that contributed to this Handbook
involve them in the aspects/impacts
analysis, as well as in the setting of
objectives and targets if they work in
areas that could have an
environmental impact.
Three Things to Avoid
(from wastewater facilities):
1. Breaking aspects into too much
detail. For example, hazardous
waste use and disposal in the lab
does not need to be broken down
into each chemical's hazardous
waste use and disposal as an
aspect.
2. Making your significance
threshold too low and thereby
taking on too many significant
aspects. Remember that for every
significant aspect you name, you
must have an operational control
(i.e., procedures, manuals, work
instructions, etc.) in place.
3. Getting bogged down when
discussing applicable scores for an
environmental aspect. Come to a
consensus and move on.
Section 3: Environmental Aspects and Impacts (Phase I)
Wastewater EMS Handbook
69
-------
REMEMBER
i Your wastewater facility has
the flexibility to determine
the criteria and the
method for determining
ignificance. This is a
subjective exercise that is
not standard for every
organization. Consider the
approach that fits your
organization and remember to
consider technical, business and
stakeholder issues.
Three Keys to
Success
(from wastewater facilities):
1. Educate, Educate, Educate
the EMS Core Team and all
employees on their roles and
responsibilities in the
environmental aspect/impact
analysis.
2. Define your significant
ranking criteria for all
employees who participate in
your ranking process so that
they know what the terms mean
as they score aspects.
3. Create cross-functional
teams for your review. Include
frontline employees from the
applicable areas and the
environmental department on
the team(s) that conduct the
aspects analysis.
To reinforce what we just learned, let's look at another wastewater
example, this time looking at the environmental aspects/impacts
from the collection and distribution of wastewater via a sanitary
sewer system.
\
The activities, aspects, and impacts of operating and maintaining a
wastewater sanitary sewer system could include:
Operation/Activity
Repairing/Maintaining
Manholes
Repair Leaking
Sewer Lines
Operate & Maintain
Pump Stations
Aspect
Use of Oils and
Lubricants
Energy Use
Sewer System
Overflows (SSOs) -
i.e., spills
Impact
Depletion of a
Natural Resource
Contamination of
Water/Land
Depletion of a
Natural Resource
Employee H&S
Degradation of
Water/Land
(Streams, Creeks,
Soil, etc.)
Impact to Public
Health
Brainstorming with the sanitary sewer and environmental staff, the EMS
Core Team scores the sewer system overflow/sewage backup aspect
for significance. Note that the criteria that scored the highest (land and
water impact and health & safety), match the impact areas that came
from your aspect/impact list.
Operation/
Activity
Operate &
Maintain
Pump
Stations
Aspect
Sewer
System
Overflows
(SSOs)
Impact
Degradation of
Water/Land
(Streams, Creeks,
Soil, etc.)
Impact to Public
Health
Land
Impact
5
Air
Impact
1
Water
Impact
5
Health &
Safety
5
Total Score
16
So, you came up with a total score of 16 for this aspect. But what does
this score mean? Once you've determined all your aspects and their
associated impact scores for the operations/activities within your
defined fenceline, you will need to establish a threshold for significance
based on what your organization can reasonably manage (for instance
anything over 15 could be considered significant in this last example).
Keep in mind that each organization has the flexibility, based on its
business, technical, legal, operational, and interested party concerns
and requirements, to set what it considers to be a significant threshold
value. As mentioned previously, make sure that everyone realizes that
each aspect that is identified as significant (i.e., a total score over your
determined threshold) will require some kind of operational or
70
Section 3: Environmental Aspects and Impacts (Phase I)
Wastewater EMS Handbook
-------
equipment control measure, training, recordkeeping and other relevant
EMS required management practices to minimize or prevent the
environmental impacts. Remember, this is a continuous process, so you
don't need to save the world the first time around!
Now, compare how other aspects within the sanitary sewer operation
and other wastewater operations scored against sewer system
overflows. Conduct a reality check with the employees in sewer
operations and maintenance and the environmental department to see if
your environmental significance ranking makes sense. Did the aspects
of your operations/activities that surfaced to the top make sense? If not,
discuss this among your group and ensure that it wasn't a scoring error.
Ensure that everyone understands how and why the aspects identified
as significant became so and that they are committed to focusing on
these areas in subsequent EMS tasks.
Step 6) Develop a System Procedure for
Identifying Your Environmental Aspects/Impacts
When you're satisfied that your process for identifying and ranking your
environmental aspects/impacts conforms to the EMS requirements, it's
time to document the process in a written system procedure. Your
system procedure clearly defines what you'll do, roles and
responsibilities, when they'll do it, methods for communicating, and
where the information will be stored. This documented procedure will be
a consistent, easily accessible, and clear guide for ensuring that this
important element of your EMS is carried out according to your plans.
For sample procedures on identifying environmental aspects from
wastewater facilities, see Appendix A.
Step 7) Check Your Environmental Aspect
Identification Procedure for EMS Conformance
Once you have your Environmental Aspect Identification Procedure in
place, review it for EMS conformance.
Check S
1) Have you conducted a sound methodology?
2) Have you included all core fenceline operations and activities?
3) Have you developed a list of significant environmental aspects
and impacts?
4) Is the aspect/impact list reviewed at least annually?
5) Does your procedure account for changes to operations and
activities?
' nee your original
p( Impact list is developed
and you have controls in place,
you need to come up with a
process to deal with change and
a way to capture any new
activities and aspects an<
them for significance.
3W
nt x
Donna Adams
Eugene, Oregon
Wastewater Division
. EMS Manual
Work Instructions, Forms,
Drawings, etc.
An Environmental Aspect system
procedure is required for this
element. A system procedure defines
the purpose (why the procedure is
needed), scope (to what
operations/areas/staff the procedure
applies), roles & responsibilities (who
needs to complete the tasks), and the
tasks that need to be completed for
this element.
Section 3: Environmental Aspects and Impacts (Phase I)
Wastewater EMS Handbook
71
-------
' elet volunteers to take part in
i i >ects analysis that have in-
depth knowledge of the activities
you are evaluating. Their
knowledge is your system.
James Naber
Buncombe County, North Carolina
Metropolitan Sewer District
F star ,sh a simple aspect ranking
>t< , A complicated ranking
system will confuse and discoi
those involved in prioritizing y>
environmental aspects.
&
Hirage
l"
Rick Bickerstaff
Charleston, South Carolina
Commissioners of Public Works
}ut/process/output
iming exercise was a great
Building exercise between the
Environmental Department and the
frontline employees.
Laura Fiffick
Houston, Texas
Port of Houston Authority
Step 8) Review and Revise Your Environmental
Aspects/Impacts
Once you have your aspect list in place and you have determined your
significant environmental issues at your wastewater facility, keep the
information up-to-date. Using the written procedure you have
developed, review your aspect list at least once a year and complete an
aspect/impact review when you have any new or changed operations or
services coming on-line.
11
Section 3: Environmental Aspects and Impacts (Phase 2)
Wastewater EMS Handbook
-------
^\ ^\ ^\
r
Environmental Aspects and Impacts
(Cut out this section for handy reference)
The Purpose of this EMS element is to:
o Identify and rank the environmental aspects and impacts of your wastewater facility.
The Results of this EMS element are:
o A list/table (EMS record) of the activities, environmental aspects and environmental impacts of your
wastewater facility.
o Significance criteria (EMS record) for ranking your priority environmental impacts.
o A system procedure (EMS document) for environmental aspect and impact identification and
significance determination.
Before you Begin this EMS element:
o Draft your environmental policy.
o Complete your wastewater legal and other requirements procedure and requirements list.
Section 3: Environmental Aspects and Impacts (Phase 2) 73
Wastewater EMS Handbook
-------
ISO 14001
Requirements
Key Links to Other
EMS Elements
Required Documents
& Records
Optional
Documents &
Records
Environmental Aspects
The organization shall
establish and maintain a
procedure(s) to identify the
environmental aspects of
its activities, products or
services that it can control
and over which it can be
expected to have an
influence, to determine
those which have or can
have significant impacts
on the environment. The
organization shall ensure
that the aspects related to
these significant impacts
are considered in setting
its environmental
objectives. The
organization shall keep
this information up-to-date.
Objectives & Targets - In
setting your environmental
goals, remember to
consider the significant
aspects of your operations
and services.
Training & Awareness -
Employees working in
significant aspect operation
and service areas need to
understand their
responsibilities in these
priority areas.
Communications -
Communicate your
significant aspects
throughout your fenceline.
Also, make a decision on
whether you will
communicate your
significant aspects to the
public.
Operational Control -
Control and manage
(through procedures, work
instructions, manuals, etc.)
all your significant aspects.
Aspect and Impact Analysis
Procedure
A List of Significant Criteria
A List of Significant
Environmental Aspects
Activity/Aspect/Impact List
Input/Output Diagrams
74
Section 3: Environmental Aspects and Impacts (Phase 2)
Wastewater EMS Handbook
-------
Section 3: Objectives & Targets and
Environmental Management Programs:
(Establishing Goals and Roadmaps for Achieving and Improving
Environmental Management)
Now that you've identified and ranked your most important
environmental aspects and impacts, it's time to set some goals
for improving your organization's environmental management.
Setting objectives and targets presents an opportunity to identify where
you want to be in the next year or two regarding your significant
aspects. Let's determine which of your significant aspects will have
specific and measurable objectives and targets for improving your
performance.
Remember, all significant aspects must be managed in accordance with
the ISO 14001 requirements; however, your organization can select
aspects to set objectives and targets. In doing so, consider your
organizational goals, environmental policy, and your organizational
abilities. If you are in a position to be enthusiastic and push
performance, then do so and select challenging objectives and targets.
On the other hand, there is no shame in taking a more conservative
approach and choosing more practical objectives and targets. Just
remember that the EMS is about continual performance improvement!
As mentioned earlier in this document, your EMS can also be
strengthened by using other important utility management tools and
programs. For example, a number of utilities, including some that
contributed to this Handbook, are using the Balanced Scorecard
approach to set performance measures for their organization. The
Balanced Scorecard gives organizations a well-organized method of
developing measures that deal with both environmental performance
and customer needs. When setting your objectives and targets, you
may wish to use the Balanced Scorecard approach to ensure they are
responsive to a full range of needs.
Let's review a few basic terms:
Environmental Objective: The internal goal your facility establishes to
improve its environmental performance. Example: Reduce air
emissions generated from the burning of diesel fuels.
Environmental Target: A measurable performance requirement that
arises from your objective. Example: Reduce sulfur dioxide, particulate
matter, and carbon dioxide emissions from the burning of diesel fuels
by 50% from 2002 levels.
Performance Indicator: A measurement tool that can be used to
evaluate and measure environmental performance in relation to a
specific target. Examples include: measuring the emissions of sulfur
dioxide, particulate matter, and carbon dioxide per year from
established baselines in order to check the progress in meeting your
target of 50% reduction from current levels. Performance indicators can
be adjusted to meet specific management needs or as necessary to
ensure progress toward reaching specific environmental targets.
Key Section Terms
Baseline - The starting point from
which to track the achievement of an
objective. Establish "normalized"
baselines to accurately measure how
your facility's environmental
performance could change overtime.
Normalized baselines will measure
your actual environmental
performance changes rather than
changes in production, customer
demand, or other non-environmental
related factors.
Environmental Aspect - Elements of
an organization's activities, products
or services that can interact with the
environment. Aspects = Causes
Environmental Impact -Any change
to the environment, whether adverse
or beneficial, that results from an
organization's activities, products or
services. Impacts = Effects
Environmental Management Program
(EMP) - A structured program with a
set of specific identifiable actions (an
"action plan") providing the direction for
EMS objectives and targets to be
obtained and tracked. Your EMP should
assign tasks, resources, responsibilities,
and timeframes for achieving your
objectives and targets.
Environmental Objective -An
overall environmental goal based on
an established environmental policy,
that an organization sets itself to
achieve. Wherever possible,
environmental objectives should be
quantified, to facilitate the evaluation
of environmental performance and the
measurement of progress towards
specific environmental targets.
Section 3: Objectives & Targets and EMPs (Phase I)
Wastewater EMS Handbook
75
-------
Key Section Terms,
continued
Environmental Target - A
detailed performance requirement,
quantified where practicable, that
arises from the environmental
objectives and that needs to be set
and met for the objective to be
achieved.
Stakeholders - Groups and
organizations having an interest or
stake in an organization's EMS (e.g.,
regulators, shareholders, customers,
suppliers, special interest groups,
residents, etc.).
NOTE
Although there are a lot of
examples from wastewater
facilities that have
implemented
EMSs, there are
" , no "standard"
environmental
objectives and
targets that make sense for all
organizations. Your objectives
and targets should reflect what
your organization does, how
well it is currently performing,
and what it wants to achieve.
COACH'S CORNER
Setting objectives and targets will help your organization
ranslate environmental goals into measurable results.
:- These goals can be factored into your organization's
' strategic plans and can facilitate the integration of
nvironmental management into your quality, health and
safety, and other management programs.
How many objectives and targets should your organization have?
Wastewater facilities that have implemented EMSs recommend that it is
best to start with a limited number of objectives (2 to 3) and then
expand the number over time. Keep your objectives simple initially,
achieve some early successes, and then build on them. As you gain
experience in managing your objectives and targets, additional and
potentially more robust objectives and targets can be set and added.
NOTE
v^ Your organization has the flexibility to determine
^ what environmental goals are appropriate based
on your needs. Objectives and targets can be
& set organization-wide or within an operation
(e.g., 20% energy reduction for your entire
wastewater treatment operation versus 20% energy
reduction for the biosolids operation).
Step-by-Step Guide to Setting
Objectives & Targets and
Establishing EMPs
Step 1) Determine the Significant Aspects for which
You'll Set Objectives & Targets
Step 2) Identify Your Objectives and Establish Target(s)
Step 3) Define the Performance Indicator(s) You'll Use
to Measure Your Targets
Step 4) Establish Your Environmental Management Programs
(EMPs) to meet the Objectives and Targets
a. List the Individual Tasks Required to Meet Your Target
b. Assign Responsibility
c. Establish Deadlines for Individual Tasks
d. Estimate Staff Time and Costs
Step 5) Get Top Management's Commitment and Approval
Step 6) Develop a Procedure for Setting Objectives & Targets and
Establishing EMPs
Step 7) Check Your Objectives & Targets and EMPs for
EMS Conformance
Step 8) Communicate Your Objectives & Targets and EMPs
Step 9) Review and Revise Your Objectives & Targets and EMPs
76
Section 3: Objectives & Targets and EMPs (Phase 1)
Wastewater EMS Handbook
-------
Step 1) Determine the Significant Aspects for
which You'll Set Objectives and Targets
Previously it was mentioned that you do not have to set objectives and
targets for every significant aspect, so how does your organization
decide which to select? Look back at your list of ranked significant
aspects and determine which aspects you want to establish
performance improvement goals based on your: 1) legal and other
requirements; 2) the views of interested parties (e.g., internal and
external stakeholders); 3) technical options; and 4) financial,
operational, and other organizational realities.
COACH'S CORNER
Be flexible in setting your objectives and targets. Define a
_ where the objectives and targets will be set determine
-------
COACH'S CORNER
Selecting the right
performance indicators for
objectives and targets
Fcan help you
understand how well
your EMS is working.
Make sure you select indicators
that actually allow you to
measure what you are trying to
improve.
Examples of EMS performance
indicators could include:
^ Number of odor complaints/
week
^ Pounds of chlorine
used/gallon of water treated
^ Energy used per unit of
production
^ Percentage of solid waste
recycled/used/year
Percentage of employees
completing environmental
training
REMEMBER
i Remember to focus
your environmental
goals on areas that
' will have the most
impact on your
environmental
footprint and your
wastewater operations. You
may want to review your
significant impacts and the
environmental policy statement
that your organization drafted
before you finalize your goals.
In this example, that the SSOs, based on their potential impact, scored
a 16 when reviewed for significance. Since you set your significance
threshold at 15, SSOs became a significant aspect.
Operation/
Activity
Operate and
Maintain
Pump
Stations
Aspect
Sewer
System
Overflows
(SSOs)
Impact
-Degradation of
Water/Land
(Streams,
Creeks, Soil,
etc.)
- Impact to
Public and
Worker Health
Land
Impact
5
Air
Impact
1
Water
Impact
5
Health &
Safety
5
Total
Score
16
Now let's look at setting an objective and target to improve our
management of SSO events. After reviewing your technical and
financial options, legal requirements, and the views of your local
community stakeholders, what is a performance-driven, but achievable
objective and target? Also remember that the best targets are those that
are measurable.
Therefore, consider your current baseline data and/or your
organization's ability to collect a good baseline for a particular target.
The following objective and target serves as an example for decreasing
the potential environmental impact of the sanitary sewer operations and
maintenance division, with a focus on decreasing the number or
percentage of SSOs.
Significant Aspect
Sewer System Overflows
(SSOs)
Objective
Reduce the number of sewer
system overflows (i.e., spills)
Target
Reduce SSOs by 40% from
FY 2002 & 2003 normalized
baseline levels
' om< .irnes behavior-based targets (e.g.,
in 3 a systems-based management
approach) are not the biggest gains in
performance measures related to your
targets, but they are very important!n
terms of culture change and should be
considered.
Donna Adams
Eugene, Oregon
Wastewater Division
78
Section 3: Objectives & Targets and EMPs (Phase 1)
Wastewater EMS Handbook
-------
Example Objectives and Targets from
Wastewater Facilities
Significant Aspect
Pollution Prevention,
Improved Biosolids Quality
Solid Waste Generation
(All Operations)
Engine Generator Operation
in Equipment Maintenance
Potable Water Used in Mixing
of Polymer (Gravity Belt
Thickener Operation and Belt
Filter Press Operation)
Water Effluent
Objective
Improve the Quality of
Biosolids and Limit Their
Effect on the Environment
Optimize Existing Recycling
Program
Reduce Air Emissions
Reduce Potable Water Use
Improve Water Quality in
Watershed
Target
Arrange for Dewatering and
Land Application of Water
Plant Residuals
Expand Recycling Program to
Aluminum, Plastics, Glass,
Cardboard and Packing
Materials; Manhole Recovery
Reduce Sulfur Dioxide
Emissions (Ibs) from the
Engine Generators by 85%
(Baseline 2002)
Reduce potable water use
(gallons) by 10%
(Baseline 2002)
1) Reduce Sediment in ABC
Creek Stormwater by 10% by
December 2005
2) Participate in and
Contribute to ABC Creek
TMDL Implementation Team
Step 3) Define the Performance Indicator(s)
You'll Use to Measure Your Targets
Performance indicators are what you will need to measure your
performance in meeting your established targets. In the case of
environmental regulations they may already be spelled out. However,
when it comes to your objectives and targets you will need to identify
appropriate "performance" indicators to track and assess progress
towards meeting your established goals.
Now that you've established a sample environmental objective and
target, set a parameter to measure the performance of a target, such as
reduction of SSOs events by 40% from 2002 levels.
Significant Aspect
Sewer System
Overflows (SSOs)
Objective
Reduce the number
of sanitary sewer
system overflows
(i.e., spills)
Target
Reduce SSOs by
40% from FY 2002 &
2003 normalized
baseline levels
Performance
Indicator
# of SSO events per
year
Factors to consider in
setting objectives and
targets
^ Ability to control
^ Ability to track /measure
^ Cost to track /measure
^ Progress reporting
^ Links to your environmental
policy's 3 commitments
NOTE
Your performance indicators
KH should be simple
and
v understandable;
measurable; and
relevant to what
your organization is trying to
achieve (i.e., its objectives and
targets).
Performance
Indicators: A Few
Words about
Measuring Your
Progress
When you establish quantifiable
objectives and targets you first need
to establish a baseline. This
baseline serves as the starting point
from which you will measure your
progress. For example, if you set an
objective to reduce hazardous waste
and a target to reduce the waste by
10% by 2005, what does that
mean? fifty pounds, 100 pounds, or
1000 pounds? You will first need to
determine how much hazardous
waste was generated the previous
year. Is information available to
make this calculation? If not, what
level of effort is necessary to define
the baseline? You may find that no
baseline data exist. If so, do not let
this stop you from moving forward.
Set a plan to determine your
baseline as a first step.
Section 3: Objectives & Targets and EMPs (Phase I)
Wastewater EMS Handbook
79
-------
A Word About
"Normalized"
Baselines
To accurately measure how your
facility performance is changing
over time, establish "normalized"
baselines where appropriate.
Normalized baselines will
measure your actual
environmental performance
changes rather than changes in
production, customer demand, or
other non-environmental related
factors.
For example, if you were
measuring the amount of salt
used on your facility roads, you
would want to establish a
normalized baseline because the
amount of snow and ice you get
(and therefore, the salt you will
use) will vary from year to year.
Average your salt use over two
or three years to normalize the
salt you use to get an accurate
baseline from which to measure.
REMEMBER
When setting up the
EMPs for your
wastewater facility,
consider that you
may already have
baseline data that
measure and track your
objectives and targets. For
example, if your target was to
decrease the amount of total
dissolved solids in your effluent
by 10%, you probably already
have baseline effluent data
from which to start to track
your success in meeting a
10% reduction.
Environmental Management Programs (EMPs)
At this point, you have identified your significant aspects and set
objectives and targets for those that you want to improve performance.
Now it is time to look at how you will achieve these goals. An important
part of your EMS is developing step-by-step action plans that define
how your organization intends to reach its objectives and targets.
These action plans (roadmaps) are called Environmental Management
Programs or EMPs.
Your EMPs are directly linked to your objectives and targetsthat is,
they describe how your organization will translate its goals into
concrete action plans so that environmental objectives and targets are
achieved.
Establish your environmental practices as a way of ensuring that your
EMS objectives and targets will be met. For example, the QualServ
program, supported by the Water Environment Federation (WEF) and
American Water Works Association (AWWA), has developed a series of
best management practices that you may wish to consult. Remember
build on what's already out there in your industry!
?
Step 4) Establish Your EMPs (Actions Plans)
Now that you have set an objective and target for your wastewater
facility, how will you achieve it? How will you accomplish your goals?
Let's look at the SSO example again and develop a program (EMP) for
achieving the target of reducing SSO events.
Your EMP should (step-by-step):
a) List the individual tasks (what and how will you do it?)
b) Assign responsibility for achieving goals (who will do it?)
c) Establish deadlines (by when?) for individual tasks
d) Estimate staff time and costs (how much?)
Use the sample Action Plan or EMP on the next page (or a similar
method) to manage and track your objective and targets.
NOTE
If you do not have baseline data for a
particular objective and target, the first step in
your EMP could be to establish the baseline.
Section 3: Objectives & Targets and EMPs (Phase 2)
Wastewater EMS Handbook
-------
Step 4a) List the Individual Tasks Required to
Meet Your Target
>
1
(
t
1
(
\rea/Operation: Sanitary Sewer Operations and Maintenance
Significant Aspect: Sewer System Overflows (SSOs)
Dbjective: Reduce the number of SSOs
Parget: Reduce SSOs by 40% from FY 2002 & 2003 normalized
vaseline levels
Start Date: 6/15/04
Completion Date 6/15/06
Tasks
Create Baseline Data
(Normalized from
CY 02 & 03 SSO events)
Develop a System to
Document
Causes/Locations/
Sources, etc. of SSOs
Implement a Fats, Oils &
Greases (FOG) Program
Communicate and Update
Staff and Implement Public
Outreach Program
Implement and Optimize
Preventative (PM)
Maintenance Program
Install SCADA and Flow
Metering Devices to
Improve Pump Station (PS)
Inspection and Monitoring
System
Communicate and Update
Staff
Develop Capacity,
Management, Operation,
and Maintenance (CMOM)
Program
Communicate Changes
to Staff
Track SSO events for CY
06 & 07 and Compare
Against your Target
Three Lessons Learned
(from wastewater facilities):
1. Track, review, and communicate
the status of your objectives and
targets, and action plans, on a regular
basis (i.e., monthly to ensure they are
on track). Report on your objectives
in a monthly status report to top
management.
2. Ask for volunteer(s) to "own" the
objectives and targets. This allocates
roles and responsibilities and
increases EMS buy-in.
3. Keep in mind as you develop your
objectives and targets and EMPs
(Action Plans) that operations and
divisions may have different priorities.
Try and relate to each group when
setting your goals. For example, show
the cost savings of your objective to
management and show the safety
benefits to frontline employees.
REMEMBER
"What gets measured,
gets managed."
Peter Drucker
Management Expert
Section 3: Objectives & Targets and EMPs (Phase I)
Wastewater EMS Handbook
81
-------
COACH'S CORNER
Involve employees
larly that will participate
r. and have
'" responsibility in
neeting your targets to
ablish and carry out
your programs. Also, clearly
communicate the expectations
defined in your programs to
those with responsibilities.
Check in frequently with key
EMP staff. How are they
progressing? Are there any
problems or concerns?
Communicating with staff on
your objectives and targets
and subsequent Action Plans
will head off or manage
problems that may arise. Make
sure any hurdles or issues are
communicated early to
management so that
resources can be re-directed
as necessary.
Step 4b) Assign Responsibility
Assign responsibility both for the overall EMP and for the individual
tasks. Make sure you communicate and confirm this with managers and
staff in responsible areas.
Area/Operation: Sanitary Sewer Operations and Maintenance
Significant Aspect: Sewer System Overflows (SSOs)
Objective: Reduce the number of SSOs
Target: Reduce SSOs by 40% from FY 2002 & 2003 normalized
baseline levels
Start Date: 6/1 5/04
Completion Date 6/15/06
Tasks
Create Baseline Data
(Normalized from
CY 02 & 03 SSO events)
Develop a System to
Document
Causes/Locations/
Sources, etc. of SSOs
Implement a Fats, Oils &
Greases (FOG) Program
Communicate and Update
Staff and Implement
Public Outreach Program
Implement and Optimize
Preventative (PM)
Maintenance Program
Install SCADA and Flow
Metering Devices to
Improve Pump Station
(PS) Inspection and
Monitoring System
Communicate and Update
Staff
Develop Capacity,
Management, Operation,
and Maintenance (CMOM)
Program
Communicate Changes to
Staff
Track SSO events for CY
06 & 07 and Compare
Against your Target
Staff
Mclntyre
Scott
Franklin
Prescott &
Murray
Martin
Jones
Prescott
Solich
Smith
Enders
82
Section 3: Objectives & Targets and EMPs (Phase 1)
Wastewater EMS Handbook
-------
Step 4c) Establish Deadlines for Individual Tasks
Plan intermediate deadlines for your EMPs. Incorporating deadlines
give those responsible a sense that this is important and needs to be
accomplished in a timely manner.
1
1
(
[
1
(
^rea/Operation: Sanitary Sewer Operations and Maintenance
Significant Aspect: Sewer System Overflows (SSOs)
Dbjective: Reduce the number of SSOs
Farget: Reduce SSOs by 40% from FY 2002 & 2003 normalized
Daseline levels
start Date: 6/1 5/04
Completion Date 6/15/06
Tasks
Create Baseline Data
(Normalized from
CY 02 & 03 SSO events)
Develop a System to
Document
Causes/Locations/ Sources,
etc. of SSOs
Implement a Fats, Oils &
Greases (FOG) Program
Communicate and Update
Staff and Implement Public
Outreach Program
Implement and Optimize
Preventative (PM)
Maintenance Program
InstallSCADAandFlow
Metering Devices to
Improve Pump Station (PS)
Inspection and Monitoring
System
Communicate and Update
Staff
Develop Capacity,
Management, Operation,
and Maintenance (CMOM)
Program
Communicate Changes to
Staff
Track SSO events for CY
06 & 07 and Compare
Against your Target
Staff
Mclntyre
Scott
Franklin
Prescott &
Murray
Martin
Jones
Prescott
Solich
Smith
Enders
Deadlines
07/01/04
08/30/04
09/30/04
10/15/04
12/30/04
06/31/05
08/01/05
11/30/05
12/30/05
01/01/06
to
12/31/07
REMEMBER
EMPs allow you to track
and assess your
progress in
accomplishing your
objectives and targets
and your policy commitments
and they also help you
quantify the economic and
environmental benefits of your
EMS.
NOTE
,X Many wastewater
. facilities and public
\ organizations have
managers initial or
sign their objectives and
targets and EMPs to confirm
their agreement with the goals
and plans. Their support in
keeping the EMS a priority is
an important key to success in
maintaining the EMP
schedule.
REMEMBER
If you expect to accomplish
i, your objective in one
-*! year, you won't want to
wait until you're in the
last month of that year to
assess your progress.
Track your progress
routinely and make the
necessary adjustments in the
schedule if there are conflicts
with high operational periods.
Section 3: Objectives & Targets and EMPs (Phase I)
Wastewater EMS Handbook
-------
Three Things to Avoid
(from wastewater facilities):
1. Biting off more than you can chew.
Begin with only two or three
objectives and targets and make sure
they are attainable and feasible for
your facility.
2. Not communicating time and
resource requirements to divisional
and line managers and supervisors
so they can alert their employees of
their objective and target and EMP
responsibilities.
3. Not establishing a normalized
baseline from which to measure your
targets. Normalized baselines are
averaged to measure your actual
environmental performance changes
rather than changes in production,
customer demand, or other non-
environmental related factors.
Provide a reality check on your
EM Ps with line managers,
department heads, and
supervisors whose operational
staff and management are
involved.
the appropriate staff
members responsible?
the timing conflict with
other operational priorities?
the tasks seem logical and
sufficient to accomplish the
target?
Step 4d) Estimate Staff Time and Costs
Confirm with managers that the resources (financial and human) are
consistent with what was described in the approved budget. Are there
other direct costs for materials? Equipment? Outside services? This
point further reinforces the need to keep management actively involved
and ensure that they are in agreement and committed to planned
activities.
Area/Operation: Sanitary Sewer Operations and Maintenance
Significant Aspect: Sewer System Overflows (SSOs)
Objective: Reduce the number of SSOs
Target: Reduce SSOs by 40% from FY 2002 & 2003 normalized
baseline levels
Start Date: 6/15/04
Completion Date 6/15/06
Tasks
Create Baseline Data
(Normalized from
CY 02 & 03 SSO events)
Develop a System to
Document
Causes/Locations/
Sources, etc. of SSOs
Implement a Fats, Oils &
Greases (FOG) Program
Communicate and Update
Staff and Implement
Public Outreach Program
Implement and Optimize
Preventative (PM)
Maintenance Program
Install SCADA and Flow
Metering Devices to
Improve Pump Station
(PS) Inspection and
Monitoring System
Communicate and Update
Staff
Develop Capacity,
Management, Operation,
and Maintenance (CMOM)
Program
Communicate Changes to
Staff
Track SSO events for CY
06 & 07 and Compare
Against your Target
Staff
Mclntyre
Scott
Franklin
Prescott &
Murray
Martin
Jones
Prescott
Solich
Smith
Enders
Deadline
s
07/01/04
08/30/04
09/30/04
10/15/04
12/30/04
06/31/05
08/01/05
11/30/05
12/30/05
01/01/06
to
12/31/07
Time
(in Person Hours)
20
20
40
16
80
120
16
120
16
40
Estimated
Costs
$$$
$$$
Total Estimated Cost for this EMP
84
Section 3: Objectives & Targets and EMPs (Phase 1)
Wastewater EMS Handbook
-------
timating your staff time and resources is an optional
;tep. Management will need to understand the resource
commitment before approving your objectives and
' targets, therefore many organizations incorporate this
information into their EMP tables.
Step 5) Get Top Management's Commitment and
Approval
Get top management buy-in and approval for your objectives and
targets and EMPs. Top management needs to ensure that your
objectives are integrated with other organizational objectives and are
consistent with the overall mission of your facility. Management also
needs to know what the efforts of achieving these goals will cost in
terms of staff time and capital expenditures, the length of time needed
to accomplish this effort, how it will interface with periods of high
operational priority, and who will be involved in the tasks.
Step 6) Develop a Procedure for Setting
Objectives & Targets and Establishing EMPs
When you're satisfied that your process for setting objectives and
targets and establishing EMPs conforms to the EMS requirements, it's
time to document the process in a system procedure. Your system
procedure clearly defines what you will do, roles and responsibilities,
when you will do it, how information will be communicated, and where
information will be stored. This documented procedure will be a
consistent, easily accessible, and clear guide for ensuring that this
important element of your EMS is carried out according to plans.
For a sample procedure on setting Objectives and Targets and example
Environmental Management Programs for a wastewater facility, see
Appendix A.
Step 7) Check Your Objectives & Targets and
EMPs for EMS Conformance
Once you have established your environmental objectives and targets,
review the process for EMS conformance.
Check S
1. Are there documented objectives and targets applicable to the
organization?
2. Are your objectives and targets consistent with your Environmental
Policy goals?
COACH'S CORNER
Make sure your
objectives and targets
are realistic and that
J^ metrics for measuring
progress and setting
;cess points are in line
vviu, uie organization's
business and technical goals.
NOTE
^ Invite your budget
L office to the meeting
^ when you set your
objectives and
targets. Since they hold
your purse strings, their
involvement is important in
determining the allocation of
funds for your new EMPs
(Action Plans).
, EMS Manual ,
Procedures
Work Instructions, Forms,
Drawings, etc.
An objective and target and EMP
procedure is recommended for this
element. A system procedure defines
the purpose (why the procedure is
needed), scope (to what
operations/areas/staff the procedure
applies), roles & responsibilities (who
needs to complete the tasks), and the
tasks that need to be completed for
this element.
Section 3: Objectives & Targets and EMPs (Phase I)
Wastewater EMS Handbook
85
-------
NOTE
To obtain the views
of externally
fcy 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. For
many wastewater
organizations, public image
and ultimately public
acceptance is a high priority
issue. Consider embracing
the local community and
giving them an opportunity to
provide input. For example,
you might find out that odor
is a real concern and should
be an operations focus area.
Involving Contractors
and Temporary Staff
On-site contractors and temporary
staff may work in areas in which
there are significant aspects or
where objectives and targets have
been set. Communicating your
objectives and targets and EMPs to
contractors and temporary staff is
important and can get you needed
buy-in on what you are trying to
accomplish. Also, keep in mind that
your suppliers (of services or
materials) can help you in meeting
your objectives and targets (e.g., by
providing more "environmentally-
friendly" products).
3. Did you consider your legal and other requirements; significant
environmental aspects; technical options; the views of your internal
and external stakeholders; and your financial, operational, and
business realities when setting your objectives and targets?
4. Did you set quantifiable performance indicators for your targets?
5. Are environmental performance improvements noted and tracked?
6. Are programs (plans) set to implement your objectives and targets?
7. Do you regularly communicate progress of your objectives and
targets to management?
Step 8) Communicate Your Objectives & Targets
and EMPs
Communicate your objectives and targets and action plans to
employees, suppliers, contractors, and external stakeholders. Open
communication will increase buy-in of your environmental goals and
what you are trying to accomplish. In addition, communication of your
goals and plans will keep the EMS on everyone's radar and ensure that
your organization is on the path to continuous improvement (i.e., your
goals are seen as important and a priority).
ACH'S CORNER
to link them to their actual job activities and the reduced or
'*" positive impacts on the local community of which they live.
Keep in mind that individuals respond to information that is
meaningful to "their world," thereby increasing the likelihood
they will follow through and act on the goals you are trying to
achieve.
Step 9) Review and Revise Your Objectives &
Targets and EMPs
Once you have your objectives and targets in place and have
determined the steps (in the form of your EMPs), for achieving your
goals, remember that a fundamental element of the EMS is to review,
assess, and improve (i.e., continual improvement!). Revisit your
objectives and targets and EMPs on a regular basis as you conduct
internal EMS audits and EMS management review, to ensure that your
organization is on the right path, and moving toward meeting its
commitments in your environmental policy and goals. This review is
especially important if you have any new or modified operations.
Consider leveraging your regular EMP tracking efforts as a vehicle,
or opportunity, to continually share and discuss progress with
top management.
Section 3: Objectives & Targets and EMPs (Phase 2)
Wastewater EMS Handbook
-------
Setting Objectives & Targets and Establishing EMPs
(Cuf ouf this section for handy reference)
The Purpose of this EMS element is to:
O Identify environmental goals (objectives and targets) that address your wastewater facility's
significant environmental impacts.
O To establish and maintain environmental management programs (action plans) for achieving your
organization's objectives and targets.
The Results of this EMS element are:
O Environmental objectives and targets that are documented and communicated.
O EMPs (action plans) for meeting your environmental objectives and targets.
Before You Begin this EMS element:
O Complete your significant aspects and impacts analysis.
Section 3: Objectives & Targets and EMPs (Phase 2) 87
Wastewater EMS Handbook
-------
ISO 14001
Requirements
Key Links to Other
EMS Elements
Required Documents
& Records
Optional
Documents &
Records
Objectives & Targets
The organization shall
establish and maintain
documented
environmental objectives
and targets, at each
relevant function and level
within the organization.
When establishing and
reviewing its objectives,
an organization shall
consider the legal and
other requirements, its
significant environmental
aspects, its technological
options and its financial,
operational and business
requirements, and the
views of interested parties.
The objectives and targets
shall be consistent with
the environmental policy,
including the commitment
to prevention of pollution.
Environmental Policy -
Your environmental
objectives and targets will
guide the vision of your
Policy.
Environmental Aspects -
When establishing your
objectives and targets, look
first at your significant
environmental aspects.
Legal & Other
Requirements - Consider
what regulations and other
requirements you must
comply with as you set your
objectives and targets.
Structure &
Responsibility- Top
management must commit
to and approve your
objectives and targets. Any
employee can contribute to
establishing and setting
parameters for your
objectives and targets.
Environmental
Management Programs -
EMPs are the action plans
that will layout how your
objectives and targets will be
accomplished.
Monitoring & Measurement-
Establish baselines and
metrics of performance for
your objectives and targets.
Management Review - The
progress of your objectives
and targets will be a major
agenda item at management
review meetings to see how
your EMS is functioning.
Documented
Objectives and Targets
Pollution Prevention
Plans
Other Business or
Organizational Goals
Section 3: Objectives & Targets and EMPs (Phase 2)
Wastewater EMS Handbook
-------
ISO 14001
Requirements
Key Links to Other
EMS Elements
Required Documents
& Records
Optional
Documents &
Records
Environmental Management
Programs (EMPs)
The organization shall
establish and maintain (a)
program(s) for achieving its
objectives and targets. It
shall include:
a) designation of
responsibility for achieving
objectives and targets at
each relevant function and
level of the organization;
and
b) the means and time-
frame by which they are to
be achieved.
If a project relates to new
developments and new or
modified activities, products
or services, program(s) shall
be amended where relevant
to ensure that environmental
management applies to such
projects.
Environmental Aspects -
When developing your
EMPs for your objectives
and targets, look first at
your significant
environmental aspects.
Objectives and Targets -
Your EMPs manage and
track (who, what, by when,
how much) your objectives
and targets.
Monitoring &
Measurement - Establish
baselines and metrics of
performance for your
quantitative objectives and
targets and subsequent
EMPs.
Management Review -
The progress of your
objectives and targets and
subsequent EMPs will be a
major agenda item at
management review
meetings to see how your
EMS is functioning.
Documented EMPs to
manage your Objectives
and Targets
Environmental
Management Program
Progress Report Form
Section 3: Objectives & Targets and EMPs (Phase 2)
Wastewater EMS Handbook
-------
Phase III: Implementing
You are now ready to begin the
Implementation Phase of the EMS
cycle. Each section of this
Handbook will guide you step-by-step
through each of the EMS activities. Refer
to the icons for case studies, sample doc-
uments, keys to success and other imple-
mentation assistance. At the
end of each section, two
handy reference sheets
review the Purpose
of each require-
ment, describe the
Results you'll be
developing, dis-
cuss how to
Prepare to do the
work, and show
how the element
links to other EMS
requirements.
In this phase, you will be focusing on
managing significant aspects that were
defined in the Planning Phase and estab-
lishing performance indicators for each of
your environmental targets to assess your
EMS progress. This phase includes defin-
ing implementation team roles and
responsibilities and establishing internal
and external lines of communication. The
activities in this phase will allow your
organization an opportunity to
take a more focused look at
the specific operations
and services that you
decided were most
significant for your
wastewater facility.
If you are using a
two-year implemen-
tation strategy, the
activities in this
phase can be comfort-
ably accomplished in
about nine months.
Here's a checklist of requirements in
this Phase:
Phase III EMS Requirements (9 months)
Structure and Responsibility
(See Section 2: Getting My Facility Ready to Implement an EMS)
Training, Awareness, and Competence
Internal and External Communication
EMS Document and Records
Operational Control
Emergency Preparedness and Response
^
^
^
^
^
^
-------
Section 3: Training, Awareness, and
Competence
As should be apparent from the previous sections of this manual,
cross-sectional involvement from across your EMS fenceline and
organization is the key to a successful and viable EMS. What's
the first step in achieving involvement? Training and awareness!
As you have learned by now, buy-in and understanding an EMS is not
automatic, especially when reaching out to various levels within your
organization. The context of your message and the level must be
applicable to the staff receiving the message in order for them to
connect their particular work activities and job functions to the EMS. In
addition, sound operational management requires that personnel
understand and follow the procedures outlining their roles and
responsibilities. This simply cannot be accomplished without, you
guessed ittraining!
Want two great reasons to train employees about environmental
management and your EMS?
Every employee can have potential impacts on the environment;
and,
Any employee can identify positive ways in which to improve
environmental management.
As part of your EMS, you will verify (i.e., have documented training
records) that everyone has received general awareness training about
the EMS, your environmental policy, and what the EMS means to each
employee doing his/her job. You will also verify that each person whose
job involves a significant environmental aspect is trained and competent
(i.e., based on certification, education, etc.) to implement procedures
and follow regulations to minimize the environmental impact of their
operations.
Step-by-Step Guide to
Training and Awareness
Step 1) Assess EMS Training Needs
Step 2) Review and Integrate EMS Training
with Your Current Training and Methods
Step 3) Conduct, Document and Maintain
Training Records
Step 4) Develop a System Procedure/Plan for EMS
Training, Awareness & Competence
Step 5) Check Your Training, Awareness and
Competence for EMS conformance
Key Section Terms
EMS Awareness Training - Training
involving an overview of the basics of
your EMS, including your
environmental policy, significant
aspects, objectives and targets, and
the importance of operating under
specific procedures and work
instructions (operational controls)
required under the EMS.
Competency Training - Employees
whose work may create a significant
environmental impact must get
appropriate training and be deemed
competent based on education,
training or experience. For example,
most wastewater facilities need to
have state licensed operators. The
license is a way to demonstrate
competency.
System Procedure -An EMS
required document that establishes
an element's purpose, scope, roles &
responsibilities, the tasks to be
completed, and where and how the
associated records and documents
are maintained.
Assessing Training
Ask Yourself:
What jobs affect the
environment?
What job activities involve a
significant aspect?
What types of training do
we currently conduct in these
areas?
Can EMS roles/responsibilities/
controls be included in this
training?
Can we tweak the training
material we already have or do
we need to develop new
materials?
How do we currently maintain
training records?
Section 3: Training, Awareness, and Competence (Phase 3)
Wastewater EMS Handbook
93
-------
Creative ways to
Provide EMS
Awareness Training
^ New employee flyer
^ Payroll or pay-stub insert
* Training videos
^ Green mousepad
^ Monthly newsletters
Three Keys to
Success
(from wastewater facilities):
/ \
1. Relate EMS and
environmental training to
employee work activities.
2. Create one training
plan/program and integrate
EMS training into it. For
example, if you have an all-
employee health and safety
training, add a few EMS slides
to the presentation.
3. Have division managers
present at training sessions to
show support for the EMS
program.
Times When
Environmental
Training is Typically
Needed
ป New employee is hired
ป Employee is transferred to a
new job
ป Procedures are changed
ป New process, material or
equipment is introduced
ป A change to objectives and tar-
gets or EMPs is made
ป New regulation affecting your
activities
ป To stay current on operations
(e.g., annual/refresher)
Step 1) Assess EMS Training Needs
All personnel receive training. Environmental/EMS training should be
tailored to the different needs of employees and to various levels or
functions in your wastewater organization. For example, someone in
operations who handles hazardous chemicals will need a different type
of environmental training from someone in procurement who purchases
hazardous chemicals. However, keep in mind that both employees
could potentially have significant impacts on the environment and must
receive at least general EMS awareness training.
Who needs to receive environmental training at your facility? In
assessing EMS training needs for your wastewater facility, consider
both general and specific needs. For example:
^ "What environmental management procedures affect Stu's daily
work and what happens if they aren't followed?"
^ "What environmental impacts might Stu's work cause?"
^ "What legal non-compliance issues might Stu's work potentially
raise?"
^ "What broad understanding of environmental issues and the EMS
does Stu need?"
^ "What type of training does Stu currently receive?"
For your EMS, everyone must understand:
1. The environmental policy
2. The significant environmental impacts of his/her work activities
3. The environmental objectives and targets you have set
4. Key EMS roles and responsibilities
5. Environmental procedures and work instructions that apply to
their work
6. The importance of following your EMS and environmental
requirements, and the potential consequences of not doing so.
Step 2) Review and Integrate EMS Training with
Your Current Training and Methods
Build on what you have in place and what currently works. Do you have
an existing training procedure or plan? If so, build upon this to ensure
that you are meeting your EMS requirements. Also, look at the training
you conduct for environmental compliance, health and safety, and other
related areas. What about certification training? You may find that many
of your existing training efforts will satisfy some of the requirements for
your wastewater EMS.
REMEMBER
ป_ Every person at your wastewater treatment facility can play
i a role in environmental management. Train your employees
to help them understand their roles and responsibilities.
94
Section 3: Training, Awareness, and Competence (Phase 3)
Wastewater EMS Handbook
-------
Step 3) Conduct, Document and Maintain
EMS Training Records
Just like any other training you conduct, you will need to document and
maintain (verify) your EMS training. For an EMS auditor, training can be
verified by a signature and date that an employee attended a class on
EMS Awareness. Another idea is an updated training matrix tracking
training sessions and required and actual attendance. Again, consider
how you currently track training needs and participation.
Remember, for your EMS, you need to train all employees on the EMS
basics, including your environmental policy, objectives and targets, and
how the EMS applies to their day-to-day activities. In addition,
employees in areas with the potential to create significant environmental
impacts must understand how to minimize those impacts and the
potential consequences of not following EMS requirements.
CASE STUDY
At the New Hampshire Department of Transportation (NH DOT),
Bureau of Traffic, an effort was made to combine the training
requirements of the Safety and EMS programs. Combining the
training programs helped reduce the overall time spent in training
and administration of the their programs. For example, 127 full and
part time positions needed training. By combining the training
requirements, the Bureau of Traffic saved about 7.5 hours each
year per employee. This amounted to 127 additional workdays that
was available to perform normal work activities.
EMS and Competence
What does it mean to be competent in your job under an EMS? It means that
employees in certain jobs (particularly operations that can cause significant
environmental impacts) have a combination of education,
training, and experience to do their day-to-day tasks and ensure that your
organization properly manages its significant aspects and environmental
impacts. Make sure you maintain records of their experience and training
(certifications, education, and previous job records, etc.) just as you would
any other verifiable training records at your facility.
Consider cost effective and creative ways to train your staff on your EMS.
For example, use a video for EMS awareness training. Computer-based
training also may be an option, especially for employees who spend much of
their time in the field and/or work varying hours/shifts.
Involving Contractors
and Temporary Staff
Make sure that contractors and
temporary staff are trained on the
basics of your EMS (awareness,
policy, emergency response, etc.).
They need specific training on their
roles and responsibilities in areas that
can cause significant impacts or in
which objectives and targets are set.
The wastewater facilities that have
EMSs in place that contributed to this
Handbook provide general EMS
awareness training to their contractors
and temporary staff, and involve them
in the aspect/impact analysis and in
the setting of objectives and targets if
their work can cause a potential
environmental impact.
Three Lessons Learned
(from wastewater facilities):
1. Identify and document training
requirements for each employee. For
example, consider using a training
matrix or table to identify employee
titles, needs, and due dates.
A sample training matrix is attached
at the end of this section and in
Appendix B.
2. Get feedback from employees on
the effectiveness of training materials
and adjust your training based on
their feed back.
3. Make your EMS training part of
other training you currently conduct
(e.g., new employee orientation,
health and safety, etc.).
Section 3: Training, Awareness, and Competence (Phase 3)
Wastewater EMS Handbook
95
-------
EMS Manual
Procedures
Work Instructions, Forms,
Drawings, etc.
A Training, Awareness, and
Competence system procedure/plan
is required for this element. A system
procedure defines the purpose (why
the procedure is needed), scope (to
what operations/areas/staff the
procedure applies), roles &
responsibilities (who needs to
complete the tasks), and the tasks that
need to be completed for this element.
Three Things to Avoid
(from wastewater facilities):
1. Making your EMS training too
technical or "jargony." Remember the
KISS principle!
2. Conducting training sessions that
are too long. Keep your training
sessions short, interesting and to the
point.
3. Having training sessions that
"preach" EMS or environmental
requirements. Remember to keep a
"blue jeans, no tie" (relatable)
message.
Step 4) Develop a System Procedure/Plan for
EMS Training, Awareness & Competence
When you're satisfied that your process for training, awareness, and
competence conforms to the EMS requirements, document the process
in a system procedure, and update your training plan. Remember, most
organizations have some type of training in place before they begin
their EMS. Build off your existing procedures and plans.
Your system procedure should clearly define what you will do, roles and
responsibilities, when they will do it, how the information will be
communicated, and where the information will be stored. This
documented procedure will be a consistent, easily accessible, and
clearly ensure that this element of your EMS is carried out according to
plans.
For samples of Training, Awareness, and Competence procedures from
wastewater facilities, see Appendix A.
CASE STUDY
Training doesn't always have to be done in a classroom setting. The
City of San Diego Environmental Services Department, Refuse
Disposal Division conducted some of its EMS awareness and
competency training in "tailgate sessions." Rather than pulling
personnel off-site for training, they took the training sessions to their
employees. Before starting up equipment in the morning or during
breaks, personnel would gather and receive training on the
environmental policy or a new work instruction. This approach saved
a significant amount of time and eliminated the need to pull
personnel off-site for training.
Step 5) Check Your Training, Awareness and
Competence for EMS Conformance
About two or three months after you have documented and
implemented your training, awareness, and competence procedure,
check to see if it is actually working according to your plan. Here are
some questions to investigate:
Check
-------
"-"x" <-'\" t-'x"
P i
Training, Awareness, and Competence
(Cut out this section for handy reference)
The Purpose of this EMS element is to:
o Identify and track environmental and EMS training requirements.
The Result of this EMS element is:
o A system procedure/plan (EMS document) that identifies and tracks your environmental and
EMS training needs.
Before you Begin this EMS element:
o Acquire a knowledge on your organization's current training programs and methods. I
o Complete your environmental aspect and impact assessment and determine significance. |
'"
Section 3: Training, Awareness, and Competence (Phase 3) 97
Wastewater EMS Handbook
-------
ISO 14001
Requirements
Links to Other EMS
Elements
Required Documents
& Records
Optional
Documents &
Records
Training, Awareness and
Competence
The organization shall
identify training needs. It
shall require that all
personnel whose work may
create a significant impact
upon the environment,
have received appropriate
training. It shall establish
and maintain procedures to
make its employees or
members at each relevant
function and level aware of
a) The importance of
conformance with the
environmental policy and
procedure and with the
requirements of the EMS;
b) The significant
environmental impacts,
actual or potential, of their
work activities and the
environmental benefits of
improved personal
performance;
c) Their roles and
responsibilities in achieving
conformance with the
environmental policy and
procedures and with the
requirements of the EMS,
including emergency
preparedness and
response requirements;
d) The potential
consequences of departure
from specified operating
procedures.
Personnel performing the
tasks which can cause
significant environmental
impacts shall be competent
on the basis of appropriate
education, training and/or
experience.
Environmental Aspects -
Employees that work in
areas of potential
significant impact need to
be aware they are in these
areas, and need to be
trained on ways to minimize
potential significant
impacts.
Legal and Other
Requirements -
Employees in regulated
areas should be trained
and have knowledge of
regulatory requirements
and the consequences of
noncompliance.
Structure &
Responsibility -All
employees need to
understand and be trained
in their EMS roles and
responsibilities, including
the basics of your EMS and
your EMS Policy.
Records - Conduct,
document, and maintain
training and competency
records, including EMS
awareness and training on
significant aspects and
objectives and targets.
Training Plans/Procedures
Environmental Training
Records
EMS Awareness Training
EMS Significance Area
Training
Certificates/Education
Records (to verify
competency) in significant
areas
Job Category Training
Matrix
Section 3: Training, Awareness, and Competence (Phase 3)
Wastewater EMS Handbook
-------
The EMS Coordinator ensures delivery of he
appropriate training modules according to this
matrix to all personnel
within the EMS scope.
Training Modules
EMS 1
EMS 2
Procedures and WIs 1
Legal Requirements
Emergency
Content
EMS Awareness
EMS Procedures
Job Specific Procedures
CMOM
CWA
Pretreatment
Action Plans
Spill Response
Staff
Operations Managers
X
X
X
X
Planning Officer
X
X
Engineering Officer
X
X
X
X
ing Technicians
,
ro
_i
X
X
X
X
X
D)
c
"5
ro
I
X
X
X
X
X
Section 3: Training, Awareness, and Competence (Phase 3)
Wastewater EMS Handbook
99
-------
Section 3: CommunicationInternal
and External
A central component of any EMS is to establish clear
communication channels both internally within your organization
and externally to interested parties. Effective, proactive
communication is often an unexpected, but a welcome benefit of EMS
implementation. You need to establish and implement procedures that
describe how your organization:
1. Ensures effective internal communication through the flow of
information from the top down, from the bottom up, and across your
entire EMS fenceline;
2. Solicits, receives, documents, and responds to external
communications; and,
3. Considers and records external communications on your significant
environmental aspects.
Internal Communication: Do employees within your organization
understand with whom to talk regarding your EMS and environmental
procedures, emergency situations, and legal and other requirements?
Communication requires the involvement of everyone within your
organization. Internal communication is important to keep staff aware of
your EMS, EMS success stories, and any changes to your operations
and services that affect your EMS.
External Communication: As public organizations, it is important to
consider proactively communicating with your local community and
other interested stakeholders (e.g., regulatory agencies, citizens,
Commissioners, etc.) about your EMS. Taking the initiative to obtain the
views of your external stakeholders will help you better understand how
the community feels about your facility. Also, getting their buy-in on
your EMS will help ensure that you are identifying their most important
environmental issues.
Step-by-Step Guide to
Communication
i
Step 1) Determine What Needs to be Communicated
Internally to Your Organization
Step 2) Determine Who You Currently Communicate
With Externally
Step 3) Determine Who has an Interest and Who has a
Potential Effect on Your EMS
Step 4) Define How Your Organization Can Best Reach
External Stakeholders
Step 5) Develop an EMS System Procedure(s) for Internal and
External Communications
Step 6) Check the Communication Procedure(s) for EMS
Conformance
Key Section Terms
External Communication -
Providing information and soliciting
input, receiving inquiries and
complaints, responding, and
documenting exchanges with
interested parties outside the
fenceline of your facility.
Internal Communication - Flow of
information top-down, bottom-up, and
across your entire EMS fenceline.
Interested Parties ("Stakeholders")
- An individual or group, internal or
external to the organization,
concerned with or affected by the
environmental performance of your
organization. For example, local
residents, citizen groups, and
environmental regulators are all
examples of "interested parties." In
addition, consider your own
employees-inside and outside of your
fenceline-to be interested parties.
System Procedure - An EMS
(ISO 14001) required document that
establishes purpose, scope, roles &
responsibilities, the tasks to be
completed, and where and how the
associated records and documents
are maintained.
Common Waste water
External Interested
Parties
("Stakeholders")
Local citizen/community groups
Neighbors
State/local environmental groups
Regulatory agencies
Advisory groups
Local Officials
Emergency response personnel
Contractors and vendors
Section 3: Communication: Internal and External (Phase 3)
Wastewater EMS Handbook
-------
Internally
Communicate:
-ป Environmental Policy
-ป Legal and Other Requirements
-* Procedures and Work
Instructions
-ป Roles & Responsibilities
-* Significant Aspects
-* Objectives & Targets
-ป EMS Progress and
Success Stories
-ป EMS Audit Results
COACH'S CORNER
Remember that great
Jeas come from front-
. line employees that
j-'work directly in areas
hat affect your
n/astewater facility's
environmental impact. Make
sure there are ways for them
to provide feedback to their
line managers and to top
management.
Externally
Communicate:
-ป Environmental Policy
-ป Significant Aspects (Optional)
-ป Objectives & Targets (Optional)
-ป Requirements to Suppliers and
Contractors
-ป Annual Reports
-ป EMS Highlights and Successes
(Optional but Highly
Recommended!)
Step 1) Determine What Needs to be
Communicated Internally to Your Organization
A good place to start in developing your EMS communication strategy is
to look at how your organization currently communicates messages
internally. How do managers currently get information to employees
and receive information and communicate back to managers? How do
line managers communicate with one another? Leverage these
strategies that are already in place, especially those that are familiar
to personnel.
REMEMBER
. Keep your communications simple,
fresh and to the point. Think KISS!
Also remember, the EMS is about
continuous improvement.
Internal Communication Vehicles
ป Employee Meetings
ป Environmental, Health, and Safety Training
ป Working Lunches (free food!)
ป Newsletters
ป Pay Stub Inserts
ป Intranet
ป Bulletin Boards
For a sample EMS newsletter, see Appendix B
Step 2) Determine Who You Currently
Communicate With Externally
Once you have your EMS internal communication strategy in place, the
first step in determining your external communication strategy is to
identify with whom you are currently communicating. As a public
organization, you probably already have external stakeholders that you
talk with, including City Commissioners, local citizens and citizen
groups, the Mayor, regulatory agencies, etc.
Many public organizations find that when they reach out within their
local communities, sometimes for the first time, they are well-received
and confronted with "Why haven't you asked us before? We have some
great ideas to share."
102
Section 3: Communication: Internal and External (Phase 3)
Wastewater EMS Handbook
-------
While ISO 14001 does not require an organization to have a truly
proactive external communications program, in all likelihood it will
benefit you organization and your EMS if you make a strong effort to
reach out to key external stakeholders. While the timing and nature of
this outreach is up to you, you may wish to consult with key
stakeholders why you have chosen to implement an EMS and what you
want to get out of it. Finally, you are encouraged to keep key
stakeholders abreast of your progress as you develop the EMS and
how your system is performing once it is in place. Again, the final
decision is always up to you, but as a public agency you have an
obligation to work closely with your key stakeholders.
CASE STUDY
The Lowell, Massachusetts Wastewater Treatment Plant asked
local residents to assist in efforts to address the facility's odor
issues. Residents in a chosen target area recorded weather
information on days the odor was prevalent, as well as the degree
of the odor and the time the odor occurred. This information
identified a pattern of specific conditions during which odors were
most prevalent. The City of Lowell responded by making changes
to its operational patterns during times when those specific
conditions had occurred and, in turn, established greater trust within
the local community.
Step 3) Determine Who has an Interest and Who
has a Potential Effect on Your EMS
Once you've identified with whom you currently communicate externally,
define additional external stakeholders or new methods of
communicating by determining: 1) who potentially has an interest in
your EMS and 2) who potentially has an affect on your EMS.
In determining what to communicate to your external interested parties,
your organization will need to assess the extent to which your strategy
will be proactive. Ask:
What is your current level of public acceptance?
What are your external stakeholder's concerns?
Have you had public relations issues in the past that require certain
strategies or cautions?
Since communication is most effective when it's a two-way dialogue,
what type of input from them would interest you most and be most
useful?
What will be the return on investment of a proactive approach?
Three Things to Avoid
(from wastewater facilities):
1. Starting your EMS communication
plans and procedures from scratch.
Build on existing communication
methods.
2. Not communicating frequently on
the progress of your EMS. Instead,
send management and employees
regular status updates of your EMS
(i.e., send three EMS "good news
bullets"
each month in your newsletter).
3. Not identifying and communicating
with your key external stakeholders
and seeking their input. The local
community and other external
stakeholders, if informed on what you
are trying to achieve, can be critical
allies for your organization.
COACH'S CORNER
^ Your organization may
mt to take a very
, proactive external
*' communications
Approach, at least initially.
Include an educational
focus and promote an
understanding of the
environmental controls
involved in the management
of your facilitythis will lead
to increased appreciation for
your wastewater services by
the community.
Section 3: Communication: Internal and External (Phase 3)
Wastewater EMS Handbook
103
-------
Three Lessons Learned
(from wastewater facilities):
1. Communicate EMS information up,
down, and across your wastewater
organization. This will promote buy-in
to your EMS.
2. Keep internal messages simple,
clear, concise, and fresh. Remember,
Keep It Simple, Simple (KISS)!
3. Proactive (two-way) communication
with external parties is important.
Take steps to obtain the views of
external stakeholders. This will help
you better understand how your
organization and your EMS is
perceived by others.
EMS Manual
Procedures
Work Instructions, Forms,
Drawings, etc.
A Communications system procedure
is required for this element. A system
procedure defines the purpose (why
the procedure is needed), scope (to
what operations/areas/staff the
procedure applies), roles &
responsibilities (who needs to
complete the tasks), and the tasks that
need to be completed for this element.
Step 4) Define How Your Organization Can Best
Reach External Stakeholders
Now that you've determined who your external stakeholders are and
the potential reasons why they might have an interest and effect on
your EMS, determine how to best reach your external stakeholders.
Consider the following methods that wastewater facilities with an EMS
have used.
External Communication Vehicles
ป Annual Reports
ป Steering Committees and/or Advisory Groups
ป Media Releases
ป Open Houses and Tours
ป Websites
ป Surveys
ป Mailings & Newsletters to Local Communities
NOTE
* Find out which issues are of greatest interest to
your external stakeholders and focus your efforts
< on what those issues (i.e., health and safety,
compliance, SSO runoff into waterways, odor
issues, etc.).
Step 5) Develop an EMS System Procedure(s) for
Internal and External Communications
When you are satisfied that your process for internal and external
communications conforms to the EMS requirements and that it allows your
organization to achieve its goals for enhancing communication, document
the process in a system procedure. As with all EMS system procedures, it
needs to clearly define what, when, how, and where.
For samples of Internal and External Communications procedures from
wastewater facilities, see Appendix A.
beginning, we involved all
?es in the EMS process.
Therefore, we improved communicat*
between ALL levels of staff in our
wastewater facility.
at'^ns
Beth Eckert
Gastonia, North Carolina
Public Works and Utilities Department
I04
Section 3: Communication: Internal and External (Phase 3)
Wastewater EMS Handbook
-------
Step 6) Check the Communication Procedure(s)
for EMS Conformance
After you have documented and implemented your communications
procedure it's time to check if it's actually working according to your
plan and establishing the necessary communication channels. Here
are some questions to investigate:
Check
-------
Internal and External Communication
(Cut out this section for handy reference)
The Purpose of this EMS element is to:
o Define and implement a procedure for identifying and communicating with internal and
external interested parties regarding your EMS process and environmental management
activities and approaches.
The Results of this EMS requirement are:
o An approved procedure(s) (EMS Document) for internal and external communication.
o A record of communications (EMS Record) with external interested parties.
o A record of your decision (EMS Record) on ways to communicate significant aspects to external
interested parties.
Before you Begin this EMS element:
o Complete your significant environmental aspects analysis.
o Identify what and how you currently communicate both internally and externally.
106 Section 3: Communication: Internal and External (Phase 3)
Wastewater EMS Handbook
-------
ISO 1400
Requirements
Links to Other EMS
Elements
Required Documents
& Records
Optional Documents
& Records
nts
Communication
With regard to its
environmental aspects and
environmental
management system, the
organization shall
establish and maintain
procedures for:
a) internal communication
between the various levels
and functions of the
organization; and
b) receiving, documenting,
and responding to relevant
communication from
external interested parties.
The organization shall
consider processes for
external communication on
its significant
environmental aspects and
record its decision.
Environmental Policy -
Your Policy must be com-
municated to all employees
and made available to the
public.
Environmental Aspects -
Employees are aware of
their roles and responsibili-
ties in relation to environ-
mental aspects. Processes
for external communication
are considered and deci-
sions recorded.
Objectives & Targets -
Communicate with employ-
ees in areas and operations
with environmental targets
so that they understand
their roles and responsibili-
ties.
Structure and
Responsibility - Roles,
responsibilities, and authori-
ties shall be defined, docu-
mented, and communicat-
ed.
Training & Awareness -
Employees are aware of
their roles and responsibili-
ties in relation to environ-
mental aspects and the
potential consequences of
departure from specified
procedures.
Communications
Procedure(s)
Record of External
Communications
Record of decision on
communicating significant
aspects to external
interested parties
List of Internal and External
Interested Parties
Section 3: Communication: Internal and External (Phase 3)
Wastewater EMS Handbook
107
-------
Section 3: EMS Documents and
Records
The EMS documents are written procedures, policies, work
instructions, manuals, etc. used to keep your EMS working and
functioning as you planned and intended. EMS documents describe
your organization's daily EMS tasks and how they are accomplished.
EMS documentation ensures that activities and operations are consistent
through the use of up-to-date procedures and work instructions. Example
EMS documents could include your aspect analysis system procedure,
your environmental policy statement, your emergency response plan, or a
work instruction on shutting down your air compressors in case of an
emergency.
EMS records, on the other hand, present objective evidence, or proof,
that your organization is following EMS procedures, policies, work
instructions, and manuals, etc., as intended. Examples include training
records, audit checklists, your list of significant aspects, and
management review meeting notes.
To ensure that your employees work from the most current procedures,
work instructions, and manuals, controlling your documents becomes
very important. In addition, both documentation and records will help
you explain your processes to auditors and other external interested
parties, as well as allow your organization to effectively preserve
institutional knowledge that would otherwise stay "between the ears"
of your personnel.
Step-by-Step Guide to
Controlling Documents and
Records
J
Step 1) Assess EMS Document Control and
Records Requirements
Step 2) Review Current Document Control and
Records Procedures
Step 3) Integrate/Develop a System Procedure(s)
for EMS Documents and Records
Step 4) Check Your Documents and Records for EMS
Conformance
Step 1) Assess EMS Document Control and
Records Requirements
From the beginning of your EMS implementation, you will be creating
EMS system procedures and other documents of your processes that you
will use to manage your EMS and meet EMS requirements. System
procedures provide the basis for your EMS, and although it takes some
time to create EMS procedures at the early stages of implementation,
don't fret! Once in place, your EMS documents simply need to be
periodically reviewed and modified as necessary to keep them current.
Key Section Terms
Controlled Documents - Policies,
procedures, manuals, and other
documents part of your EMS that
require control and are maintained.
A controlled document is one that is
reviewed for relevance to your
activities on a regular schedule
(typically annually) to ensure that
the most current version is being
used "in the field."
EMS Manual - An EMS document
that describes your core system
elements and how the different
elements are interrelateda
"roadmap" for your EMS. Auditors
find a manual very useful when
verifying your EMS.
EMS Records - Reports, checklists,
training, and other data generated
that provides verification that your
organization is following the EMS as
intended.
System Procedure - An EMS
(ISO 14001) required document that
establishes purpose, scope, roles &
responsibilities, the tasks to be
completed, and where and how the
associated records and documents
are maintained.
Work Instruction - Documented
work tasks at your facility that
provide a detailed understanding of
how specific work process(es) are
accomplished. For example, an
instruction or checklist on the proper
disposal of recyclables (batteries, oils
and greases, rags, etc.) in your auto
maintenance shop.
Section 3: EMS Documents and Records (Phase 3)
Wastewater EMS Handbook
I09
-------
EMS Required System
Procedures
* Environmental Aspects
ป Legal and Other
Requirements
ป Communication
ป Document Control
ป Operational Control
(for Significant Aspects)
ป Emergency Response
ป Nonconformance and
Corrective and Preventative
Action
ป Records
Other Commonly
Produced EMS
Procedures
ป Objectives and Targets
ป Environmental Management
Programs
ป Management Review
Other Typical EMS
Documentation
* Maintenance Manuals
* Work Instructions
* Contractor Contact
Information
* Contracts
* Permits and Related
Guidance Material
Example EMS Records
* Training Records
* Delivery Logs/Bills
* Calibration Results
* Audit Reports and
Checklists
* A List of Your Significant
Aspects
* Management Review
* Meeting Notes
In addition to EMS system procedures, your organization will rely upon
other documentation specific to operations and services. This
documentation (e.g., work instructions, maintenance manuals, etc.) will
be referenced in your EMS system procedures and your EMS Manual
and is used to instruct employees on how to execute specific tasks.
Examples include a work instruction for calibrating a pH meter and a
manual for maintaining your air compressors.
EMS Records
EMS records are a direct result of your EMS procedures and activities
and demonstrate that your organization is doing what the EMS
documentation says you are doing.
Your EMS records should be traceable to and identified with an activity
or operation, maintained for review, and disposed of if no longer
applicable.
NOTE
/l^r 'n orcler to meet EMS requirements, maintain EMS
"" ** records including EMS Awareness Training, EMS Audit
(.Checklists, a Significant Aspect List, etc. However, do
& not forget about maintaining records related to your
environmental aspects. For example, an air permit or a
' calibration record, if in areas that can lead to significant
impacts, need to be tracked and maintained as EMS records and
available for your EMS auditors review.
Step 2) Review Current Document Control and
Records Procedures
Once you have taken a look at the EMS requirements for maintaining
your EMS documents and records, review what procedures/systems
you have in place to meet the requirements and those that will work
best for your wastewater facility.
ป Will a paper or electronic process, or maybe a combination of both,
work best?
ป Who has the responsibility and authority for creating and revising
documents?
ป Which documents should be controlled and how do you ensure that
employees refer to the correct versions?
ป Does your organization currently employ a standard document for-
mat and numbering system?
ป Does the current system meet EMS requirements?
Section 3: EMS Documents and Records (Phase 3)
Wastewater EMS Handbook
-------
Step 3) Integrate/Develop a System Procedure(s)
for EMS Documents and Records
When you're satisfied that your process for managing and controlling
your documents and records conforms to the EMS requirements,
integrate that process with your current systems or document both
processes in a system procedure.
Your team should develop an EMS system procedure for Document
Control that ensures documents are:
Easily located
Periodically reviewed
Readily available to personnel that need them
Removed immediately if obsolete and replaced
with current versions.
In addition, your procedure must clearly identify who is responsible for
preparing documents, making necessary changes, and ensuring that
documents are kept current. In other words, your organization needs a
clearly defined system that designates authority for review and approval
of documentation at various levels.
For samples of Document Control and Records procedure(s) from
wastewater facilities, see Appendix A.
Step 4) Check Your Documents and Records for
EMS Conformance
About two or three months after you have documented and
implemented your Document Control and Records Management
procedure(s) check and see if the procedure(s) is working according to
your plan. Here are some questions to investigate:
Document Control Check v'
1) Are the document control and record management procedures
being followed in practice?
2) How do you verify that current versions of documents/procedures
are being used?
3) Are your documents legible and dated?
4) Do you have a process to remove obsolete documents?
Policy
EMS Manual
Procedures
Work Instructions, Forms,
Drawings, etc.
Document Control and Records
Management system
procedure( s )
i s
required
f o r
this
element.
A
system
-------
Three Lessons Learned
(from wastewater facilities):
1.
Develop
a
document
management
system
early
i n
t h e
EMS
implementation
s o
that
EMS
documentation
will
b e
immediately
managed.
Use
your
existing
Records Management Check S
1) Have you identified what EMS records need to be maintained?
2) Have you determined the period of time necessary for retaining
your environmental records?
3) How are your records stored and retrieved (electronic vs. hard
copy)?
4) Are you maintaining all the records as required for your EMS?
5) Are records easily accessible?
The EMS Manual (ISO 14001, 4.4.4)
It is recommended that you maintain a summary of your EMS that:
ป Describes the basics of your system's 17 core elements (and how
the elements relate to each other), and
ป Provides where you can find related documentation.
An EMS Manual or "roadmap" summarizes how the pieces of your EMS
fit together and can be a very useful tool. Think of it as your EMS's
roadmap to all 17 EMS elements.
For a sample EMS Manual from a wastewater facility, see Appendix A.
-------
Document Control and Records Management
(Cut out this section for handy reference)
The Purpose of this EMS element is to:
o Write or modify your document control procedures to ensure documents are
managed and kept up to date.
o Write or modify your records management procedures to ensure that all records are
tracked and maintained.
The Results of this EMS element are:
o A document control procedure (EMS Document) for assuring that EMS procedures, work
instructions, manuals, and policies are available at locations where they apply; and that they
are periodically reviewed, are current, accurate, complete, and effective.
o A records management system (EMS Document) for assuring that all records required to
support your organization's EMS are identified, controlled and accessible.
Before you Begin this EMS element:
o Consider your organization's current document and records management control
procedures and tools.
-------
ISO 14001
Requirements
Document Control
The
organization
shall
establish
and
maintain
a
procedure
f o r
controlling
a I I
documents
required
b y
this
Internationa
Standard
t o
ensure
that
a )
They
can
b e
located;
b )
They
are
periodically
reviewed,
revised
a s
necessary
and
approved
f o r
adequacy
b y
authorized
personnel;
c )
The
current
versions
o f
relevant
Links to Other EMS
Elements
Demonstrate
document
control
o n
EMS
required
and
recommended
procedures,
work
instructions
manuals,
policies,
etc.)-
Required Documents
& Records
Document
Control
Procedure
Optional Documents
& Records
Master
List
o f
Documents
-------
ISO 14001
Requirements
Records
The
organization
shall
establish
and
maintain
procedures
f o r
t h e
identificati
o n ,
maintenance
and
disposition
o f
environmental
records.
These
records
shall
include
training
records
and
t h e
results
o f
audits
and
reviews.
Environmental
records
Links to Other EMS
Elements
A
number
o f
EMS
elements
will
generate
environmental
records
that
need
t o
b e
tracked
Required Documents
& Records
Records
Management
Procedure
Optional Documents
& Records
Master
Records
List
-------
QtycfGcEtonia
Beth Eckert, Environmental/Administrative Man
Revision #: 7
Revision Date: 5/12/03
-------
Section 3: Operational Control
An EMS is about "managing" or controlling your facility's
environmental impacts and, in particular, operations and services
from which your identified significant environmental impacts,
objectives and targets, and regulatory requirements are derived. What
is operational control and how do you document it? You probably
already have procedures, work instructions, permits, maintenance
manuals, and similar in place for many of your operations and services.
In other words, documents, processes, and programs are in place for
how you do a particular job or operation, who is responsible, etc. This
shows control and management of an operation or service.
The following steps will allow your organization to determine which
operations or services should be covered by documented procedures
and work instructions and how those operations should be controlled.
Step-by-Step Guide to
Establishing Operational
Control
Step 1) Identify Significant Environmental
Operations
Step 2) Review and Draft Operational Controls
Step 3) Review Maintenance and Calibration
Requirements
Step 4) Check Operational Controls for
EMS Conformance
Step 5) Communicate Operational Controls
Step 1) Identify Significant Environmental
Operations
Determining which operations should be covered by documented
operational controls and how those operations should be controlled is
an important step in developing your EMS. Review the operations and
services that are related to your significant aspects and objectives and
targets that you identified earlier. Now review your regulatory
requirements in these areas.
Is it clear to your employees how you want these activities to be
conducted and controlled? In other words, do these activities have
manuals, procedures, work instructions, and similar documents and
instructions to manage how their day-to-day tasks are accomplished?
Keep in mind that you might need documented operational controls in
order to manage significant aspects and legal requirements, regardless
of whether you established objectives and targets for each of them.
Key Section Terms
Operational Controls - Documents
that specify the way to execute a
certain activity or operation.
Operational controls are assigned to
operations and services involving
significant aspects and are
documented through the use of work
instructions, procedures, manuals,
programs, etc. Examples include
maintenance work, pretreatment
operations, chemical ordering, etc.
System Procedure - An EMS -
(ISO 14001) required document that
establishes purpose, scope, roles &
responsibilities, the tasks to be
completed, and where and how the
associated records and documents
are maintained.
Work Instruction - A series of
steps and activities directed to a very
specific area or process. Examples
include cleaning the rake at
wastewater pretreatment operations
and calibrating a pH meter.
Three Lessons Learned
(from wastewater facilities):
1. The most effective operational
controls are short and to the
point. Several examples from
wastewater facilities are included
in the appendices of this Handbook.
2. In determining which operations
and activities need to be controlled,
look beyond operations and services.
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.
3. Use photos and diagrams where
applicable for your operational
controls. For example, a diagram
showing the direction and how far to
turn a valve is much clearer than text.
Section 3: Operational Control (Phase 3)
Wastewater EMS Handbook
II7
-------
Three Things to Avoid
(from wastewater facilities):
1. Not including suppliers and
contractors that provide operations,
goods, and services that have a direct
impact on your facility's significant
aspects and objectives and targets.
Cross-reference your significant
environmental aspect list and your
objectives and targets with the
associated supplier and contractor
operations to ensure operational
control.
2. Starting from scratch when
developing your operational controls.
Most wastewater organizations had
about 80% of the necessary
documentation in place when they
began their EMS implementation.
3. Overlooking the maintenance and
calibration of equipment for significant
environmental aspect areas and
objectives and targets. Maintenance
manuals and calibration records also
demonstrate control.
Involving Contractors
and Temporary Staff
If your contractors and temporary
staff are in areas or provide
services that affect your significant
environmental impacts, objectives
and targets, or legal and other
requirements, make sure that they
have procedures, work instructions,
and/or maintenance manuals, etc.
that cover and show control of
those operations and services. For
example, if you use an off-site
contractor to maintain a piece of
equipment that is within one of your
identified significant areas, make
sure they have a documented work
instruction that they follow to
maintain the equipment.
Step 2) Review and Draft Operational Controls
Once you have a list of operations and services that require documented
operational controls, take a look at what you already have in place to
manage these activities. Do your current procedures reflect what is
actually being done at your wastewater facility? How do you control the
operations now and are the controls adequate? Can the employees,
whose work the procedures describe, easily understand them?
If you have documented operational control procedures already in place
for your significant activitiesgreat! Reference and document them in
your EMS Manual (see EMS Documents and Records later in this
section). If not, you will need to add language to current procedures
and/or draft new procedures to ensure adequate control of your
significant environmental operations, legal requirements and your
objectives and targets.
For an example of an Operational Control Procedure, see Appendix A.
Step 3) Review Maintenance and Calibration
Requirements
Maintenance and calibration of equipment in areas that could have
significant environmental impact must be considered for your
wastewater EMS. Once you have identified operations that require
control and have documented your procedures and work instructions for
these, determine the maintenance and calibration requirements for
these operations and services and document and maintain these
records. Don't ignore the maintenance manuals that come with your
equipment.
Some organizations place critical monitoring equipment under a special
calibration and preventive maintenance program. This can help to
ensure accurate monitoring and make your employees aware of which
instruments are most critical for environmental monitoring purposes.
/ iter ou have identified your significant environmental
p( ;, there are two separate paths to follow (a fork in the
road). The first is setting your objectives and targets and then
developing environmental management programs to achieve
your targets. The second path is to ensure that you have or
develop operational controls to deal with any other significant
aspects you have identified that may not be covered iinder
your current objectives and targets and the associatec
programs to meet them.
7
Donna Adams
Eugene, Oregon
Wastewater Division
IIS
Section 3: Operational Control (Phase 3)
Wastewater EMS Handbook
-------
REMEMBER
You probably already have some of the procedures, work
instructions, maintenance manuals, etc. that demonstrate
control of your identified significant environmental operations
and services. Now it's simply a matter of documenting what
you have in place OR establishing and writing new
procedures and work instructions in your significant areas
that need them.
Step 4) Check Operational Controls for EMS
Conformance
About two or three months after you have documented and
implemented your Operational Controls procedures, check if they are
working according to your plan. Here are some questions to investigate:
Check S
1. Have you identified all operations and activities associated with
significant environmental aspects, legal requirements and
environmental objectives & targets?
2. Are these operations and activities under control through
programs, documented procedures, work instructions, etc.?
3. Have you communicated and trained your employees, suppliers,
vendors, and contractors on applicable procedures, work
instructions, and policies?
Step 5) Communicate Operational Controls
Review your documented procedures and work instructions (controls)
with all applicable employees. Communicating your procedures with the
people who will need to implement them will help secure their input.
Also remember to communicate operational controls with applicable
vendors, contractors, suppliers and temporary staff.
NOTE
1 Operational control is demonstrated and can be
^ communicated through other EMS elements, including
training, communication, document control, records
management, and emergency preparedness and response.
Use your current procedures, work instructions, and manuals relevant
to these elements as ways to demonstrate control.
establish control for all your identified significant
ye :. Then, establish controls for all your aspects and
activities. This will bring consistency and accountability tc
those on your frontline who are ensuring environmental
stewardship.
Rick Bickerstaff
Charleston, South Carolina
Commissioners of Public Works
Three Keys to Success
(from wastewater facilities):
1. Check in with all of your
shifts and satellite offices for
improvement suggestions, to test
your procedures and to get
involvement and buy-in to the
EMS. If changes are made to
procedures, make sure affected
personnel are communicated
with and trained accordingly.
2. Keep the language in your
procedures and work instructions
clear and simple. A good check is
to ask someone unfamiliar with
the activity if he/she could
complete the work using the
instructions provided.
3. Start by looking at the significant
environmental aspects and legal
requirements that you identified in
Phase 1. Identify the operations
and services that are related and
then consider what types of
controls are needed to manage
these environmental aspects and
1 compliance requirements.
Examples of
Operations and
Services that may
Require Operational
Controls:
Management/disposal of wastes
Approval of new chemicals
Storage & handling of raw
materials and chemicals
Equipment maintenance &
servicing
Wastewater pretreatment
Management of contractors
Section 3: Operational Control (Phase 3)
Wastewater EMS Handbook
119
-------
.V
r
I Operational Control
I (Cut out this section for handy reference)
The Purpose of this EMS element is to:
o Define and implement a procedure for controlling (procedures, work instructions, manuals,
etc.) the significant operations and services, objectives and targets, and compliance requirements
of your organization.
The Results of this EMS element are:
o Documented methods to control (e.g., procedures, work instructions, maintenance manuals, etc.)
operations and services that affect your facility's significant environmental aspects, objectives
and targets, and compliance requirements.
Before you Begin this EMS element:
o Complete your significant environmental aspects analysis.
j
_0
b
120 Section 3: Operational Control (Phase 3)
Wastewater EMS Handbook
-------
ISO 14001
Requirements
Links to Other EMS
Elements
Required Documents
& Records
Optional Documents
& Records
Operational Control
The organization shall
identify those operations
and activities that are
associated with the
identified significant
environmental aspects in
line with its policy,
objectives and targets.
The organization shall
plan these activities,
including maintenance, in
order to ensure that they
are carried out under
specified conditions by:
a) Establishing and
maintaining documented
procedures to cover
situations where their
absence could lead to
deviations from the
environmental policy and
the objectives and targets;
b) Stipulating operating
criteria in the procedure;
c) Establishing and
maintaining procedures
related to the identifiable
significant environmental
aspects of goods and
services used by the
organization and
communicating relevant
procedures and
requirements to suppliers
and contractors.
Policy - To satisfy the com-
mitments made in your
environmental policy,
operations and activities
must be controlled.
Environmental Aspects -
Identified significant envi-
ronmental aspects must
have documented
procedures (i.e., controls)
in place.
Legal and Other
Requirements - Regulated
operations must have docu-
mented procedures (i.e.,
controls) in place.
Objectives and Targets -
The environmental goals
set by your organization
must have documented pro-
cedures (i.e., controls) in
place.
Training - Training is
required for employees,
vendors, service providers,
and contractors that could
significantly affect the envi-
ronment.
Monitoring and
Measurement - Equipment
in potentially significant
areas must be properly
maintained and calibrated.
Documented operational
controls (e.g., procedures,
work instructions, manuals,
etc.) for significant aspects
and areas and for your
objectives and targets.
A list of operations and
services related to your
significant environmental
aspects, objectives and
targets, and compliance
programs.
Section 3: Operational Control (Phase 3)
Wastewater EMS Handbook
I2I
-------
Section 3: Emergency Preparedness
and Response
Even in the best-managed facilities, accidents and emergency
situations can and do occur. Today's post 9/11 threats and
realities require that facilities remain vigilant and prepare for an
entirely new variety of changing pressures and risks. Under the Public
Health Security and Bioterrorism Preparedness and Response Act of
2002, many local utilities are now required by the U.S. Environmental
Protection Agency to conduct vulnerability assessments and to certify
that updated emergency response plans exist. The EMS process offers
enormous potential for water providers to proactively identify and
successfully manage environmental as well as security risks and
vulnerabilities.
The intent of the EMS Emergency Preparedness and Response
element is to ensure that effective plans for preparing for and
responding to emergencies are available, easily accessible, and clearly
understood by everyone that might need them.
Emergency response is fundamentally integrated into everyday
operations, activities, and services, guiding an organization to
continuously improve the management of their risks and threats over a
short and long-term basis. The ultimate goal is to protect employees
and the community, to prevent and minimize environmental impacts,
and to reduce operational damage. Those wastewater and drinking
water utilities who have conducted vulnerability assessments will find
that this point in the EMS process is also a great place to incorporate
plans for ensuring the security of their facilities.
Step-by-Step Guide to
Emergency Preparedness and
Response
Step 1) Identify Existing Emergency Plans and/or
Procedures
Step 2) Identify Potential Accident and Emergency "
Scenarios
Step 3) Define How Your Organization Can Prevent
Emergency Incidents and Mitigate Impacts
Step 4) Develop EMS System Procedures/Plans for Emergency
Preparedness and Response
Step 5) Check Your Procedures/Plans to Ensure Conformance to
EMS Requirements
Key Section Terms
Emergency Situation - Condition
(e.g., spills, releases, fires, etc.) that
can have an environmental impact
and that requires an emergency
response or action.
Emergency Response - Actions
taken to address an environmental
incident.
Emergency Response Plan - A
detailed plan that describes the
logistics, procedures, who to contact,
roles and responsibilities, reporting
requirements, etc. in the event of an
emergency or spill.
The Public Health Security and
Bioterrorism Preparedness and
Response Act of 2002 - Federal
requirements for public water and
wastewater utilities to conduct a
vulnerability assessment and to certify
to the U.S. EPA that emergency
response plans have incorporated the
assessment information and have
been fully integrated into their
operations.
Vulnerability Assessment - A tool
to assist water utilities in
systematically evaluating their
susceptibility to potential threats and
identifying corrective actions that can
reduce or mitigate the risk of serious
consequences from adversarial
actions (e.g., vandalism, insider
sabotage, terrorist attack, etc.). For
more information please see the
Vulnerability Assessment Fact Sheet.
Section 3: Emergency Preparedness & Response (Phase 3)
Wastewater EMS Handbook
123
-------
Common Emergency
Contacts
Police
Local Emergency Responders
Fire Department
Medical Services
Internal Emergency
Coordinator(s)
Three Keys to
Success
(from wastewater facilities):
1. Evaluate the effectiveness of
your emergency response
plans on a regular (at least
annually) basis by conducting
drills and exercises. Ensure
that all emergency response
actions are reviewed and
documented.
2. Make emergency response
plans available, easily
accessible, and clearly
understood by everyone who
might need them. Effective
training and well
communicated plans will help
prevent and minimize potential
environmental impact that
could occur as a result of the
accident or emergency.
3. Evaluate the effectiveness of
your emergency response
procedures/plans and
vulnerability assessments on a
regular basis (at least
annually). Consider using your
wastewater staff in your
emergency and security drills
as part of their training
program.
NOTE
Emergency preparedness and response is a heavily
regulated area for wastewater facilities. The importance of
^ this EMS element should be communicated and trained
to all employees and contractors.
In order to fulfill EMS requirements, you need to establish and
implement procedures that describe how your organization:
1. Identifies potential for and responds to accidents and emergency
situations;
2. Prevents and mitigates the environmental impacts that may be
associated with them;
3. Reviews and revises, where necessary, emergency preparedness
and response procedures after the occurrence of accidents and
emergency situations; and,
4. Periodically tests such procedures where practicable.
Step 1) Identify Existing Emergency Plans
and/or Procedures
Most organizations will find that they already have a number of
emergency response plans in place. For example, most wastewater
facilities must have Spill Prevention, Control, and Countermeasure
(SPCC) plans in place. Sticking with the Keep It Simple, Simple (KISS)
rule, review what you already have in place first and evaluate how they
address the EMS requirements. Your emergency and response
procedures/plans ensure that potential accidents and emergency
situations are identified, avoided, and mitigated if they do occur. By all
means, if you have plans in place that work, keep them and build from
them to develop a comprehensive approach.
In reviewing your existing emergency plans, consider:
S Are the plans current?
S Have contact information or telephone numbers changed?
S When was the last time we tested them?
S Is training adequate and up-to-date?
S Are new and temporary employees being trained?
S Are there gaps between what is in place and what the EMS
requires?
NOTE
Review previous spills and other emergencies and
k your responses as a guide to where future accidents
' or incidents could occur and be prevented. Take the
lessons learned from previous emergencies to review
if your plans are effective.
124
Section 3: Emergency Preparedness & Response (Phase 3)
Wastewater EMS Handbook
-------
Step 2) Identify Potential Accident and
Emergency Scenarios
When you have reviewed your existing emergency preparedness and
response plans, take a moment to brainstorm potential emergency
situations that could arise from your organization's everyday activities
and operations. You may also want to consider the potential risks from
accidents and/or hostile acts. Your EMS can help ensure that your
employees are adequately prepared for potential scenarios, including
security risks.
NOTE
. FIRST RESPONDERS
> More often than not, frontline (i.e., shop floor) employees
^will be the first responders to an incident and must
know what procedures to take to manage potential
emergency scenarios effectively.
Remember, your organization's response plans may overlap (i.e., who
to call, who to report to, etc.) for a number of emergency situations. It's
good to ensure that personnel know exactly what to do in each different
situation. In addition, if you have already conducted a vulnerability
assessment to identify your security risks, you may want to include this
information in your emergency plans as well.
COACH'S CORNER
/-\
Communicate with local officials (fire department,
hospital, etc.) about potential emergencies at your
vyx wastewater facility and how they can support your
\JjEresponse efforts. Involving local responders in mock drills
is an excellent way to reinforce training, keep them
informed of any changes to operations, and get feedback
on the effectiveness of your plans/procedures.
Three Things to Avoid
(from wastewater facilities):
1. Not inviting local emergency
response agencies into your facility
for emergency reviews and drills.
Local responders need to know the
layout and any changes to operations
of your facility. In addition, response
agencies can assist you in developing
and updating your response plans.
2. Thinking only about response -
focus on how to prevent accidents
and emergencies in the first place.
3. Starting your emergency
preparedness and response
procedures/plans from scratch. Build
on what you currently have in place
for responding to emergencies and
accidents.
Ir ;ide t reviews give an
< at ition the opportunity to step
oack and evaluate what went right
and what went wrong after an
emergency situation. These re
facilitate positive change and
continual improvement.
3 reviews
'*
Rick Bickerstaff
Charleston, South Carolina
Commissioners of Public Works
Section 3: Emergency Preparedness & Response (Phase 3)
Wastewater EMS Handbook
125
-------
- EMS Manual
Procedures
Work Instructions, Forms,
Drawings, etc.
Emergency Preparedness and
Response Procedures/Plans are
required for this element. A system
procedure defines the purpose (why
the procedure is needed), scope (to
what operations/areas/staff the
procedure applies), roles &
responsibilities (who needs to
complete the tasks), and the tasks
that need to be completed for this
element.
F JU5- jn both internal and external
i ~pc "e criteria. Team build with
iuoa/ and state emergency response
agencies. Coordinate exercises
involving both employees and
external agencies together. This
tests the response of both parties
and promotes team work. In
addition, conduct bi-annual drills (or
more frequent) to test your system.
James Naber
Buncombe County, North Carolina
Metropolitan Sewer District
Step 3) Define How Your Organization Can
Prevent Emergency Incidents and Mitigate
Impacts
As your facility puts this EMS element in place, focus on emergency
response and do not overlook and forget that accident prevention is
equally important. Spend time looking at ways to prevent environmental
accidents in the first place. However, emergencies still happen in the
best planned and managed operations. Therefore, ask:
How can we mitigate the potential impacts of these situations?
Are there adequate controls in place now?
Step 4) Develop EMS System Procedures/Plans
for Emergency Preparedness and Response
Being prepared for emergencies means that you have identified all
potential emergency situations that could arise, and have developed,
put in place, and tested emergency response procedures.
Effective emergency preparedness and response plans are a core
element of an EMS. They should be readily available, easily accessible,
and clearly understood by everyone who might need them. From a
practical perspective, your plans should include up-to-date emergency
contact information, including current contact names (POCs) and
current phone numbers. Make this information available throughout
your facility, especially in areas where there is potential for accidents
and emergencies.
Your emergency response procedures/plans should include actions that
will minimize any environmental impact that could occur as a result of
an accident, emergency or threat (e.g., in the case of security plans,
this might include alternative water supply secured, public notice
created and ready for immediate distribution, etc.).
COACH'S CORNER
A systems approach can successfully integrate
^*Li environmental and security considerations into everyday
business operations. Roles and responsibilities are
^defined based upon activities related to your priority risks
rTand vulnerabilities, empowering employees to analyze,
control, and mitigate impacts related to their daily work.
These designations can also be utilized to control and
monitor access to critical areas and processes within a
facility that relate to operations identified in vulnerability
assessments. In essence, employees throughout an organization
take on a real sense of ownership for emergency response in their
daily responsibilities and within the organization as a whole.
126
Section 3: Emergency Preparedness & Response (Phase 3)
Wastewater EMS Handbook
-------
Your EMS leadership team will periodically review your emergency
response plans and verify that they are realistic operationally,
environmentally, technologically, and financially, and in the case of
security response plans, that they meet any regulatory requirements
imposed under the Public Health Security and Bioterrorism
Preparedness and Response Act of 2002.
For samples of emergency preparedness and response procedures
from wastewater facilities, see Appendix A.
NOTE
FIRST RESPONDERS
Each organization should test their emergency
response plans regularly in order to verify their
effectiveness, to apply lessons learned, and to apply
any new technological enhancements.
Step 5) Check Your Emergency Procedures/Plans
to Ensure Conformance to EMS Requirements
Check
-------
Water Security Legislation
EPA's Water Protection Task Force
(WPTF) and Regional Offices, work-
ing with many partners, are taking
actions to improve the security of the
nation's drinking water and waste-
water infrastructure in line with EPA's
Strategic Plan for Homeland Security.
Federal Legislation impacting water
security includes the Public Health
Security and Bioterrorism
Preparedness and Response Act of
2002 (Title IV), which amends the
Safe Drinking Water Act and specifies
required actions of community drink-
ing water systems and the responsi-
bilities of the U.S. EPA must take to
improve the security of the nation's
drinking water
infrastructure.
For additional information, visit
www.epa.gov/safewater/security.
U.S. EPA Water Emergency Response/Security Resources and
Guidance Documents
Vulnerability Assessment Fact Sheet, produced by the U.S. EPA Office
of Water in November 2002. Describes the purpose and six basic ele-
ments of vulnerability assessments to help water systems evaluate
potential threats and identify corrective actions to prepare for and
respond to an attack.
Instructions to Assist Community Water Systems in Complying with the
Public Health Security and Bioterrorism Preparedness and Response
Act, Produced by the U.S. EPA Office of Water in January 2003.
Protecting Your Community's Assets: A Guide for Small Wastewater
Systems, Produced by the National Environmental Training Center for
Small Communities.
Security Vulnerability Self-Assessment Guide for Small Drinking Water
Systems Serving Populations of 3,300 and 10,000, The guide was
developed by the Association of State Drinking Water Administrators
(ASDWA) and the National Rural Water Association (NRWA) in May
2002.
Model Emergency Response Guidelines, Produced by the U.S. EPA
Office of Water in April 2002.
Water Information Sharing and Analysis Center (Water ISAC),
Information service to provide water systems with a secure web-based
environment for early warning of potential threats and a source of
knowledge about water system security.
Section 3: Emergency Preparedness & Response (Phase 3)
Wastewater EMS Handbook
-------
Checklist for Emergency Preparedness & Response
Does your plan describe the following?
X
X
X
X
X
X
X
X
X
X
Potential emergency situations (such as fires, explosions, spills or releases of hazardous materials, and
natural disasters)?
Hazardous materials used on-site (and their locations)?
Key organizational responsibilities (including emergency coordinator)?
Arrangements with local emergency support providers?
Emergency response procedures, including emergency communication procedures?
Locations and types of emergency response equipment?
Maintenance of emergency response equipment?
Training/testing of personnel, including the on-site emergency response team (if applicable)?
Testing of alarm/public address systems?
Evacuation routes and exits (map), and assembly points?
Section 3: Emergency Preparedness & Response (Phase 3)
Wastewater EMS Handbook
129
-------
CASE STUDY
Security Management
Recently, a wastewater facility identified a large chemical storage area as a high priority (significant)
environmental issue that it wanted to manage as part of its EMS. Using a parallel approach, the facility
integrated its security issues into the Plan-Do-Check-Act system and identified the chemical storage
tank as a high priority security risk as well. The facility's objective was to determine how to manage this
environmental and security issue in an efficient and cost-effective way. Drawing on the experiences of
employees up, down, and across the organization, and on best practices information and product
substitutions gathered from a variety of state, trade association and federal web sources, the
wastewater facility determined that product substitution could be a technologically realistic,
operationally feasible, and cost-effective solution. Until the new product was fully implemented, trainers
updated existing training with "need to know" environmental and security competency training for
employees who worked with the chemical tanks and provided awareness training for others about the
risks involved. This example shows how the plan-do-check-act process can work effectively for both
environment and security (vulnerability) outcomes.
Case Study Example : Anytown, USA Water Plant
LEGEND
I. Chlorine Storage Shed
2. Anhydrous Ammonia
Storage Tank
3. Hydrofluosilicic
Acid Tank
. Calcium Oxide Silo
6. Diesel Fuel
(aux. generator)
130
Section 3: Emergency Preparedness & Response (Phase 3)
Wastewater EMS Handbook
-------
Emergency Preparedness and Response
(Cut out this section for handy reference)
The Purpose of this EMS element is to:
o Establish or modify emergency preparedness and response procedures/plans that address
the potential for and response to accidents and emergency situations.
The Result of this EMS element is:
o Verification that your organization's emergency preparedness and response procedure(s)/plan(s)
(EMS Document) are effective in relation to the significant environmental aspects and objectives
and targets of your organization.
Before you Begin this EMS element:
o Complete your significant environmental aspects analysis.
i
Section 3: Emergency Preparedness & Response (Phase 3) 131
Wastewater EMS Handbook
-------
ISO 1400
Requirements
Links to Other EMS
Elements
Required Documents
& Records
Optional Documents
& Records
Emergency Preparedness
and Response
The organization shall
establish and maintain
procedures to identify
potential for and respond
to accidents and
emergency situations, and
for preventing and
mitigating the
environmental impacts that
may be associated with
them.
The organization shall
review and revise, where
necessary, its emergency
preparedness and
response procedures, in
particular, after the
occurrence of accidents or
emergency situations.
The organization shall also
periodically test such
procedures where
practicable.
Environmental Aspects -
Environmental aspects are
reviewed for potential emer-
gency situations.
Legal and Other
Requirements - Spills,
fires, and other emergency
events that are likely to
have legal (e.g., reporting)
requirements.
Training & Awareness -
Employees that respond to
emergencies are trained
and certified.
Communication - All
employees understand what
they need to do in case of
an emergency.
Document Control -
Emergency response proce-
dures/plans are controlled
so that the most recent ver-
sion(s) are being utilized.
Emergency
Procedures/Plans
Records of Emergency
Incidents, Training, and
Drills
None
132
Section 3: Emergency Preparedness & Response (Phase 3)
Wastewater EMS Handbook
-------
Phase IV: Checking & Corrective Action
You are now ready to begin the
Checking and Corrective Action
Phase of the EMS cycle. Each sec-
tion of this Handbook will guide you step-
by-step through each of the EMS activi-
ties. Refer to the icons for case studies,
sample documents, keys to successes
and other implementation
assistance. At the end of
each section, two
handy reference
sheets review the
Purpose of each
requirement,
describe the
Results you'll be
developing, dis-
cuss how to
Prepare to do the
work, and show how
the element links to other
EMS requirements.
In this phase, you will define and docu-
ment methods that your organization will
use to verify that your EMS is effective
and functioning as you intended. The
check, an EMS audit or review, is a tool
that you will periodically use to identify
any flaws or weaknesses in your EMS.
This information can help you assess how
well your EMS is performing and help
your organization continually improve. As
part of the audit process, your
organization will take correc-
tive actions on any EMS
"findings" to make sure
that nonconformances
are examined for its
root causes, correct-
ed, and prevented
from re-occurring. If
you are using a two-
year cycle, the activi-
ties in this phase can
be comfortably accom-
plished in about
five months.
Here's a checklist of requirements in this
Phase:
Phase IV EMS Requirements (5 months)
Monitoring and Measuring
EMS Internal Auditing
Nonconformance & Corrective/Preventative Action
^
^
^
-------
Section 3: Monitoring & Measurement
(Assessing how well your system is performing)
So far, you've identified your significant environmental aspects, set
objectives and targets, and conducted a review of your operations
and services to identify applicable regulatory and other
requirements. You have also put procedures and work instructions
(operational controls) in place to ensure that your environmental issues
(i.e., significant aspects) are managed. The next step is to monitor and
measure your progress in meeting your objectives and targets, and
assess your compliance toward meeting your regulatory requirements.
Monitoring and measuring allows you to track your environmental
performance and improve efficiency by managing what you do.
Remember, you can't manage what you can't measure! The results of
your objectives and targets and other environmental efforts are easier to
demonstrate when current and reliable data are available and
referenced against a defined baseline. These data can help you
demonstrate the value of the EMS to top management, as well as to
other interested parties such as your local community.
In this section you will develop ways to:
Identify key characteristics of operations and activities that can
have significant impact
Track performance (including progress in achieving your objectives
and targets)
Monitor conformance with operational controls
Calibrate and maintain monitoring equipment
Periodically evaluate your compliance with applicable laws and
regulations
Step-by-Step Guide for
Monitoring and Measuring
Your Key Environmental
Activities
Step 1) Determine What You Currently Monitor
and Measure
Step 2) Identify What You Need to Monitor and
Measure to Determine How Your EMS is
Performing
Step 3) Assess Compliance and Track Your
Environmental Performance
Step 4) Develop an EMS System Procedure for
Monitoring and Measurement
Step 5) Check Your Monitoring and Measurement Procedure for
EMS Conformance
Step 6) Communicate Progress and Performance
Key Section Terms
Baseline - The starting point from
which the meeting of an objective is
to be measured. Establish
"normalized" baselines to accurately
measure how your facility's
environmental performance could
change over time. Normalized
baselines will measure your actual
environmental performance changes
rather than changes in production,
customer demand, or other non-
environmental related factors.
Environmental Aspect - Element of
an organization's activities, products
or services that can interact with the
environment. Aspects = Causes
Environmental Management
Program (EMP) - A structured
program with a set of specific
identifiable actions (an "action plan")
providing the direction for EMS
objectives and targets to be obtained
and tracked. Your plan should assign
tasks, resources, responsibilities, and
timeframes for achieving your
objectives and targets.
Environmental Objective -An
overall environmental goal based on
an established environmental policy,
that an organization sets itself to
achieve. Wherever possible,
environmental objectives should be
quantified to facilitate the evaluation
of environmental performance and the
measurement of progress towards
specific environmental targets.
Environmental Target - A detailed
performance requirement, quantified
where practicable, that arises from
the environmental objectives and that
needs to be set and met in order for
the objective to be achieved.
Section 3: Monitoring and Measurement (Phase 4)
Wastewater EMS Handbook
135
-------
Key Section Terms,
continued
Key Characteristic - An element
of an operation or activity that can
be measured or evaluated for
environmental performance
of objectives and targets.
Performance Indicators -
Measurement tools, selected by
management that can be used
to support the evaluation of
environmental performance in
relation to a specific target.
Performance indicators may be
adjusted to meet specific
management needs or as
necessary to ensure progress
towards specific environmental
targets.
Three Keys to Success
(from wastewater facilities):
1. Evaluate the information that
you collect for value. If you are
going to spend the time and
resources to collect it, make sure
that it is useful.
2. Include top management and
other decision makers in setting
up what you will monitor and
measure. Checking in with them
will help you identify what you
need to measure to provide
meaningful results and maximize
the benefits you'll receive from
your EMS.
3. Remember your external
stakeholders (i.e., city
commissioners, citizen groups,
etc.) as you determine what to
monitor and measure.
Step 1) Determine What You Currently
Monitor and Measure
Examine your wastewater operations and services and determine what
you are currently monitoring and measuring. Your environmental
regulations are a good place to start, since these requirements typically
include monitoring, measuring, (permit limits, etc.) and reporting
components (Toxic Release Inventory (TRI), etc.). How well do these
measurements serve your EMS purposes? What additional monitoring
or measuring might be needed as your organization continues to move
beyond compliance?
Step 2) Identify What You Need to Monitor and
Measure to Determine How Your EMS is
Performing
Your organization will track data and information, collected through your
EMS on a continuing basis, to determine whether and how your
wastewater facility is achieving its environmental objectives and targets
and to properly manage your significant aspects. Information collected
by monitoring and measuring your key environmental issues can help
make this determination and answer the questions: Is your EMS being
carried out as planned? Is your organization achieving its commitments
and its objectives and targets? What information is most valuable?
To determine what you need to monitor and measure, identify
wastewater operations and services that affect your environmental
performance. What are the key characteristics of the operations,
services and related equipment and how do you measure these
characteristics to ensure proper performance?
jKni' /ring and measurement takes the pulse of an
;a ation. Their application can be the most important
tools in a manager's toolbox with regard to setting goals,
objectives and targets, and improving overall operations.
Rick Bickerstaff
Charleston, South Carolina
Commissioners of Public Works
REMEMBER
u Start by looking at what's regulated and then look at
the significant aspects and objectives and targets that
you identified earlier.
I36
Section 3: Monitoring and Measurement (Phase 4)
Wastewater EMS Handbook
-------
Let's review the sanitary sewer overflow (SSO) significant aspect
example again and make a sample list of the operational controls, key
characteristics, monitoring and measurement methods, and calibration
needs for operating and maintaining wastewater pump stations.
Operation with
Significant
Environmental
Aspect
Operate and
Maintain Pump
Stations
Significant
Aspect
Sewer
System
Overflows
(SSOs)
Operational
Controls
*Pump
Maintenance
Manual(s);
ปWork
Instructions on
Cleaning
Sewer
Mainlines;
* Emergency
Generator
Operations and
Maintenance
Key
Characteristics
of Operation
or Activity
*# of Alarms
* Flow per
Capita
ป#of
Overflows
ป#of
Cleanings per
Month
Monitoring or
Measurement
Methods
* Measure
Quantities;
* Monitor Lift
Stations;
* Census
Data;
* Monthly
Operating
Reports
Equipment
& System
Calibration
Needs
ป Flow
Meters;
ป SCADA
NOTE
^
Environmental measurement can be a combination of
process and outcome measures. In other words, you
may want to consider measurements that assess
"how" you are doing something as well as
measurements for "what" is produced.
Outcome measures look at results of a process or activity, such
as the amount of waste generated or the number of spills.
Process measures look at "upstream" factors, such as
the number of employees trained on a topic.
Consider selecting a combination of process and outcome measures
that are appropriate to your wastewater facility. For example, using the
SSO significant aspect example above, an outcome measure would be
the number of overflows per year and a process measure could be the
number of cleaning or maintenance activities completed per month to
prevent line blockage and that would consequently reduce the chance
for an overflow event.
Step 3) Assess Compliance and Track Your
Environmental Performance
An EMS requires you to periodically evaluate your compliance with
applicable laws and regulations. In practice, most organizations go
through some form of compliance audit and this can be done either by
internal staff or by an outside organization. While the compliance audit
is generally a way to determine if you are actually in compliance, you
should also use it as a way of determining if your organization is well
A Word on Calibration
As part of meeting meeting your
monitoring and measurement
requirements, you will need to
document calibration requirements
and dates for equipment used in
areas where you identified
significant aspects, where you set
objectives and targets, and in areas
where you have compliance
requirements. Example calibrated
equipment could include gauges
used to monitor stack air emissions
or a pH meter used to measure
effluent water quality. Make sure a
regular schedule is in place to
calibrate the equipment and make
sure you retain your calibration
records. Remember, some
equipment may be calibrated off-
site, so make sure the vendor
supplies you with a copy of the
records.
.! REMEMBER
maintenance manuals
that come with your
equipment. They may
contain calibration and/or
measurement methods for your
equipment. In addition, your
equipment may have calibration
procedures set by the
manufacturer that must be
followed.
Section 3: Monitoring and Measurement (Phase 4)
Wastewater EMS Handbook
137
-------
Three Lessons Learned
(from wastewater facilities):
1. Start with a relatively simple
monitoring and measurement
process, looking at your legal
requirements and significant aspects.
It is OK to start small and build over
time as you gain experience in
evaluating your performance.
2. Select performance indicators that
will provide the information you need
to make effective decisions about
your EMS.
3. Don't forget about on- and off-site
contractors that calibrate and/or
maintain equipment that is within your
identified significant operations and
services.
Three Things to Avoid
(from wastewater facilities):
1. Going out of your way to monitor
and measure everything. Start with
what is required by law and then
examine your objectives and targets.
Don't collect data for data's sake!
2. Not committing the necessary
resources (human and dollars) to
track performance information over
time.
3. Not communicating the
performance and progress of your
objectives and targets to
management and staff.
suited to address instances of noncompliance should they occur. In
other words, are you able to effectively manage compliance as well as
audit for it? When determining if you are effectively managing
compliance, you should use this opportunity to make sure that proper
procedures are in place to respond to instances of noncompliance,
determine the root causes of noncompliance, and make any changes to
your system to help ensure that the noncompliance does not recur.
Effective compliance management is an essential part of an EMS.
Once you know what to measure and what indicators that you will use,
assess and track your objectives and targets so you know how well they
are performing. Remember to have regular checks on the progress of
your objectives and targets and report the results to top management.
Remember to also assess and track your significant aspects. Keeping
track of your significant aspects will let you know how well they are
managed (being controlled) and also provide you with a baseline for
potential future objectives and targets.
For example, have operational controls (procedures, work instructions,
etc.) been documented for each of your significant aspects? Have
employees been trained on any changes to emergency preparedness
and response plans? Are your training records up to date and
documented? Do employees whose work involves significant aspects
understand their roles and responsibilities?
NOTE
What about issues that are not so easy to quantify? For
example, better odor management in wastewater
treatment plants, improved public image, and improved
v relationship with stakeholders? It takes some rather
l\ creative "indicators" to quantify these
improvements. Talk to your peers in the wastewater
industry to see how they measured these types of
issues.
I38
Section 3: Monitoring and Measurement (Phase 4)
Wastewater EMS Handbook
-------
The top five performance indicators that the wastewater facilities that
contributed to this Handbook used to monitor and measure their EMS
performance are included below:
Wastewater Facility
Buncombe County,
North Carolina
Charleston, South
Carolina
Eugene, Oregon
Gastonia, North
Carolina
San Diego, California
Performance Indicator
Quarterly internal audits
Environmental compliance audits
Quarterly management review meetings
Monthly steering committee meetings
Monthly ISO Team meetings.
Random inspections to ensure conformance to standard operating
procedures.
Monthly reporting of objectives & targets associated with continual
improvement.
Regulatory monitoring is performed through established monitoring
systems. Items are monitored on varied recurring cycles (each
month to once every 3 years) depending on the regulatory
requirements.
Employees are encouraged (with incentives) to fill out Corrective-
Preventive Action Requests (CPARs). These requests provide
opportunities for preventing pollution and improving operations.
Performance measurement is performed through our Productivity
Measurement Program (PMP). Tasks are valued at certain levels
based upon the length of time to accomplish with a specified
manpower requirement. Incentives are provided for attaining set
goals, and inter-departmental competition is also fostered.
Regulatory compliance and reporting
Objectives and targets
Internal/external audits (EMS, compliance)
Training records (completion)
Document control (reviews and updates)
Compliance
Internal audits (EMS and Compliance)
Public comments - Review of communications with external
parties/customer satisfaction surveys
Communication and cooperation among staff and management
Costs and efficiencies particularly with regard to energy and
chemical usage
Sanitary sewage overflow reduction
Targets and objectives tracking
Recycled material tracking
CPAR status
Standard operating procedures status
,1 REMEMBER
ฃJ
Remember to track and
record your EMS
benefits, especially the
ones realized from our
objectives and targets. These
will make an impression with
management as you move
forward with your EMS.
Section 3: Monitoring and Measurement (Phase 4)
Wastewater EMS Handbook
139
-------
EMS Manual
Work Instructions, Forms,
Drawings, etc.
A Monitoring and Measurement
system procedure is required for this
element. A system procedure defines
the purpose (why the procedure is
needed), scope (to what
operations/areas/staff the procedure
applies), roles & responsibilities (who
needs to complete the tasks), and the
tasks that need to be completed for
this element.
NOTE
vv You can monitor and
^~. ^
quantify other
v. organizational
* benefits that the
EMS brings, such
as efficiency savings, reduced
landfill costs from recycling
efforts, and accidents/fines
avoided, etc., when tracking
your EMS performance.
Involving Contractors
and Temporary Staff
It is important to involve contractors
and temporary employees in this
phase of your EMS, especially if
they work in areas that can create
a significant impact on the
environment and/or monitor or
maintain equipment for your
significant aspects and/or
objectives and targets.
Communicate with and train
contractors and temporary staff on
their roles and responsibilities.
Step 4) Develop an EMS System Procedure for
Monitoring and Measurement
When you're satisfied that your process for monitoring and measuring
conforms to the EMS requirements, document the process in a system
procedure. As with all EMS system procedures, it needs to clearly
define what, who, when, how, and where.
For samples of Monitoring and Measurement procedures from
wastewater facilities, see Appendix A.
.1 REMEMBER
To be compliant with the requirements of ISO 14001, you also
need to establish and maintain a documented procedure for
evaluating compliance with environmental laws. You should
ป'e set up a Legal and Other Requirements procedure in your
ning Phase of the EMS.
Step 5) Check Your Monitoring and Measurement
Procedure for EMS Conformance
Check to see if your procedure is working according to your plan. Here
are some questions to investigate:
Check
-------
CASE STUDY
Eugene, Oregon Wastewater
"Paper Products Consumption"
To achieve the target of reducing overall
paper goods consumption by 30%, we devel-
oped and implemented extensive facility-
wide conservation, recycling, training, and
purchasing programs.
We greatly exceeded our target, and actually
reduced paper use by 50% total. We
reduced janitorial paper use by 48%, and
office paper use by 37%.
To achieve this substantial reduction, we
implemented the following strategies:
Provided easily accessible, shared infor-
mation on alternative products (kitchen prod-
ucts, cornstarch plates and cups, etc.). We
tested dish drying racks in the kitchens to
reduce paper towel use, and we will use
cloth towels for large events.
Installed cloth towel mechanisms in most
restrooms, reducing paper use by 4.6 tons
compared to 2002.
Implemented an extensive employee
awareness program, including equipment
use training that emphasized waste reduc-
tion for printers, copiers and fax machines.
Redesigned documentation to minimize
paper waste, and use electronic distribution
where possible. In addition, we are partici-
pating in the WADERS pilot project for regu-
latory electronic reporting, and transitioning
to the maximum electronic reporting possi-
ble, resulting in a drastic reduction of office
paper use.
2003 Savings from Reducing Paper
Use by 7.6 Tons
129.2 trees
52842 gallons of water
3515 gallons of oil
4457 pounds of air pollution
23 cubic yards of landfill space
30988 KWh of electricity
Developed procedures and purchasing
guidelines that target reduced paper use and
emphasize purchase of products with recy-
cled content.
Continued with our previous objective to
purchase paper goods containing higher
recycled content. We increased purchases of
products with greater than 30% recycled
content by weight from 97% to 98% from
2002.
Annual Paper Purchases
per employee
n Janitorial
Office
Section 3: Monitoring and Measurement (Phase 4)
Wastewater EMS Handbook
141
-------
^\ ^\ ^\
r___________________________________
Monitoring and Measurement
(Cut out this section for handy reference)
The Purpose of this EMS element is to:
o Monitor and measure the performance of your EMS, including your significant aspects,
objectives and targets, legal compliance and operational controls.
The Result of this EMS element is:
o A procedure (EMS Document) to control monitoring and measurement activities that affect your
significant environmental aspects and compliance requirements.
Before You Begin this EMS element:
o Complete your significant aspects and impacts analysis.
142 Section 3: Monitoring and Measurement (Phase 4) 142
Wastewater EMS Handbook
-------
ISO 14001
Requirements
Links to Other EMS
Elements
Required Documents
& Records
Optional Documents
& Records
Monitoring and
Measurement
The organization shall
establish and maintain
documented procedures
to monitor and measure,
on a regular basis, the key
characteristics of its
operations and activities
that can have a significant
impact on the
environment. This shall
include the recording of
information to track
performance, relevant
operational controls and
conformance with the
organization's
environmental objectives
and targets.
Monitoring equipment
shall be calibrated and
maintained and records of
this process shall be
retained according to the
organization's procedures.
The organization shall
establish and maintain a
documented procedure for
periodically evaluating
compliance with relevant
environmental legislation
and regulations.
Environmental Aspects -
Determining your significant
aspects will identify the
operations and services
that you will need to
monitor and measure.
Legal and Other
Requirements - A status
check on compliance needs
to be assessed and
continually monitored.
Objectives & Targets -
Your environmental goals
need to be tracked and
measured to determine
how well they are
performing and meeting
your intentions.
Operational Control - Your
significant aspects must
have controls (procedures,
work instructions, manuals,
etc.) in place.
Management Review - Top
Management will review the
progress and performance
of your objectives and
targets to help determine if
you are on track and/or to
see if resources are
allocated appropriately.
Monitoring and
Measurement Procedure
Calibration Records
Calibration and
Maintenance Procedure
List of devices, location,
calibration frequency and
method, etc.
Maintenance Manuals
Section 3: Monitoring and Measurement (Phase 4)
Wastewater EMS Handbook
143
-------
Section 3: EMS Internal Auditing
o
nee your organization has established its EMS, verify its
effectiveness. The process of reviewing and verifying your EMS
through an internal audit is critical and key to improving your system.
An EMS internal audit is a tool that your wastewater facility will use
periodically to identify where things are working well and where
improvements are needed. This information will help you assess how
well your EMS is performing. The internal audit is a documented review
of whether your organization is doing what it said it would do to manage
its environmental issues and whether it is doing so effectively. An EMS
internal audit is conducted by your organization's employees to
determine your conformance with the ISO 14001 Standard.
NOTE
An EMS external audit is an EMS review conducted by
an independent, third-party to determine EMS
. conformance, typically as means to seek third-party
certification (see Section 4 for more information on
third-party certification).
Your EMS internal audit is a snapshot in time. It evaluates your
documents, procedures, and records and reviews their implementation
effectiveness and consistency. The audit looks at your facility's planned
activities for meeting its objectives and targets and controlling its
significant aspects. It also looks for signs of management's commitment
to the environmental policy and the EMS, and awareness and
competency among all your wastewater employees.
Step-by-Step Guide to EMS
Internal Auditing
Step 1) Select and Train EMS Internal
Auditors
Step 2) Determine EMS Audit Scope and
Frequency
Step 3) Prepare Staff for Your EMS Internal Audit
Step 4) Conduct an EMS Desktop Review
Step 5) Conduct an EMS Internal Audit
a. Hold an Opening Meeting
b. Audit for EMS Conformance
c. Report EMS Audit Findings
Step 6) Develop a System Procedure for Conducting EMS
Internal Audits
Step 7) Check the EMS Internal Audit Procedure for EMS
Conformance
Key Section Terms
Audit Finding -A discovery of lack
of conformance to the requirements
of an (ISO 14001-based) EMS
criteria/checklist. All audit findings
must be resolved as found during
the internal audit or through a formal
EMS process of corrective and
preventative action.
Corrective Actions -As a result of
the audit findings, corrective action
reports (CARs) are assigned to all
nonconformances to correct EMS
deficiencies as they occur. CARs
track an audit finding, assigning tasks
to be completed, responsibilities,
and timeframes.
EMS Audit - A planned and
documented review performed in
accordance with a documented audit
procedure for the purpose of
verifying, through interview and an
evaluation of EMS documents and
records, conformance with the
applicable elements of your EMS.
EMS Auditor - A qualified and
trained individual who conducts EMS
audits. Each EMS Auditor should
attend documented training that
presents the requirements of a
standard (e.g., ISO 14001) EMS
and of your organization's EMS audit
procedure and discusses their roles
in an EMS internal audit.
EMS Lead Auditor - A qualified
and trained individual who plans,
organizes, and directs your
organization's EMS internal audits.
The EMS Lead Auditor is the leader
of your EMS audit team and will
report audit findings and observations
to management.
Section 3: EMS Internal Auditing (Phase 4)
Wastewater EMS Handbook
145
-------
Key Section Terms,
continued
Major Nonconformance - A
deficiency in meeting the
requirements of an EMS. One or
more of the 17 elements of the EMS
which are not addressed (e.g., no
system procedure) or implemented
(e.g., a number of employees are not
aware that you have an
Environmental Policy).
Minor Nonconformance -A finding
that leads to a failure to conform
completely with an EMS element, but
is not considered to be a breakdown
in your system, (e.g., for example, a
number of employees were overdue
on their EMS refresher train ing.
Observation -A recognition of
something done incorrectly or an area
of concern. While not a major or
minor nonconformance with an EMS
requirement, if done correctly it could
strengthen the EMS or if done
incorrectly, could potentially cause a
system failure. Remember to also
document positive observations -
things you are doing well.
System Procedure -An EMS
(ISO 14001) required document that
establishes purpose, scope, roles &
responsibilities, the tasks to be
completed, and where and how the
associated records and documents
are maintained.
NOTE
Vfc The size of a typical
EMS audit team will
vary depending
. on the size of
your facility. It is
ecommended that
you have at least two to three
qualified members on your
team. This will allow you to
rotate your auditors to different
areas and prevent scheduling
conflicts when auditors are sick
or on vacation.
Step 1) Select and Train EMS Internal Auditors
Your own qualified and trained employees are the best people to
conduct an internal audit. If possible, train at least two people as EMS
internal auditors, with one as the lead auditor. This will allow your
auditors to work as a team. This also allows audits to take place when
one auditor is unavailable.
Your auditors should be objective, and not audit his/her own areas of
operation or service. For example, if your wastewater lab manager is
one of your internal auditors, he/she should not be auditing your
laboratory operations.
NOTE
Your EMS internal auditors require training in order to
be effective reviewers of your system. Consider a
three-day EMS Audit Overview or five-day EMS
Lead Auditor training conducted by EMS training
organizations in your area. For training, contact a certified
Registrar Accreditation Board (RAB) commercial organization in
your area ( ). Also consult the
or contact a Local
>utifthev offer EMS
for auditors. LRCs can be found on the
http://www.rabnet.com/ec_main.shtml
;hnical Assistance Providers (TAP) Director
IER Center
Website
Step 2) Determine EMS Audit Scope and
Frequency
Next, determine how often you want to conduct your internal audits and
determine your audit scope. All programs and elements of your EMS
should be audited every year. Audit your entire EMS at one time each
year or break your review into specific elements for more frequent
audits, where you would review a sampling of elements every quarter,
but still audit all EMS elements within a year.
To determine the scope and frequency of your EMS internal audits,
consider the environmental importance of the activities and the results
of your previous audits. For example, you may want to focus audit
efforts on significant aspect areas and activities or your objectives and
targets, as well as on the findings from your previous EMS audits. This
will direct your EMS audits to the most important areas for potential
improvement.
C jnd ct internal audits quarterly to simplify the audit
iC' ; and to get a quarterly check up on how you
is working. These quarterly audits and their results
then be reviewed in a quarterly management revie
Ull
jur FMS
s can
w.
James Naber
Buncombe County, North Carolina
Metropolitan Sewer District
146
Section 3: EMS Internal Auditing (Phase 4)
Wastewater EMS Handbook
-------
A sample EMS audit scope and schedule is shown below. Review your entire EMS at least every year,
beginning with a review of all EMS elements during your first internal audit. Then, consider conducting a
sampling of EMS elements every quarter, as shown in the schedule below. Also, remember that your EMS
internal audits can be integrated with other reviews you currently conduct (e.g., environmental, health and
safety, quality, or security audits, etc.).
A Sample EMS Audit Scope and Schedule
(For an Example of Internal Audits Conducted Every Quarter)
15014001:1996
4.2
Environmental Policy
01/2005
*
04/2005
07/2005
*
10/2005
01/2006
*
4.3.1
4.3.2
4.3.3
4.3.4
Environmental Aspects
Legal and other Requirements
Objectives and Targets
Environmental Management Programs
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
4.4.1
4.4.2
4.4.3
4.4.4
4.4.5
4.4.6
4.4.7
Structure and Responsibility
Training, Awareness and Competence
Communication
Environmental Management System
Documentation
Document Control
Operational Control
Emergency Preparedness and Response
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
4.5.1
4.5.2
4.5.3
4.5.4
Monitoring and Measurement
Nonconformance & Correct/Prev Action
Records
EMS Audit
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
4.6 Management Review
Previous Findings of Nonconformance
Section 3: EMS Internal Auditing (Phase 4)
Wastewater EMS Handbook
147
-------
Three Lessons Learned
(from wastewater facilities):
1. Make "cheat sheets" for your
employees. For example, post
significant aspects and objectives and
targets in work areas and have wallet
cards made of your environmental
policy so that employees do not have
to memorize the EMS.
2. Work with your staff's schedule so
that you do not disrupt the routine of
daily operations in the area you are
auditing - be flexible with your audit
schedule.
3. Establish a well-defined audit
schedule and plan. Also, use an EMS
checklist. These tools will effectively
prepare your EMS auditor(s) and
keep your audits consistent.
Three Things to Avoid
(from wastewater facilities):
1. Trying to be too "textbook" and/or
using too much EMS jargon during
the internal audits. Your internal
auditors should take what they know
and relate it to the activities that are
being reviewed - then tie in the EMS
requirement.
2. Not providing the necessary
training for your internal auditors.
Make sure your auditors understand
the EMS and ISO 14001
requirements AND what you are trying
to accomplish with your internal audits
(i.e., environmental improvement).
3. Not preparing staff for your EMS
Audits - all employees should
understand what is expected of them
during an EMS internal audit.
Step 3) Prepare Staff for Your EMS Internal Audit
You've developed an EMS internal audit scope and agreed on an audit
schedule. You are ready to begin and so are your internal auditors. Your
job as lead EMS auditor is to support the audit function by preparing
your managers, employees, and all documents and records. All of these
should be readily available to your audit team according to a pre-
arranged audit schedule.
In advance of the audit, prepare management by:
^ Reviewing their EMS responsibilities
^ Rehearsing the type of questions that the auditor might ask
(NSF Guide Second Addition, Appendix A, pages 153 - 156)
^ Organizing and tracking corrective actions that the audit identifies.
^ Indicating on managers' calendars suggested times for the pre-audit
meeting to review the audit scope, plan and schedule, and the
closing meeting to share audit findings
^ Encouraging them to be visible, involved, and available for the
month of preparation preceding the registration audit
Prepare employees by:
^ Emphasizing the "find, fix, and prevent" opportunity the audit provides
^ Reviewing the environmental policy and confirming the role it has in
employees' daily activities
^ Reviewing significant aspects, objectives and targets with relevant
department managers and folks on the front-line
^ Rehearsing the types of questions that an auditor might ask them
(you may want to use the checklist you developed in the internal
audit)
^ Reviewing EMS roles and responsibilities
Prepare documents and records by:
^ Ensuring they are current, easily retrievable, and controlled accord-
ing to your document control procedures
For sample EMS Audit Checklists, Plans, and an Audit Report Template
from wastewater facilities, see Appendix B.
148
Section 3: EMS Internal Auditing (Phase 4)
Wastewater EMS Handbook
-------
Step 4) Conduct an EMS Desktop Review
An EMS "desktop" or document review is a review of written EMS
policies, procedures and records that is developed before you conduct
your full EMS internal audit and interview personnel. The desktop
review is conducted to provide the audit team with a "snapshot"
overview of an organization's EMS elements and how they fit together.
A desktop review also provides the audit team with a first look at an
organization's EMS and how the system elements fit with your current
environmental programs and will therefore increase the efficiency of
your full EMS internal audit.
Step 5) Conduct an EMS Internal Audit
Step 5a) Hold an Opening Meeting
Before you begin your internal audit, conduct an EMS opening meeting
with management and relevant staff. During the meeting, go over: 1) the
members of the audit team and introduce the team leader; 2) review the
audit scope and the checklists/questionnaires that will be used; and 3)
the audit schedule. Also, leave time at the end for questions.
This meeting will help set the stage on what to expect for your
employees and management.
Step 5b) Audit Your System for EMS Conformance
Check your EMS by touring the site and observing the operations and
services within your fenceline. While on-site, your audit team will want
to review work practices and operations, interview employees, and
examine procedures, documents and records.
Although not a requirement, it's important to use an EMS audit
checklist/protocol to conduct your EMS internal audit. The checklist
provides your audit team with typical ISO 14001 language, and audit
tips and suggestions to ensure that all EMS elements and their
requirements are covered and reviewed. Besides, it's a great tool to
ensure consistency!
Step 5c) Report EMS Audit Results
As your audit team conducts and finalizes your internal EMS review,
they will be taking notes, making observations, documenting audit
findings, and writing up (if applicable) findings of nonconformance. Audit
findings are typically documented and noted in a final report as either 1)
observations (i.e., suggestions for improvement or a note on something
done well); 2) major nonconformances (e.g., an entire system element
is missing); 3) or minor nonconformances (e.g., One or two employees
in the administration are overdue on EMS refresher training).
Nonconformances are discrepancies in your EMS that require attention
through a corrective action. Corrective Action Reports (CARs) will be
noted by the lead auditor and/or environmental management
representative (EMR). CARs should include include the discrepancy
and the timeframe, and the person(s) responsible for bringing the
discrepancy back into EMS conformance.
Your EMS Lead Auditor will be
tasked with completing an audit plan
to determine the scope of each of
your internal audits. The following
should be included in each audit
plan:
^ a statement of the audit
objectives
^ an identification of the specific
elements being audited
^ a review of any special emphasis
or focus (e.g., corrective actions
from previous EMS audits)
^ references to appropriate plans,
procedures, or requirements
documents
^ a timetable for the audit
^ an identification of the Audit
Team and the members assigned
rolls
^ audit materials such as
checklists, questionnaires, etc.
Three Keys to
Success
(from wastewater facilities):
< >
k b
1. Streamline the EMS internal
auditing process to be
understandable for employees.
Don't make the process too
lengthy or complicated.
2. Perform an internal audit of
your EMS system and
processesnot individuals.
3. Make the EMS internal audit
process positiveidentify the
good things and compliment
peopleas well as identify the
opportunities for system
improvements.
Section 3: EMS Internal Auditing (Phase 4)
Wastewater EMS Handbook
149
-------
An EMS Internal Audit is a tool to
improve your system. View it < >u ,
and as an effective manageme t fo< /.
Beth Eckert
Gastonia, North Carolina
Public Works and Utilities Department
EMS Manual
Procedures
Work Instructions, Forms,
Drawings, etc.
An EMS Internal Audit system
procedure is required for this element.
A system procedure defines the
purpose (why the procedure is
needed), scope (to what
operations/areas/staff the procedure
applies), roles & responsibilities (who
needs to complete the tasks), and the
tasks that need to be completed for
this element.
Examples of Nonconformance:
No external/internal communication procedure
Emergency preparation procedure exists, but is not posted
A number of employees are not aware that you have an
Environmental Policy
An EMS nonconformance requires a documented corrective action. An
observation is a recognition noted during the audit that a system
element may lead to a nonconformance; or if done correctly, could
strengthen your EMS.
Examples of Observations
Procedures that are long and difficult to follow
Poor housekeeping
EMS knowledge of pretreatment staff was excellent
More on documenting, managing, and closing out nonconformant EMS
audit findings can be found in this Handbook in the next Section on
Nonconformance and Corrective and Preventative Actions.
Step 6) Develop a System Procedure for
Conducting Your EMS Internal Audits
Document your internal audit process in a system procedure that clearly
defines what you'll do, roles and responsibilities, when they'll do it, how
the information will be communicated, and where the information will be
stored. This documented procedure will be a consistent, easily
accessible, and clear guide for ensuring that this important element of
your environmental management system is carried out according to
your plans.
REMEMBER
, Documenting a procedure is not enough to satisfy the EMS
requirement and the audit team. It's critical to put the
procedure into practice in your facility - to implement it and do
what you say you will do. Within a few months it's time to
verify that your procedure is working well, and if necessary,
make any improvements.
For sample EMS Internal Auditing procedures from wastewater facilities,
see Appendix A.
ISO
Section 3: EMS Internal Auditing (Phase 4)
Wastewater EMS Handbook
-------
Step 7) Check the EMS Internal Audit Procedure
for EMS Conformance
Here are some questions to investigate regarding your EMS internal
audit procedure:
Check S
1. Have you determined who will be conducting your EMS Internal
Audits?
2. Are they qualified and trained?
3. Do you have an EMS audit program that verifies the conformance
of your EMS?
4. Are EMS findings of nonconformance documented?
5. Are corrective and preventative actions implemented for audit
findings of past nonconformance?
6. Are audit checklists and reports maintained as EMS records?
7. Are audit results communicated to management?
>r jlici internal auditors from various levels and functions
:h rganization to provide different viewpoints of *he
system. Set schedule to audit the entire system on
yearly basis.
""
James Naber
Buncombe County, North Carolina
Metropolitan Sewer District
REMEMBER
Your internal auditing program is a great tool for identifying
areas to improve your system. In addition, it is a valuable
step in preparing for external audits if you are pursuing
third-party accreditation. Set up your internal audits to
mirror the scope of your external audits.
Your EMS Internal
Audit can Accomplish
Several Things,
Including:
1. It lets you know if the EMS
element is being implemented as
planned.
2. It gives employees practice in
being audited.
3. It gives audit teams a chance to
practice their auditing skills.
4. It reinforces everyone's
involvement and responsibility in your
EMS.
5. It's a teaching tool to get
employees to understand each
element of the EMS.
6. It's an important tool to measure
how your system is or is not
continually improving.
7. It's a "find, fix, and prevent"
opportunity to identify weaknesses in
procedures and work instructions
before they become a documented
part of
your EMS.
Jo/r nunication of your audit goals
c ave/s of the organization is
crucial in providing a level of
comfort and knowledge to fielt
crews.
uon ;s
L
Chris Toth
City of San Diego
Wastewater Collection Division
Section 3: EMS Internal Auditing (Phase 4)
Wastewater EMS Handbook
I5I
-------
Auditor Credentials
c> Independent of the areas being
audited
c> Has an understanding of
relevant laws and regulations
c> EMS training
c> An understanding of audit
process and procedures
c> Good communication skills
c> An attention to detail
NOTE
A systems audit
looks for system
^ elements and
, system
linkages. For
example, did the
environmental goals you set
consider your significant impacts
and what you said in your policy
statement? A compliance audit
looks for regulatory violations
based on meeting specific laws
and regulations. For example,
are the discharges from your
outfall within the permit limits?
Involving Contractors
and Temporary Staff
If your contractor and temporary
employees work in operations and
services that your organization
identified as significant, they should
understand what is expected of
them during your internal EMS
audits. For example, temporary
and contractor staff should
understand the basics of your EMS
Policy, what operations and
services have significant aspects,
and the environmental goals your
wastewater facility is looking to
achieve.
Suggestions on Conducting EMS Internal
Audits from Wastewater Facilities and
Other Public Organizations
We've benefited from hiring an outside consultant to train
our internal audit team. The outside expert credibility factor
worked wonders in a short time.
We partnered with other public entities in our region and are
using each other's audit teams for internal EMS audits. We
get a fresh look at our own system, and we learn a lot about
how others have implemented and improved their EMS.
These are extremely valuable experiences for all
of us.
We handed out a manual of all our work to date before our
internal audit training. This proved very valuable in showing
off the big picture and reinforcing what we had alreadv
accomplished so far. It also made the audits that muc
easier to conduct at each facility.
152
Section 3: EMS Internal Auditing (Phase 4)
Wastewater EMS Handbook
-------
,-t &. -Jr,
EMS Internal Auditing
(Cut out this section for handy reference)
The Purpose of this EMS element is to:
o Establish an effective EMS internal audit program to continually evaluate and improve your
EMS system.
The Results of this EMS element are:
o An EMS audit procedure (EMS Document) that covers scope, frequency, methods and
responsibilities.
o A mechanism for EMS internal audit results (EMS Record) to be reported to management for the
purpose of management review.
o An EMS Internal Audit Schedule/Plan that covers all elements of the EMS requirements.
o A group of trained EMS internal auditors identified and available to conduct EMS internal audits.
o Internal audit documentation, including checklists, reporting documents (e.g., an internal audit
report), and summary documents (EMS Records) to review and follow-up on the results of audits.
Before you Begin this EMS element:
o Implement all elements of your EMS.
o Conduct EMS employee awareness and understanding training for all staff to prepare them
for the internal audit process.
'" '" "
Section 3: EMS Internal Auditing (Phase 4) 153
Wastewater EMS Handbook
-------
ISO 14001
Requirements
Key Links to Other
EMS Elements
Required Documents
& Records
Optional
Documents &
Records
Environmental Management
System Audit
The organization shall
establish and maintain (a)
program(s) and procedures
for periodic EMS audits to
be carried out, in order to:
a) determine whether or not
the environmental
management system
1) conforms to planned
arrangements for
environmental management
including the requirements
of this International
Standard; and
2) has been properly
implemented and
maintained; and
b) provide information on
the results of audits to
management.
The organization's audit
program, including any
schedule, shall be based on
the environmental
importance of the activity
concerned and the results
of previous audits. To be
comprehensive, the audit
procedures shall cover the
audit scope, frequency and
methodologies, as well as
the responsibilities and
requirements for conducting
audits and reporting results.
Structure &
Responsibility -
Employees and
management are aware of
their roles for your EMS
internal audit program.
Training & Awareness -
Your organization has
qualified, trained and
capable EMS internal
auditors. All staff are aware
of their responsibilities
during the EMS internal
audit.
Corrective Actions -
Establish a report (CAR)
that identifies EMS audit
discrepancies, action items,
responsibilities and
timeframes for improving
your system.
Management Review -
Meet with top management
to discuss new or changed
priorities based on your
internal audit results.
EMS Audit Procedure
Audit Records/Reports
Corrective Action Reports
(CARs)
List on Nonconformances
Audit Plan/Schedule
List of Qualified
EMS/QS Auditors
154
Section 3: EMS Internal Auditing (Phase 4)
Wastewater EMS Handbook
-------
Section 3: EMS Nonconformance and
Corrective/Preventative Actions
What is an EMS Nonconformance?
Anonconformance is the audit term used to describe one or more
EMS requirements that have not been addressed (i.e., no
procedure) or have not been implemented (e.g., employees not
following a procedure) within your organization's defined EMS fenceline.
Examples of Nonconformance:
No external/internal communication procedure
Emergency preparation procedure exists, but is not posted
A number of employees are not aware that you have an environ-
mental policy
Step-by-Step Guide to
Nonconformance and
Corrective and Preventative
Action
Step 1) Identify EMS Nonconformances
Step 2) Identify Root Causes and Prevent their
Reoccurrence
Step 3) Implement Corrective and Preventative
Actions
Step 4) Update and Communicate EMS Corrective
and Preventative Actions
Step 5) Develop a System Procedure for Nonconformance and
Corrective and Preventative Actions
Step 6) Check Your Nonconformance and Corrective and
Preventative Action Procedure for EMS Conformance
Step 1) Identify EMS Nonconformances
EMS nonconformances (potential problems or areas requiring
improvement) can be initiated in a number of ways, including through 1)
audit "findings"; 2) suggestions from employees (e.g., from working with
day-to-day operating procedures); and 3) monitoring your significant
environmental issues. To manage your EMS nonconformances, identify
and investigate your EMS deficiencies, determine their root causes, and
implement corrective and preventative actions to manage them and
verify their effectiveness. A corrective and preventative action program
will do this for you.
A sample Corrective/Preventative Action Request/Report (CPAR) is
attached at the end of this Section.
Key Section Terms
Audit Finding - The discovery of a
lack of conformance to the
requirements of an EMS (ISO 14001-
based) criteria/checklist. All audit
findings must be resolved as found
during the internal audit or through a
formal EMS process of corrective and
preventative action.
Corrective Actions -As a result of
the audit findings, corrective action
reports (CARs) are assigned to all
nonconformances to correct EMS
deficiencies as they occur. CARs
track an audit finding, and assign
tasks to be completed,
responsibilities, and timeframes.
Corrective Action Request (CAR) -
A report form to identify, track and
manage corrective actions.
EMS Audit - A planned and
documented review performed in
accordance with a documented audit
procedure for the purpose of
verifying, through interview and an
evaluation of EMS documents and
records, conformance with the
applicable elements of your EMS.
Major Nonconformance -A
deficiency in meeting the
requirements of an EMS. One or
more of the 17 elements of the EMS
are not addressed (e.g., no system
procedure) or implemented (e.g., not
following a system procedure as
written).
Minor Nonconformance - A finding
that leads to a failure to conform
completely with an EMS element, but
is not considered to be a breakdown
in your system. For example, a
number of employees were overdue
on their EMS refresher training.
Section 3: Nonconformance and Corrective and Preventative Actions (Phase 4)
Wastewater EMS Handbook
I55
-------
Key Section Terms,
continued
Observation -A recognition of
something done incorrectly or an area
of concern. While not a major or
minor nonconformance with an EMS
requirement, if done correctly it could
strengthen the EMS or if done
incorrectly, could potentially cause a
system failure.
Preventive Actions - A proactive
approach to managing actions that
are assigned to any EMS
nonconformance made that will
prevent potential environmental
issues before they occur.
Root Cause - Underlying reason that
led to or may lead to an EMS
nonconformance. For example, if a
group of employees were not
following a procedure, the underlying
cause could be that they were not
properly trained on the procedure or
that an updated procedure was not
communicated to them.
System Procedure -An EMS
required document that establishes
an element's purpose, scope, roles &
responsibilities, the tasks to be
completed, and where or how the
associated records and documents
are maintained.
Typical Causes of EMS
Nonconformances
Include:
S Poor communication
S Faulty or missing procedures
S Equipment malfunction (or lack
of maintenance)
S Lack of training
S Lack of understanding of an
EMS requirement
S Not following an EMS
requirement
Step 2) Identify Root Causes and Prevent
their Reoccurrence
While many corrective actions may be "common sense," look beneath
the surface to determine why the problems occurred in the first place.
Many organizations use the term "root cause" in their corrective and
preventative action processes. By determining the root causes of your
nonconformances, you are simply looking past the most obvious or
immediate reasons to determine why it occurred.
For example, a new procedure was recently updated by the document
control center to include an EMS initiative to recycle oil and grease.
However, it was noted on the most recent EMS internal audit that
employees in maintenance were not disposing of their oils and greases
properly. So how would you determine the root cause of this
nonconformance?
By performing a check of the potential sources or causes of
nonconformance.
ป Was the procedure updated with the new recycling initiative? Yes.
ป Were all employees in maintenance trained and was the new
procedure communicated? Yes.
ป Were they using the most current procedure? No.
Even though employees were trained on the new procedure, it was
determined that employees were still using a hard copy procedure that
was outdated and that did not include the updates on recycling. It's
important to find the cause of the nonconformance in order to fix it and
prevent it from reoccurring.
Step 3) Implement Corrective and Preventative
Actions
Correct, prevent and manage the nonconformance until it is corrected.
This is done through a corrective/preventive action request or CAR.
A CAR identifies and describes the EMS nonconformance, the action
items needed to implement the correction, the person(s) responsible for
implementing and tracking the correction, and the timeframes for
completion. A CAR is an EMS record and documents and tracks
corrective actions until the action items from the nonconformance are
completed by the established timeframes.
156
Section 3: Nonconformance and Corrective and Preventative Actions (Phase 4)
Wastewater EMS Handbook
-------
Step 4) Update and Communicate EMS
Corrective and Preventative Actions
Update and communicate what you have learned. Based on your root
cause review, you may need to update, train, and communicate
procedures and work instructions, establish new programs, calibrate
equipment, etc.
Let's look back at our example in which the personnel in maintenance
were not recycling their oils and greases. It was determined through
identifying the nonconformance root cause that the employees in
maintenance were using an outdated procedure. As part of updating
and communicating the completion of this particular CAR, and to
prevent this nonconformance from occurring again: 1) make sure that
the document control center "manages" (see section on EMS document
and records) all hard copy procedures and work instructions; and 2)
communicates and trains the changes to maintenance employees.
In addition, as part of "institutionalizing" this or other corrective actions,
inform management so that your EMS improvements will become the
new way to do things in your day-to-day operations. For example, from
now on, the document control center will put a stamp or footer on all
hard copy procedures with the following language: "If printed, this
document is obsolete. See an employee from the Document Control
Center for the most current version."
REMEMBER
Monconformances can also be identified outside of an EMS
audit. Anyone in your wastewater facility can identify and
report findings and make recommendations. This should be
encouraged. Find ways to get employees involved in the EMS
mprovement process - whether formally or informally (for
example, via suggestion boxes, contests or incentive
programs).
Step 5) Develop a System Procedure for
Nonconformance and Corrective and
Preventative Action
Document your process for nonconformance and corrective and
preventative action in a system procedure that clearly defines what
you'll do, roles and responsibilities, when they'll do it, how the
information will be communicated, and where the information will be
stored. This documented procedure will be a consistent, easily
accessible, and clear guide for ensuring that this important element of
your EMS is carried out according to your plans.
For samples of Nonconformance and Corrective and Preventative
Action procedures from wastewater facilities, see Appendix A.
COACH'S CORNER
Follow a "find, fix, and
-^ prevent" approach for
smaller issues rather
"T'than go through
documentating
nonconformances. If
you're unsure which approach
to follow you can start by
documenting every finding
and filling out a corrective
action request (CAR) and then
scale back at a later date.
Remember, an EMS is about
continual improvement.
NOTE
Completed CARs are
. EMS records that
need to be
traceable to an
operation or
activity and maintained
for review.
Involving Contractors
and Temporary Staff
Contractor and temporary
employees should understand what
is expected of them during your
internal EMS audits. Therefore, if
an EMS audit finding is found
within their operation or service at
your facility, they need to
understand their roles and
responsibilities in correcting the
nonconformance (finding), and
preventing the EMS audit finding
from reoccurring.
Section 3: Nonconformance and Corrective and Preventative Actions (Phase 4)
Wastewater EMS Handbook
I57
-------
EMS Manual
Procedures
Work Instructions, Forms,
Drawings, etc.
A Nonconformance and Corrective
and Preventative Action procedure is
required for this element. A procedure
defines the purpose (why the
procedure is needed), scope (to what
operations/areas/staff the procedure
applies), roles & responsibilities (who
needs to complete the tasks), and the
tasks that need to be completed for
this element.
Three Keys to
Success
(from wastewater facilities):
1. Focus on correcting and
preventing problems.
Preventing problems is
cheaper than fixing them after
they occur (or after they
reoccur).
2. EMS nonconformances
should be analyzed to detect
patterns or trends. Identifying
trends allows you to anticipate
and prevent future problems as
well as identify things going
well.
3. Be sure that your corrective
& preventive action process
specifies roles and
responsibilities and schedules
for completion for Corrective
Action Reports (CARs).
Step 6) Check Your Nonconformance and
Corrective and Preventative Action Procedure for
EMS Conformance
About two or three months after you have documented and
implemented your Nonconformance and Corrective and Preventative
Action procedure, check to see if it is working according to your plans.
Here are some questions to investigate:
Check V
1. Do you have a procedure for identifying, managing, tracking, and
completing (closing) EMS nonconformances?
2. Does your process include identifying the root cause and assigning
responsibilities and timeframes for completing the corrective
actions?
3. Do you document and record your corrective actions?
4. Do you have a procedure to prevent nonconformances from
reoccurring?
NOTE
Start thinking about your EMS
\ nonconformances as opportunities to
improve. Also, don't forget to document what
you are doing well!
/ ter .n EMS nonconformance, consult with your employees
/ they would implement a solution. Your frontline
employees have great ideas on how to improve operations,
since they wrestle with the same type of issues each
The challenge of a manager is how to get ideas out of these
individuals, use their knowledge, and reward them for their
concepts and foresight.
f these
their
Rick Bickerstaff
Charleston, South Carolina
Commissioners of Public Works
I58
Section 3: Nonconformance and Corrective and Preventative Actions (Phase 4)
Wastewater EMS Handbook
-------
I hei you receive a nonconformance, take a breath and try
th about the whole system. Try to avoid jumping in with
a quick fix. A quick fix can trigger other unintended
consequences that may be another problem down the
Donna Adams
Eugene, Oregon
Wastewater Division
Three Lessons Learned
(from wastewater facilities):
1. Your corrective actions should be
based on good information and
analysis of root cause. While many
corrective actions may be "common
sense," you need to look beneath
the surface to determine why
problems occur.
2. Designate employees from the
areas where the nonconformances
occurred as the ones responsible for
implementing their corrective and
preventative actions. These
personnel will be the best at
identifying appropriate corrective and
preventative actions, and the process
will get them involved in the EMS.
3. Review your EMS progress
regularly and follow up to ensure
that corrective actions taken are
effective.
Three Things to Avoid
(from wastewater facilities):
1. Starting from scratch. If your
organization has a system for
correcting environmental compliance
findings and/or an ISO 9001
management system, use your
current methods as models (or
integrate with them) for your EMS.
2. Not documenting and resolving
your nonconformances in a timely
manner.
3. Not documenting EMS activities
that are going well. In addition to
documenting nonconformances or
problems with your EMS, identify and
document EMS successes. This will
motivate your staff and help ensure
EMS buy-in.
Section 3: Nonconformance and Corrective and Preventative Actions (Phase 4)
Wastewater EMS Handbook
I59
-------
^\~
Nonconformance and Corrective and Preventative Action
(Cut out this section for handy reference)
The Purpose of this EMS element is to:
o Implement a Corrective and Preventative Action (improvement) process that will identify and
manage problems identified in your EMS.
The Results of this EMS requirement are:
o A Nonconformance and Corrective and Preventive Action procedure (EMS Document), that
identifies, tracks and closes out corrective and preventative actions.
o Corrective and Preventative Action Reports (EMS Records).
Before you Begin this EMS element:
o Develop formal (e.g., audits) and non-formal (e.g., employee suggestions) methods to identify
nonconformances or areas that require improvement within your EMS.
160 Section 3: Nonconformance and Corrective and Preventative Actions (Phase 4)
Wastewater EMS Handbook
-------
ISO 14001
Requirements
Key Links to Other
EMS Elements
Required Documents
& Records
Optional
Documents &
Records
Nonconformance and
Corrective and Preventive
Action
The organization shall
establish and maintain
procedures for defining
responsibility and authority
for handling and
investigating
nonconformance, taking
action to mitigate any
impacts caused and for
initiating and completing
corrective and preventive
action.
Any corrective or
preventive action taken to
eliminate the causes of
actual and potential
nonconformances shall be
appropriate to the
magnitude of problems
and commensurate with
the environmental impact
encountered. The
organization shall
implement and record any
changes in the
documented procedures
resulting from corrective
and preventive action.
Operational Control -
make sure controls (e.g.,
procedures, work
instructions, manuals, etc.)
are in place to prevent
EMS nonconformances.
Monitoring &
Measurement - monitor
your significant
environmental aspects to
determine if they are under
control.
EMS Audits - internal EMS
reviews provide a source to
identify EMS
nonconformances.
Management Review -
review nonconformances,
corrective and preventative
actions, and completion of
nonconformant issues with
management as a way to
continually improve and
institutionalize the EMS at
your facility.
Nonconformance and
Corrective and Preventive
Action Procedure
Corrective and Preventive
Action Requests (CPARs)
CAR Logs
Section 3: Nonconformance and Corrective and Preventative Actions (Phase 4)
Wastewater EMS Handbook
I6I
-------
Corrective/Preventative Action Request/Report
A. Area/Department:
Audit Date:
Auditee(s):
B. Description of Non-Conformance:
Audit Criteria:
Applicable ISO 14001 Element:
Auditor(s):
Date:
C. Root Cause Analysis:
D. Corrective Action:
Date of Implementation:
E. Preventative Action:
Date of Implementation:
F. Verification of Completion:
Date of Verification:
Auditor (signed): Date:
I62
Section 3: Nonconformance and Corrective and Preventative Actions (Phase 4)
Wastewater EMS Handbook
-------
Phase V: Management Review
YDU are now ready to begin the
Management Review Phase of the
EMS cycle. Each section of the
Handbook will guide you step-by-step
through each of the EMS activities. Refer to
the icons for case studies, sample
documents, keys to success-
es and other implementa-
tion assistance. At the
end of each section,
two handy reference
sheets review the
Purpose of each
requirement,
describe the Res-
ults you'll be devel-
oping, discuss how to
Prepare to do the work,
and show how the element
links to other EMS
requirements.
In this phase, your organization will take
the opportunity to assess your EMS per-
formance and judge the suitability, ade-
quacy, and effectiveness of the system.
As part of this review, your EMS Team will
consider, through dialogue with senior
management, new organizational goals.
This phase is an opportunity for top man-
agement to review and fine-tune your
EMS and make course corrections, if
needed. Top management will
determine whether the EMS
is functioning as you
intended, where addi-
tional resources may
need to be allocated,
if your environmen-
tal policy is appro-
priate or needs to
be revised, and if
your organization's
objectives and targets
are on track. If you are
using a two-year cycle, the
activities in this phase can be
comfortably accomplished in about
one month.
Here's a checklist of requirements in this
Phase:
Phase V EMS Requirements (1 month)
Management Review
Organizational Goal Assessment
Apply Lessons Learned for Continual Improvement
^
^
^
-------
Section 3: Management Review
The management review is the final element in your EMS cycle
("Act"). It's an opportunity to review the effectiveness of your EMS
with top management and fine-tune your EMS and make course
corrections. Top management will help determine whether the EMS is
functioning properly, where additional resources need to be allocated,
and if the environmental policy is appropriate or needs to be revised.
The management review provides opportunities for continual
improvements to be implemented into the system.
The management review element provides the opportunity for
constructive dialogue with management to judge the suitability,
adequacy, and effectiveness of the EMS. Seize the opportunity to reflect
upon your organization's environmental policy and commitment to
continuous improvement. Are resources, both time and monetary, being
strategically employed? Are there any course corrections that need to
be made? Are you on the right path to efficiently and effectively meeting
your organization's EMS objectives and targets?
Step-by-Step Guide to
Management Review
Step 1) Determine When and What to Review
Step 2) Identify Who Should Attend Your
Management Review
Step 3) Document Accomplishments and
Follow-up Actions
Step 4) Develop an EMS System Procedure for
Management Review
Step 5) Check Your Management Review Procedure
for EMS Conformance
Step 1) Determine When and What to Review
Schedule your Management Reviews at appropriate intervals, typically
after your EMS internal audits, to check on the progress of your
objectives and targets, but at least annually. Determine a management
review frequency that will work best for your organization.
What to Review
There is a wide range of information you can report to management.
Decide with your Core Team the appropriate information to
communicate. Present the information to management so it is easily
understood without overloading them with details.
Key Section Terms
EMS Audit - A systematic,
documented verification process of
objectively obtaining and evaluating
an organization's EMS to determine
whether or not it conforms to the
environmental audit criteria pre-
defined by the organization and
applicable standards (i.e. the ISO
14001 Standard).
Continual Improvement - The
principle of continual improvement,
as fundamental to the ISO 14001
Standard, is intended to ensure that
an organization does not simply
adopt an EMS, or other Plan-Do-
Check-Act based management
system, for cosmetic purposes and
thereby remain static. Continual
improvement is the process of
enhancing a management system to
achieve improvement in overall
performance and effectiveness in line
with the organization's management
policies.
Environmental Policy - Statement
by the organization of its intentions
and principles in relation to its overall
environmental performance which
provides a framework for action and
for the setting of its environmental
objectives and targets.
Environmental Objective - Overall
environmental goal, arising from the
environmental policy, that an
organization sets itself to achieve,
and which is quantified where
practicable. Objectives are based on
specific significant aspects.
Environmental Target - Detailed
performance requirement, quantified
where practicable, based on an
organization's defined environmental
objectives and that must be met to
achieve those objectives.
Section 3: Management Review (Phase 5)
Wastewater EMS Handbook
I65
-------
Management Review:
Questions to Consider
* Did we achieve our objectives
and targets? If not, why not?
* Is our environmental policy still
relevant to what we do?
* Are we applying resources
effectively?
* Are our procedures clear and
adequate? Do we need other
controls or to modify any?
* Are we monitoring our EMS
(e.g., via EMS audits)?
* What do the results of those
audits tell us?
* What other changes are com-
ing? What impacts (if any) will
these have on our EMS?
* What stakeholder concerns
have been raised since our last
review?
* How are stakeholder concerns
being addressed?
Three Things to Avoid
(from wastewater facilities):
1. Not communicating with top
management on what they would like
to review to access the performance
of the EMS.
2. Conducting only annual reviews.
Consider having management
reviews every quarter to give
management an update and to check
the progress of your EMS.
3. Not training top management on
the fundamentals of an EMS. If
Management understands what an
EMS can do for you, they will
understand what it can accomplish for
your organization.
Use objective information from internal audits and other "checks." Focus
on performance and not on process or procedures. You might consider
providing some information (e.g., status on meeting EMS objectives and
targets, etc.) to management before the meeting. Since the EMR is the
communication "link" between the organization's EMS activities and
management, it is his/her responsibility to pull the information and
materials together to allow management to conduct an adequate and
constructive review. However, as with all EMS activities, this is a team
effort. Work together with your Core Team and other personnel to
ensure that everyone is on the same page and that information flows
laterally and from the top-down and the bottom-up.
Step 2) Identify Who Should Attend Your
Management Review
Make sure you get managers involved that can make key decisions
regarding your EMS. You identified top management (Phase I) earlier in
the implementation process. Are these the same people you will have in
the management review meeting?
Two kinds of people should be involved in the management review
process:
=> People who have the right kind of information/knowledge
=> People who can make decisions about the organization and its
resources (top management).
Wastewater organizations that have implemented EMSs at their
facilities have indicated that Public Works Directors, General Managers,
Plant Managers, Line and Division Managers (especially within areas
where objectives and targets were set), the EMR, and invited
City/County Commissioners, other local leaders and citizen groups
attended Management Reviews.
Step 3) Document Accomplishments and
Follow-up Actions
EMS progress and updates from implementing the EMS can be
reported back to management in the monthly "good news" stories or in
other creative ways. During management review meetings, make sure
that someone documents and records what issues were discussed,
what decisions were reached, and follow up on action items and
responsibilities.
REMEMBER
Remember to track and document your EMS performance
and benefits to management on a regular basis. How well you
are reaching your environmental goals, avoiding accidents
and spills, and saving money is very important to
management as they develop plans and allocate resources.
I66
Section 3: Management Review (Phase 5)
Wastewater EMS Handbook
-------
Your EMR is responsible for gathering the meeting
information, agenda topics, planning, scheduling, etc.
for management reviews.
Conduct a management review at least
annually to review your entire EMS. To be
more proactive, conduct quarterly
management reviews to assess internal
quarterly audits and quarterly legal
requirements. This allows a snap sho
three months, of your system progress
o v>
ss
James Naber
Buncombe County, North Carolina
Metropolitan Sewer District
Step 4) Develop EMS System Procedures for
Management Review
When you're satisfied that your process for conducting management
review conforms to the EMS requirements, document the process in a
system procedure. As with all EMS system procedures, it needs to
clearly define what, who, when, how, and where.
For samples of Management Review procedures and a Management
Review Agenda from wastewater facilities, see Appendix A.
Step 5) Check Your Management Review
Procedure for EMS Conformance
Check v'
1. Are management reviews scheduled on a regular (at least annual)
basis?
2. Does the management review check for the effectiveness of the
EMS based on policy, Objectives & Targets, previous audits,
changes to operations, etc.?
3. Are management reviews documented and recorded? Are action
items tracked?
/ .ten jting to implement improvements to your operation* win
ft ) if you don't have management's full support,
commitment and involvement.
'/OP* win
77
Rick Bickerstaff
Charleston, South Carolina
Commissioners of Public Works
Information to Cover
During the
Management Review
^ Audit results - EMS and
compliance status
^ External communications
^ Progress on achieving objectives
and targets
^ Progress towards or achievement
of environmental performance
measures
^ Reports of emergencies, spills,
other incidents and/or accidents
^ Status of corrective actions
^ Results of action items from
previous management review
meetings
^ Policy revision based on EMS
effectiveness and suitability
^ Changing circumstances (e.g.,
changes in operations or servic-
es, new customers, etc.)
EMS Manual
,
Work Instructions, Forms,
Drawings, etc.
A Management Review system
procedure is required for this
element. A system procedure defines
the purpose (why the procedure is
needed), scope (to what
operations/areas/staff the procedure
applies), roles & responsibilities (who
needs to complete the tasks), and the
tasks that need to be completed for
this element.
Section 3: Management Review (Phase 5)
Wastewater EMS Handbook
I67
-------
Three Keys to
Success
(from wastewater facilities):
1. Top management must receive
frequent updates, especially with
regard to the status and
performance of your EMS
objectives and targets.
2. Management reviews should
assess how changing
circumstances might influence the
suitability, effectiveness or
adequacy of your EMS. Changing
circumstances might be internal to
your organization (such as new
facilities, changes in products or
services, new customers, etc.) or
might be external factors (such as
new laws, new scientific
information, changes in political
leadership, or changes in adjacent
land use).
3. 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.
Three Lessons Learned
(from wastewater facilities):
1. Communicate and review with top
management to find out what they
would like to see in order to assess
the EMS. If the meeting is relative to
management, they will continue to be
more engaged and committed to
the EMS.
2. Provide top management with just
a summary of the EMS. Top
management are "big picture" people
and do not need a lot of detail during
the management review meetings.
3. Ensure that all levels of
management (division, line managers,
etc.) participate in management
review meetings.
I68
inning has improved considerably. Prior to
stablishment, no formal, consistent structure
was available for environmental planning. Also, our
planning is much more focused by having a
management review process. EMS drivers are
known in our place, and employees have a better
understanding of the reasons behind planning
initiatives. Additionally, knowledge of our facility's
impact on the environment has been heightened
and is reviewed on a regular basis.
Duty's
ened
Rick Bickerstaff
Charleston, South Carolina
Commissioners of Public Works
f am jement review meetings provide good
d ;e for progress and improvement, a
resource for future projects, and a strategic
direction for future departments' involvement.
Tri-County Metropolitan Transportation District
Portland, Oregon
Section 3: Management Review (Phase 5)
Wastewater EMS Handbook
-------
r ____________
Management Review
(Cut out this section for handy reference)
The Purpose of this EMS element is to:
o Establish a management review system to check the effectiveness and adequacy of the EMS.
The Results of this EMS element are:
o Identification and confirmation of a group of key management level personnel who will attend
scheduled management review sessions.
o Development of a management review procedure (EMS Document) that addresses the
requirements of the EMS and is appropriate and effective to your organization's operations
and services.
o Establishment of a schedule, agenda, and meeting notes (EMS Record) for your management
reviews.
Before you Begin this EMS element:
o Establish an EMS internal audit and corrective action system.
o Establish all elements of your EMS.
""
169 Section 3: Management Review (Phase 5)
Wastewater EMS Handbook
-------
ISO 14001
Requirements
Links to Other EMS
Elements
Required Documents
& Records
Optional Documents
& Records
Management Review
The organization's top
management shall, at
intervals that it
determines, review the
environmental
management system, to
ensure its continuing
suitability, adequacy and
effectiveness. The
management review
process shall ensure that
the necessary information
is collected to allow
management to carry out
this evaluation. This
review shall be
documented.
The management review
shall address the possible
need for changes to policy,
objectives and other
elements of the
environmental
management system, in
the light of environmental
management system audit
results, changing
circumstances and the
commitment to continual
improvement.
All elements of the EMS are
linked as part of the
Management Review.
Management Review
Procedure
Meeting Minutes
Management Review
Agenda
Section 3: Management Review (Phase 5)
Wastewater EMS Handbook
170
-------
Section 4: Third-Party Registration
Now that you have conducted your EMS Internal Review and
Management Assessment at your wastewater facility, you may
want to consider a third-party audit of your EMS and go for ISO
certification.
EMS third-party registration provides a check that an organization has
met the requirements of an ISO 14001 EMS and has demonstrated a
commitment to environmental management and improvement.
Furthermore, public organizations have achieved a number of benefits
from EMS implementation and registration/certification, including public
(local community) recognition and managing environmental issues in a
more consistent way. This section describes the process and benefits of
having your facility go through a third-party review based on the ISO
14001 International EMS Standard. Most Publicly Owned Treatment
Works (POTWs) in the U.S., including those who helped develop this
guide, have followed this approach to EMS implementation.
What this Section Will Cover:
O Third-Party Registration
O Why Wastewater Facilities Choose Third-Party Registration
O The Benefits of Third-Party Registration
O Step-by-Step Overview of a Third-Party Registration
Process
O The Keys to Selecting a Third-Party Registrar
O The Costs and Typical Timeline of Third-Party Registration
O The Keys, Lessons Learned and Things to Avoid when
Considering Third-Party Registration
O EMS Registrar POCs with Wastewater and Public Sector
Experience
"=> FAQs
Key Section Terms
ISO 14001 - The standard protocol
(requirements document) in the ISO
14000 series that specifies the nec-
essary elements of an EMS.
Auditor - Person with the
qualifications to conduct an EMS
audit.
American National Standards
Institute Registrar Accreditation
Board (ANSI-RAB) - Body that
accredits ISO 14001 Environmental
Management Systems (EMS)
registrars and auditors.
Conformance - To verify an
organization's EMS to a specified
standard (ISO 14001).
Registrar - A third-party
organization that awards the EMS
certification.
Registration -A recognized valida-
tion that an EMS has passed an
accredited independent, third-party
audit.
Self-Declaration - An internal
review of conformance to all ele-
ments of an EMS. EMS self-declara-
tion is an organization's statement
that it conforms with all elements of
the ISO 14001 Standard.
Surveillance -Ascheduled sam-
pling of EMS elements to maintain a
third-party registration.
Third-Party -An independent EMS
auditor that is qualified to conduct
EMS audits.
Section 4: Third-Party Registration
Wastewater EMS Handbook
I7I
-------
Implementing
an ISO 14001
EMS does not
require third-
party registration.
However, many organizations,
including wastewater
operations, have experienced
benefits from obtaining third-
party registration.
One wastewater facility used a RFP
selection process to choose its
Third-Party registrar based on the
following criteria:
0 Registrar's experience
conducting ISO Registration
Services. (20 Points)
0 Registrar's experience
conducting ISO Registration
Services for public
agencies, particularly
wastewater treatment
agencies. (20 points)
0 Qualifications and
experience of assigned lead
auditor(s). (20 points)
0 Match of registrar's auditing
philosophy with our EMS
policy, goals, and
objectives. (20 points)
0 Registrar's experience and
reputation for satisfactory
work, judgment, integrity, and
reliability. (Used Reference
Checks)
(20 points)
0 Overall cost of the proposal.
(20 points)
What is Third-Party Registration?
Third-party registration is an independent review and recognized
validation of an organization's EMS. An organization can meet the
objectives and requirements of an ISO 14001 EMS either through self-
declaration or through third-party registration. Many public organizations
that have chosen third-party registration have experienced a greater
level of credibility with their communities and outside stakeholders
because of the independent review.
NOTE
Keep in mind that a third-party EMS conformance review
k is not a compliance audit. Prepare and keep staff on
. their toes, but realize that this review is to assist
you in meeting your EMS goals on continuous
improvement.
Third-Party Registration Audit
Looks for system elements and
linkages
Based on verifying that the 17
elements of an EMS are
institutionalized
Focuses on employee interviews
and document review
Regulatory Compliance Audit
Looks for regulatory violations
Based upon meeting applicable
environmental laws and regulations
Focuses on individual operations
and outputs
Why Wastewater Facilities Choose Third-
Party Registration: The Drivers & Benefits
A successful third-party review of an organization's EMS can help
maintain a system's integrity, establish credibility, and inspire greater
confidence in external stakeholders (e.g., the public, regulators,
governments, and other organizations); third-party registrars
act independently and review an organization's EMS in an
unbiased manner.
To jdd system credibility from an outside independent source."
Buncombe County, North Carolina
"Good Public Relations" and "Incentives from regulatory agencies to provide
benefits to environmentally proactive organizations."
Gastonia, North Carolina
"To force private contractors to achieve similar service and verifiable levels."
San Diego, California
m
Section 4: Third-Party Registration
Wastewater EMS Handbook
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Internal Benefits of a EMS Third-Party Registration:
Assures that EMS system elements are in place and working as
expected
Protects the investment made in the EMS
Keeps management's and staff's attention on the EMS
External Benefits of a EMS Third-Party Registration:
Provides credibility and commitment to external stakeholders
Improves relationship with regulators
Supports federal and state EMS incentive programs
Questions to Think About When Considering a
Third-Party Registration:
ป Are competitors and peer organizations pursuing registration?
ป Are "customers" indicating that they require or desire registration?
ป Will registration improve the relationship with regulatory agencies?
ป Will insurers offer preferential treatment because of perceived lower
risk?
ป Will registration improve public relations with the surrounding
community?
Step-by-Step Guide to Third-
Party EMS Registration
1) Select a Registrar
2) Prepare Staff for EMS Third-Party
Registration Audit
3) Have an EMS Desktop Review Conducted
4) Support the EMS Third-Party Registration Audit
5) Follow-up on the EMS Third-Party Registration Audit
Step 1) Select a Registrar
How should you go about selecting a registrar to externally verify your
EMS? And what should you look for in a registrar? What about costs?
These questions were put to wastewater facilities that have been there.
Asking the "right" questions...
Each organization must consider whether an ISO 14001 registration will
provide worthwhile benefits. Five (5) wastewater treatment facilities
NOTE
1' Each organization must consider whether an ISO 14001
. registration will provide worthwhile benefits. Five
j^ wastewater treatment facilities from around the country
~ and of various sizes were asked to provide their
experiences, lessons learned and the keys to success as they
went through the process of third-party registration. All of the facilities
have implemented and maintained third-party registered EMSs.
Waste water Facility
Benefits
"Third-Party EMS registration
confirms to the public and regulatory
agencies that the ISO standard is
being conformed to. Second, having
a Third-Party audit prompts CPWs
staff to develop better strategies on
how to conform to the standard.
Third, the Third-Party audit gives
management a greater sense that
the system is in place and is i
exactly what it was designed
accomplish."
se mar
If
Rick Bickerstaff
Charleston, South Carolina
Commissioners of Public Works
if Thi\
Th( Third-Party registration process
3v is the staying power to build a
system that, now if maintained as
intended, will provide a framework
for continual environmental and
other organizational improvements.
This system ensures management's
continued involvement in clearly
defining our environmental goals,
keeps staff more engaged and
accountable, provides another
perspective outside of the
organization, provides us a much
better document control system, and
provides better credibility and
service to the communities we
Donna Adams
Eugene, Oregon
Wastewater Division
serve.
Section 4: Third-Party Registration
Wastewater EMS Handbook
173
-------
Keys to Success
1. Be flexible. Don't stress over
on-site recommendations during
the EMS third-party registration
audit. The auditor should allow
ample time to modify and close
out any minor or major
nonconformances.
2. Prepare the Steering
Committee, EMS Team,
Department Supervisors and
frontline employees concerning
questions that could arise during
the third-party audit. The frontline
level employees need to
understand that they do not need
a textbook answer for a question.
Simply tell them to answer
questions in their own words.
3. Make "cheat sheets" for the
employees (i.e. post the
significant aspects, impacts,
objectives, targets,
environmental policy, and
emergency procedures in all
departments). This allows the
employees an avenue of
discussion with the auditor if
they cannot remember the
details. The employee can show
the third-party auditor the
bulletin board information.
4. Look for ISO 14001 third-
party auditors with wastewater
and public sector credentials
and experience.
5. Look for registrars that have a
Board of Directors and a
mechanism to give feedback on
their auditing. Sometimes,
auditors can be inflexible and
difficult to work with. Discuss
this with their review board or
the auditing organization they
work for.
from around the country and of various sizes were asked to provide
their experiences, lessons learned and the keys to success as they
went through the process of third-party registration. All of the facilities
have implemented and maintained third-party registered EMSs.
NOTE
Four of five of the wastewater managers
conducted qualifying interviews with Registrars.
Four of five interviewed multiple Registrars.
Wastewater facilities that conducted interviews to qualify registrars
considered the following to be the most important in registrar selection:
Public, utility, chemical and wastewater sector experience.
Comfort with the auditor; personality of the auditor relating to
staff; staff level of comfort and friendliness with the auditor (i.e.,
shirt and tie NO; blue jeans and boots YES).
Good price for services received.
Knowledge of how public entities are set up and operate.
The added value expected from the registrar through the
registration process.
Technical and auditing expertise of the registrar staff.
Step 2) Prepare Staff for EMS Third-Party
Registration Audit
Congratulations! You've made the decision that a third-party registration
of your EMS makes good business sense. You've interviewed several
registrars, and have decided on one company that best suits your
organization. You've signed a contract, developed an audit plan and
agreed on an audit schedule. You are ready to go and so are the
auditors. Generally, when the auditors arrive they will have a tight
schedule of documents to review, people to interview, reports to write,
and audit results to discuss. Your job is to support the audit function by
preparing your managers, your employees, and your documents and
records. All of these should be readily available for the auditors
according to the prearranged audit schedule.
Well in advance of the audit, prepare management by:
^ Reviewing their EMS responsibilities
^ Rehearsing the type of questions that the auditor might ask them
(see NSF guide Second Addition, Appendix A, pages 153 - 156)
^ Preparing them to organize and track corrective actions that the
audit identifies, (i.e., how the organization will respond to
nonconformances if found)
NOTE
^ A team of individuals typically made the choice on which
registrar to select at wastewater treatment facilities, with
op management giving the final approval (sign-off).
174
Section 4: Third-Party Registration
Wastewater EMS Handbook
-------
^ Indicating on managers' calendars suggested times for the
pre-audit meeting to review the audit scope, plan and schedule,
and the closing meeting to share audit findings
^ Encouraging them to be visible, involved, and available for the
month of preparation preceding the registration audit
^ Freeing up the Environmental Management Representative to
accompany auditors on their rounds
Well in advance of the audit, prepare employees by:
^ Emphasizing the "find, fix, and prevent" opportunity the audit provides.
^ Reviewing the environmental policy and confirming the role it has in
employees' daily activities
^ Reviewing significant aspects, objectives and targets with relevant
department managers and the front-line
^ Rehearsing the type of questions that the auditor might ask
employees (you may want to use the checklist you developed in
the internal audit)
^ Reviewing EMS roles and responsibilities
NOTE
Wastewater Facilities: Four of Five have six-month
surveillance audits and One of Five have
three-month surveillance audits.
Well in advance of the audit, prepare documents and records by:
^ Ensuring they are current, easily retrievable, and managed accord-
ing to your document control procedures
Step 3) Have an EMS Desktop Review
Conducted
An EMS "desktop" or document review, required for an EMS
registration audit, is a review (by a third-party) of EMS policies,
procedures and records before the third-party auditor comes onsite to
conduct a full EMS audit and interview personnel. Some auditors
prefer to conduct this onsite in conjunction with other audit activities.
The desktop is conducted to provide the auditor a "snapshot" overview
of an organization's EMS elements and how they fit together. A
desktop review also provides the auditor with a first look at an
organization's EMS and how the system elements fit with your current
environmental programs and will therefore increase the efficiency of
the third-party on-site audit.
An EMS desktop review will benefit the organization by assuring that
key documents and records are in place and accessible.
NOTE
The five wastewater facilities that have an EMS in
place and contributed to this Handbook had
EMS desktop reviews conducted approximately
two months before the third-party on-site audit.
Lessons Learned
(from wastewater facilities):
1. Don't be afraid to disagree with the
auditor and stand up for your program
if you feel what you have done meets
the requirements of the standard.
2. Contact other organizations that
have been successful in passing their
thir-party registration audit for
information and documentation
examples, so that you learn from the
experiences of other organizations.
3. Keep it simple! This is particularly
true for your environmental aspect
identification and for how you
determine environmental significance.
If you have a complicated aspect
analysis system, third-party
registration may be harder to maintain.
4. Only have one current procedure
available for what you do! Remove old
documents before your third-party audit.
5. When the third-party auditors
come out to review your EMS, make
sure to stress to employees that the
auditors are not auditing them, but
auditing a system.
Section 4: Third-Party Registration
Wastewater EMS Handbook
175
-------
Things to Avoid
(from waste/water facilities):
1. Scheduling audits with major
commitments prior to and after the
audit. You will want ample time to
reflect on the system prior to the
audit and after.
2. Unnecessary interruptions during
the registration audit.
3. Selecting registrars with no
technical or related industry
expertise.
4. Being unprepared! The
Environmental Management
Representative, Document
Administrators and all key staff
must be prepared before a
third-party audit.
NOTE
Consider having a third party
review your EMS whether you
decide to officially certify to
ISO 14001 or not. An external
^ set of eyes will help
you identify new
v opportunities to
r improve your EMS
that you may have
missed. If cost is an issue,
consider asking other public
organizations in your area to
form a pool of qualified
auditors and review each
other's EMSs.
NOTE
\ Do not stress! Employees do not have to give textbook
ranswers to the auditor. They simply need to know the
basics of an EMS and how it affects their jobs.
Step 4) Support the EMS Third-Party Registration
Audit
Support an EMS registration audit by:
*~ Providing facilities (i.e., place to work, computers, etc.) required for
the third-party audit team to be effective and efficient.
*~ Providing access to on-site areas and systems to interview person-
nel and retrieve documents and records.
*~ Cooperating with the audit team so that the EMS third-party audit
objectives will be achieved.
Step 5) Follow-up on the EMS Third-Party
Registration Audit
Once the third-party audit has been completed, the audit team will review the
findings so that the organization will have a clear understanding of the audit
team's findings. One of the following recommendations will then be given:
Recommend registration: certification is immediately issued and the
organization is added to the public register.
Recommend registration after corrective actions: minor non-
conformances or "find, fix, and prevent" issues were found and will be
corrected within a prescribed time period that is agreed upon by both
the auditing organization and the facility.
Recommend onsite re-audit: one or more findings of major
nonconformance were found or enough minor nonconformances were
identified by the third-party audit to show system inconsistencies.
Remember that this is a find, fix, and prevent management system. A
finding of a major nonconformance is unlikely since you've had the
third-party auditor(s) conduct a desktop review and you've prepared
your staff. Use your own internal EMS audits and the third-party audit
as an opportunity to improve your EMS.
NOTE
An ISO 14001-based EMS registration is valid for three
\ years. Once completing the registration, an organization
*can choose to have an EMS surveillance (sampling)
audit every six months or every year, but must have all
elements of an (ISO 14001) EMS audited at least every three years
to maintain third-party registration.
I76
Section 4: Third-Party Registration
Wastewater EMS Handbook
-------
Activities/Timeline of EMS Initial Registration
Process
ป Development and solicitation of RFP or Qualifications - average
one to two months
ป Interviewing, Negotiations and Selection - average one month
ป Arrangement of Audit Schedule - average one month
ป Pre-Review (Desktop Audit) - average one to two months
ป Registration Audit - average three days
These tasks take place concurrently.
What if I do not Choose Third-Party Registration?
If all requirements of an ISO 14001 EMS are fully implemented and self-
declared, then the organization will reap the same internal benefits as an
organization earning third-party registration. The primary difference
between the two is the independent, objective credibility provided by a
third-party registration. If the third-party objectivity and credibility are
irrelevant to the organization, then self-declaration of an ISO 14001 EMS
may be preferred.
/' O 1,001 Registration conveys a
sil , professional image to our
sewer ratepayers and to community
non-go vernmental organizations.
ISO 14001 Registration also
provides our own employees with a
real sense of professional
competence and accomplishment.
Our employees connect with our
governmental organization being a
business system and our
management decisions based >
a Plan-Do-Check-Act system,
than politics or personalities.
Chris Toth
City of San Diego
Wastewater Collection Division
/ ,O i gistration gets an objective
t c :yes in to look at your system
and it adds credibility to what you
have done. Additionally, we feel that
it strengthens our position against
potential privatization since it would
be difficult for a private company to
compete with our management
process and offer the same
customer service to our citizens anc
the environment and manage /
organization better than we do,
Beth Eckert
Gastonia, North Carolina
Public Works and Utilities Department
Table 1.0 Costs and Number of Auditors/Days for EMS Initial and
Surveillance Audits.
WW Facility
Buncombe
Gastonia
San Diego
Charleston
Eugene
Fenceline
WW Plant
Two WW Plants, lab,
pretreatment
Operations and
Maintenance Division
WW Plant
WW Division, not
including O&M
Size (In
Average
MGDOF
WW)
40
22
180
36
62
Year of
Initial
Registration
2002
2001
1999
1999
2001
Initial
Registration
Cost
$ 10,500
$ 7,500
$ 7,000
$ 11,000
$ 8,300*
#of
Auditors
1
2
2
2
1
# of Days
Auditor(s)
On Site
2.5
2.5
3
4
3
Ongoing Costs of
(External)
Surveillance/
Maintenance
Audits (in
Dollars/Year)
$ 3,000
$ 3,200
$ 5,000
$ 9,000
$ 3,000
#of
Auditor(s)
1
1
2
2
1
# of Days
Auditor(s)
On Site
1.5
1
3
4
1
Note: included application fee, desk audit, on-site readiness review, registration audit, and final report
Section 4: Third-Party Registration
Wastewater EMS Handbook
177
-------
Table 2.0 EMS Registrar Experience and POC Information.
from EMS Waste water Steering Committee
EMS Registrar POC Info
Wastewater Experience?
(Yes Or No)
Public Organization Experience?
(Yes Or No)
Registrar name: NSF International
Strategic Registrations, Ltd
Address: 789 N. Dixboro Road,
Ann Arbor, Ml 48105
Phone #: 1-888-NSF-9000
Email Contact:
Website: www.gehrke@nsf-isr.org
Yes
Yes
Registrar Name: Advanced Waste
Management
Address: 6430 Hixson Pike,
Chattanooga, TN 37343
phone #: 423-843-2206
Email Contact: mail@awm.net
Website: http://www.awm.net
With Charleston CPW Only
No
Registrar Name: AQA International
Address: 1105 Belleview Avenue,
Columbia, SC 29201
Phone #: 803-779-8150
Email contact: bob@aqausa.com
Website: www.aqausa.com
Yes
Yes
ABS Quality Evaluations
Registrar Name: Georgene Porter
Address: 16855 Northchase Drive,
Houston, TX 77060
Phone #: 281-877-6800
Email contact:
Website: www.absconsulting.com
Yes
Yes
ABS Quality Evaluations
Registrar Name: Jack Carmody
Address: 16855 Northchase Drive,
Houston, TX 77060
Phone #: 281-877-6800
Email Contact:
Website: www.absconsulting.com
Yes
Yes
178
Section 4: Third-Party Registration
Wastewater EMS Handbook
-------
Frequently Asked Questions about ISO 14001 Third-Party Registration
While third-party registration may be common in industry, it
is a relatively new concept for public entities. The PEER
Center has gathered the questions most commonly posed
about ISO 14001 registration and asked a registrar to
answer them for you. Questions are organized in a
"Before," "During," and "After Registration" format:
Before Registration:
Q. What is the difference between the terms
and "certification?"
A. In common usage and even in publica* d terms
are used interchangeably. The distinction r nade that
you "register" a management system e rtify" to a
product standard but this distinction is rarely noted in the
world of ISO 14001. Even the Standard refers to
"certification/registration."
Q. Who is ANSI-RAB and what is their role in registration?
A. RAB stands for the Registrar Accreditation Board. The
American National Standards Institute (ANSI) and RA
have joined to form the National Accreditation Progr;
(NAP) for ISO 14001 and 9000. The NAP also covers 1
accreditation of providers offering the 36-hour Lead El
Auditor course. Registration programs for both EMS c,,,^
QMS auditors are operated solely by RAB, separate from
the NAP.
RAB, headquartered in Milwaukee, Wl, is a not-for-d
organization that is financially self-supported and governed
by a 15-member board of directors. Members of the board
represent both quality and environmental stakeholders and
include technical experts, business executives, industry
representatives, and employees of registrar organizations.
Q. How can I find out who the accredited registrars are?
A. The RAB website at www.rabnet.com contains a list of
accredited registrars.
Q. How can I find out who the registrars with wastewater
and/or public sector experience?
A. Check the POC table (Table 2.0) on page 7.
Q. What if I do not like the registrar audit team or team
leader?
A. RAB says that your registrar must inform you of the
names of your audit team members in time for you to appeal
against the appointment of any particular auditor. So, if for
some reason, you do not feel like the assigned auditor is the
right one for your organization, let your registrar know as
soon as possible.
During Registration:
Q. What happens if I disagree with a finding made by the
registrar?
A. As noted above, accredited registrars are required to
have procedures or policies to address dispute resolution.
Ask your registrar about this process before the audit begins.
Q. What happens if the auditor finds a regulatory
noncompliance during the registration audit?
A. Good question! First of all, it does not mean that you
have automatically failed the audit. If your registrar identifies
a noncompliance, RAB says that you may still become
registered if your EMS addresses such noncompliances
a/hen taken into consideration, the noncompliances do
a major nonconformance with ISO 14001
auditor is not there primarily to determine
if you ,. >mpliance, but rather to determine if you are
adequat laging your compliance obligations as part
of your I
to ensure that your EMS is adequately
mpliance issues is to: 1) Be knowledgeable
jderal, state, and local environmental and legal
,ients; 2) Undertake periodic assessments of your
compliance; 3) Have procedures in place to identify
respond to instances of noncompliance, including
rocedures to identify the root causes of noncompliance to
nsure they do not reoccur.
Your accredited registrar is required to have methods for
Iandling and reporting any discoveries of noncompliance
o be sure to ask how they would handle this situation if it
rises.
After Registration:
Q. Once I have successfully completed the audit and
become registered to ISO 14001, what is next? Are follow-
up audits required?
A. Yes, follow-up audits, called surveillance audits, are
required and are another strength of the third-party audit
system. The required surveillance after you achieve
registration is another strength of the third-party system.
Surveillance helps to ensure that your EMS stays in
conformance with ISO 14001 and that it is continually
improving. Under RAB's requirements you have two options
for surveillance:
1. A six-month surveillance cycle with no re-audit after
three years, or
2. An annual surveillance with a re-audit after three years.
With either option, the number of audit days/year is
the same, except for the re-audit. For example, you
can choose to have your auditor on site for two days
once a year or for one day twice a year. There are
pros and cons for each option.
Q. Can I lose my registration?
A. Yes you can, but if you diligently address all issues
identified during the surveillance audits in order to maintain
and improve your EMS, this is unlikely to occur.
Section 4: Third-Party Registration
Wastewater EMS Handbook
179
-------
Section 5: Maintaining Your EMS
Congratulations! You have developed an EMS at your wastewater facility and have successfully completed
the initial audit of your system. You have established a clear policy that sets the stage for your EMS,
thoroughly analyzed your environmental "footprint," and set measurable objectives and targets for your EMS.
You have also trained your employees on their responsibilities under the EMS, modified a number of
operational procedures and controls, performed an internal audit of the system, and conducted at least one
management review. It is now time to maintain and update the EMS foundation that you put in place.
As part of maintaining and improving the groundwork that you put in place, you will be testing, reviewing, and
updating your EMS policy and procedures, continuing to train and communicate with employees and the
public, reviewing your environmental impacts, and checking and improving your system through internal
audits and management reviews. Also, you will continue to maintain the enthusiasm and buy-in from
employees, the public, and management by tracking and reporting on the performance and benefits of your
EMS.
The table below presents the stages of EMS development, from developing and implementing your system, to
engraining the EMS as the way you do business.
Timeline
The Stages of EMS Development1
-- Beginning -- -- Deploying -- -- Maturing --
EMS Under Development EMS Registered/In Conformance EMS as a Business Practice
0-2 years
2-5 Years
5+ Years
Goals
Develop an EMS - build on policies, proce-
dures, and programs that are in place
Complete initial third party audit
Strengthen linkages among the EMS ele-
ments
Demonstrate the performance and (cost)
benefit of the EMS, both internally and to
key stakeholders
Continue to define and meet stakeholder
needs
Achieve/maintain high level of environmen-
tal performance and demonstrate real busi-
ness value
Activities
Strengthen compliance and other programs
Understand ISO 14001 requirements and
the systems approach
Learn how to communicate the EMS to the
public; train employees
Building foundation policies, procedures,
and programs
Use the EMS to integrate and align existing
programs and systems:
quality/health & safety
Asset Mgmt, CMOM, QualServ
resource allocations
operational controls
information and support systems
training
communication and reporting
Continue to develop and enhance metrics
for EMS and other performance tracking
Improve efficiency through process improve-
ment
Streamline systems
Consolidate documentation
Include EMS and other environmental data
in the strategic planning process and in
daily business decisions
Tracking of nonconformances with empha-
sis on prevention ("find, fix, and prevent").
Corrective/preventive action process is well
established.
Characteristics
Energy/resource intensive
Management provides resources, but direct
involvement may be limited
Use available or very simple metrics to
measure EMS performance
Corrective (and particularly preventive)
action processes in development
EMS is still being refined
Focus is still on the present, not the future
EMS is becoming part of the business
process
Cultural change starting
Management understanding and use of
EMS in key decisions increases
High level of management involvement
EMS serves as a launch pad for new envi-
ronmental initiatives
Use of environmental metrics is well estab-
lished, metrics continue to improve, and
clearly support business goals
Linkages within the EMS and with other
management systems are well established
and understood
Cultural change continues as the EMS
becomes the way the organization does
business
' Adapted from NSF International
Section 5: Maintaining Your EMS
Wastewater EMS Handbook
I8I
-------
Section 6: Conclusion
In this Handbook, we have attempted to give other wastewater agencies and public entities a clear sense of the
steps needed to put an effective EMS in place, based in large part on the experiences of agencies that have
successfully done so and are now seeing the benefits of their efforts. Clearly, there is much more information
that could be provided, but one of the strengths of this project is the enthusiasm of these agencies and their
willingness to share information and insights with their colleagues. With this in mind, we urge you to contact
these individuals for more information as you develop your own EMS. They are the true "experts." Here is their
contact information:
Donna Adams
Environmental Health & Safety Coordinator
City of Eugene, Wastewater Division
410 River Road
Eugene, OR 97404
ph 541-682-8613
fax 541-682-8601
donna.j. adams@ci. eugene. or. us
Ellen R. Barrett
President, The Barrett Group
16116 Tana Tea Circle
Fort Mill, South Carolina 29708
ph 803-802-3894
fax 530-504-8508
ebarrett@cetlink. net
Rick Bickerstaff
Assistant Superintendent
Wastewater Collection Department
Commissioners of Public Works
Charleston, SC28814
ph 843-308-8201
BickerstaffRE@CharlestonCPW. com
Beth Eckert
EMS Coordinator, City of Gastonia
PO Box1748
Gastonia, NC 28053
ph 704-866-6035
fax 704-867-0120
bethe@cityofgastonia. com
David James
Texas Natural Resources Conservation
Commission
Department: SBEA
PO BOx13087(MC112)
Austin, TX 78711
ph 512-239-3184
djames@tceq. state, tx. us
James Naber
EHS Manager
Buncombe County Metropolitan Sewerage District (MSD)
PO Box 8969
Asheville, NC 28814
ph 828-254-9646
fax 828-254-3299
jnaber@msd. buncombe.nc. us
Jim Newton, P.E., DEE
Environmental Program Manager
Kent County Levy Court Public Works
414 Federal Street
Dover, DE 19901
ph 302-744-2437
fax 302-736-2100
james. newton@co. kent. de. us
Eileen O'Neill
Director of Training and Technical Services
Water Environment Federation
601 Wythe Street
Alexandria, VA 22314-1994
ph 703-684-2462
fax 703-684-2492
eoneill@wef.org
Chris Toth
Deputy Director, Wastewater Collection Division
City of San Diego
9150 Topaz Way
San Diego, CA 92123
ph 858-654-4161
fax 858-654-4139
ctoth@sandiego.gov
Section 6: Conclusion
Wastewater EMS Handbook
183
-------
Appendix A
EMS Sample Documentation
I. Environmental Policy
II. Legal & Other Requirements
III. Environmental Aspects And
Impacts
IV. Objectives and Targets
V. Environmental Management
Programs
VI. Training
VII. Internal & External
Communication
VIM. Document Control And
Record Management
IX. Environmental Management
System (EMS) Manual
X. Operational Control
XI. Emergency Preparedness
XII. Monitoring And
Measurement
XIII. EMS Internal Audit
XIV. Nonconformance And
Corrective Action
XV. Management Review
-------
SAMPLE EMS DOCUMENTATION
ENVIRONMENTAL POLICY
Charleston CPW - Environmental Policy
City of San Diego WWC - Environmental Policy
Kent County DPW - Environmental/Biosolids Policy
-------
File/Retrieval ID (Optional):
Record Schedule No./Retention Period:
03603A/Permanent
Originator: P2 Team
Commissioners of Public Works
4.2 - Environmental Management System - Environmental Policy Statement
The Charleston Commissioners of Public Works (CPW) is committed to the
improvement of the environment for present and future generations through:
The treatment and delivery of safe potable water.
The collection, treatment, and proper disposal of wastewater.
The responsible impact of its activities, products and services on the
environment.
The continual environmental improvement and the prevention of pollution.
Compliance with all applicable federal, state, and local laws, regulations,
statutes and other environmentally related requirements to which the
organization subscribes.
The establishment of environmental objectives and targets that are
periodically reviewed to ensure success.
And communication of its Environmental Management System to CPW
associates and to other interested parties.
CPW will establish and maintain an Environmental Management System (EMS) that
corresponds to the ISO 14001 Standard and the mission, vision, strategic business plan
and core values adopted by CPW.
William Koopman, Jr.,
General Manager
John Cook, PE,
Assistant General Manger
Kin Hill, PE,
Director of Operations
Dorothy G. Harrison,
Director of Administrative Services
Document No.: P2-4.2 (11/15/2002)
Page 1 of 1
Document Distribution
Controlled Original - Chairman, P2 Team
All other copies are uncontrolled
-------
METROPOLITAN WASTEWATER DEPARTMENT
WASTEWATER COLLECTION DIVISION
ENVIRONMENTAL POLICY
The Wastewater Collection (WWC) Division of the City of San Diego Metropolitan Wastewater
Department is committed to providing safe and effective sewer maintenance services in a responsible and
pro-active manner. A central mission of the WWC Division is to prevent discharges to waters of the U.S.,
protect local riverine and coastal resources and public health, support Departmental strategic goals and
meet regulatory agency standards at the lowest possible cost.
In fulfilling this commitment, it is the policy of the WWC Division to:
continually improve the Division's work processes and practices, communicate its efforts to protect
environmental health and public safety to interested stakeholders, and effectively manage or minimize
impacts to San Diego's urban and coastal environment;
comply with legal and regulatory requirements applicable to the Division, as well as with other
voluntary standards to which we subscribe; and,
prevent environmental pollution that may be attributable to WWC Division operations, and otherwise
seek to minimize waste and impacts to natural resources.
In keeping with this policy, the WWC Division will establish and maintain an Environmental
Management System that provides a framework for setting, and periodically reviewing, the WWC
Division's environmental objectives and targets for each of its processes, services and/or activities.
This policy is communicated regularly to all WWC Division staff and will be made available to
regulatory agencies, the general public, or other interested parties upon request.
(rev-10-02)
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KENT COUNTY LEVY COURT
POLICY
POLICY NUMBER:
SUBJECT:
ADOPTION DATE:
EFFECTIVE DATE:
SUPERCEDES:
SUPPLEMENTS:
E-6 PAGE
Environmental/Biosolids Policy
December 9, 2003
December 9, 2003
N/A
N/A
1 OF 1 PAGE(S)
The Kent County Levy Court commits to reduce the impact of its operations on the environment, by
adopting the International Organization for Standardizations ((ISO) 14001 Environmental Management
Systems standards, and the National Biosolids Partnership (NBP) Code of Good Practice for the
wastewater collection and treatment facility operations directed by the Department of Public Works.
In addition, the Levy Court requires all Public Works contractors employed at the covered facilities to
abide by this policy.
The Levy Court commits to:
Comply with all applicable environmental laws and regulatory requirements, to the NBP Code
of Good Practice and any other requirements to which the organization subscribes;
Have an environmental and biosolids vision and mission, then develop/achieve the objectives
and targets to implement this mission;
Improve continuously, through the EMS, management of our environment, our wastewater
effluent and our biosolids product;
Readily share our wastewater operations and biosolids information with interested stakeholders;
and
Practice daily pollution prevention activities.
This policy is communicated to all Kent County employees and the general public.
DRAFTED BY:
REVIEWED BY:
DATE SUBMITTED:
Kent County Department of Public Works Environmental Management
Systems Core Team
Global Environmental and Technology Foundation for the US EPA and
the Sewer Advisory Board
December 9, 2003
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SAMPLE EMS DOCUMENTATION
LEGAL AND OTHER REQUIREMENTS
Charleston CPW- Handling of Legal Requirements Procedure
City ofGastonia WWTP - EMS/Legal and Other Requirements Review
Standard Operating Procedure
City of San Diego WWC- Regulatory Tracking and Analysis Procedure
-------
CPW ENVIRONMENTAL MANAGEMENT SYSTEM
PROCEDURE
The on-line version and secured hardcopy are the controlled documents. The secured
hardcopy will be identified by an "Official Document" stamp giving date of
distribution. Any and all other documents are uncontrolled. Contact the EMS
Program Manager for revision level status.
Effective Date:
Revision: 2
Title:
Prepared By:
Reviewed By:
Approved By:
Date Approved:
October 1, 2000
Identification Number: EMS - 4.3.2
Page 1 of 3
Handling of Legal Requirements Procedure
EMS Procedures Subcommittee
EMS Management Steering Committee
William E. Koopman, Jr., General Manager
John Cook PE, Assistant General Manager
August 25, 2000
0.0 Requirement ISO 14001; Sub Clause 4.3.2
1.0 Purpose
This document describes the procedure to be followed for accessing and tracking
regulatory and other legal requirements.
2.0 Scope
This procedure is used to facilitate tracking of legal requirements and to assist
departments in the maintenance of regulatory compliance applicable to ISO 14001
Environmental Management System activities, products, or services.
3.0 Responsibility & Authority
3.1 Sections heads and departments heads are responsible to identify and analyze
environmental regulations and other legal requirements relevant to their activities,
products or services and communicating this information to the associates within
their section or department.
3.2 It is the responsibility of all associates to comply with the regulations.
-------
Effective Date: October 1, 2000 Page 2 of 3
Revision: 2 Identification Number: EMS - 4.3.2
Title: Handling of Legal Requirements Procedure
4.0 Procedure
4.1 Determination of the Type of Regulatory Requirement to be Identified
Each department shall identify the relevant environmental laws, regulations and
industry standards CPW adheres to. This may include international, federal, state,
regional and local regulations. Types of regulatory requirements to be identified
include environmental legislation that covers the protection of air, water, land,
natural resources and humans.
4.2 Impacts
A listing of major areas of the environment impacted by the department
operation; that is, air, water, soil, flora, fauna, and human (such as Risk
Management) will be made. The list will also include major types of wastes or
products that the operation generates or utilizes such as domestic waste, chemical
waste, waste oils, hazardous waste, paper, metals, glass, and so forth.
4.3 Agency Lists
A check of agency lists will be made. If the departmental operation impacts a
component of the environment or generates waste, the corresponding agency
should be consulted for regulatory requirements that may apply.
4.4 Regulatory Services
A regulatory service, library, or regulatory contact (such as South Carolina
Department of Health and Environmental Control) will be made to get a copy of
relevant environmental regulations. All levels of government will be checked to
see if there are regulatory requirements impacting departmental operations.
4.5 New Project or Change to Existing Operation
Each department shall review environmental requirements prior to the initiation
of a new project or modification of an existing operation. The department head
will check and coordinate with Design and Construction to ensure applicable city
and county codes are identified and met.
4.6 Consulting Engineers and Contractors working on site shall be made aware of this
procedure to ensure regulatory requirements are identified and met.
4.7 Organization and Tracking
A listing of regulatory summary sheets, or the regulations themselves, shall be
maintained, by paper file or electronically, and updated as necessary.
-------
Effective Date: October 1, 2000 Page 3 of 3
Revision: 2 Identification Number: EMS - 4.3.2
Title: Handling of Legal Requirements Procedure
4.8 Each department shall maintain a listing of regulatory requirements, including
detailed summary sheets, or the regulations themselves. This listing may be
maintained, by paper file or electronically or both and updated as necessary and at
least annually. Regulatory listings or summaries should be posted electronically
or made easily accessible to other departments.
5.0 Related Documentation
5.1 Regulations
5.2 Laws and Acts
5.3 Regulatory Self Assessment Reports
5.4 Permits and Permit Applications
-------
Standard Operating Procedure - EMS-01 00.001
Name: EMS/Legal and Other Requirements Review
Procedure
Prepared By: Beth Eckert, Environmental/Administrative Manager
Approved By: Beth Eckert, Environmental/Administrative Manager
Signature:
Corresponding
Requirements:
ISO Standard: 4.3 & 4.3.2
EMS Manual: 4.3 & 4.3.2
NBP Element: #4
Revision #: 5
Revision Date: 3/17/03
Effective Date: 1/1/00
Page
1 of 3
EMS/Legal and Other Requirements Review
Standard Operating Procedure
1.0 Purpose
1.1 The following procedure covers various requirements for reviewing areas of the
Environmental Management System (EMS). This procedure also provides a process for
identifying, reviewing, and maintaining the legal and other requirements documents.
Designated levels of management for each area of the EMS will complete the reviews.
2.0 Associated Equipment
2.1 None
3.0 Associated Reference Material
3.1 ANSI/ISO 14001-1996 Environmental Management Systems - specifications with
guidance for use.
3.2 City of Gastonia - Environmental Management System Manual (EMS-0100.000)
3.3 Legal and Other Requirements document (EMS-01'02.001)
3.4 National Biosolids Partnership (NBP) EMS Guidance Manual March, 2001
4.0 Procedure
4.1 EMS Manual
4.1.1 The EMS Team will review the EMS Manual, which includes a review of the EMS
policy, annually. See EMS Legal and Other Requirements document (EMS-
0102.001) reporting section for more specific scheduling. Any required revisions
will be reported to the POTW Director for approval and the EMS Coordinator, or
designee, will make the appropriate changes.
4.1.2 Any proposed changes to the EMS policy will be reviewed and approved by the
City Council as deemed necessary by the Management Review Board (MRB).
4.2 Aspects and Impacts
***This is an uncontrolled copy of a controlled document printed 8/20/2004 at 8:40 AM***
-------
Name- Number:
EMS/ Legal and other Requirements Review Procedure - EMS-0100.001
Revision #: 5
Revision Date: 3/17/03
Effective Date: 1/1/00
Page 2 of 3
4.2.1 A review of the aspects and impacts and significance will be conducted annually
for existing and new operations. Also, at any time during the year that a process
is added or modified. See EMS Legal and Other Requirements document (EMS-
0102.001) reporting section for more specific scheduling. Any changes to the
current significance list will be updated by the EMS Coordinator, or designee.
4.3 Emergency response plans
4.3.1 A review of the emergency response plans will be conducted semi-annually. See
EMS Legal and Other Requirements document (EMS-0102.001) reporting
section for more specific scheduling. Any changes will be reported to Division
Supervisor for approval. The Division Safety Supervisor will make the approved
changes to the plans and forward to the EMS Coordinator, or designee. The
EMS Coordinator, or designee, will update the computer network and issue
controlled copies using the appropriate distribution lists.
4.4 Quarterly MRB report review
4.4.1 At least quarterly, the MRB will review compliance reports, EMS Improvement
Program progress reports, EMS audit results, and any documented corrective
actions reports. Any changes to the EMS as a result of these reviews will be
approved by the EMS Coordinator.
4.4.2 The MRB will review monthly compliance with existing regulations and the
suitability and adequacy of the EMS.
4.4.3 The legal and other requirements for the current quarter being reviewed and the
up-coming quarter will be discussed at the quarterly MRB meeting.
4.5 Legal and Other Requirements
4.5.1 At least quarterly, persons listed in the Legal and Other Requirements document
(EMS-0102.001) as the responsible party will review the existing legal and other
requirements for their area and identify any new or modified items. They are
responsible for reporting this information to the EMS Coordinator, or designee,
for updating the Legal and Other Requirements document (EMS-0102.001).
***This is an uncontrolled copy of a controlled document printed 8/20/2004 at 8:40 AM***
-------
Name- Number:
EMS/ Legal and other Requirements Review Procedure - EMS-0100.001
Revision #: 5
Revision Date: 3/17/03
Effective Date: 1/1/00
Page 3 of 3
4.5.2 This information shall include, but is not limited to, new permit dates, inspection
dates, contractor information, regulatory reporting requirements, and review
dates of any identified legal and other requirements currently listed.
4.5.3 After the information is updated in the Legal and Other Requirements document,
designated supervision in each area will review and approve the changes and
send them to the EMS Coordinator, or designee. The EMS Coordinator, or
designee, will update the ISO directory and distribute controlled documents as
directed by the document control matrix (EMS-0101.000).
4.6 Objectives and Targets
4.6.1 Annually, designated supervisors in each area will review the current list of
significant aspects and impacts along with the current objectives and targets and
establish a revised list of objectives and targets for the coming year. See EMS
Legal and Other Requirements document (EMS-0102.001) reporting section for
more specific scheduling.
4.6.2 Any new objectives and targets and/or revisions will be submitted to the
designated supervisor in each area for review and approval. The EMS
Coordinator, or designee, after receiving approved objectives and targets will
enter the revisions onto ISO directory and update the EMS improvement
programs.
5.0 Revision History
Revision
Date
3/17/03
3/17/03
3/17/03
#
5
5
5
C/PAR #
EMS-0084
EMS-0116
Reason for
Revision
C/PAR
C/PAR
Clarification of procedure and
expansion
Description of Revision
Added a modification history section
Added NBP requirements as a part of the WWTD's
participation in the NBP demonstration group.
Reorganized procedure for clarification purposes and
expanded it for the department.
***This is an uncontrolled copy of a controlled document printed 8/20/2004 at 8:40 AM***
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DD-SEOP 4.3.2
REGULATORY TRACKING AND ANALYSIS
1.0 PURPOSE AND SCOPE
The purpose of this procedure is to ensure that the Wastewater Collection Division (WWC) of
the Metropolitan Wastewater Department (MWWD) has access to laws, and regulations that
apply to its operations.
This procedure covers laws, regulations, and other requirements established at the federal, state
and local levels that apply to the operations of WWC Division sections. The WWC Division
takes these requirements into consideration when setting its environmental objectives and targets
(Reference to DD SEOP 4.3.3, Establishment of Environmental Objectives and Targets).
2.0 DEFINITIONS
Reserved
3.0 RESPONSIBILITY AND AUTHORITY
3.1 The MWWD Environmental Monitoring and Technical Service Division (EMTSD) and
Environmental Program Management Division (EPM) are two of several service
providers to the WWC Division, as outlined in the Service Level Agreements (SLA). The
EMTSD and EPM bear primary responsibility within the overall MWWD for tracking
and maintaining updated records and reference documents for environmental laws and
regulations as well as environmental permitting requirements.
3.2 WWC Division personnel, including the Deputy Director or each Section Manager will
be delegated to disseminate information regarding any changes in regulations that could
affect operations or administration.
4.0 PROCEDURE
General
The permitting and other legal requirements applicable to WWC Division operations are
determined and routinely monitored by the numerous city organizations, including but not
limited to the Metropolitan Wastewater Department Environmental Monitoring and Technical
Service Division (EMTSD) Permits and Compliance Division and the Engineering and Program
Management (EPM) Division. Additional regulatory support is provided by other City
Departments, regional water enforcement agencies and the U.S. EPA. Such requirements are
documented in Section-specific operating permit inspection checklists prepared by the EMTSD
Permits and Compliance Section Head, which are distributed to the EMR.
DD-SEOP 4.3.2 June 2003
Legal Requirements Rev 1
MWWD WWC Division 1
-------
The EMR is responsible for coordinating the update of this information with EMTSD and EPM
or in liaison with other appropriate City Departmental or resource agency staff at least once per
year or whenever:
an existing applicable environmental rule or regulation is modified;
an existing activity, product or service is to be modified; or
a new activity, product or service is considered.
Compliance with the requirements identified in each section-specific list is verified by or at the
direction of the EMR or DD at least annually, as described in Chapter 5, Section 5.1. The EMR
maintains access to copies of relevant legislation through contacts with appropriate regulatory
agency representatives, libraries, information services, and/or the City Attorney's office.
As detailed in DD SEOP 4.5.4, "Environmental Management System Audits and Compliance
Verification", the WWC is responsible for auditing the regulatory compliance status of the
Division on a based upon a pre-determined schedule, and providing copies of appropriate
inspection check sheets to the EMR, EMTSD or EPM as applicable, with comments.
Follow-up evaluations of regulated status will occur on a bi-annual basis, or will occur sooner if
changes in the applicable laws and regulations are identified or significant changes in the
operations of WWC Division occur.
4.1 Within MWWD, the EMTSD and EPM share specific responsibilities for tracking
applicable environmental laws and regulations and identifying those related to the
operations of the WWC Division. The Divisions employ a variety of techniques and
information sources to regularly track, identify and evaluate applicable laws and
regulations. These include, but are not limited to:
Federal Government's Federal Register;
commercial services and databases;
Internet and WWC Division Intranet web sites;
the City Attorney's office;
information made available and provided by trade associations and membership
organizations; and
communications with federal, state and local regulatory agencies and authorities.
4.2 The EMTSD and EPM monitor these information sources on a regular basis i.e. quarterly
to ensure that new regulations and issues are identified and managed in coordination with
the WWC in a timely manner.
4.3 As necessary, "off-site" resources (e.g., consultants and attorneys) may be called upon to
assist in evaluating applicable laws and regulations or in developing programs in
response to applicable laws and regulations. Where off-site resources are used for this
purpose, the EMTSD and/or EPM is responsible for coordinating the effort with
appropriate WWC Division staff.
DD-SEOP 4.3.2 June 2003
Legal Requirements Rev 1
MWWD WWC Division 2
-------
4.4 The EMTSD, EPM and Section Managers disseminate information on applicable laws
and regulations (and the adherent potential impacts of the activities, processes, operations
conducted by the WWC Division) to appropriate personnel. The determination of which
personnel must be informed and the method for providing the information is at discretion,
based on the circumstances of each situation.
4.5 The EMTSD and EPM compile and maintain copies of significant applicable
environmental laws and regulations. Where copies of such laws and regulations are not
maintained at the Section Head's offices, EMR will ensure that ready access is available
from other sources (i.e., the other sources listed in Item 2 above).
4.6 If periodic site audits (i.e., planned environmental inspections, general environmental
compliance audits, ISO 14001 environmental management system audits, etc.) or
management reviews indicate or identify additional laws and regulations must be tracked
and evaluated, the EMR ensures that these activities take place.
4.7 The EMR will ensure that appropriate changes are developed and implemented in cases
where new environmental regulations, Division environmental policies and/or industry
standards could affect the continued performance of the ISO 14001 environmental
management system.)
5.0 REFERENCES
WWC Division Environmental Management Plan
Section 3.1, Environmental Aspects
Section 3.2, Legal Requirements
Section 3.3, Objectives and Targets
DD-SEOP 4.3.1, Environmental Aspects and Impacts Identification
DD-SEOP 4.3.3, Establishment of Environmental Objectives, Targets and Programs
DD-SEOP 4.5.4, Environmental Management System Audits and Compliance Verification
DD-SEOP 4.3.2 June 2003
Legal Requirements Rev 1
MWWD WWC Division 3
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SAMPLE EMS DOCUMENTATION
ENVIRONMENTAL ASPECTS AND IMPACTS
Kent County DPW - Determination of Significant Aspects Procedure
Kent County DPW- Significant Aspect List
Rivanna Sewer and Water Authority - Significant Aspect List
-------
Kent County Dept. of Public Works
Dover, Delaware
Environmental Procedures Manual
Determination of Significant Aspects
Title:
Determination of Significant Aspects
Document No.:
2-02-POl
Prepared By:
Jim Newton
Date Effective:
11-01-2003
Approved By:
Page:
Iof9
Revisions No. :
0
CONTENTS
1.0
2.0
3.0
4.0
5.0
6.0
7.0
8.0
9.0
PURPOSE
SCOPE
DEFINITIONS
REFERENCES
REQUIREMENTS
RESPONSIBILITIES
DOCUMENTS
RECORDS
ATTACHMENTS
10.0 APPENDICES
11.0 REVISION HISTORY
1.0 PURPOSE
1.1 The purpose of this procedure is to establish the general requirements for the work proc-
ess of determining the significant environmental aspects that are applicable to the Kent
County Dept. of Public Works Regional Wastewater Treatment Facility.
1.2 The purpose of this work process is to establish the Kent County Dept. of Public Works
specification for determining the significant environmental aspects that apply to the facil-
ity to facilitate compliance with the applicable requirements.
2.0 SCOPE
2.1 This procedure addresses the determination of significant environmental aspects applica-
ble to the Kent County Dept. of Public Works Environmental Program.
3.0 DEFINITIONS
3.1 Activity - Something that occurs at the wastewater facility in order to transport wastewa-
ter, or produce clean wastewater or Kentorganite.
3.2 Critical Control Point - An environmental aspect that is considered critical to ensuring a
quality biosolids product as required under the National Biosolids Partnership (NBP)
EMS program.
3.3 Environmental Aspect - The element of any activity, as defined above, that interacts with
the environment. An aspect is the element that causes the impact to the environment
from any activity that occurs at the wastewater facility, examples, include burning fuel,
used oil recycling, etc.
Kent County Dept. of Public Works
Dover, Delaware
Title:
Determination of Significant Aspects
-------
Environmental Procedures Manual
Determination of Significant Aspects
Document No.:
2-02-POl
Prepared By:
Jim Newton
Date Effective:
11-01-2003
Approved By:
Page:
2 of 9
Revisions No. :
0
3.4 Environmental Impact - Any change to the environment, either positive or negative,
wholly or partially resulting from the wastewater facility's activities. An impact is the
effect of any aspect with respect to the environment. Examples include degradation of air
or water quality, depletion or conservation of natural resources, etc.
3.5 Frequency/Probability - The number of times an environmental aspect occurs (e.g.,
daily, monthly, yearly, infrequently, etc.) or the likelihood of the aspect occurring (very,
not very).
3.6 Input/Output (I/O) Charts - Diagrams used to describe activities that occur at the waste-
water facility. Each diagram presents the activity, key resources needed by the activity,
products and byproducts of the activity, and wastes generated by the activity.
3.7 Significant Environmental Aspect - An environmental aspect that the Core Team has de-
termined to be serious enough to be included in the EMS program's objectives and tar-
gets in order to ensure that it is properly controlled.
4.0 REFERENCES
4.1
ual
Kent County Dept. of Public Works Environmental Management System Program Man-
5.0 REQUIREMENTS
5.1 Identifying Activities
Each activity that occurs at the Kent County Regional Wastewater Treatment Facility
shall be identified to its smallest or most manageable component in order to ensure that
all potential environmental impacts are considered. The activity shall be a subset of the
main activities presented in the I/O chart presented as Attachment A.
5.1.1 Each area manager shall identify all activities that occur under his/her direction.
The list shall be maintained as Appendix A to this procedure.
5.1.2 Each area manager shall present the activity as a completed I/O chart and submit
them to the EMS Core Team for review. All completed charts shall be presented
as Appendix B to this procedure.
5.1.3 Area managers shall use operations personnel to assist in the preparation of the
I/O charts for their area. As an option, each area manager shall ask all operations
personnel to list five (5) activities that they routinely perform. The list shall be
prepared and consolidated by the Core Team
-------
Kent County Dept. of Public Works
Dover, Delaware
Environmental Procedures Manual
Determination of Significant Aspects
Title:
Determination of Significant Aspects
Document No.:
2-02-POl
Prepared By:
Jim Newton
Date Effective:
11-01-2003
Approved By:
Page:
3 of 9
Revisions No. :
0
5.2 Identifying Aspects
The EHS Core Team shall conduct a review of the I/O charts for each area and determine
with consultation of the area managers and operations personnel the aspects associated
with the each chart. The aspects shall be listed on the aspect table presented as Attach-
ment C. All completed aspect tables shall be presented as Appendix C to this procedure.
5.3 Identifying Impacts
For each aspect presented on the Table included as Attachment C, an environmental impact shall
be assigned. This shall be based on impacts in one of the following areas:
Changes in air quality
Changes in water quality
Direct exposure to agent
Changes in habitat
Nuisance (including odor)
Conserves/depletes resources
Frequency/Probability
Is it regulated
Is it a critical control point
5.4 Determining Significance
The EMS Core team shall determine the significance of each environmental aspect by using best
professional judgment with respect to the impacts associated with each aspect, assigning a value
from 0-5 for each aspect (with 0 being no impact, and 5 being major impact). The value as-
signed for the aspect shall be the value that represents the average of all of the values determined
by the Core Team for that aspect. A regulated activity will receive a rating of 5 and an unregu-
lated activity will receive a rating of 0. A critical control point (CCP) will receive a rating of 3,
while an activity that is not a CCP will receive a rating of 0. A ranking shall be prepared and
presented to the Core Team by the Environmental Program Manager for all aspects evaluated in
this manner. The Core Team shall meet to evaluate the final rankings of all environmental as-
pects, and determine which of these shall be designated "significant." The prioritized list shall
be maintained as Appendix D to this procedure.
6.0 RESPONSIBILITIES
6.1 Determining the activities, preparing the I/O charts, and completing the environmental aspect
tables shall be the responsibility of the area managers for the facility with the EMS Core
Team providing quality control.
6.2 The EMS Core Team shall develop the significance criteria for all identified environmental
aspects under the direction of the Environmental Program Manager, and assign the final
rankings for all environmental aspects. The criteria shall be set such that no more than 6-8
aspects shall be given the ranking of "significant".
-------
Kent County Dept. of Public Works
Dover, Delaware
Environmental Procedures Manual
Determination of Significant Aspects
Title:
Determination of Significant Aspects
Document No.:
2-02-POl
Prepared By:
Jim Newton
Date Effective:
11-01-2003
Approved By:
Page:
4 of 9
Revisions No. :
0
6.3 The Environmental Program Manager will publish the prioritized list of significant as-
pects as an appendix to this procedure and ensure that it is current.
6.4 The significant aspect list will be reevaluated yearly and compared against the list of ob-
jectives and targets to determine if new objectives and targets are required and whether
the current list of significant aspects supports the current objectives and targets.
7.0 DOCUMENTS
7.1 Related Documents
None
8.0 RECORDS
8.1 Required Records
The list of activities; the list of aspects, and the priority list of aspects shall all be main-
tained as appendices to this procedure.
8.2 Records Control
All records, if required, pertaining to this procedure shall be controlled in accordance with the
Environmental Management System Procedures 2-11-P02, Controlling Records, and 2-10-P02,
Confidentiality.
9.0 ATTACHMENTS
9.1 Attachment A - Diagram of major activities associated with the wastewater facility.
9.2 Attachment B - Blank I/O diagram
9.3 Attachment C - Blank aspect table
10.0 APPENDICES
10.1 Appendix A - List of all identified activities associated with the Kent County regional
wastewater treatment facility.
10.2 Appendix B - Completed I/O charts associated with the activities listed in Appendix A.
10.3 Appendix C - Aspect tables provided for each of the activities listed in Appendix A.
-------
Kent County Dept. of Public Works
Dover, Delaware
Environmental Procedures Manual
Determination of Significant Aspects
Title:
Determination of Significant Aspects
Document No.:
2-02-P01
Prepared By:
Jim Newton
Date Effective:
11-01-2003
Approved By:
Page:
5 of 9
Revisions No. :
0
10.4 Appendix D - Prioritized list of aspects as determined following the significance criteria
presented in Section 5.4.
11.0 REVISION HISTORY
Revision
No.
0
Effective Date
Responsible Person
Jim Newton
Description of Revision
Initial Issue
Appv. By
-------
ATTACHMENT A
Wastewater Treatment Plant
Products
Resources
Wastewater
Air
Electricity
Heat
Waste
Heat
Spills
Air emissions
Solid wastes
Treated Wastewater
Kentorganite
Byproduct
-------
ATTACHMENT B
INPUT/OUTPUT CHART
Resources
ACTIVITY
Wastes
Products
Byproducts
-------
ATTACHMENT C
BLANK ENVIRONMENTAL ASPECT CHART
-------
-------
Dept/Area/Operation
Activity
Environmental Aspects
Changes Air Quality
Changes Water Quality
Direct exposure to agen
Changes Habitat
Nuisance
o
Depletes Natural Resou
Regulated
Critical Control Point
Frequency/Probability
V
o
u
Total Environmental S
Significant
Operational Control(s)
-------
Operation:
Org/Operation:
Aspects and Impacts Worksheet
Dept/Area/Operation
Ag Ops - Applying
Kentorganite
Biosolids - Drying
Biosolids - Drying
Ag Ops - Applying
Kentorganite
Maintenance - Force Mains
Biosolids - Drying
Operations - Chlorine
Addition
Maintenance - Pump Station
Operations - Air
Compressors
Operations - Laboratory
Maintenance - Pump Station
Biosolids - Dewatering
Maintenance - Safety
Operations - Aeration
Basins
Ag Ops - Applying
Kentorganite
Ag Ops - Applying
Kentorganite
Operations - Clarifiers
Operations - Sulfur Dioxide
Addition
Activity
Spreading of Kentorganite
Run scrubber
Run boilers
Spills of Kentorganite
Spill mitigation
Run dryers
Connecting chlorine containers
Spill mitigation
Operating blowers
Sample Analysis
Emergency generator maintenance
Preventive maintenance
Confined Space entry
Air diffusing
Loading of Kentorganite
Off loading Kentorganite
Emergency generator operations
Connecting sulfur dioxide containers
Environmental Aspects
Dust, odor, fuel, air pollution
Air pollution, electricity, spills, leaks
Electricity, fuel, air pollution
Lime usage, fuel, solid waste, oils
Lime usage, fuel
Electricity, Dowtherm, spills, drums, leaks
Chlorine leak,
Lime usage, fuel
Electricity, air pollution, noise, fuel
Electricity, fuel, chemicals, air pollution, solid and hazardous waste, water,
paper, spills
Fuel, electricity, air pollution
Fuel, electricity, rags
Electricity, air pollution, rags, fuel usage
Electricity, air, air pollution
Fuel, dust, air pollution, odors, spills
Dust, fuel, spills, air pollution
Electricity, fuel, noise air pollution
Sulfur dioxide leak
Env. Impacts
Changes Air Quality
3
4
4
4
2
4
5
3
4
2
4
2
3
4
3
3
3
3
Changes Water Quality
1
2
1
1
3
1
2
4
4
3
1
1
2
2
1
1
1
1
Direct exposure to agent
3
1
1
5
4
2
5
4
1
4
1
3
4
0
2
2
0
4
Changes Habitat
2
1
1
0
3
1
2
2
1
0
1
2
1
0
0
1
0
2
Nuisance (odor, etc.)
4
3
2
5
3
1
4
3
3
2
3
4
4
2
4
4
1
3
Depletes Natural Resource
3
2
3
0
3
2
3
2
5
3
2
2
3
4
3
1
1
3
Regulated?
5
5
5
5
5
5
0
5
0
0
5
0
0
0
0
0
5
0
Critical Control Point?
3
3
3
3
0
3
0
0
0
3
0
3
0
3
3
3
3
0
Frequency/Probability
4
5
5
1
1
5
3
1
5
5
3
3
3
5
4
4
5
3
Sig.
Total Environmental Score
28
26
25
24
24
24
24
24
23
22
20
20
20
20
20
19
19
19
Significant?
Y
Y
Y
Y
Y
Y
Y
Y
Operational Control(s)
Page 1 of 4
-------
Operation:
Org/Operation:
Aspects and Impacts Worksheet
Dept/Area/Operation
Operations - Chlorine
Addition
Operations - Chlorine
Addition
Maintenance - Pump Station
Operations - Inflow
Operations - Sulfur Dioxide
Addition
Operations - Sulfur Dioxide
Addition
Maintenance - Pump Station
Biosolids - Drying
Operations - Air
Compressors
Operations - Air
Compressors
Maintenance - Force Mains
Operations - Chlorine
Addition
Maintenance - Pump Station
Operations - Chlorine
Addition
Maintenance - Force Mains
Operations - Clarifiers
Maintenance - Force Mains
Operations - Sulfur Dioxide
Addition
Maintenance - Force Mains
Maintenance - Force Mains
Maintenance - Pump Station
Activity
Monitoring/controlling chlorine addition
Repairing chlorine equipment
Pump/Motor maintenance
Odor scrubbing
Preventive maintenance
Monitoring/controlling sulfur dioxide addition
Bar screen maintenance
Run scrubbers
Emergency generator operation
Preventive maintenance
Force main cleaning
Receiving chlorine containers
Wetwell maintenance
Cleaning chlorine contact chamber
Hydrogen peroxide operation
RAS Pumping
Gravity/lateral inspection repair
Receiving sulfur dioxide containers
Sewer/ vacuum truck operation
Air relief valves inspection and repairs
Air scrubber maintenance
Environmental Aspects
Chlorine leak,
Chlorine leak,
Electricity, spills, rags
Solid waste, electricity, water, chemicals
Sulfur dioxide leak
Sulfur dioxide leak
Electricity, fuel, landfill of waste grease and rags, air pollution
Electricity, air pollution, spills, water
Fuel, electricity, noise
Electricity, solid waste
Pig material, fuel, electricity, solid waste
Leaking chlorine,
Fuel usage, grease, landfill of rags, chemical usage, air pollution
Chlorine, solid waste, skin contact
Chemical usage, air pollution, spills
Water, electricity
Wastewater, spills, air pollution, fuel
Sulfur dioxide leak
Wastewater, spills, air pollution, fuel
Fuel, air pollution, grease, rags, chemicals, lime
Electricity, carbon, spills
Env. Impacts
Changes Air Quality
4
4
2
3
3
3
3
3
2
1
2
3
3
2
1
1
1
3
3
2
1
Changes Water Quality
1
1
1
0
1
1
1
2
2
2
2
1
2
1
1
4
2
1
2
1
1
Direct exposure to agent
4
4
3
2
4
4
4
0
0
0
4
4
4
4
2
U
4
3
3
3
2
Changes Habitat
1
2
0
0
2
1
1
0
0
0
2
2
1
1
1
U
2
2
1
1
1
Nuisance (odor, etc.)
2
4
4
3
3
2
5
1
1
1
3
3
4
2
1
1
3
3
3
4
2
Depletes Natural Resource
2
2
2
1
2
2
1
2
2
2
2
2
1
1
3
2
2
2
2
2
1
Regulated?
0
0
5
5
0
0
0
5
5
5
0
0
0
5
5
U
U
0
0
0
fa
Critical Control Point?
0
0
0
0
0
0
0
0
3
3
0
0
0
0
0
3
U
0
0
0
U
Frequency/Probability
5
2
2
5
3
5
3
5
2
3
2
2
2
1
3
fa
2
2
2
3
3
Sig.
Total Environmental Score
19
19
19
19
18
18
18
18
17
17
17
17
17
17
17
16
16
16
16
16
16
Significant?
Operational Control(s)
Page 2 of 4
-------
Operation:
Org/Operation:
Aspects and Impacts Worksheet
Dept/Area/Operation
Ag Ops - Building and
Grounds
Operations - Aeration
Basins
Maintenance - Pump Station
Operations - Clarifiers
Pretreatment
Maintenance - Pump Station
Maintenance - Safety
Operations - Clarifiers
Biosolids - Dewatering
Operations- Inflow
Operations - Aeration
Basins
Pretreatment
Biosolids - Drying
Biosolids - Dewatering
Biosolids - Dewatering
Operations - Grit Removal
Ag Ops - Fueling Operations
Pretreatment
Biosolids - Drying
Biosolids - Dewatering
Pretreatment
Operations - Grit Removal
Maintenance - Safety
Ag Ops - Vehicle
Maintenance
Ag Ops - Building and
Grounds
Operations - Inflow
Maintenance - Force Mains
Operations - Inflow
Operations - Clarifiers
Operations - Laboratory
Ag Ops - Fueling Operations
Activity
Herbicide application
Preventive maintenance
Process controls/SCADA
WAS Pumping
Take samples
Bypass/Godwin Tanking
Trench digging
Tank cleaning
Run belt presses, conveyors
Filter screening
Skimming floatable
Review Camera and Card Key Results
Move Kentorganite
Dose ferric chloride
Convey cake to dryers
Removal of grit
Filling fuel tanks
Transport Sample
Run conveyors
Mix polymer and Dose biosolids
Issue SIU Permits
Preventive maintenance
Outside contractors
Service vehicles
Pesticide application
Preventive maintenance
Preventive maintenance
Scum removal
Flow balancing
Sampling
Fueling vehicles
Environmental Aspects
Fuel, chemical, solid/hazardous waste, water, spills
Electricity, solid waste, fuel
Electricity, water, rags
Water, electricity
Spills of samples, waste paper due to chain of custody forms
Spills, fuel usage, water transportation, electricity, air pollution
Electricity, air pollution, rags, fuel usage, spills, contaminated water
Wastewater, fuel, electricity
Electricity, water, spills, trash, belts
Solid waste, electricity, water
Solid waste, fuel
Fuel related to transportation to pump station sites, air pollution from
vehicles
Fuel, air pollution, oil
Electricity, spills, waste ferric chloride
Electricity, wash down water, spills
Solid waste, electricity, fuel
Air pollution, spills, electricity
Fuel related to transportation, potential spills, air pollution from vehicles
Electricity, wash down water, spills
Electricity, spills, trash, waste chemicals
Generate paper and waste paper, electricity and ink for computers
Solid waste, electricity
Electricity, fuel, spills, air pollution
Air pollution, rags, paper, electricity, spills, solid waste
Fuel, chemicals, water, solid/hazardous waste, spills
Solid waste, electricity
Electricity, oil and grease rags, fuel
Solid waste, electricity, water, chemicals
Electricity, air pollution
Fuel, electricity
Air pollution, spills, electricity, paper
Env. Impacts
Changes Air Quality
2
1
1
1
0
2
2
3
3
1
0
2
2
1
2
1
2
2
1
1
1
0
1
1
2
0
1
1
1
0
2
Changes Water Quality
2
1
1
3
1
3
1
3
1
3
3
1
1
1
1
2
1
1
2
1
0
1
1
1
2
2
1
1
2
0
1
Direct exposure to agent
2
5
2
0
1
3
4
4
1
1
2
1
1
3
1
1
2
1
0
2
0
1
2
1
2
1
1
1
0
3
1
Changes Habitat
3
0
0
0
0
0
2
0
0
0
0
0
1
0
0
0
1
0
0
0
1
0
1
0
3
0
1
0
0
0
0
Nuisance (odor, etc.)
0
1
3
1
0
3
3
2
1
3
3
0
0
0
1
3
2
0
1
0
0
0
3
1
0
0
1
1
1
1
1
Depletes Natural Resource
1
1
1
2
0
2
1
2
0
1
1
0
1
0
0
1
2
0
0
0
1
1
1
3
1
1
1
1
1
1
2
Regulated?
5
0
0
0
5
0
0
0
0
0
0
5
0
0
0
0
0
0
0
0
5
0
0
0
0
0
0
0
0
0
0
Critical Control Point?
0
3
3
3
3
0
0
0
3
0
0
0
3
3
3
0
0
3
3
3
3
3
0
0
0
3
0
0
0
0
0
Frequency/Probability
1
3
4
5
5
2
2
1
5
5
5
5
4
5
5
5
3
5
5
5
1
5
2
4
1
3
4
5
5
5
3
Sig.
Total Environmental Score
16
15
15
15
15
15
15
15
14
14
14
14
13
13
13
13
13
12
12
12
12
11
11
11
11
10
10
10
10
10
10
Significant?
Operational Control(s)
Page 3 of 4
-------
Operation:
Org/Operation:
Aspects and Impacts Worksheet
Dept/Area/Operation
Operations - Chlorine
Addition
Administration
Operations - Sulfur Dioxide
Addition
Pretreatment
Pretreatment
Pretreatment
Ag Ops - Applying
Kentorqanite
Biosolids - Drying
Pretreatment
Ag Ops - Applying
Kentorqanite
Ag Ops - Vehicle
Maintenance
Pretreatment
Maintenance - Safety
Operations - Clarifiers
Maintenance - Pump Station
Ag Ops - Building and
Grounds
Biosolids - Dewaterinq
Ag Ops - Applying
Kentorganite
Pretreatment
Operations - Laboratory
Administration
Ag Ops - Building and
Grounds
Ag Ops - Fueling Operations
Ag Ops - Vehicle
Maintenance
Ag Ops - Building and
Grounds
Activity
Preventive maintenance
HVAC of Buildings
Repairing sulfur dioxide equipment
Conduct public relations
Sample Haulers
Analyze Samples
Delivering Kentorganite
Preventive maintenance
Administer Program
Public relations
Heat shop
Set up samples
Rigqinq and Bracinq Operations
Preventive maintenance
Preventive maintenance
Yard work
Monitorinq offlow/pH
Weighing of Kentorganite
Permit Haulers
Preventive maintenance
Maintaining files, etc.
Building maintenance
Spill cleanup
Change parts
Snow removal
Environmental Aspects
Chlorine
Fuel, electricity
Sulfur dioxide leak
Fuel related to transportation to sites, air pollution from vehicles, waste
paper, electricity and ink for computers
Fuel related to transportation, potential spills, air pollution from vehicles
Waste paper, electricity and ink for computers
Fuel, air pollution, spills, dust
Fuel, electricity, rags
Waste paper, electricity and ink for computers
Fuel, paper
Air pollution, electricity, LP gas
Wash jars and samplers, add preservatives, potential spills of
preservatives
Electricity, spills, grease, oil, raqs
Electricity, fuel, solid waste
Electricity, fuel, oil, grease, chemical usage, air pollution
Fuel, solid waste, spills
Paper
Fuel, air pollution, paper
Waste paper, electricity and ink for computers
Chemical usage, air pollution, spills, solid waste
Paper, electricity
Fuel, electricity, solid waste, chemical usage
Air pollution, rags, paper, absorbent
Electricity, rags, paper
Fuel, salt/sand mixtures, spills
Env. Impacts
Changes Air Quality
2
3
2
2
2
1
2
1
1
2
1
1
1
0
0
0
0
1
1
0
0
0
1
0
0
Changes Water Quality
0
1
0
0
1
0
1
1
0
0
0
2
0
2
0
0
0
0
0
0
0
0
1
0
0
Direct exposure to agent
1
0
1
1
1
0
0
0
0
1
0
1
2
1
1
0
0
0
0
1
0
0
1
1
0
Changes Habitat
1
0
1
1
0
1
0
0
1
0
0
0
0
0
0
2
0
0
1
0
0
0
0
0
0
Nuisance (odor, etc.)
1
0
1
0
0
0
1
1
0
0
1
1
0
0
1
0
0
1
0
0
0
0
1
0
0
Depletes Natural Resource
1
2
1
1
0
1
0
1
1
0
2
0
1
1
1
1
1
0
1
1
2
1
0
1
3
Regulated?
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Critical Control Point?
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Frequency/Probability
3
3
2
3
4
5
4
3
4
4
3
1
2
2
3
3
5
4
2
3
3
4
1
3
1
Sig.
Total Environmental Score
9
9
8
8
8
8
8
7
7
7
7
6
6
6
6
6
6
6
5
5
5
5
5
5
4
Significant?
Operational Control(s)
Page 4 of 4
-------
RIVANNA SEWER AND WATER AUTHORITY - CHARLOTESSVILLE, VIRGINIA
8.3 Sample of Environmental Aspect, Impact Identification, and Ranking
Operation:
Compost Yard
Activity
Drying w/
blowers
Aspect
Fuel/electricity
consumption, air
emissions, solid
waste generation
Env. Impact
Depletion of natural
resources, degradation of
air quality, landfill space
rt
1
^
=
of
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03
hH
O
e
o>
o
1
1
o.
E
hH
*-
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=
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J a
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=
w
1
=
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c.
w
L.
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a.
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z
s
1
Total
7
ฃ*
S2
,,
S2
bJD
i/j
N
Operational
Control(s)
8.4 Significant Environmental Aspects (Currently for Moores Creek Wastewater Treatment
Plant)
Activity
Wastewater Treatment
(Digestion/Flares, Thickening;
Screening/grit removal, Primary
treatment, clarification, grease
removal; Filter press); Compost;
Septage Receiving; Rivanna
Pump Station Use & Maintenance
Septage Receiving
Pretreatment
Chemical handling (receiving)
Wastewater Treatment/Effluent
Wastewater collection, transport,
and pump (within Plant)
Office Administration-Paper &
office supplies use; Recycling;
Contract management;
Procurement
Aspect
Odors
Potential
spills/Runoff/
Release
Chemical addition
Potential spills
Water release
Possible overflows
energy consumption,
Solid waste
Environmental
Impact
Nuisance
Degradation of water
quality
Degradation of water
quality
Water, soil
degradation
Modification of
water quality
Degradation of water
and soil quality,
natural resource
depletion, nuisance
Landfill use, natural
resource depletion
Operational Control(s)
Odor Control Plan (Under
Development)
VPDES Permit; SPCC Plan;
Stormwater Discharge
Permit and Pollution
Prevention Plan
SPCC Plan; Stormwater
Discharge Permit and
Pollution Prevention Plan
VPDES Permit
Standard contract language;
Recycling Plan;
Procurement Policy (all
under development)
-------
SAMPLE EMS DOCUMENTATION
OBJECTIVES AND TARGETS
City of Gastonia WWTP- Objectives and Targets Procedure
City of Charleston CPW- Objectives and Targets
City of Eugene WWTP- Objectives and Targets
City of Gastonia WWTP- Objectives and Targets
Kent County DPW- Procedure and Objectives and Targets
Buncombe County MSD - Objectives and Targets
-------
Standard Operating Instruction - EMS-01 00.007
Name: Objectives and Targets Procedure
Prepared By: Beth Eckert, Environmental/ Administrative Manager
Approved By: Beth Eckert, Environmental /Administrative Manager
Signature:
Corresponding
Requirements:
EMS Manual: 4.3.3
ISO Standard: 4.3.3
NBP Element: 5
Revision Date: 02/13/03
Revision #: 3
Effective Date: 03/01/01
Page 1 of 3
Objectives and Targets
Standard Operating Procedure
1.0 Purpose
1.1 The following procedure provides guidance for the development and review of
objectives and targets, and associated improvement programs for the Wastewater
Treatment Division.
2.0 Associated Equipment
2.1 None
3.0 Associated Reference Material
3.1 City of Gastonia - Environmental Management System Manual (EMS-0100.000)
3.2 ISO 14001 Standard: ANSI/ISO 14001-1996 Environmental Management Systems -
specifications with guidance for use.
3.3 National Biosolids Partnership (NBP)- Elements of an Environmental Management
System for Biosolids
3.4 Objective and Targets Improvement Plan Summary - EMS-0102.007
3.5 Improvement Program - EMS-01'01.007'A-Program ID#
3.6 Significant Environmental Aspects - EMS-0101.003D-year-revision#
4.0 Procedure
4.1 The WWTD will establish and/or revise an objectives and targets list annually, by April
1st of each year, by considering at least the following information:
4.1.1 Legal and other requirements
4.1.2 Significant environmental aspects and impacts and critical control points for
the current year - EMS-0101.003D-year-revision#
4.1.3 Prevention of pollution
4.1.4 Product Quality
4.1.5 Technological options
4.1.6 Financial, operational, and business requirements
4.1.7 NBP-Code of Good Practice
"THIS IS AN UNCONTROLLED COPY OF A CONTROLLED DOCUMENT PRINTED 8/20/2004 AT 9:11 AM"
-------
Name -Number:
Objectives and Targets
-EMS-0100.007
Revision #: 3
Revision Date: 02/13/03
Effective Date: 03/01/01
Page 2 of 3
4.1.8 Good Neighbor Policy
4.1.9 Authoritative information sources on relevant topics (i.e. WEF Manuals of
Practice)
4.1.10WWTD environmental policy
4.1.11 Views of interested parties - Management Review Board quarterly reports
and External communication log books
4.1.12 Progress reports on the previous years objectives and targets
4.2 Objectives and targets may also be amended at other times during the year as a result
of new or revised operations, activities, and/or regulations.
4.3 When there are projects that relate to new developments and new or modified activities,
products or services; the program shall be amended where relevant to ensure that
environmental management applies to such projects.
4.4 Objectives and Targets may be removed from a current list by the Management Review
Board (MRB) if circumstances surrounding an objective and target change during the
year.
4.4.1 This removal shall take place following a review of its technological and/or
economical feasibility by the Division Manager WWT and/or either of the
two Assistant Managers. This change shall be documented and explained
in a C/PAR.
4.5 Each Objective and Target will be assigned a unique program ID # and an Improvement
Plan (EMS-0101.007A- Program ID#) will be developed.
4.5.1 This program shall include:
4.5.1.1 Designation of responsibility for achieving the objectives and
targets at each relevant function and level of organization;
4.5A.2 Means and time-frame by which they are to be achieved.
4.6 The Objective and Target Improvement Summary (EMS-0102.007) and each
Improvement Plan must be approved by the Division Manager WWT and budgeting
provisions made, where necessary, to accomplish the stated objectives and targets.
4.7 The EMS Coordinator, or designee, is responsible for their maintenance and facilitating
their reporting to the Management Review Board (MRB).
"THIS IS AN UNCONTROLLED COPY OF A CONTROLLED DOCUMENT PRINTED 8/20/2004 AT 9:11 AM"
-------
Name -Number:
Objectives and Targets
-EMS-0100.007
Revision #: 3
Revision Date: 02/13/03
Effective Date: 03/01/01
Page 3 of 3
5.0 Revision History:
Revision
Date
5/20/02
5/20/02
8/7/02
2-13-03
#
1
1
2
3
C/PAR #
EMS-0074
EMS-0084
EMS-0116
Reason for
Revision
External Auditor
C/PAR
C/PAR
Description of Revision
Removal of Deviations statement from Level II procedures
Added a modification history section
Incorporated in NBP requirements for element 5 and the
NBP element reference for document control linkage as
required in revision 5 of the document control procedure
Converted Form #: EMS-01 01 .007 to Reference Chart #:
EMS-0102.007. NO TRAINING REQUIRED
"THIS IS AN UNCONTROLLED COPY OF A CONTROLLED DOCUMENT PRINTED 8/20/2004 AT 9:11 AM"
-------
Environmental Management System
Summary of Objectives and Targets
Record File/Retrieval ID (Optional):
Record Schedule No./Retention Period:
Page 1 of 3
Prepared by: WWCD EMS Progress Team / Senior Supervisors
Approved by/Date: A. Williams / Feb. 9, 2004
Purpose/Scope: To identify and communicate environmental objectives and targets based upon consideration of CPW's analysis of operational requirements, significant environmental
impacts, regulatory standards and compliance, technological options, financial resources, the views of interested parties and the strategic business plan.
Instructions: Each CPW department and/or group having been identified by the P2 Team, as having significant environmental impacts (and/or impacts which management requires
departments to track), shall complete this form. This form is to be updated annually (and retained as a departmental record) and updated thereafter when modifications and/or changes occur
in CPW activities, products, and/or services. Results of the activities listed below are to be reported as they occur in the departments Monthly Operating Report (MOR). Note: This form may
be replicated on a computer or duplicated on a photocopier. The computer copy must look similar to this document and contain the same information.
Aspect Item
Sewer System
Overflows
(Significant Aspect)
inflow & infiltration
(I & I) (Significant
Aspect)
Inflow & Infiltration
(I & I) (Significant
Aspect)
inflow & infiltration
(I & I) (Significant
Aspect)
Specific Negative Impact
(Enter a brief description.)
Contamination of
environment
Loss of natural
resources through
energy use
Loss of natural
resources through
energy use
Loss of natural
resources through
energy use
Objective &
Target ID/No.
_____
(System
Cleaning
Program)
IP-2004.02
(Closed-circuit
Television
Inspection
Program)
IP-2004.03
(Mainline
Rehab
Program)
IP-2004^04
(Lateral Lining |
Process)
Objective
Reduce the number
of sewer system
overflows by
systematically
cleaning designated
mainlines.
Acquire system
condition and critical
data for proper
asset management.
Rehabilitate existing
mainlines to prolong
their life and
increase efficiency.
Rehabilitate laterals
utilizing the Cured in
Place Process
Target/Performance Indicator
Clean 556,200' (46,350' monthly
ave.) of wastewater collection
mainlines on problem and high-
risk areas through the 2004-CY.
(Ronald Inabinet)
Perform CCTV inspections on
288,000' (24,000' monthly ave.)
on the collection system through
the 2004-CY. (Franklin Yates)
Rehab 8000' of wastewater
collection mainlines by October 31,
2004. (Franklin Yates)
Performance Record
WWCD Monthly
Operating Report;
Work Orders
WWCD Monthly
Operating Report;
Inspection reports
WWCD Monthly
Operating Report
Rehabilitate 65 laterals using the
CIPP process. Complete by Oct.
31, 2004. (Tony Coker)
WWCD Monthly
Operating Report;
Work orders
Inflow & Infiltration
(I & I) (Significant
Aspect)
Loss of natural
resources through
energy use
IP-2004.05 | Repair defects in the
(Infrastructure | collection system
Repair | possibly contributing
Program) I to inflow &
I infiltration (I & I).
Perform 540 (45 ave. per month)
various point and service repairs
for 2004-CY. (Tony Coker)
WWCD Monthly
Operating Report;
Work orders
Form No.: P2-4.3.3-001 (1/29/2004)
Paae 1 of 1
DOCUMENT DISTRIBUTION
Controlled Original - Chairman, P2 Team
All other copies are uncontrolled.
-------
Objectives and Targets - Continuation Sheet
This sheet may be used as an attachment to the EMS Objectives and Targets form when additional space is required.
NOTE: This form may be replicated on a computer or duplicated on a photocopier. The computer copy must look
similar to this document and contain the same information.
Record File/Retrieval ID (Optional):
Record Schedule No./Retention Period:
Page 2 of 3
Aspect Item
Preventive
Maintenance
Exfiltration
Emergency
Preparedness/
Response
Computerized
Maintenance
Management
System (CMMS)
Training
Specific Negative Impact
(Enter a brief description.)
Potential problems
with equipment
operation resulting in
backups and SSOs
Contamination of
waterways
Increased potential for
damage to
infrastructure,
equipment and
environment
Potential for
maintenance activities
to be incomplete; loss
of permanent records
Lack of intellectual
capital with regard to
environmental and
Form No.: P2-4.3.3-001 A (2/4/2003)
Paae 1 of 1
Objective &
Target ID/No.
IP-2(mC)6
(Valve
Exercising
Program)
IP-2004.07
(Water Quality
Assurance
Program)
IP-2004.09
(Flow Control
Program)
IP-2004.10
(Asset
Management
and Evaluation
Program)
IP-2004.11
(Skills-based
Training
Objective
Ensure all critical
valves are in good
operation should an
emergency occur.
Identify leaks in
collection system
resulting in the
potential
contamination of
waterways.
Develop procedures
for redirecting flows
during emergency
situations.
Develop a system
for evaluating the
infrastructure for
prioritizing
rehabilitation
initiatives.
Establish improved
controls regarding
training
Target/Performance Indicator
Develop a valve-exercising
program. Include drawings
delineating valves to operate,
SOI(s) & schedule(s). Establish
program by May 1, 2004. (Harry
McGee)
Identify locations where
wastewater mains cross
waterways and create a CIS map
of those locations. Complete by
May 1, 2004.
Develop an inspection schedule
and create work orders in the
CMMS by October 31, 2004.
(Gregory Daniels)
Develop a flow control program
involving valves associated with
force mains. Include drawings
delineating valves to operate
during specified emergencies.
Finalize by July 1, 2004. (Harry
McGee)
Performance Record
WWCD Monthly
Operating Report;
Associated drawings
(CIS); Standard
Operating
Instruction(s);
City Works scheduling
via work orders
WWCD Monthly
Operating Report;
Standard Operating
Instruction(s); Work
Orders
WWCD Monthly
Operating Report;
Associated drawings
(CIS); Standard
Operating
Instruction(s)
Develop an asset
management/evaluation program
to include the production of
reports identifying system
rehabilitation priorities.
Accomplish by July 1, 2004. (Chris
Hendricks)
WWCD Monthly
Operating Report;
Standard Operating
Instruction(s);
Associated standard
reports
Establish procedures & reports for
managing the SET Training
database. Accomplish by July 1,
WWCD Monthly
Operating Report;
Standard Operating
DOCUMENT DISTRIBUTION
Controlled Original - Chairman, P2 Team
All other copies are uncontrolled.
-------
Objectives and Targets - Continuation Sheet
This sheet may be used as an attachment to the EMS Objectives and Targets form when additional space is required.
NOTE: This form may be replicated on a computer or duplicated on a photocopier. The computer copy must look
similar to this document and contain the same information.
Record File/Retrieval ID (Optional):
Record Schedule No./Retention Period:
Page 3 of 3
Aspect Item
Operational
Evaluations
Air Release Valve
PM
Inflow & Infiltration
(I & I) (Significant
Aspect)
Computerized
Maintenance
Management
System (CMMSJ
Specific Negative Impact [ Objective &
(Enter a brief description.} !a.r.9.?t I.9/.M..9
operational
effectiveness
Improper evaluations
resulting in unqualified
rehabilitation planning
Loss of operational &
design effectiveness of
force mains & pump
stations; exfiltration
Loss of natural
resources through
energy use
Potential for
maintenance activities
to be incomplete; loss
Improvement
Program)
IP-2004.12
(Pump Station
Operational
Evaluation
Program)
______
(Air Release
Valve PM
Program)
IP-2004.14
(I&I
Reduction Plan)
IP-2004.15
(CMMS Phase-
in Project)
Objective
management.
Develop
methodologies &
criteria for
establishing pump
station rehabilitation
priorities.
Ensure air release
valves are working
properly.
Establish a standard
methodology for
mitigating I&I
Encompass all
aspects of
operations within
CMMS.
Target/Performance Indicator
2004. (Susan Roberts)
Develop formal, logical criteria for
determining schedules for pump
station rehabilitation. Complete
by Aug. 1, 2004. (Harry McGee)
Performance Record
Instruction(s);
Standard training
management reports
Establish an air release valve
inspection and maintenance
program. Complete by Aug. 1,
2004. (Ronald Inabinet)
Develop a manual and/or SOI(s)
for I & I reductions. Include a
structured, comprehensive
approach to I&I reduction within
the document(s), and complete by
Sept. 1, 2004. (Franklin Yates)
Phase-in all Technical Section
operations into CityWorks CMMS
program by Oct. 1, 2004. (Chris
Hendricks)
WWCD Monthly
Operating Report;
Grading Criteria
Worksheet; Schedules
(if needed)
WWCD Monthly
Operating Report;
Standard Operating
Instruction(s);
Inspection and PM
schedule
WWCD Monthly
Operating Report;
Standard Operating
Instruction(s); I & I
Manual (if necessary)
WWCD Monthly
Operating Report;
CityWorks technical
work orders
Note: Identification number IP-2004.08 was purposely not used to maintain numbering consistency with the Departmental
Incentives.
Form No.: P2-4.3.3-001 A (2/4/2003)
Paae 1 of 1
DOCUMENT DISTRIBUTION
Controlled Original - Chairman, P2 Team
All other copies are uncontrolled.
-------
City of Eugene - Wastewater Division
Environmental Management System
2004 Objectives and Targets
Objective Target
Reduce Consumption of
Natural Resources
Reduce Power Consumption
Reduce Solid Waste
Improve Quality of Treated
Wastewater Effluent
Reduce use of Toxic
Chemicals
Reduce Air Pollution
Reduce Potable Water Use
Improve the fuel efficiency of the Division's fleet (gasoline and diesel
vehicles)
Increase the amount of non-petroleum-based fuels by the Division's fleet
Reduce annual electrical power consumption of WPCF by 5% (Baseline
2000)
Improve the electrical efficiency of the Division's pump stations
Reduce annual electrical power consumption of BMP (measured as kwh/dry
ton biosolids produced) by 5% (Baseline 2002)
Minimize quantities of non-recyclable wastes (Excluding grit truck waste
and dewatering press screenings)
Minimize recyclable wastes from solid waste disposal sent to landfill
Reduce total solid waste (tons) by 15% based on cubic yards taken to
landfill (Baseline 2002)
Reduce wastewater facility influent mercury loading by 10% (Baseline
summer 2001)
Perform chemical assessment and prioritization for reduction
Reduce sulfur dioxide emissions (Ibs) from the engine generator by 85%
(Baseline 2002)
Reduce potable water use (gallons) by 10% (Baseline 2002)
-------
CitvofGastonia
""n IT'
Ul/astewater Treatment
Program # & Name
EMS-2001-001
Electrical Usage
PRE-2001-001
Oil & Grease
WWEMS-2002-001
Biosolids
Management Study
WWEMS-2002-002
Augmented Training
Program
WWEMS-2002-004
National Biosolids
Partnership EMS
WWEMS-2002-005
Master Plan Study
WWEMS-2003-003
Disposal of Water
Plant Residuals
Corresponding Reauirements:
EMS Manual: 4.3.3 and 4.3.4
ISO Standard: 4.3.3 Objectives and
Targets and 4.3.4 Environmental
Management Programs
NBP Element: 5
Corresponding procedures:
EMS-0100.007& Individual
improvement programs listed below
Policy / Aspect Item
Pollution Prevention - More
efficient use of electrical
resources
Pollution Prevention
Continual Improvement
Continual Improvement
Continual Improvement
Continual Improvement
Polution Prevention, Improved
Biosolids Quality
2003 Environmental Objectives & Targets
Improvement Plan Summary
Document No: EMS-0102.007
Purpose: To establish a summary of objectives and targets for
prevention of pollution and for continual environmental improvement
through specific programs.
Specific Negative Impacts
drain on natural resources
surface water quality; public
relations
ground water quality, legal
requirements.
surface water quality; ground
water quality, air quality, natural
resource use, state regulations
ground water quality, legal
requirements.
surface water quality; ground
water quality, air quality, natural
resource use, state regulations
soil & ground water quality, state
regulations
Revision*: 2
Revision Date: 10/21/03
Objective
Make incremental improvements in the efficient use of
electrical energy.
Develop and implement an improved oil and grease program
for the City of Gastonia
To perform thorough evaluation and assessment both
intermediate and long term plans for the City's residuals
management needs, by performing a system wide master plar
study, adopting a National Biosolids Partnership EMS, and
contracting professional services consultants to evaluate any
remaining needs identified by first two steps.
To modify current training processes to better ensure
extensive knowledge of the trainers, comprehensiveness of
topics trained upon and thorough review of effectiveness of
training.
To successfully implement the National Biosolids Partnership
program into our existing environmental management system
and achieve certification for NBP EMS while maintaining ISO
14001 certification.
To perform a broad and thorough evaluation of the
wastewater collection and treatment systems and determine
what overall direction should be pursued and where
improvements should be made.
Improve the quality of biosolids generated in Gastonia's
program and limit their effect on the environment through
landfill disposal of water treatment plant residuals.
Revised By: David Shellenbarger, Asst. Div. Manager - Compliance
Approved By: Larry Cummings, Division Manager VWVT
Signature: Page 1 of 1
Target
Reduce electrical usage/gallon treated by
5% at each WWTP by 12/31/03
Complete public education and implement
fat, oil & grease program and inspect all
identified restaurants by December 2004.
Complete thorough evaluation and
assessment of biosolids area by July
2004.
Identify areas for improving training in
Division and provide sufficient training in
identified areas to employees by June
2006.
Receive outside certification of NBP EMS
by February 2005.
Complete master plan study of wastewater
system by December 2003.
Arrange for dewatering and land
application of water plant residuals. Begin
disposal by December 31 ,2003
Performance Indicator
Quarterly review electrical costs at each
plant during MRB.
Quarterly review of progress with
Management during the MRB.
Quarterly review of progress with
Management during the MRB.
Quarterly review of progress with
Management during the MRB.
Quarterly review of progress with
Management during the MRB.
Quarterly review of progress with
Management during the MRB.
Quarterly review of progress with
Management during the MRB.
***THIS IS AN UNCONTROLLED COPY OF A CONTROLLED DOCUMENT PRINTED 8/19/2004 AT 10:32 AM***
-------
Kent County Dept. of Public Works
Dover, Delaware
Environmental Procedures Manual
Objectives and Targets
Title:
Setting and Tracking Objectives and Targets
Document No.:
2-04-POl
Prepared By:
Jim Newton
Date Effective:
11-01-2003
Approved By:
Page:
Iof6
Revisions No.:
0
CONTENTS
1.0 PURPOSE
2.0 SCOPE
3.0 DEFINITIONS
4.0 REFERENCES
5.0 REQUIREMENTS
6.0 RESPONSIBILITIES
7.0 DOCUMENTS
8.0 RECORDS
9.0 ATTACHMENTS
10.0 APPENDICES
11.0 REVISION HISTORY
1.0 PURPOSE
1.1 The purpose of this procedure is to establish the general requirements for the work proc-
ess of setting and tracking EMS objectives and targets based upon significant environ-
mental aspects that are applicable to the Kent County Dept. of Public Works Regional
Wastewater Treatment Facility.
1.2 The purpose of this work process is to establish the Kent County Dept. of Public Works
specification for setting and tracking EMS objectives and targets that apply to the facility
to facilitate compliance with the applicable requirements.
2.0 SCOPE
2.1 This procedure addresses the setting and tracking of EMS objectives and targets applica-
ble to the Kent County Dept. of Public Works Environmental Program.
3.0 DEFINITIONS
3.1 Activity - Something that occurs at the wastewater facility in order to transport wastewa-
ter, produce clean wastewater or produce quality biosolids (Kentorganite).
3.2 Baseline - The starting point from which the meeting of an objective is to be measured,
such as the number of kilowatt hours of electricity used to run the basin blowers for
2002.
3.3 Objective - An overall goal, arising from the environmental policy and the list of signifi-
cant environmental aspects and critical control points, that an organization sets itself to
achieve. An example would be to reduce energy consumption across the facility.
3.4 Target - a measurable performance requirement that arises from an objective. An exam-
ple would be to reduce energy consumed by the biosolids dryers by 10% by January
2005.
-------
Kent County Dept. of Public Works
Dover, Delaware
Environmental Procedures Manual
Objectives and Targets
Title:
Setting and Tracking Objectives and Targets
Document No.:
2-04-P01
Prepared By:
Jim Newton
Date Effective:
11-01-2003
Approved By:
Page:
2 of 6
Revisions No.:
0
4.0 REFERENCES
4.1 Kent County Dept. of Public Works Environmental Management System Program Man-
ual
5.0 REQUIREMENTS
5.1 Identifying Objectives
5.1.1. The Core Team will evaluate the list of significant environmental aspects and critical
control points generated under Environmental Management System Procedure 2-04-P01
for areas of commonality.
5.1.2 A list of objectives will be prepared by the Environmental Management System Repre-
sentative to address the general common significant environmental aspects and critical
control points, and compared to the environmental/biosolids policy. The objectives
would be agreed to by the Core Team and posted on the Public Works website.
5.2 Identifying Targets
5.2.1 The Core Team will evaluate the selected objectives and determine the tasks required to
meet each objective. The Core Team will assign target dates and responsible parties to
ensure that the dates are met. The Core Team will communicate the selected objectives
and targets with senior management to ensure that adequate resources and support is
available to accomplish the required elements.
5.2.2 A table will be prepared for each objective with all target activities, dates and responsible
parties listed. This table will be posted on the Public Works website and maintained by
the Environmental Management System representative.
5.3 Tracking Objectives and Targets
5.3.1 The Core Team will evaluate each objective and compare key objective and target actual
accomplishments with the planned program on a quarterly basis.
5.3.2 The Core Team will revise the objectives and targets, as necessary, to ensure that move-
ment is continuing to be made towards completion.
5.3.3 Management will review the objectives and targets annually, and recommend changes
based upon their review.
-------
Kent County Dept. of Public Works
Dover, Delaware
Environmental Procedures Manual
Objectives and Targets
Title:
Setting and Tracking Objectives and Targets
Document No.:
2-04-POl
Prepared By:
Jim Newton
Date Effective:
11-01-2003
Approved By:
Page:
3 of 6
Revisions No.:
0
6.0 RESPONSIBILITIES
6.1 The EMS Core Team shall develop the objective and targets based upon the significant
environmental aspects and critical control points developed under Environmental Man-
agement System Procedure 2-04-POl.
6.2 The Core Team shall prepare a list of target activities and determine appropriate baseline
information in order to meet selected objectives.
6.3 The Environmental Management System Representative shall maintain and post the list
of objectives and target activities, dates and responsible persons.
6.4 The Core Team shall conduct a quarterly progress evaluation and make modifications as
necessary to selected objectives and targets.
6.5 Senior management shall conduct an annual review of selected objectives and targets,
and provide necessary resources to ensure that they are met.
7.0 DOCUMENTS
7.1 Related Documents
None
7.2 Document Control
This procedure shall be controlled in accordance with the Environmental Management System
Procedures 2-12-P01, Controlling Documents. Maintaining this Procedure is the responsibility
of the Environmental Program Manager to facilitate retrievability of the documents and up-to-
date information.
8.0 RECORDS
8.1 Required Records
The list of activities; the list of aspects, and the priority list of aspects shall all be main-
tained as appendices to this procedure.
8.2 Records Control
All records, if required, pertaining to this procedure shall be controlled in accordance
with the Environmental Management System Procedures 2-11-P02, Controlling Records.
-------
Kent County Dept. of Public Works
Dover, Delaware
Environmental Procedures Manual
Objectives and Targets
Title:
Setting and Tracking Objectives and Targets
Document No.:
2-04-P01
Prepared By:
Jim Newton
Date Effective:
11-01-2003
Approved By:
Page:
4 of 6
Revisions No.:
0
9.0 ATTACHMENTS
There are no attachments to this procedure.
10.0 APPENDICES
10.1 Appendix A - List of selected objectives and targets currently being addressed by the
EMS.
11.0 REVISION HISTORY
Revision
No.
0
Effective Date
Responsible Person
Jim Newton
Description of Revision
Initial Issue
Appv. By
-------
Kent County Dept. of Public Works
Dover, Delaware
Environmental Procedures Manual
Objectives and Targets
Title:
Setting and Tracking Objectives and Targets
Document No.:
2-04-POl
Prepared By:
Jim Newton
Date Effective:
11-01-2003
Approved By:
Page:
5 of 6
Revisions No.:
0
Appendix A
List of selected objectives and targets currently being addressed by the EMS.
-------
-------
2003-2004 Objectives and Targets Table
Objective Target
Reduce air pollution
Reduce sulfur, particulate and CO emissions
by 50% from CY 2002 levels
Significant Aspects and
CCPs Addressed
1,2,3,6,8
Environmental Management Program
Replace 75% of diesel usage with biodiesel in operating
equipment
Replace emergency generator diesel fuel with biodiesel
Get DNREC to agree to use alternative electricity operation
Replace dryer diesel fuel with bio-fuel made from grease trap
waste or biodiesel
Proposed Date
June 30, 2005
June 30, 2005
June 1, 2004
December 1, 2004
June 1, 2006
Date
Completed
Reduce energy consumption
Reduce or eliminate effects of chlorine and
sulfur dioxide
Reducing sanitary sewer overflows (a.k.a.
spills)
Reduce electricity usage by 20% from CY
2002 levels
Improve safety of existing processes or switch
to an alternative disinfection method
Reduce SSOs by 40% form CY 2002 levels
1,2,3,6
2,4,5,8
Enroll in EPA Green Lights program
Get DNREC to agree to use alternative electricity operation
Upgrade to more energy efficient pumps, lights, etc.
Seek renewable energy alternatives such as wind
Evaluate chlorine hazard potential
Hire consultant to look at cost effective alternatives
Develop plans for alternatives or ways to improve safety of
current systems
Budget finances
Secure financing
Construct
Operate
Develop system to document sources of SSOs
Implement FOG program
Develop action plans to reduce or eliminates SSOs
Develop CMOM program
December 31,2005
June 30, 2004
December 31,2004
December 31,2005
December 31,2006
June 30, 2009
September 30, 2004
December 31,2004
June 30, 2006
November 30, 2006
July 1, 2007
December 31,2008
June 30, 2009
June 30, 2005
June 30, 2004
December 31,2004
December 31,2004
June 30, 2005
-------
MSB - Buncombe County
EMS Environmental 2004 Objectives & Targets
Objective
Sludge Handling
Improvements
Research Lagoon material
placement alternatives.
Septage Receiving Station
Vulnerability Assessment
Target
Install new belt filter
presses, new refractory
and heat exchanger by
August 2004
Restore lagoon to
originally intended use
and ash disposal only by
December 2005
Construct by December
2004
Complete Assessment
Review by July 2004
Baseline
NA
NA
N/A
N/A
Target
NA
NA
N/A
N/A
Objective
Owner
John Kiviniemi
John Kiviniemi
John Kiviniemi
John Kiviniemi
;gal/ Other
quirements
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ignificant
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nancial, &
nerational
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-
Business
Goals
^
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'
nterested
Parties
X
-
-
Printed copy becomes obsolete after 5 days of being printed
Last printed 8/20/2004 9:17AM
EMSFM4.3.3. 06
-------
SAMPLE EMS DOCUMENTATION
ENVIRONMENTAL MANAGEMENT PROGRAMS
Charleston CPW- WWCD Improvement Plan
Charleston CPW- System Cleaning Program
-------
Environmental Management System
Summary of Objectives and Targets
Record File/Retrieval ID (Optional):
Record Schedule No./Retention Period:
Page 1 of 3
Prepared by: WWCD EMS Progress Team / Senior Supervisors
Approved by/Date: A. Williams / Feb. 9, 2004
Purpose/Scope: To identify and communicate environmental objectives and targets based upon consideration of CPW's analysis of operational requirements, significant environmental
impacts, regulatory standards and compliance, technological options, financial resources, the views of interested parties and the strategic business plan.
Instructions: Each CPW department and/or group having been identified by the P2 Team, as having significant environmental impacts (and/or impacts which management requires
departments to track), shall complete this form. This form is to be updated annually (and retained as a departmental record) and updated thereafter when modifications and/or changes occur
in CPW activities, products, and/or services. Results of the activities listed below are to be reported as they occur in the departments Monthly Operating Report (MOR). Note: This form may
be replicated on a computer or duplicated on a photocopier. The computer copy must look similar to this document and contain the same information.
Aspect Item
Sewer System
Overflows
(Significant Aspect)
inflow & infiltration
(I & I) (Significant
Aspect)
Inflow & Infiltration
(I & I) (Significant
Aspect)
inflow & infiltration
(I & I) (Significant
Aspect)
Specific Negative Impact
(Enter a brief description.)
Contamination of
environment
Loss of natural
resources through
energy use
Loss of natural
resources through
energy use
Loss of natural
resources through
energy use
Objective &
Target ID/No.
_____
(System
Cleaning
Program)
______
(Closed-circuit
Television
Inspection
Program)
IP-2004.03
(Mainline
Rehab
Program)
IP-2004^04
(Lateral Lining |
Process)
Objective
Reduce the number
of sewer system
overflows by
systematically
cleaning designated
mainlines.
Acquire system
condition and critical
data for proper
asset management.
Rehabilitate existing
mainlines to prolong
their life and
increase efficiency.
Rehabilitate laterals
utilizing the Cured in
Place Process
Target/Performance Indicator
Clean 556,200' (46,350' monthly
ave.) of wastewater collection
mainlines on problem and high-
risk areas through the 2004-CY.
(Ronald Inabinet)
Perform CCTV inspections on
288,000' (24,000' monthly ave.)
on the collection system through
the 2004-CY. (Franklin Yates)
Rehab 8000' of wastewater
collection mainlines by October 31,
2004. (Franklin Yates)
Performance Record
WWCD Monthly
Operating Report;
Work Orders
WWCD Monthly
Operating Report;
Inspection reports
WWCD Monthly
Operating Report
Rehabilitate 65 laterals using the
CIPP process. Complete by Oct.
31, 2004. (Tony Coker)
WWCD Monthly
Operating Report;
Work orders
Inflow & Infiltration
(I & I) (Significant
Aspect)
Loss of natural
resources through
energy use
IP-2004.05 | Repair defects in the
(Infrastructure | collection system
Repair | possibly contributing
Program) I to inflow &
I infiltration (I & I).
Perform 540 (45 ave. per month)
various point and service repairs
for 2004-CY. (Tony Coker)
WWCD Monthly
Operating Report;
Work orders
Form No.: P2-4.3.3-001 (1/29/2004)
Paae 1 of 1
DOCUMENT DISTRIBUTION
Controlled Original - Chairman, P2 Team
All other copies are uncontrolled.
-------
Objectives and Targets - Continuation Sheet
This sheet may be used as an attachment to the EMS Objectives and Targets form when additional space is required.
NOTE: This form may be replicated on a computer or duplicated on a photocopier. The computer copy must look
similar to this document and contain the same information.
Record File/Retrieval ID (Optional):
Record Schedule No./Retention Period:
Page 2 of 3
Aspect Item
Preventive
Maintenance
Exfiltration
Emergency
Preparedness/
Response
Computerized
Maintenance
Management
System (CMMS)
Training
Specific Negative Impact
(Enter a brief description.)
Potential problems
with equipment
operation resulting in
backups and SSOs
Contamination of
waterways
Increased potential for
damage to
infrastructure,
equipment and
environment
Potential for
maintenance activities
to be incomplete; loss
of permanent records
Lack of intellectual
capital with regard to
environmental and
Form No.: P2-4.3.3-001 A (2/4/2003)
Paae 1 of 1
Objective &
Target ID/No.
IP-2(mC)6
(Valve
Exercising
Program)
IP-2004.07
(Water Quality
Assurance
Program)
IP-2004.09
(Flow Control
Program)
IP-2004.10
(Asset
Management
and Evaluation
Program)
IP-2004.11
(Skills-based
Training
Objective
Ensure all critical
valves are in good
operation should an
emergency occur.
Identify leaks in
collection system
resulting in the
potential
contamination of
waterways.
Develop procedures
for redirecting flows
during emergency
situations.
Develop a system
for evaluating the
infrastructure for
prioritizing
rehabilitation
initiatives.
Establish improved
controls regarding
training
Target/Performance Indicator
Develop a valve-exercising
program. Include drawings
delineating valves to operate,
SOI(s) & schedule(s). Establish
program by May 1, 2004. (Harry
McGee)
Identify locations where
wastewater mains cross
waterways and create a CIS map
of those locations. Complete by
May 1, 2004.
Develop an inspection schedule
and create work orders in the
CMMS by October 31, 2004.
(Gregory Daniels)
Develop a flow control program
involving valves associated with
force mains. Include drawings
delineating valves to operate
during specified emergencies.
Finalize by July 1, 2004. (Harry
McGee)
Performance Record
WWCD Monthly
Operating Report;
Associated drawings
(CIS); Standard
Operating
Instruction(s);
City Works scheduling
via work orders
WWCD Monthly
Operating Report;
Standard Operating
Instruction(s); Work
Orders
WWCD Monthly
Operating Report;
Associated drawings
(CIS); Standard
Operating
Instruction(s)
Develop an asset
management/evaluation program
to include the production of
reports identifying system
rehabilitation priorities.
Accomplish by July 1, 2004. (Chris
Hendricks)
WWCD Monthly
Operating Report;
Standard Operating
Instruction(s);
Associated standard
reports
Establish procedures & reports for
managing the SET Training
database. Accomplish by July 1,
WWCD Monthly
Operating Report;
Standard Operating
DOCUMENT DISTRIBUTION
Controlled Original - Chairman, P2 Team
All other copies are uncontrolled.
-------
Objectives and Targets - Continuation Sheet
This sheet may be used as an attachment to the EMS Objectives and Targets form when additional space is required.
NOTE: This form may be replicated on a computer or duplicated on a photocopier. The computer copy must look
similar to this document and contain the same information.
Record File/Retrieval ID (Optional):
Record Schedule No./Retention Period:
Page 3 of 3
Aspect Item
Operational
Evaluations
Air Release Valve
PM
Inflow & Infiltration
(I & I) (Significant
Aspect)
Computerized
Maintenance
Management
System (CMMS)
Specific Negative Impact [ Objective &
(Enter a brief description.} !a.r.9.?t I.9/.M..9
operational
effectiveness
Improper evaluations
resulting in unqualified
rehabilitation planning
Loss of operational &
design effectiveness of
force mains & pump
stations; exfiltration
Loss of natural
resources through
energy use
Potential for
maintenance activities
to be incomplete; loss
Improvement
Program)
IP-2004.12
(Pump Station
Operational
Evaluation
Program)
______
(Air Release
Valve PM
Program)
IP-2004.14
(I&I
Reduction Plan)
IP-2004.15
(CMMS Phase-
in Project)
Objective
management.
Develop
methodologies &
criteria for
establishing pump
station rehabilitation
priorities.
Ensure air release
valves are working
properly.
Establish a standard
methodology for
mitigating I&I
Encompass all
aspects of
operations within
CMMS.
Target/Performance Indicator
2004. (Susan Roberts)
Develop formal, logical criteria for
determining schedules for pump
station rehabilitation. Complete
by Aug. 1, 2004. (Harry McGee)
Performance Record
Instruction(s);
Standard training
management reports
Establish an air release valve
inspection and maintenance
program. Complete by Aug. 1,
2004. (Ronald Inabinet)
Develop a manual and/or SOI(s)
for I & I reductions. Include a
structured, comprehensive
approach to I&I reduction within
the document(s), and complete by
Sept. 1, 2004. (Franklin Yates)
Phase-in all Technical Section
operations into CityWorks CMMS
program by Oct. 1, 2004. (Chris
Hendricks)
WWCD Monthly
Operating Report;
Grading Criteria
Worksheet; Schedules
(if needed)
WWCD Monthly
Operating Report;
Standard Operating
Instruction(s);
Inspection and PM
schedule
WWCD Monthly
Operating Report;
Standard Operating
Instruction(s); I & I
Manual (if necessary)
WWCD Monthly
Operating Report;
CityWorks technical
work orders
Note: Identification number IP-2004.08 was purposely not used to maintain numbering consistency with the Departmental
Incentives.
Form No.: P2-4.3.3-001 A (2/4/2003)
Paae 1 of 1
DOCUMENT DISTRIBUTION
Controlled Original - Chairman, P2 Team
All other copies are uncontrolled.
-------
CPW EMS ID No: EMS - 4.3.3 Objectives & Targets
ISO 14001, Sub Clause 4.3.3 Objectives & Targets
Program Name:
Revision Date: Feb. 6, 2004
System Cleaning Program
Prepared By: Ronnie Inabinet
Approved By: A. Williams, Superintendent
Signature: On File
Pgm. No. (Obj. & Target ID): IP-2004.01
Section: Maintenance
Wastewater Collection Department
Environmental Management Systems
Improvement Program
Page 1of1
1. Background / Purpose:
System cleaning is essential to the proper maintenance and operation of the wastewater collection
system. Without scheduled maintenance of the collection system sediment, debris, grease, roots, solids
and deposits build up and accumulate in the system. An emphasis is placed on areas that historically
have experienced blockages within the system.
2. Objective / Scope:
Objective:
The objective of the WWCD System Cleaning Program is to reduce the number of Sewer System
Overflows (SSO's) experienced by systematically cleaning designated mainlines.
Scope:
Cleaning is accomplished through the use of Boss and Harben cleaning units and Vac Trucks. This
equipment utilizes pressures of up to 4000 PSI to scour the pipewalls within the collection system.
Various specialized nozzles are utilized during this cleaning process. These nozzles are specifically
designed to accomplish certain types of cleaning, providing the most effective means to achieve the
desired results.
3. Target / Timelines:
Clean 556,200 feet (monthly ave. of 46,350) of wastewater collection mainlines on problem and high-risk
areas through the 2004-CY.
See associated Objective & Target Action Plan for action items, responsibilities and schedules.
4. Performance Indicator:
WWCD Monthly Operating Report
Work Orders
5. Resource Allocation:
For funds allocation, see the 2004 Wastewater Collection Department Operations & Maintenance
Budget, Responsibility Number 013, Cost Center (Group Number) 3400 - Operation and Maintenance
Budget.
6. Related Documents:
2004 EMS Summary of Objectives & Targets
WWCD Monthly Operating Report
Work orders
P(Hobson1 ):/Dept. Work/ Wastwater Shared./ISO/Objectives & Targets/2004 Objectives & Targets/2004-01 System Cleaning Prgm.doc
Form No.: VWVCD F051 (01/26/04)
Paae 1 of 1
DOCUMENT DISTRIBUTION
Controlled Original - VWVCD Superintendent
All other copies are uncontrolled.
-------
SAMPLE EMS DOCUMENTATION
TRAINING
Charleston CPW- Training, Awareness and Competence Procedure
City of Gastonia WWTP- Training Procedure
-------
CPW ENVIRONMENTAL MANAGEMENT SYSTEM PROCEDURE
The on-line version and secured hardcopy are the controlled documents. The secured
hardcopy will be identified by an "Official Document" stamp giving date of
distribution. Any and all other documents are uncontrolled. Contact the EMS
Program Manager for revision level status.
Effective Date: October 1,2000 Page 1 of 3
Revision: 2 Identification Number: EMS - 4. 4. 2
Title: Training, Awareness and Competence Procedure
Prepared By: EMS Procedures Subcommittee
Reviewed By: EMS Management Steering Committee
Approved By: William E. Koopman Jr., General Manager
John Cook PE, Assistant General Manager
Date Approved; August 25, 2000
0.0 Requirement: ISO 14001, Sub Clause 4.4.2 Training
1.0 Purpose
To identify, provide and track training that will help associates to minimize
environmental impacts and increases operating efficiencies.
Scope
ISO 14001, sub clause 4.4.2, requires CPW to identify training needs and provide
specific training to those associates whose work activities could cause adverse
environmental impact.
3.0 Responsibility & Authority
3.1 Each department head shall identify environmental training needs.
3.2 The department head is responsible for maintaining environmental training
requirements.
3.3 Environmental training needs will be evaluated annually by the department.
4.0 Procedure
4.1 Identification of Training Needs
-------
Effective Date: October 1,2000 Page 2 of 3
Revision: 2 Identification Number: EMS -4.4.2
Title: Training, Awareness and Competence Procedure
The knowledge and skills of associates necessary for the department to
achieve environmental objectives will need to be identified. Knowledge
and skill levels should be considered in recruitment and personnel
selection. Ongoing development of associate skills will occur through
internal and external training and education programs.
4.2 Conduct of Environmental Training
Training appropriate to the achievement of environmental policies, objectives
and targets will be provided to all personnel within the department.
Associates should have an appropriate knowledge base, which includes
training in the methods and skills required to perform their tasks in an
efficient and competent fashion and knowledge of the impact their activities
can have on the environment if performed incorrectly.
4.3 Legal and Other Requirements
Education and training will be performed in each department to ensure that
associates have appropriate and current knowledge of regulatory
requirements, environmental policy and the department's procedures and
objectives. The level and detail of training will be determined according to
the work assignment or task.
4.4 Training Elements
Departmental environmental training programs should have the following
elements:
Identification of associate training needs to accomplish job assignment;
Development of a training plan to address defined needs;
Training of target associate groups;
Documentation of training received;
Evaluation of training received.
NOTE: Examples of types of Environmental Training:
Environmental Policy All associates would be required to receive this
training to gain an understanding and commitment to the environmental
policy, objectives, and targets of CPW.
-------
Effective Date: October 1,2000 Page 3 of 3
Revision: 2 Identification Number: EMS -4.4.2
Title: Training, Awareness and Competence Procedure
Strategic Environmental Management Senior management may receive this
training to gain commitment and alignment of CPW's environmental policy.
Skills Enhancement Associates with environmental responsibilities linked to
significant aspects shall be required to receive identified training to improve
performance in specific areas of the department (e.g. operations, laboratory,
engineering, maintenance, etc).
Regulatory Compliance Associates whose actions can affect environmental
compliance shall be required to receive training on the appropriate regulatory
and internal work instruction requirements and be made aware on the
consequences of regulatory non-compliance or deviation from approved work
instructions.
4.5 Adequate Resources
Adequate resources are to be made available to provide the identified
training. In certain cases, training may require certified trainers, such as
CDL, HAZWOPER or CPR. Environmental training will also be provided
within six months of an associate's hire date. Annual refresher training will
be conducted on CPW policy, and departmental objectives and targets.
4.6 Tracking the Training Hours
To document compliance with regulatory and policy requirements, training
hours will be collected and tracked. The department head will compare
training received with the training plan to ensure policy goals are met.
Training records should include:
Associate name,
Job title,
Job description,
Training requirements,
Total training hours by category
5.0 Related Documents and Data
5.1 Environmental Training Records
5.2 Instructor Certification Records
5.3 CPW Training Record Form
-------
Standard Operating Procedure - EMS-0100.005
Name: Training Procedure
Prepared By: Beth Eckert, Environmental /Administrative Manager
Approved By: Beth Eckert, Environmental /Administrative Manager
Corresponding
Requirements:
ISO Standard: 4.4.2
EMS Manual: 4.4.2
NBP Element: 8
Revision Date: 3/3/03
Revision #: 6
Effective Date: 11/4/99
Signature: page 1 Of 5
1.0 Purpose
1.1 The City of Gastonia Wastewater Treatment Division (WWTD) began implementing an ISO
14001 Environmental Management System (EMS) in January , 2000 and a National
Biosolids Partnership EMS in July 2002. As a part of this process, the Division has
identified and established documented procedures for the control and monitoring and
measuring of the EMS, the significant aspects and impacts and critical control points
determined by the Division, and the identified legal and other requirements, when
necessary. Due to the nature of the WWT business, processes involved in the control and
monitoring and measuring of most significant aspects and meeting legal and other
requirements have been practiced for many years throughout the WWT facilities. Also, most
staff employed by the Division have been adequately performing these tasks in the absence
of documented procedures.
1.2 Management and most operations and laboratory staff have received certifications in water
treatment, wastewater treatment, pretreatment, and/or laboratory work. Training at the
WWT facilities has historically been done via on the job training by existing employees and
supervisors. This process will not be deleted, rather, it will be supplemented by the
existence of documented procedures for reference.
1.3 Once they have been formalized, documented training will be done for each employee on
procedures relevant to their job duties. However, tasks required to be done in the course of
treating or monitoring the wastewater will be performed as needed even in the absence of
documented procedures and/or documented training.
1.4 This procedure is to establish a guide for the training of current and future personnel on the
EMS and related documents and procedures.
2.0 Associated Equipment
2.1 None
3.0 Associated Documents
3.1 Document Control Matrix for EMS System - EMS-0101.000A
3.2 Document Control Matrix for Crowders Operations - WCR-0101.000A
"THIS IS AN UNCONTROLLED COPY OF A CONTROLLED DOCUMENT PRINTED 8/20/2004 AT 9:27 AM****
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Name - Number: Training Procedure - EMS-0100.005
Revision #: 6
Revision Date: 3/3/03
Effective Date: 11/4/99
Page 2 of 5
3.3 Document Control Matrix for Crowders Laboratory - WCR-0101.100A
3.4 Document Control Matrix for Long Creek Operations -WLC-0101.000A
3.5 Document Control Matrix for Long Creek Laboratory -WLC-0101.100A
3.6 Document Control Matrix for Pretreatment - WPR-0101.000A
3.7 Document Control Matrix for Biosolids - WRF-0101.000A
3.8 A spect and Impact Ranking Form - EMS-0101.003E
3.9 Procedure Training Sign-In Sheet -EMS-0101.005A
3.10 Training Matrix - EMS-0102.005B
3.11 National Biosolids Partnership EMS Guidance Manual
3.12 National Biosolids Partnership Manual of Good Practice
4.0 Procedure
4.1 All employees will be trained on the EMS policy and to a general EMS awareness level. All
contractors will be notified of the environmental policy via mail and/or notification upon
arrival at the site. Signs referencing the EMS policy have been posted at the entrance to the
WWT facilities and the Resource Recovery Farm and policies are in the entrance areas or
conference room of each Division location for review by visitors.
4.2 Personnel that can have a significant impact on the environment through their work
practices will be trained on:
4.2.1 The importance of conformance to the environmental policy, requirements of the
environmental management system, and emergency preparedness and response
requirements. Roles and responsibilities related to these will be communicated.
4.2.2 The potential or actual significant environmental impacts of their work activities.
4.2.3 The relevant procedures identified in the training matrix, the benefits of adhering to the
procedures and potential environmental consequences of departure from them.
4.3 Training requirements of contractor personnel will be established on a case by case basis.
City Staff who serves as the Contractors Contact person shall establish and track these
requirements.
4.4 Training roles of Division personnel are as follows:
4.4.1 EMS Coordinator and management will identify training needs (Training Matrix EMS-
0101.005B) regarding the EMS procedures and the EMS Coordinator, or designee,
"THIS IS AN UNCONTROLLED COPY OF A CONTROLLED DOCUMENT PRINTED 8/20/2004 AT 9:27 AM* ***
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Name - Number: Training Procedure - EMS-0100.005
Revision #: 6
Revision Date: 3/3/03
Effective Date: 11/4/99
Page 3 of 5
will train area Supervisors and management on relevant procedures. The EMS
Coordinator shall assist supervisors upon request with the training of other personnel.
4.4.2 Supervisors are responsible for identifying training needs of their respective personnel
on area Standard Operating Instructions (SOIs). Supervisors are also responsible for
ensuring that the identified training needs of their personnel on EMS procedures and
area SOIs are met.
4.4.3 Persons either preparing a procedure or approving a procedure are not required to
receive documented training on the procedure. Either of these persons must train
Division staff that has been identified as needing the training. This may involve the
training of Supervisors or other Division personnel so that they may appropriately train
identified Division staff.
4.5 Standard Operating Instructions must be developed for each activity which has an impact
on a significant environmental aspect or that is needed to properly control a critical control
point (as identified on the Aspect and Impact and Critical Control Point Ranking Form #
EMS-0101.003E). The area supervisors are responsible for using their knowledge of the
operation of their area to determine which procedures affect the significant environmental
aspects.
4.5.1 Additionally, supervisors are to refer to the list of critical control points and the NBP
Manual of Good Practice for additional information pertaining to procedure
requirements to address activities at control critical control points.
4.6 All employees must receive training on documented procedures and revisions which are not
exempted via the Corrective/Preventative Action procedure (EMS-0100.004). The area
supervisors are responsible for determining which procedures are required for each
employee.
4.7 Training needs will be indicated on the training matrix form (EMS-0102.005B) by gray
shading. The EMS coordinator or other personnel authorized to make changes on the read-
only drive must be notified of any changes in the employee training requirements.
4.8 The EMS Coordinator or designated personnel will train all new employees on policy and
EMS awareness on their first day of work, whenever possible, and all current EMS
procedures appropriate for the position within 30 days of reporting to work.
"THIS IS AN UNCONTROLLED COPY OF A CONTROLLED DOCUMENT PRINTED 8/20/2004 AT 9:27 AM* ***
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Name - Number: Training Procedure - EMS-0100.005
Revision #: 6
Revision Date: 3/3/03
Effective Date: 11/4/99
Page 4 of 5
4.8.1 Supervisors must make arrangements with the EMS Coordinator to ensure training is
completed as required when a new employee reports to work with the Division.
4.9 Training will not be required on revised procedures where the intent of the procedure is not
revised, merely logistics i.e. spelling, grammar, numbering, etc... This occurrence will be
tracked by a C/PAR.
4.10 When deemed appropriate by the Supervisor, retraining may be done only on the modified
portion of a revised procedure. When training is done this way the revised section must be
noted on the training form.
4.11 Retraining will be done as a result of an incident where a procedure was not properly
followed.
4.12 All trained personnel must sign the sign-in sheet (EMS-0101.005A) to document their
training and understanding of the procedure.
4.13 The effectiveness of the training will be evaluated by an oral or written test, and/or by
observation of the employee performing the task according to procedure. The supervisor or
person designated to perform the training will use this information to evaluate whether the
training is sufficient or if more training is required. When the training is judged to be
sufficient, the supervisor/trainer will date and initial the "Training Sufficient" section of the
training sign-in-sheet (EMS-0101.005A) and the employee will be permitted to perform the
task unsupervised.
4.13.1 In the event that training is done over a period of time and not on one day, the training
may be documented by the entry of a range of dates on the training form and matrix.
4.13.2 Many employees may only be required to perform various portions of a procedure.
Training may only be performed on the portion of the procedure that is appropriate
and the sections of the procedure trained on must be indicated on the training form
(EMS-101.005A).
4.14 The sign-in sheet must be submitted to the EMS Coordinator, or designee, for recording on
the Training Matrix (EMS-0101.005B).
4.15 All internal EMS auditors must have either received training from an outside EMS auditing
training course or have observed at least one internal audit, audited under the guidance of a
previously qualified auditor, and have been trained on the City's EMS Auditing procedure.
Prior to auditing without guidance, new auditors must have been deemed sufficiently trained
"THIS IS AN UNCONTROLLED COPY OF A CONTROLLED DOCUMENT PRINTED 8/20/2004 AT 9:27 AM* ***
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Name - Number: Training Procedure - EMS-0100.005
Revision #: 6
Revision Date: 3/3/03
Effective Date: 11/4/99
Page 5 of 5
and able to perform audits by the EMS Coordinator. Internal training and determination
must be documented on a procedure training sign-in form (EMS-0101.005A).
4.15.1 Documentation verifying external auditor training will be maintained in EMS files.
4.16 Compliance auditors are chosen by the Division Manager based on knowledge and
experience. The Division staff who are currently serving as compliance auditors have
prepared the auditing procedures based on their knowledge and experience. Future internal
compliance auditors must receive documented training on the auditing procedure and
observe at least one audit prior to becoming a compliance auditor.
5.0 Revision History:
Revision
Date
3/3/03
#
6
6
C/PAR #
EMS-0084
EMS-0116
Reason for
Revision
C/PAR
C/PAR
Description of Revision
Added a modification history section
Added NBP requirements as a part of the WWTD's
participation in the NBP demonstration group.
"THIS IS AN UNCONTROLLED COPY OF A CONTROLLED DOCUMENT PRINTED 8/20/2004 AT 9:27 AM* ***
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SAMPLE EMS DOCUMENTATION
INTERNAL AND EXTERNAL COMMUNICATION
Charleston CPW- Internal Communication Procedure
Charleston CPW- External Communication Procedure
City of San Diego WWC- Communication and Environmental Information
-------
CPW ENVIRONMENTAL MANAGEMENT SYSTEM
PROCEDURE
The on-line version and secured hardcopy are the controlled documents. The secured
hardcopy will be identified by an "Official Document" stamp giving date of
distribution. Any and all other documents are uncontrolled. Contact the EMS
Program Manager for revision level status.
Effective Date: October 1,2000 Page 1 of 3
Revision: 2 Identification Number: EMS -4.4.3 (A)
Title: Internal Communication Procedure
Prepared By: EMS Procedures Subcommittee
Reviewed By: EMS Management Steering Committee
Approved By: William E. Koopman Jr., General Manager
John Cook PE, Assistant General Manager
Date Approved: August 25, 2000
0.0 Requirement: ISO 14001, Sub Clause 4.4.3 Communication
1.0 Purpose
To build understanding, cooperation, and involvement from all associates in the
performance of their duties in an environmentally conscious manner.
2.0 Scope
ISO 14001, sub clause 4.4.3, with regard to environmental objectives and targets,
requires establishing processes to report internally and, where desired externally, on the
environmental activities of the organization.
3.0 Responsibility & Authority
3.1 Communication of environmental issues is the responsibility of all CPW
departments.
3.2 It is the responsibility of every associate to communicate environmental
concerns, problems, or suggestions to their supervisor.
-------
Effective Date: October 1,2000 Page 2 of 3
Revision: 2 Identification Number: EMS -4.4.3 (A)
Title: Internal Communication Procedure
4.0 Procedure
4.1 Communication through Normal Management Channels
4.1.1 Management Channel s
The traditional flow of information from one management level to
the next is appropriate and will be used to communicate
environmental information. Periodic, or routine staff meetings
with open dialogue is encouraged.
4.1.2 Communication through Internal Newsletters
Certain environmental communications will be made through
internal newsletters. Programs that promote environmental
excellence should be communicated to CPW associates and
considered for release to the public.
4.1.3 Communication through Videos
Videos may be used to relay environmental information to large
groups of associates.
4.1.4 Communication through e-mail and Special Memos
Announcements concerning environmental improvement
programs, upcoming internal audits, DHEC inspections, etc. will
be disseminated through e-mail for large groups of associates or by
special memo to specific individuals or groups.
4.1.5 Communication through Suggestion Boxes
Suggestion boxes will be made readily available to all associates.
Communication in this form coming directly from individual
associates is a valuable source of information about potential
environmental impacts. Suggestions will be evaluated concerning
environmental improvements. Rewards will be considered for
suggestions that are implemented.
4.1.6 Special Communication via Attorney
Effective Date: October 1,2000 Page 3 of 3
-------
Revision: 2 Identification Number: EMS - 4. 4. 3 (A)
Title: Internal Communication Procedure
Certain environmental information should be relayed only to those
with a need to know by an attorney. When communication is done
in this way the information is protected by the Attorney-Client
privilege doctrine.
4.1.7 Recognition Communication
Both positive and negative recognition must be given to associates.
Positive recognition shall be given in accordance with CPW
recognition programs. Negative recognition must be given if
employees knowingly violate regulations or CPW policies that
adversely impact the environment. Disciplinary action will be
administered in accordance with CPW policy.
4.2 Related Documents and Data
4.2.1 Records containing internal communication sent to associates.
4.2.2 Records containing associate feedback.
-------
CPW ENVIRONMENTAL MANAGEMENT SYSTEM PROCEDURE
The on-line version and secured hardcopy are the controlled documents. The secured
hardcopy will be identified by an "Official Document" stamp giving date of
distribution. Any and all other documents are uncontrolled. Contact EMS Program
Manager for revision level status.
Effective Date: October 1,2000 Page 1 of 3
Revision: 2 Identification Number: EMS -4.4.3 (B)
Title: External Communication Procedure
Prepared By: EMS Procedures Subcommittee
Reviewed By: EMS Management Steering Committee
Approved By: William E. Koopman Jr., General Manager
John Cook PE, Assistant general Manager
Date Approved: August 25, 2000
0.0 Requirement: ISO 14001, Sub Clause 4.4.3 Communication
1.0 Purpose
The purpose of this procedure is to define the steps that CPW follows to:
(1) Control the receipt, documentation and response to external communications
regarding CPW s environmental aspects
(2) Consider external communication procedure on significant environmental aspects
(3) Document related decisions
2.0 Scope
ISO 14001, sub clause 4.4.3, with regard to external communication requires establishing
processes on receiving, documenting and responding to communications from external
interested parties.
3.0 Responsibility & Authority
3.1 The department head (or designee) investigates the need for external
communication.
3.2 The Customer Relations Specialist prepares releases of public interest.
3.3 The General Manager (or designee) authorizes prepared releases to the
public.
-------
Effective Date: October 1, 2000 Page 2 of 3
Revision: 2 Identification Number: EMS -4.4.3 (B)
Title: External Communication Procedure
4.0 Procedure
4.1 External Communication Channels
4.1.1 With regard to CPW s environmental aspects or environmental
management system (EMS) the department head (or designee)
investigates the need for external communication on a case by case
basis. The investigation can be initiated by, but is not limited to,
the following:
Complaints and/or inquires from customers, SCDHEC,
community groups, or other interested parties
External promotional activities regarding CPW environmental
policy or programs
New or changing environmental regulations
NOTE 1: Such communications include, but are not limited to:
Statements regarding CPW's policy commitment to the
environment
Statements regarding CPW's significant environmental aspects
and their potential impacts
External interested party concerns and questions, and responses
to these concerns and questions
Reports on performance with regard to environmental quality,
objectives and targets, and on compliance with environmental
regulations as determined by audits and management reviews
Communications initiated by or to be received by potential
legal entities
4.1.2 The department head or (designee) identifies the extent and/or
impact of the problem or inquiry and determines what information
needs to be communicated.
4.1.3 The department head or (designee) obtains the needed information
from the appropriate associates within CPW or the department and,
as necessary assistance from the Customer Relations Specialist,
-------
Effective Date: October 1,2000 Page 3 of 3
Revision: 2 Identification Number: EMS -4.4.3 (B)
Title: External Communication Procedure
who constructs the content, format, and method of the
'communication accordingly. Designated individuals are then
authorized to release information to external parties.
4.1.4 Statements regarding CPW environmental policy, significant
environmental aspects and their potential impacts, reports on
environmental performance or compliance with regulatory
requirements and communications to legal entities, shall be
reviewed and approved by the CPW General Manager (or
designee) prior to release.
NOTE 2: Information in the communication should be understandable, adequately
explained, verifiable, and presented in a consistent form. Methods to be
considered include, but are not limited to:
External newspapers or newsletters
Public announcements and/or news conferences (TV, radio,
etc.)
Paid advertisements or public notices in newspapers, industry
journals, or other publications
Annual reports
Regulatory submissions and public records
Commission meetings
Letters, memos and other correspondence
Electronic mail messages; faxes, etc.
Bill inserts
Internet Web Site
4.1.5 Executive management (or designee) issues the communication to
the required recipients and interested parties.
4.1.6 A copy of communication received or sent, as well as any requests
that initiated the communication and/or requests for the
information shall be retained for a period of 5 years.
4.2 Related Documents and Data
4.2.1 Records regarding EMS external communications.
-------
DD-SEOP-4.4.3
COMMUNICATION OF ENVIRONMENTAL INFORMATION
(INTERNAL AND EXTERNAL)
1.0 PURPOSE AND SCOPE
This procedure describes the methods to be used for documenting and responding to inquiries
related to the environmental policies, practices, and performance of the City of San Diego's
Metropolitan Wastewater Department (MWWD) Wastewater Collections (WWC) Division.
This procedure applies to inquiries made by interested parties external to the WWC Division, as
well as WWC Division employees, contractors, or suppliers. The procedure does not apply to
the resolution of questions that may be raised during routine environmental training activities,
internal, and external audits.
2.0 DEFINITIONS
2.1 Interested Party
For the purposes of this procedure, an interested party is defined as an individual, organization,
or group interested in, concerned with, or affected by the environmental performance of the
WWC Division. Examples of interested parties include regulatory agencies or authorities,
community groups, environmental organizations, the press, private citizens, employees, and
employee organizations; the definition may also be extended to contractors or suppliers working
at or delivering materials or services to individual WWC Division sections.
2.2 Computerized Maintenance Management System
Any Computerized system that functions as a tool for dispatching and documenting WWC
Division field personnel to sewer related emergencies.
3.0 RESPONSIBILITIES
3.1 Environmental Management Representative
The Environmental Management Representative (EMR) has primary responsibility for
coordinating, receiving, logging, and evaluating all inquiries about WWC Division's
environmental policies, practices, and performance with appropriate WWC Section Managers,
staff and the MWWD Public Information Section. The EMR is responsible for responding
directly to inquiries related to the ISO 14001 Environmental Management System (EMS), made
by WWC Division personnel, but shall review all external EMS inquiries with the responsible
Section Manger, Deputy Director and/or Public Information Section prior to making a response.
3.2 WWC Division Personnel
Any WWC Division employee who is contacted by an interested party requesting information
regarding the Division's environmental policies, practices, or performance shall refer all such
DD-SEOP 4.4.3 June 2003
Communication of Environ. Information (Int. and Ext.) Rev 1
MWWD WWC Division 1
-------
inquiries to the appropriate supervisor or Section Manager, who in turn will answer or direct the
inquiry to the EMR (or Deputy Director as needed) for evaluation and appropriate action.
3.3 Deputy Director, WWC Division
The WWC Deputy Director is responsible for evaluating external information requests with the
EMR, for providing direction as to whether a written or verbal response is required, and for
reviewing and approving all written responses.
3.4 Section Manager
The Section Manager is responsible for responding to, and logging any inquiries concerning
section specific performance and/or programs. The Section Manager may direct inquiry to
appropriate Section staff and /or EMR.
4.0 PROCEDURE
General
Internal communication may be conducted through any of the following manners:
normal management channels i.e. meetings where information flows from one
management level to the next)
electronic message and e-mail
memos, posters and circulars on notice boards
internal newsletter
training programs
External communication issues will be conducted through the following means:
Sewer Pump Stations Section, Construction/TV Section, Main Cleaning Maintenance
Section, Engineering Section, Maintenance Coordination/Scheduling Section, Administration
Section:
Sewer Response Inquiry: All inquires of this nature need to be referred to the Sewer
Emergency Hotline at (619) 515-3525 and documented in the current CMMS per the
WWC Division Sewer Overflow Response and Tracking Plan.
Food Establishment Waste Discharge Section:
Sewer Infrastructure Inquiry: All FEWD inquiries of this nature will be documented and
tracked in the FEWD CMMS.
All Sections:
Environmental Policy Inquiry: Document the inquiry in the current CMMS and refer the
inquiry to EMR
DD-SEOP 4.4.3 June 2003
Communication of Environ. Information (Int. and Ext.) Rev 1
MWWD WWC Division 2
-------
The procedure consists of the following steps:
4.1 The EMR shall document the receipt of written or verbal inquiries related to WWC
Division's environmental policies and performance on an Environmental
Communications Log form (DD-F-001.0, see the example provided as Figure 1). The
EMR shall then evaluate the source and content of the inquiry.
4.2 If the inquiry was received verbally from an interested party within WWC Division, the
EMR shall respond verbally, briefly note the content of the response on DD-F-001.0, and
enter the date the response was made.
4.3 If the inquiry is in the form of a written complaint or request for specific information
from an interested party from outside the Division, the EMR shall confer with the WWC
Deputy Director or appropriate Section Manager(s) and determine an appropriate
response. If a verbal response is determined to be appropriate, the EMR shall make the
contact and record the action in the log as noted in Step 2.
4.4 If a letter or other documented response is required, the EMR shall prepare a draft for the
Deputy Director's review, and shall resolve any comments prior to transmittal. Requests
for copies of WWC Division's environmental policy (Section 2 of the WWC Division's
Environmental Management Plan) shall be honored in all cases. The EMR shall record
the type of response on the log, and enter the date of the response.
4.5 Completed Environmental Communications Log pages and associated incoming and
outgoing correspondence shall be retained as environmental records in compliance with
Section 5.3 of the WWC Division Environmental Management Plan.
4.6 Section Managers will respond to inquiries concerning the performance of their direct
staff. The Section Manager may direct inquiries to the EMR.
4.7 The procedures for handling of media communication shall be as follows:
4.7.1 All questions and calls from the press have to be channeled to the MWWD Public
Information Officer (PIO).
4.7.2 The PIO shall make reference to Corporate Communication Department prior to any
news release to media.
4.7.3 The EMR shall log the details of the media communication when issued by the PIO in
Master Log (Figures 2).
5.0 REFERENCES
WWC Division Environmental Management Plan
Section 2, Environmental Policy
Section 4.3, Communications
Section 5.3, Records
WWC Division Sanitary Sewer Overflow Response and tracking Plan (SORTP)
DD-SEOP 4.4.3 June 2003
Communication of Environ. Information (Int. and Ext.) Rev 1
MWWD WWC Division 3
-------
Figure 1
Form DD-F-001.0
External Communications Record
Date Communication Received
Type of Communication (circle one)
Received From
Address/Telephone Number/
E-Mail
Internal External
Content of Communication (attach copy if possible)
Will Organization Respond?
Date of Response
Person Responding
Position
YES NO
Nature of Response (attach copy if possible)
Are Internal Actions Necessary? (If Yes, fill out a Corrective & Preventive Action Form, DD-
F-006.0.
Contact Person:
Date Completed:
Log No.:
DD-SEOP 4.4.3
Communication of Environ. Information (Int. and Ext.)
MWWD WWC Division 4
June 2003
Revl
-------
Figure 2
External Communications Tracking Log Master List
EXTERNAL COMMUNICATIONS TRACKING LOG MASTER LIST
LOG DATE RECEIVED DATE ACTION
NO. RECEIVED BY TAKEN
DD-SEOP 4.4.3 June 2003
Communication of Environ. Information (Int. and Ext.) Rev 1
MWWD WWC Division 5
-------
SAMPLE EMS DOCUMENTATION
DOCUMENT CONTROL AND RECORD MANAGEMENT
Charleston CPW- Document Control Procedure
Charleston CPW- Record Management Procedure
City of Eugene WWTP - Records Procedure
Kent County DPW- Controlling Documents Procedure
-------
CPW ENVIRONMENTAL MANAGEMENT SYSTEM
PROCEDURE
The on-line version and secured hardcopy are the controlled documents. The secured
hardcopy will be identified by an "Official Document" stamp giving date of
distribution. Any and all other documents are uncontrolled. Contact the EMS
Program Manager for revision level status.
Effective Date: October 1,2000 Page 1 of 2
Revision: 3 Identification Number: EMS - 4.4.5
Title: Environmental Management System Document Control
Procedure
Prepared By: EMS Procedures Subcommittee
Reviewed By: EMS Management Steering Committee
Approved By: William E. Koopman Jr., General Manager
John Cook PE, Assistant General Manager
Date Approved; August 25, 2000
0.0 Requirement ISO 14001; Sub Clause 4.4.5
South Carolina Department of Archives and History. Division
of Archives and Records Management
1.0 Purpose
This document describes the procedure to be followed for the approval, issue, and
maintenance of all environmental management system (EMS) controlled documentation.
2.0 Scope
This procedure shall apply to all CPW EMS controlled documentation.
3.0 Responsibility & Authority
All EMS controlled documentation shall be subject to approval by the following before
issue and release:
a) General Manager and Assistant General Manager for EMS Procedures
affecting all CPW departments
b) Section Head and/or Department Head for site specific EMS
documentation
c) EMS Program Manager for ISO 14000 EMS documentation
4.0 Procedure
4.1 EMS procedures, processes, work instructions, associated records shall be
defined, appropriately documented and updated as necessary. Each department
-------
Effective Date: October 1,2000 Page 2 of 2
Revision: 3 Identification Number: EMS - 4.4.5
Title: Environmental Management System Document Control
Procedure
will clearly define the various types of documents and records which establish the
EMS.
4.2 A record (master list) of EMS controlled documentation affecting all CPW
organizations shall be maintained within Information Services. EMS
documentation (i.e., procedures or work instructions, records) which are specific
to a department, shall be maintained and controlled within the department and
include:
1) Reference number
2) Issue number
3) Disposition of copies
4.3 Distributed copies of EMS controlled documents shall be stamped "Official
Document" with the date of distribution.
4.4 All EMS official documents will be of a standard format and contain the
following:
Effective date of distribution
Number of document pages
Revision number
Title of document
Preparer (originator) of document
Approval authority (original on file if published electronically)
Identification number
4.5 Distribution of EMS "official documents" may be published electronically with
read only status. The original paper document with approval signature shall be
retained on file.
4.6 All copies of EMS documentation that become obsolete by reissue shall be
promptly removed, marked obsolete and handled in accordance with the "EMS
Records Procedure."
5.0 Related Documents and Data
5.1 South Carolina Local Government Records Manual
5.2 EMS Records Procedure
-------
CPW ENVIRONMENTAL MANAGEMENT SYSTEM PROCEDURE
The on-line version and secured hardcopy are the controlled documents. The secured hardcopy
will be identified by an "Official Document" stamp giving date of distribution. Any and all other
documents are uncontrolled. Contact the EMS Program Manager for revision level status.
Effective Date: October 1,2000 Page 1 of 4
Revision: 3 Identification Number: EMS - 4.5.3
Title: EMS Records Procedure
Prepared By: EMS Procedures Subcommittee
Reviewed By: EMS Management Steering Committee
Approved By: William E. Koopman Jr., General Manager
John Cook PE, Assistant General Manager
Date Approved: August 25, 2000
0. 0 Requirement: ISO 14001, Sub Clause 4.5.3; Records Management, Section 30-1-80,
Code of Laws of South Carolina, 1976 as amended.
1.0 Purpose:
The purpose of this procedure is to define the steps that CPW follows to ensure that
environmental management system (EMS) records are properly identified, collected, indexed and
filed to allow for ready access and retrieval.
NOTE: All records created or received by the Commissioners of Public Works during the
course of business are considered public records and as such are governed by
Section 30-1-80, Code of Laws of South Carolina, 1976, as amended. It will be
the duty of the Commission to establish and maintain an active and continuing
records program in compliance with all statutory guidelines, and to provide for
the economical and efficient management of all Commission records from their
creation or receipt, through their ultimate disposition.
2.0 Scope:
2.1 This procedure applies to EMS CPW records that associates use, handle or
maintain.
2.2 The EMS Records Procedure will provide for:
1.) Record Generation
2.) Record Review
3.) Active Records Storage
4.) Inactive Record Retirement
2.3 Definition of Terms
Active Records - Records that must be maintained in office space
because they are referred to once a month or more and are needed to
conduct daily business.
-------
Effective Date: October 1, 2000 Page 2 of 4
Revision: 3 Identification Number: EMS - 4.5.3
Title: EMS Records Procedure
Disposition - The final action that puts into effect the results of an
appraisal decision for a series of records. Transfer to an archival
repository, transfer to a records center, or destruction are some possible
disposition actions.
Document - Recorded information, regardless of form or medium. Also
called record or documentary material.
Environmental Management System (EMS) Record Records that
are defined as EMS records by the department and listed on the Master
Control Document Register as records necessary to maintain conformance
with the EMS and ISO 14001 requirements.
Inactive Records - Records referred to less than once a month and are
suitable for storage outside of the immediate office.
Record - Recorded information, regardless of physical form or
characteristics of the medium (e.g. paper, photograph, sound records, or
computer generated, machine readable record) made or received by an
organization to fulfil its legal obligations or to transact business.
Records Retention/Disposition Schedule - Document that specifies
actions for the retention and disposition of current, inactive, and non-
current records series of an organization or agency.
Record Series - Documents arranged according to a filing system or
maintained as a unit because they relate to a particular subject or function,
result from the same activity, have a particular form, or share some other
relationship arising out of their creation, receipt, or use.
Scheduling - The action of establishing retention periods for records and
providing for their proper disposition at the end of active use. See
Records Retention/Disposition Schedule.
3.0 Responsibility and Authority
3.1 The department document control representative ensures that EMS records
are properly identified, collected indexed, filed, and stored to allow for
ready access and retrieval, at the department level, and that these records
are properly disposed in accordance with the CPW Records Management
Policy RM-PM-01.
3.2 The Records Retention Specialist/Information Services will provide for:
1.) Inventory, appraisal, and scheduling of records according to the
policies and procedures as set forth by the South Carolina
Department of Archives and History and the EMS;
2.) Preservation and restoration of records deemed to be of vital,
continuing, or enduring value;
3.) Destruction of records which have outlived their administrative,
legal, or fiscal value;
4.) Transfer and maintenance of inactive and semi-active office records
to approved storage facilities;
-------
Effective Date: October 1, 2000 Page 3 of 4
Revision: 3 Identification Number: EMS - 4.5.3
Title: EMS Records Procedure
5.) Reporting of all required program information to the South Carolina
Department of Archives and History;
6.) Disaster preparedness and recovery efforts for CPW records.
4.0 Procedure
4.1 EMS Record Generation
When an EMS record is needed or generated, the appropriate associate
(specified in the procedure or work instruction) completes the record.
4.2 EMS Record Review
The associate conducts a review of the EMS record and forwards the
record to the document control representative for review and filing.
NOTE: The EMS record's review ensures that:
1.) The record is complete and legible;
2.) Signatures and initials are filled in where necessary;
3.) The information contained in the record is correct and has not been
improperly altered;
4.) Any errors that have been made in the record have been properly
corrected, (a single line drawn through the error) the correction
initialed and dated;
5.) The record has an approved Record Retention Schedule authorizing
its final disposition.
NOTE: It will be the responsibility of the department document control representative to
notify the Records Retention Specialist/Information Services of all new EMS
record series. A Record Series Inventory Form will be completed by the
document control representative for each record series and forwarded along with
pertinent information to the Record Retention Specialist
4.3 Active Record Storage
The department document control representative reviews the EMS record
for completeness and accuracy and either sends the record back for
correction or files the record according to procedure.
NOTE: Containers for storing active records within the department may be folders, file
cabinets, boxes, computer directories, etc., provided they allow the record to be
properly identified and stored so as to minimize deterioration, damage, or loss.
4.4 Record Retrieval
When a record is removed from filing the person will check out the record
in accordance with department procedures.
4.5 EMS Records Purge
-------
Effective Date: October 1, 2000 Page 4 of 4
Revision: 3 Identification Number: EMS - 4.5.3
Title: EMS Records Procedure
Annually or when quantity warrants, the document control representative
(or designee) purges all EMS records that are past their retention period
and disposes of them according to the CPW Records Management Policy
RM-PM-01.
4.6 Inactive EMS Records Retirement
EMS Records that are infrequently needed but must be kept for a specific
amount of time for legal, fiscal or administrative reference value should
be transferred to inactive records storage in accordance with the CPW
Records Management Policy RM-PM-01.
4.7 Inactive EMS Records Retrieval
Requests for EMS record retrieval can be made via telephone,
electronically, or in writing. All requests for EMS records placed in
storage are to be made through the Records Retention Specialist and/or the
document control representative for the respective department in
accordance with the CPW Records Management Policy RM-PM-01.
4.8 Final Records Disposition
EMS records must be disposed of in accordance with the CPW Records
Management Policy RM-PM-01
5.0 Related Documents and Data
5.1 Document Control Procedure (EMS-4.4.5)
5.2 SC Department of Archives and History Record Series Inventory Form -
RS-I-1(90) (EMS-4.5.3 -2)
5.3 SC Department of Archives and History Records Retention Schedule Document -
RS-S2(91)(EMS-4.5.3 -3)
5.4 CPW Records Transfer List Document - RTL3.97 (EMS-4.5.3 -4)
5.5 CPW Records Disposal Authorization Document RDR3.97
(EMS-4.5.3 -5)
5.6 SC Department of Archives and History Microfilm Quality Certification for
Records Disposition - TEMP-61(3/93) (EMS-4.5.3 -6)
5.7 SC Department of Archives and History Authorization for Disposal of Original
Paper Records Stored in Optical Disk Systems (TEMP-80 2/95) (EMS-4.5.3 -7)
5.8 SC Department of Archives and History Microfilm Transmittal and Receipt -
ARM - 8A(94) (EMS-4.5.3-8)
5.9 Inactive Record Charge-Out (EMS-4.5.3-9)
5.10 CPW Records Management Policy RM-PM-01
-------
-[ Deleted:
CITY OF EUGENE - WASTEWATER DIVISION
Procedure
Subject:
Last Reviewed By:
Approved By:
Records
Linda Delaplain
Original Date:
4/28/00
Management Team
Document No.
Revision No.:
Date Approved:
VWV-00017
2
9/1 0/03
Purpose
This procedure describes the process to be used for maintaining all records stored by the Division. These records
include internal records such as audit records; old versions of revised policies, procedures, and work instructions;
records stored in databases (including training, maintenance system, laboratory system, chemical inventory system,
distributed control system, etc.; instrument maintenance records; all completed data forms; and other documentation
that provides documentation of the Divisions activities. External records include contracts, permits, and other
documents that are provided by outside sources.
Scope
This procedure applies to all records that may be stored for the Division in the document imaging system, manual files,
databases, or archive files.
New Records
Record Retention and Disposal
Definitions
Archive Files - all records stored in Centrifuge Building are referred to as archive files
Document Control
Document Imaging System
Manual Files
Record Owner
Records
Safety Requirements
All specific safety requirements will be included or referred to in specific work instructions.
Procedure (Include reporting requirements and precautionary steps in this section)
Accountability:
New Records
Division Staff
Procedure
Records
Responsibility:
Create and/or receive documentation to be maintained as a record for the
Division.
Page 1 of 2
Document No.: WW-00017; Rev. No. 2
Last Revised: 9/10/03
-------
-[ Deleted:
Route record to Document Control Staff.
NOTE: If record is to be stored in archives, provide list of documents to be
stored to Document Control Staff.
Document Control Staff Receive document(s) to be stored as a record(s).
Determine filing location of record.
If record is to be maintained as an image, scan the document into
Laserfiche.
If record is to be filed in the manual files, file.
If record is to be archived, enter into archive database, print label for
archive box and attach to box, route to archive storage.
If the record is a training record, enter into training database. Route all
Training Verification Forms to Laserfiche for scanning.
Record Retention and Disposal
Document Control Staff On an annual basis, review all records and their retention times. Identify
records that are eligible for disposal using the Record Retention Schedule.
Route Record Disposal Report to record owner for authorization to dispose of
the record.
Division Staff Review list of records eligible for disposal. Approve records for disposal or note
new date for disposal. Route Record Disposal Report back to Document
Control Staff.
Document Control Staff Make changes noted on the Record Disposal Report related to disposal dates.
Routes revised Record Disposal Report to Division Management Team for
approval.
Division Management Team Reviews Record Disposal Report, approves or denies records for disposal, and
routes back to Document Control Staff.
References
ISO 14001 Standard, 4.5.3 Records
EMS Manual. Records Policy
Record Retention Schedule
Procedure Page 2 of 2 Document No.: WW-00017; Rev. No. 2
Records Last Revised: 9/10/03
-------
Kent County Dept. of Public Works
Dover, Delaware
Environmental Procedures Manual
Controlling Documents
Title:
Controlling Documents
Document No.:
2-12-POl
Prepared By:
Jim Newton
Date Effective:
12-01-2003
Approved By:
Page:
Iof6
Revisions No.:
0
CONTENTS
1.0 PURPOSE
2.0 SCOPE
3.0 DEFINITIONS
4.0 REFERENCES
5.0 REQUIREMENTS
6.0 RESPONSIBILITIES
7.0 DOCUMENTS
8.0 RECORDS
9.0 ATTACHMENTS
10.0 REVISION HISTORY
1.0 PURPOSE
1.1 The purpose of this procedure is to establish the general requirements for the work proc-
ess of controlling documents at the Kent County Dept. of Public Works Regional Waste-
water Treatment Facility.
1.2 The purpose of this work process is to establish the Kent County Dept. of Public Works
Document and Data Control specification.
2.0 SCOPE
2.1 This procedure addresses all documents and data relating to the requirements of ISO
14000, including documents of external origin as applicable, including:
(a) Environmental Program Manual
(b) Procedures
(c) Process Instructions
(d) Design Output and Change Documentation
(e) Special Process Control Documentation
(f) Associated Reference Documentation and Lists
2.2 Environmental Management System Records are handled in accordance with the Kent
County Dept. of Public Works Environmental Management System Procedure 2-11-POL
3.0 DEFINITIONS
3.1 Approved Document or Data - Any informational or instructional paper, drawing, micro-
fiche, microfilm, electronic data, magnetic tape or disc which has been formally approved for is-
sue. This includes, but is not limited to, the following: guides, manuals, procedures, process in-
structions, regulations, rules, specifications and standards.
-------
Kent County Dept. of Public Works
Dover, Delaware
Environmental Procedures Manual
Controlling Documents
Title:
Controlling Documents
Document No.:
2-12-POl
Prepared By:
Jim Newton
Date Effective:
12-01-2003
Approved By:
Page:
2 of 6
Revisions No.:
0
3.2 Controlled Copy- Any copy of an approved document issued to a particular branch, depart-
ment or individual, which has been uniquely identified as a "Controlled Copy" and is trace-
able for recall. The use of a controlled copy ensures that work affecting process safety is
performed to the applicable revision of the document, and that the current revision status is
established.
3.3 Environmental Program Document Control- Control of documents related to the environ-
mental program used to manage and oversee the environmental program.
3.4 EMS Librarian - The person responsible for maintaining all controlled documents and updat-
ing the documents as they are revised.
3.5 Traceability - For documentation, the ability to preserve the revision identity of a copy from
its point of issuance to its assigned recipient so that it can be identified or recalled as re-
quired.
4.0 REFERENCES
None
5.0 REQUIREMENTS
5.1 Classes of Documentation
There are three classes of documentation represented by policy, procedures and process
instructions:
5.1.1 Documents produced internally, for example the Environmental Management
System documents and the program element procedures and process instructions;
5.1.2 Documents produced outside Kent County Dept. of Public Works, but approved
for use as references, for example standards and codes of government or industry
organizations pertaining to the work process undertaken by Kent County Dept. of
Public Works permanent or contract personnel; and
5.1.3 Incoming documentation, that is to be verified on receipt such as vendor-supplied
documents.
5.2 Issuing and Maintaining Controlled Documents
5.2.1 Controlled Documents - In order to ensure that only the latest edition of any one
Environmental Management System document is being used it is necessary to en-
sure that the release of the appropriate document is controlled.
-------
Kent County Dept. of Public Works
Dover, Delaware
Environmental Procedures Manual
Controlling Documents
Title:
Controlling Documents
Document No.:
2-12-POl
Prepared By:
Jim Newton
Date Effective:
12-01-2003
Approved By:
Page:
3 of 6
Revisions No.:
0
5.3
5.2.2 Control of all EMS documents shall be the responsibility of the EMS Librarian.
As each revision is prepared, the approved document shall be submitted to the
EMS Librarian for inclusion in the control system.
5.2.3 All documents shall be maintained in Adobe Acrobat 5.0 "pdf" form on the cen-
tral network V drive. The EMS Librarian shall ensure that the document is con-
verted to "pdf" format. It shall be secured so that it cannot be modified without a
specific password.
5.2.4 All controlled documents shall be available to staff via the Adobe Acrobat
Reader.
5.2.5 Once a document is printed, it shall be considered uncontrolled, unless stamped
"Controlled" by the EMS Librarian. Such documents shall expire within 90 days
of issuance, and must be reissued for additional 90-day periods.
5.2.6 In addition, a statement shall be added to the document that reads "This document
is an UNCONTROLLED DOCUMENT, valid only on (the day it is
printed), unless stamped CONTROLLED COPY in red ink."
Control
5.3.1 The Environmental Management System Manual, Procedures, and Work Instructions
shall be controlled in accordance with this procedure. Numbering of these documents is
described in the Kent County Dept. of Public Works Environmental Management System
Procedure 2- 10-P01.
5.3.2 A controlled Copy Issuance list shall be maintained under the authority of the Environ-
mental Program Manager and in accordance with the Environmental Management Sys-
tem Procedure 2-12-P02, Establishing and Maintaining Libraries.
5.3.3 Documents prepared under this program shall also be maintained using the Greenware
software package.
5.4 Approval
Document approval authority is given by category as follows:
5.3.1 The Environmental Management System Manual, Procedures, and Work Instruc-
tions approval shall be as indicated in the Kent County Dept. of Public Works
Environmental Management System Procedure 2-10-P01, Developing Policies,
Procedures and Work Instructions.
Kent County Dept. of Public Works
Dover, Delaware
Title:
Controlling Documents
-------
Environmental Procedures Manual
Controlling Documents
Document No.:
2-12-POl
Prepared By:
Jim Newton
Date Effective:
12-01-2003
Approved By:
Page:
4 of 6
Revisions No.:
0
5.3.2 Environmental Management System design output, change documentation and
process control documentation, including Approved Lists, shall be approved by
the appropriate Manager, as described in the Kent County Dept. of Public Works
Environmental Management System Procedure 2-01-POL
5.3.3 Reference documentation is considered approved by virtue of reference in the
base document.
5.4 Approved Lists
Approved lists shall be maintained by category as follows:
The Environmental Management System Manual, Procedures, and Process Instructions,
shall be listed on an "Environmental Management System Documents List", maintained
under the authority of the Environmental Program Manager (Reference Kent County
Dept. of Public Works Environmental Management System Procedure 2-10-P01).
5.5 Reference Documentation
Environmental Management System reference documentation shall be listed under an
"Approved Reference Documents" section of the library catalog, maintained under the
authority of the Environmental Program Manager (reference the Kent County Dept. of
Public Works Environmental Management System Procedure 2-12-P02 Establishing and
Maintaining Libraries).
5.6 Environmental Management System Records
Environmental Management System Records shall be maintained under the authority of
the department or unit administrative personnel.
5.7 Approved Forms
An Environmental Management System Approved Forms list shall be maintained under
the authority of the Environmental Program Manager (Reference the Kent County dept.
of Public Works Environmental Management System Procedure 2-11-P02 Controlling
Records).
5.8 Corrective Action
A master CAR list shall be maintained under the authority of the Environmental Program
Manager (Reference the Kent County Dept. of Public Works Environmental Management
System Procedure 2-15-P01 Controlling Non-Conforming Conditions and 2-15-P02
Managing Corrective and Preventive Action).
Kent County Dept. of Public Works
Dover, Delaware
Title:
Controlling Documents
-------
Environmental Procedures Manual
Controlling Documents
Document No.:
2-12-POl
Prepared By:
Jim Newton
Date Effective:
12-01-2003
Approved By:
Page:
5 of 6
Revisions No.:
0
6.0 RESPONSIBILITIES
The responsibility for Kent County Dept. of Public Works Library (s) rests with each of the De-
partment Management Representatives responsible and shall be coordinated with the Environ-
mental Program Manager for technical consistency.
7.0 DOCUMENTS
7.1 Related Documents
7.1.1 Kent County Dept. of Public Works Environmental Management System Manual
Section 2 Management System
7.1.2 Kent County Dept. of Public Works Environmental Manual Section 5 Environ-
mental Work Processes
8.0 RECORDS
8.1 Required Records
A listing of library documents is to be maintained by the Environmental Program Man-
ager and responsible Management or Supervisory personnel to facilitate retrievability of
the documents and up-to-date information.
8.2 Records Control
All records, if required, pertaining to this procedure shall be controlled in accordance
with the Environmental Management System Procedures 2-11-P02, Controlling Records.
8.3 Transmittal Confirmations
Transmittal Confirmations are Environmental Management System Records and shall be
maintained in accordance with the Kent County Dept. of Public Works Environmental
Management System Procedure 2-11-P02 Controlling Records.
9.0 ATTACHMENTS
9.1 None
Kent County Dept. of Public Works
Dover, Delaware
Title:
Controlling Documents
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Environmental Procedures Manual
Controlling Documents
Document No.:
2-12-P01
Prepared By:
Jim Newton
Date Effective:
12-01-2003
Approved By:
Page:
6 of 6
Revisions No.:
0
10.0 REVISION HISTORY
Revision No.
0
Effective Date
Responsible Person
Jim Newton
Description of Revision
Initial Issue
Appv. By
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SAMPLE EMS DOCUMENTATION
ENVIRONMENTAL MANAGEMENT SYSTEM (EMS) MANUAL
CityofGastonia WWTP - EMS Manual
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City of Gastonia
Wastewater Treatment Division
ISO 14001 - Environmental
Management System Manual
Prepared By: Beth Eckert, Industrial Chemist
Approved By: Coleman Keeter, Superintendent of WWTD
Signature:
Revision #: 0 / Revision Date: December 7, 1999 / Effective Date: January 1, 2000
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Name - Number: Environmental Management System Manual - EMS-01 00.000
MANUAL
SECTION
SECTION 0
SECTION I
SECTION II
4.2
4.3
4.3.1
4.3.2
4.3.3
4.3.4
4.4
4.4.1
4.4.2
4.4.3
4.4.4
4.4.5
4.4.6
4.4.7
4.5
4.5.1
4.5.2
4.5.3
4.5.4
4.6
ISO
SECTION
4.2
4.3
4.3.1
4.3.2
4.3.3
4.3.4
4.4
4.4.1
4.4.2
4.4.3
4.4.4
4.4.5
4.4.6
4.4.7
4.5
4.5.1
4.5.2
4.5.3
4.5.4
4.6
TABLE OF CONTENTS
Revision #: 0
Revision Date: 12/7/99
Effective Date: 1/1/00
Page 2 of 12
TITLE PAGE
TABLE OF CONTENTS
INTRODUCTION
DISTRIBUTION, REVISION, & CONTROL
ENVIRONMENTAL POLICY
PLANNING
Environmental Aspects
Legal and Other Requirements
Objectives and Targets
Environmental Management Programs
IMPLEMENTATION & OPERATION
Structure and Responsibility
Training, Awareness and Competence
Communication
2
3
4
5
6
6
7
8
8
9
9
9
10
Environmental Management System Documentation 10
Document Control 10
Operational Control
Emergency Preparedness and Response
CHECKING AND CORRECTIVE ACTION
Monitoring and Measurement
Non-conformance and Corrective Action
Records Management
Environmental Management System Audits
MANAGEMENT REVIEW
11
11
11
11
11
12
12
12
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SECTION I - INTRODUCTION
The City of Gastonia's Wastewater Treatment Division (GWWTD) is responsible for treating Gastonia's
industrial, commercial, and domestic wastewater to meet state and federal limits for discharge to the surface
waters as well as for proper management of its biosolids. Gastonia has two wastewater treatment operations
that are designated for these activities. Additionally, the WWTD manages a resource recovery farm and the
operations of a contractor that is responsible for land application of biosolids at permitted locations
throughout the county.
Wastewater Treatment Operations
Crowder's Creek Wastewater Treatment Plant, 5642 South York Road, Gastonia, NC 28054
Long Creek Wastewater Treatment Plant, 3000 Long Creek Disposal Plant Rd., Dallas, NC 28034
Resource Recovery Farm, 208 Goldmine Rd., Bessemer City, NC
In order to improve management of environmental issues related to these operations and sites, the Gastonia
Wastewater Treatment Division has implemented an ISO 14001 environmental management system. This
Environmental Management System (EMS) manual presents the environmental policy, structure of the
management system, and related documents for the Gastonia Wastewater Treatment Division.
The EMS is designed according to the requirements set forth by the ISO-14001 Standard. Sections 4.2-4.6
parallel the ISO-14001 Standard number scheme. Each of these sections provide specific information or
instructions necessary for complying with the requirements in the ISO-14001 Standard.
The EMS manual is the responsibility of the EMS Project Coordinator and is to be reviewed yearly and
updated as appropriate, see review procedure (EMS-0100.001). The issued copies of this manual are under
control of the EMS Project Coordinator.
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SECTION II - DISTRIBUTION, REVISION, AND CONTROL
The distribution of this manual shall be conducted manually by the EMS Project Coordinator. The version
accessed on the computer system shall be considered the "controlled" copy. There will be a "Master Copy"
in hard copy form maintained by the EMS Project Coordinator. This copy shall have the signature of the
Superintendent of the Wastewater Treatment Division and the date of approval.
Any part of the manual in hard copy form, other than the master copy and controlled copies issued per the
distribution list, shall be considered "UNCONTROLLED" and will have "****THIS IS AN
UNCONTROLLED COPY OF A CONTROLLED DOCUMENT****" automatically inserted at the bottom
of each page when printed.
The manual will be reviewed a minimum of once per year. The EMS Management Team shall have the
responsibility for reviewing the manual annually in October.
Recommendations for revisions shall be forwarded to the EMS Project Coordinator. The EMS Project
Coordinator will be responsible for all revisions to the manual. He/she will maintain a record of external
distribution, if applicable, and maintain obsolete copies on file.
This manual will be controlled manually and in accordance with the Gastonia Document Control Procedure
(EMS-0100.002)
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SECTION 4.2 - ENVIRONMENTAL POLICY
The EMS Management Team will review the policy annually. If revisions are necessary, the revised policy
will be adopted by the City Council in November.
The policy will be made available to the public through the City of Gastonia's web-site. The policy will be
communicated to all WWTD employees through training events.
CITY OF GASTONIA
WASTEWATER TREATMENT DIVISION
ENVIRONMENTAL POLICY
The City of Gastonia Wastewater Treatment Division is committed to the implementation of a management
system which will minimize negative and advance positive impacts on the environment and which will control
the wastewater treatment costs to be borne by the consumer. Believing these goals to be fully achievable, the
Wastewater Treatment Division is firmly committed to and will:
Establish procedures to promote continuing improvement of compliance with all applicable environmental
laws and regulations.
Establish procedures to continue efforts to strengthen and improve knowledge of environmental issues within
the Division.
Seek optimal operation of the Wastewater Treatment Facilities to minimize environmental impacts where
technically and economically feasible, even if not required by law or regulation.
Promote cooperation and understanding with the public, customers, and governmental agencies in developing
economically feasible and environmentally sound wastewater treatment objectives.
Continue to promptly report all noncompliance issues in accordance with applicable governmental reporting
requirements, evaluate causes of noncompliance, and implement corrective actions.
Establish procedures for periodic review of environmental compliance with all laws and regulations, as well
as with the ISO 14001 Environmental Management System.
Establish procedures to ensure all that employees are knowledgeable of, and understand and comply with., all
applicable environmental laws and regulations.
Promptly correct any practice or condition not in compliance with this policy.
All employees are expected to comply with the spirit as well as the letter of this policy.
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SECTION 4.3 - PLANNING
Location and description of all reference materials has been identified the Document Control / Training
Matrix (EMS-0101.002A) which is located electronically at U:\ISO\Forms\EMS-0101.002A and a hard
copy in the office of EMS Coordinator.
The following definitions are provided in the ISO-14000 Standards.
4.3.1 Environmental Aspects
Environmental Aspects - Elements of the organization's activities, products or services which can interact
with the environment.
Environmental Impact - Any change to the environment, whether adverse or beneficial, wholly or partially
resulting from an organization's activities, products or services.
Significant Environmental Aspect - An environmental aspect that has or can have a significant
environmental impact.
GWWTD has identified all known environmental aspects and related impacts of our activities and products
that we can control and have influence over in order to determine which can have a significant impact on the
environment.
The EMS Management Team shall review at least annually per the EMS Review procedure (EMS-0100.001)
the list of environmental aspects and impacts and identify the significant aspects using the Aspects and
Impacts procedure (EMS-0100.003), aspects ranking form (EMS-0101.003A), significant aspects
determination form (EMS-0101.003B), and the significant aspect listing form (EMS-0101.003C). The EMS
management team will also review aspects and impacts of any new operations, activities, or laws for
significance determination. Significant aspects will be considered in setting the environmental objectives.
The EMS management team will consist of the following personnel:
ORC Crowder's WWTP
Lab Supervisor Crowder's WWTP
ORC Long Creek WWTP
Lab Supervisor Long Creek WWTP
ORC of Biosolids
Assistant Superintendent of WWTD
Pretreatment Coordinator
The list of environmental aspects, related impacts and identified significant aspects and impacts will be kept
up to date. The list will be comprehensively reviewed annually in November.
4.3.2 Legal and Other Requirements
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The Gastonia Wastewater Treatment Division is required to comply with a variety of legal and other
requirements that are applicable to the environmental aspects of its activities, products or services. The
following personnel identify environmental regulations and requirements, which govern GWWTD activities
and products:
ORC Crowder's WWTP
Environmental laws relating to treatment and discharge of industrial and municipal wastewater.
Lab Supervisor Crowder's WWTP
Environmental laws relating to the testing of wastewater samples.
ORC Long Creek WWTP
Environmental laws relating to treatment and discharge of industrial and municipal wastewater.
Lab Supervisor Long Creek WWTP
Environmental laws relating to the testing of wastewater samples.
ORCofBiosolids
Environmental laws relating to the management and application of wastewater treatment plant biosolids.
Assistant Superintendent of WWTD
Environmental laws relating to the operation of an industrial/municipal wastewater treatment plant.
Pretreatment Coordinator
Environmental laws related to handling wastewater discharged from commercial or industrial dischargers.
The following resources are used to identify applicable legal and other requirements:
Documents:
CFR books (Code of Federal Regulations) - covers solid waste, hazardous waste, air emission, wastewater,
stormwater, biosolids regulations.
EPA Standard Testing Methods - Covers EPA certified wastewater testing procedures.
Regulatory Personnel: direct mailings and discussions with regulators. Representative personnel attend
seminars.
Software: Application which is designed for fast regulatory searches. (CD-ROM)
Internet Access - Review of EPA newsletter
Regulator Training: plant personnel shall attend Conferences and workshops with key environmental
responsibility on a regular basis to maintain up-to-date knowledge of current and upcoming regulatory
requirements.
Periodic permitting and reporting requirements are documented and reviewed for accuracy as identified in the
Legal and Other Requirements listing (EMS-0101.001).
All employees affected by new regulations will be trained on those regulations by their supervisor according
to individual training matrices (EMS-0101.002B).
4.3.3 Objectives and Targets
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GWWTD establishes environmental objectives and targets annually during December by considering at least
the following information:
> Legal and other requirements
> Significant environmental aspects and impacts
> Prevention of pollution
> Technological options
> Financial, operational, and business requirements
> GWWTD environmental policy
> Views of interested parties
These objectives and targets will be documented and maintained according to the objectives and targets
procedure (EMS-0100.007) and the EMS review procedure (EMS-0100.001). Objective and targets may be
amended at other times during the year as a result of new or revised operations, activities, and/or regulations.
4.3.4 Environmental Management Programs
GWWTD has developed an EMS program entitled Objectives and Targets Improvement Plan (EMS-
0101.007) that shall be used to achieve its objectives and targets. This program shall include:
> designation of responsibility for achieving the objectives and targets at each relevant function and level of
organization;
> means and time-frame by which they are to be achieved.
The objectives, targets, and programs will be reviewed and approved annually per the EMS review procedure
(EMS-0101.001) by the Superintendent of the WWTD during the budget development process. The EMS
Project Coordinator is responsible for their maintenance and reporting. Projects that relate to new
developments and new or modified activities, products or services, the program shall be amended where
relevant to ensure that environmental management applies to such projects.
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SECTION 4.4 - IMPLEMENTATION & OPERATION
4.4.1 Structure and Responsibility
GWWTD has defined, documented and communicated the roles, responsibility and authority of personnel in
order to facilitate effective environmental management. These are identified in the roles and responsibilities
listing (EMS-0100.006).
The Superintendent of the WWTD is responsible for assuring that adequate human resources, other
resources, and training are available to implement and control this EMS.
The EMS Project Coordinator is responsible for ensuring that this EMS is established, implemented and
maintained and for reporting on its performance to top management
4.4.2 Training, Awareness and Competence
All employees within the WWTD will be trained on the EMS policy and records maintained in the office of
the EMS Coordinator. Based on the annual aspects and impacts analysis each department shall identify
training needs for those employees whose work activities may create a significant impact upon the
environment. All procedural training records will be maintained in each area supervisor's office. Relevant
procedures identified in the Document Control / Training Matrix (EMS-0101.002A) shall be established and
maintained to ensure employees are aware of:
> The importance of conformance with the environmental policy and procedures and with the requirements
of the Environmental Management System;
> The significant environmental impacts, actual or potential of their work activities and the environmental
benefits of improved personal performance;
> Their roles and responsibilities in achieving conformance with the environmental policy and procedures
and with the requirements of the Environmental Management System, including emergency preparedness
and response requirements;
> The potential consequences of departure from specified operating procedures.
Personnel performing the tasks, which can cause a significant environmental impact on the environment,
shall be evaluated for competence on the basis of appropriate education, training, and/or experience as
identified in the roles and responsibilities listing (EMS-0100.006). Records of competency and individual
training are maintained in the individual training matrices (EMS-0101.002B). During annual performance
reviews employees will be evaluated on their demonstration of environmental competency.
All new employees will receive training on EMS related procedures, policy and requirements of the
environmental management system upon commencement of work with the City of Gastonia via PowerPoint
presentation located at U:\ISO\training\ISOawareness training. New or revised procedures affecting
existing personnel will be communicated upon implementation.
Training requirements of contractor personnel will be established under the terms of contract. Follow-up will
be done annually to evaluate conformance with the contract. City of Gastonia maintenance personnel will be
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trained on procedures identified in the Document Control / Training Matrix.
4.4.3 Communication
GWWTD has developed procedures for handling internal communications between the various levels and
functions of the department. The EMS Project Coordinator is responsible for communicating information
relative to the EMS to upper management and the EMS Team. The EMS Team is responsible for
communicating information to affected employees.
GWWTD has documented a procedure for receiving, documenting, and responding to relevant
communications from external parties (EMS-0100.008).
GWWTD has recorded its decision on considering processes for external communication of its significant
environmental aspects. GWWTD will provide a listing of its significant environmental impacts to any
interested party. Additionally, the GWWTD has held a seminar for external parties to discuss significant
environmental impacts.
4.4.4 Environmental Management System Documentation
GWWTD has developed an EMS documentation system that is organized in a four-tier structure
EMS Manual Level 1
EMS Procedures Level 2
Standard Operating Procedures/Work Instructions Level 3
Forms/Records Level 4
Each of these levels will provide direction to relative documents in other levels.
4.4.5 Document Control
GWWTD has established a Document Control System that controls all documents and data that relate to
satisfying the elements of the ISO 14001 standard and ensures:
> they can be located;
> they are periodically reviewed, revised as necessary and approved for adequacy by authorized personnel;
> the current versions of relevant documents are available at all locations where operations could
significantly impact the environment;
> obsolete documents are assured against accidental use and those retained for legal or knowledge
preservation suitably identified;
> they are legible, dated, readily identifiable and properly stored.
GWWTD has developed procedures and responsibilities concerning the creation and modification of various
types of documents as identified in the Document Control Procedure (EMS-0100.002).
4.4.6 Operational Control
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GWWTD has identified operations and activities associated with the identified significant environmental
aspects. Each department shall plan these activities, including maintenance, in order to ensure they are
carried out under specified conditions by:
> Establishing and maintaining documented standard procedures to cover situations where their absence
could lead to deviations from the environmental policy, objectives and targets;
> Stipulating operating criteria in the procedures;
> Establishing and maintaining procedures related to supplies and services used by the plant and
communicating relevant procedures and requirements to suppliers and contractors.
All operating procedures are identified in the document control / training matrix (EMS-0101.002A)
4.4.7 Emergency Preparedness and Response
GWWTD has developed an emergency response plan (WLC-0100.010 and WCR-0100.010) and a Risk
Management Plan (EMS-0100.010) which deals specifically with Chlorine and/or Sulfur dioxide related
emergencies. The plan identifies the potential for accidents and emergency situations and the corresponding
response. The plan also considers the prevention and mitigation of any environmental impacts associated
with accidents or emergency situations.
These plans shall be reviewed at least every three years.
SECTION 4.5 CHECKING AND CORRECTIVE ACTION
4.5.1 Monitoring and Measurement
GWWTD has established and maintains a system for measuring and monitoring the key characteristics of our
operations that can have a significant impact on the environment. This system includes recording
information to track performance, relevant operational controls and conformance with the established
objectives and targets.
> Monitoring equipment shall be calibrated and maintained and records kept in the office of the responsible
supervisor.
> A documented procedure (EMS-0100.009) has been established to periodically evaluate compliance with
relevant environmental legislation and regulation.
4.5.2 Non-Conformance and Corrective Action
GWWTD has established and maintains a procedure to determine the need for and implementing corrective
and preventative actions (EMS-0100.004).
> All employees are empowered to report, document and take temporary action for any nonconformities
relating to environmental impacts.
> Corrective and preventative actions are taken to eliminate the causes of actual or potential
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nonconformities and are appropriate to the magnitude of problems and commensurate with the
environmental impact.
> Changes to documented procedures resulting from corrective or preventative actions are recorded.
4.5.3 Records Management
GWWTD has established procedures for identification, maintenance, and disposition of all environmental
records. These records are kept to demonstrate conformance to GWWTD's EMS, the ISO 14001 standard and
applicable regulations.
> Environmental records are legible, identifiable, and traceable to the corresponding activity or product
involved.
> Environmental records are stored in a way that they are retrievable and protected against damage,
deterioration or loss.
> The retention times for all environmental records are established and recorded.
Refer to the Document Control / Training Matrix (EMS-0101.002A) and /or the Legal and Other
Requirements (EMS-0101.001) documents for retention times and locations.
4.5.4 Environmental Management System Audits
GWWTD has established and maintains procedures to carry out periodic audits of the environmental
management system (EMS). The EMS audit procedure (EMS-0100.011) will determine the scope,
frequency, methodology, and responsibility for the audits.
> The purpose of audits is to determine if the EMS has been properly implemented and maintained.
> Results of the EMS audits are reviewed with the Management Review Board (MRB).
SECTION 4.6 MANAGEMENT REVIEW
The Management Review Board (MRB) reviews the EMS quarterly to ensure continuing suitability,
adequacy, and effectiveness of the EMS. This review is documented.
The MRB addresses the possible need for changes to the policy, objectives, and other elements of the EMS.
Observations, conclusions and recommendations are document for necessary action and changes
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SAMPLE EMS DOCUMENTATION
OPERATIONAL CONTROL
Charleston CPW- Operational Control Procedure
City of San Diego WWC- Operational Control Procedure
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CPW ENVIRONMENTAL MANAGEMENT SYSTEM
PROCEDURE
The on-line version and secured hardcopy are the controlled documents. The secured
hardcopy will be identified by an "Official Document" stamp giving date of
distribution. Any and all other documents are uncontrolled. Contact EMS Program
Manager for revision level status.
Effective Date: October 1,2000 Page 1 of 3
Revision: 1 Identification Number: EMS - 4. 4. 6 (A)
Title: Operational Control Procedure
Prepared By: EMS Procedures Subcommittee
Reviewed By: EMS Management Steering Committee
Approved By: William E. Koopman Jr., General Manager
John Cook PE, Assistant General Manager
Date Approved: August 25, 2000
0.0 Requirement: ISO 14001, Sub Clause 4.4.6 Operational Control
1.0 Purpose
This procedure is used to ensure monitoring and operating instructions are properly
identified, issued and controlled, and to ensure that all relevant documents necessary for
the proper operation of the process are present.
2.0 Scope
This procedure applies to all associates who issue and control monitoring and operating
instructions at CPW where EMS requirements are in place.
3.0 Responsibility & Authority
3.1 The department head (or designee) is responsible for the approval, revision,
and issuance of monitoring and operating instructions and ensuring associates
have the necessary training to perform the job.
4.0 Procedure
4.1 Issue and Control of Monitoring and Operating Instructions
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Effective Date:
Revision: 1
Title:
October 1, 2000 Page 2 of 3
Identification Number: EMS -4.4.6 (A)
Operational Control Procedure
4.1.1 Prior to placing new or modified monitoring or control equipment
in service the department head will direct the drafting of
monitoring or operating instructions for that operation.
NOTE: Monitoring and operating instructions should include the following
information where relevant:
Monitoring and Operating Instruction Title and Identification Number
Process or equipment name
Operating criteria
Startup instructions
Shut down instructions
Emergency operation (loss of power, SCAD A, etc)
Inspection and test instructions
Corrective action instructions
Revision date and approval
Safety requirements
Housekeeping
Location of manufacturer's reference material
4.1.2 The draft monitoring and operating instructions are submitted to
the appropriate supervisor(s) to review for operability,
completeness, consistency and clarity.
4.1.3 The supervisor(s) note any changes or concerns and forwards back
to the individual or team that prepared the draft.
4.1.4 The individual or team that prepared the draft makes the necessary
corrections.
4.1.5 The department head reviews and approves the new or revised
monitoring and operating instructions.
4.1.6 The department head (or designee) issues the monitoring and
operating instructions to the appropriate supervisor(s).
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Effective Date: October 1,2000 Page 3 of 3
Revision: 1 Identification Number: EMS - 4. 4. 6 (A)
Title: Operational Control Procedure
4.1.7 The supervisor(s) ensures the operators have the necessary
training, including the environmental impacts or potential
consequences in deviating from the specified work instructions.
4.1.8 The department head (or designee) ensures the documents are
available and controlled at all appropriate locations, the most
current versions are available for use, and obsolete versions are
prevented from further use.
4.1.9 Obsolete documents to be retained for legal and or knowledge
preservation are removed and marked "Obsolete.
4.2 Related Documents and Data
4.2.1 Training Records
4.2.2 Records of Change to related documented procedures
4.2.3 Manufacturer's Reference Mated al
4.2.4 Document Control Procedure
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DD-SEOP 4.4.6
OPERATIONAL CONTROL
1.0 PURPOSE AND SCOPE
The procedure for identifying operational controls for operations and activities that are identified
as potential critical environmental impacts. This procedure applies to all situations at the
MWWD WWC Division, or areas within the control or influence by MWWD WWC Division,
where its absence could lead to deviations from the division environmental policy and the
objectives and targets.
2.0 RESPONSIBILITY AND AUTHORITY
It is the responsibility of the EMS Environmental Management Representative, Section
Managers and their designees to prepare appropriate procedures ensuring effective management
of critical control points and for those situations where the absence of a procedure could lead to
deviations from the Environmental Policy and the objectives and targets.
3.0 PROCEDURE
3.1 Operational control procedures shall be established by the WWC for operations that have
been identified to have significant environmental impacts and/or where their absence
could result in significant environmental impacts.
3.2 The Operational control procedures shall be established and maintained by the
appropriate WWC Section and may cover the following:
Process operations, maintenance and equipment specifications criteria
Methods of chemical storage, handling and transfer
Spill and clean up
Management and disposal of wastes
Operation and Maintenance of Sensitive or Critical Environmental Control
Equipment
3.3 Most operational control and maintenance procedures shall be established as the third
level documentation (excepting those activities determined to be inter-departmental in
nature and that apply to multiple sections within WWC). All procedures shall be made
available at the point of use. (refer to Documentation matrix in Document Control
procedure, DD SEOP 4.4.5)
DD-SEOP 4.4.6 June 2003
Operational Control Rev 1
MWWD WWC Division 1
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3.4 Operational control procedures shall also make reference to existing documented
Departmental and/or Division Instructions that cover at least the following or in whose
absence may lead to a deviation from the environmental policy:
Purchase or transfer of goods and services and use of external resources
Hazardous tasks
Hazardous materials
Maintenance of calibrated safety equipment
3.5 The relevant EMS requirements, including the WWC Environmental Policy, shall be
communicated to suppliers and contractors.
3.6 The Section manager reviews the "Standard Operating Procedures" (DD-SEOP 4.4.4) for
environmental protection and control content and makes improvement to existing
procedures, or develops new procedures as required.
3.7 New or revised SOP's are to be processed by the Document Control Group (DCG). DD-
SEOP 4.4.5.
3.8 Procedures are reviewed and revised based on corrective actions recommended as the
result of environmental incidents (such as spills or releases) or environmental audits;
when new processes or products are introduced, or when new environmental regulations
are identified that could reasonably affect MWWD WWC Division operations.
3.9 The Section Managers are responsible for approving Section specific Standard
Maintenance Procedures (SMP's) or Operating Procedures (SOP's) where the absence of
SOP's could lead to a significant environmental impact.
4.0 REFERENCES
DD-SEOP 4.3.1, Environmental Aspects and Impacts Identification
DD-SEOP 4.3.3, Establishment of Environmental Objectives, Targets and Programs
DD-SEOP 4.4.4, Standard Environmental Operating Procedures
DD-SEOP 4.4.5, Document Control
DD-F-002.0, Aspects and Impacts Register
DD-SEOP 4.4.6 June 2003
Operational Control Rev 1
MWWD WWC Division 2
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SAMPLE EMS DOCUMENTATION
EMERGENCY PREPAREDNESS
Charleston CPW - Emergency Preparedness & Disaster Recovery Procedure
City of San Diego WWC - Emergency Preparedness and Response Procedure
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CPW ENVIRONMENTAL MANAGEMENT SYSTEM
PROCEDURE
The on-line version and secured hardcopy are the controlled documents. The secured
hardcopy will be identified by an "Official Document" stamp giving date of
distribution. Any and all other documents are uncontrolled. Contact the EMS
Program Manager for revision level status
Effective Date: October 1,2000 Page 1 of 7
Revision: 2 Identification Number: EMS - 4. 4. 7
Title: Emergency Preparedness & Disaster Recovery
Procedure
Prepared By: EMS Procedures Subcommittee
Reviewed By: EMS Management Steering Committee
Approved By: William E. Koopman Jr., General Manager
John Cook PE, Assistant General Manager
Date Approved: August 25, 2000
0.0 Requirement: ISO 14001, Sub Clause 4.4.7 Emergency Preparedness/Response
1.0 Purpose
To minimize disaster impacts and return CPW back into operation in a safe, quick, cost
effective and environmentally sensitive way.
2.0 Scope
ISO 14001, sub clause 4.4.7, applies to the need to identify, prevent, and respond to
emergencies and the period of time following the emergency event.
3.0 Responsibility & Authority
3.1 Executive management is responsible for ensuring that an emergency
preparedness program is implemented and for approving the emergency
preparedness plans.
3.2 Section heads and department heads are responsible for plan development,
plan implementation and emergency preparedness team selection.
3.3 Emergency Preparedness Team(s) (response/disaster recovery) are
responsible for dealing with immediate threats to associates, the public and
the environment and assisting in returning CPW back to functional operation
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Effective Date: October 1,2000 Page 2 of 7
Revision: 2 Identification Number: EMS -4.4.7
Title: Emergency Preparedness and Disaster Recovery Procedure
4.0 Procedure
4.1 Up-front Activities
4.1.1 The department head/section head will initiate the process to
prepare a disaster response/recovery plan. The department head
will assemble the Emergency Response/Disaster Recovery
Team(s).
After review and approval of the plan(s), the team(s) will test the
plan as conditions allow and, communicate the plan to associates
and document. At least annually, or in the event of a disaster,
review the plan and recommend plan modifications as necessary.
4.1.2 Duties of the Department Head/Facility Manager
The duties of the department or facility manager include the
following aspects:
a) Identify potential risks to facilities and processes;
b) Identify and implement Best Management Practices
(BMP's) where necessary (i.e., Process Safety
Management, Risk Management, Hurricane Preparedness,
etc.);
c) Establish incident reporting procedures;
d) Maintain, testing and inspection equipment according to
specified frequency and procedures;
e) Establish emergency preparedness training for facility
personnel;
f) Review new and significantly modified equipment or
processes for modification of emergency response plans as
necessary;
g) Manage emergency response change to new or modified
equipment or processes;
h) Review at least annually, facility procedures for release
prevention and emergency response;
i) Review and update hazard assessments at least every five
years or as a result of changes;
j) Audit compliance of prevention programs at least every
three years as required by the EPA Risk Management Plan
and OSHA's Process Safety Management Standard.
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Effective Date: October 1,2000 Page 3 of 7
Revision: 2 Identification Number: EMS -4.4.1
Title: Emergency Preparedness and Disaster Recovery Procedure
4.1.3 Identification/Impact Assessment of Facility Resources
The department head or facility manager will inventory critical
operations and available resources to identify and assess potential
risk in the event the facility is destroyed in part or in total. This
inventory should identify what critical items may need to be
quickly replaced. The inventory should include, a description of
required personnel skills, necessary chemicals or equipment, and
identification of vendor sources.
4.1.4 Impact Minimization Strategies
An impact minimization strategy will be prepared for the identified
resources that are critical and have a high likelihood of being
impacted or destroyed. For example, this may include special
training, backup files, backup communications or operations at
other locations, additional containment around some chemicals and
wastes, temporary containment (sandbagging) around critical
equipment, bracing, and fire suppression equipment.
4.1.5 Phone Numbers and Contacts
There should be documented emergency numbers in both the
emergency plan and disaster recovery plan. As a minimum the
following should be included:
a) department head, section head, or facility manager
b) relevant civil defense contacts, (fire, police, toxic
release contacts, FEMA, etc)
c) executive management
d) safety manager
4.1.6 Routine Inspections
The department's status, resources and supplies in terms of disaster
recovery should be inspected frequently. As resources or facilities
change, preparedness and recovery plans should be updated.
4.1.7 Off-site Disaster Headquarters
The affected department head, with input from the section head
and/or executive management, will establish a working
headquarters and necessary communication links.
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Effective Date: October 1,2000 Page 4 of 7
Revision: 2 Identification Number: EMS -4.4.7
Title: Emergency Preparedness and Disaster Recovery Procedure
4.1.8 Production and environmental control equipment will be
appropriately maintained with preventive maintenance controls.
4.1.9 Critical Data
Regulatory records, account data, etc. should be backed up and
stored in a protected environment. Software systems, such as,
Supervisory Control and Data Acquisition (SCADA) essential to
production will be backed up with the ability to function at other
locations. Paper type files, which are critical to the operation
should be copied and filed at a backup location or stored
electronically or on microfiche, in a fire-resistant location.
4.1.10 Supplies
Some supplies should be purchased before a disaster, for the health
and safety of the associates. Supplies should include such items as
food, water, bedding, flashlights, tools, first aid kits, etc. for at
least a three-day period.
4.1.11 Environmental Protection Supplies
Environmental protection supplies, such as spill cleanup materials,
personal protection equipment, over-pack drums, etc. and materials
required in regulatory plans such as the Risk Management Plan
(RMP) will be maintained.
4.1.12 Emergency Plan Training and Distribution
It is important to prepare and distribute emergency plans to
essential associates before a disaster occurs. Training on
emergency response and disaster recovery will be given and
documented to team members and associates involved in work that
may cause significant environmental impact.
4.2 Disaster Control
4.2.1 During and Immediately Following a Disaster
After the immediate crisis is under control, the following activities
should occur. These steps are considered as recovery actions.
4.2.2 Convene the Emergency Response Team/Disaster Recovery Team
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Effective Date:
Revision: 2
Title:
October 1, 2000 Page 5 of 7
Identification Number: EMS -4.4.1
Emergency Preparedness and Disaster Recovery Procedure
The ERT/Disaster Recovery Team will transition into a disaster
recovery team (DRT). Additional members will/may be added at
this time and include management, operations, safety, purchasing
and finance members.
4.2.3 Area Inspections
The DRT will do an initial audit for safety hazards and, if any are
found, notify associates to stay out of the affected area until
corrected. Additional inspections would be made to assess facility
or equipment operability and preliminary cost estimates on
financial damage.
4.2.4 Associate Needs
After assessing immediate safety needs, longer-term needs should
be considered. This may include information to families or help in
locating families. This may include additional supplies such as
food, water, blankets, and temporary shelter for associates, etc.
4.2.5 Insurance Companies/Relief Agencies
Proper insurance representatives/federal agencies should be called
to schedule site visits as soon as possible.
4.2.6 Human Resource Skills Bank
Associates who are able to report to work should report to an
identified individual or location so that recovery needs can be
matched with associate skills and assigned appropriate recovery
tasks.
4.2.7 Reestablish Process Control and Utilities
During the disaster some utilities may have shut down by accident
or design. The DRT will work with the water and wastewater
departments and with the gas and electric companies to restore
service.
Effective Date:
Revision: 2
October 1, 2000 Page 6 of 7
Identification Number: EMS -4.4.1
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Title: Emergency Preparedness and Disaster Recovery Procedure
4.2.8 Reestablish Communications
CPW personnel will need to be directed during communication
outages. Telephone company personnel may be needed to
reestablish critical phone lines. It may be necessary to use cellular
phones and radios for initial communications. Once
communications are reestablished, a call-center should be set up to
respond to associate and public questions and concerns.
4.2.9 Facility Repairs
Start work in restoring damaged facilities, based upon critical
need.
4.2.10 Reassess and verify that chemical and waste systems are working
and not causing adverse environmental impacts. If a potential
problem is noted, it should be checked out, and if necessary,
immediately corrected.
4.2.11 Reestablish SCADA and Computer Systems
Some operations are totally dependent upon computer systems.
These must be repaired or relocated as quickly as possible.
Computer systems that support customer services should be
reestablished as quickly as possible.
4.2.12 Replacement of Critical Files
Any essential files that may have been destroyed should be re-
created by off-site or back-up files. This is especially important
concerning certain customer or associate personnel files.
4.2.13 Reestablish Financial and Human Resources System
It may be necessary to shift certain financial and HR systems, such
as compensation and benefit administration to another site for a
period of time.
4.2.14 Media
Contacts from, or to the media, should be directed by CPW
executive management or an authorized designee.
Effective Date: October 1,2000 Page 7 of 7
Revision: 2 Identification Number: EMS -4.4.1
Title: Emergency Preparedness and Disaster Recovery Procedure
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4.3 Post Incident Investigation
4.3.1 In the event of an emergency situation or accident that has
significantly impacted the environment or which has the potential
to do the same, a post incident investigation will be conducted. An
emergency situation or accident requiring a post incident review is
one in which there is the potential to be a major violation of a
regulatory permit, a major impact to public health or services, or a
major impact to the environment. The need for a post incident
investigation shall be determined by executive management or the
appropriate department head and a post incident review team shall
be assembled accordingly to conduct the investigation. Such post
incident investigations shall evaluate the cause(s) of the incident
and identify factors which should be evaluated for preventing or
mitigating the impacts of future incidents, including revising its
emergency preparedness and response procedures and
documenting the results.
4.3.2 Corrective Action Plan
The affected department shall prepare a corrective action plan (if
necessary) and submit the plan and subsequent plan amendments
to the Post Incident Review Team for review and approval. The
EMS program manager (or designee) shall track the activities of
the corrective action plan and perform verification surveillance(s)
upon completion of corrective action plan activities and submit
recommendation(s) for closure to the Post Incident Review Team.
4.4 Related Documents and Data
4.4.1 Emergency Response Plans
4.4.1 Inventory of Damaged Facilities
4.4.2 Spill Report Records.
4.4.3 Injury Report Records
4.4.4 Emergency Response and Disaster Recovery Team records
4.4.5 FEMA, Damage Survey Report Forms
4.4.6 Post Incident Review Report
4.4.7 Corrective Action Plan
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DD-SEOP 4.4.7
EMERGENCY PREPAREDNESS AND RESPONSE
1.0 PURPOSE AND SCOPE
This document defines the procedures to establish and maintain plans and to identify the
potential for, and responses to, incidents and emergency situations on employees, public and the
environment and for preventing and mitigating the likely illness, injury and environmental
impacts that may be associated with them.
This procedure and associated operational controls address or consider impacts and degree of
risks associated with environmental aspects, issues related to illness and injury, and corrective
actions associated with the following:
accidental discharges to water and land
accidental emissions to the atmosphere
specific environmental and/or ecosystem effects associated with accidental
releases
unsafe work practices and/or conditions
The procedure also specifies the process utilized by the company to periodically review
emergency preparedness and response procedures in light of operational changes, and following
the occurrence of an unexpected incident or event.
2.0 DEFINITIONS
3.0 RESPONSIBILITIES
4.0 PROCEDURE
4.1 Identification of Emergency Situation
4.1.1 The General Water Utility Supervisor, Standby and Duty Supervisors, and EMR (as
appropriate) shall be responsible to identify potential emergency response situations
where environmental impacts may result.
4.1.2 The identification of potential emergency situations shall be reviewed once a year during
the emergency drills or when a new response and containment activity is being
introduced.
4.1.3 The emergency situations shall be updated in the above mentioned applicable documents.
4.2 Emergency Response Procedures
4.2.1 Procedures covered by this DD-SEOP are described in detail in the WWC Divisions
Sewer Overflow Response and Tracking Plan (SORTP). This document contains sewer
overflow response and notification procedures for use at the operations level in
DD-SEOP 4.4.7 June 2003
Emergency Preparedness and Response Rev 1
MWWD WWC Division 1
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specifically responding to emergency events. Additionally, the document is intended for
use by Division management in determining the types and levels of resources necessary
to respond to and mitigate emergency situations. The SORTP and relevant attachments is
therefore incorporated by reference into this DD-SEOP.
4.2.2 The referenced documents provide the following information for adaptation into this
procedure:
Regulatory Requirements
Receiving Information Regarding Sewer Overflows
Dispatching Crews to Sewer Spill Sites
Definitions of incidents and responder requirements
Emergency management structure and organization-spill event notification listing
Emergency procedures are provided for each of the categories of operational
scenarios identified
Post-emergency response notification and reporting procedures and investigation
follow up
Sanitary Sewer Overflow Tracking Database
4.2.3 The above mentioned applicable documents shall be make available either by hard copies
or soft copies to the following:
Section Manager
Duty Supervisor
Central Operations Management Center (COMC)
Sewer Alarm Monitoring Section (SAMS)
City of San Diego Dispatch Center (Station 38)
4.3 Emergency Training
4.3.1 Awareness training of the emergency response and spill notification procedures shall be
provided to all new employees during the orientation briefing conducted by the Section
Manager and I&OS department.
4.3.2 Appropriate WWC staff shall be trained in their roles during an emergency situation.
Practical exercise (where appropriate) shall be conducted to familiarize with their roles.
The I&OS Division and respective WWC Section Managers shall coordinate training of
the ERT members.
4.4 Emergency drills and situations
4.4.1 Emergency drills involving hazardous materials usage should be carried out according to
a pre-determined schedule. The I&OS Division together with the ERT shall schedule
such drills involving partial or all the operations at each location.
4.4.2 The EMR and ERT Rep shall discuss the results of the emergency drills or cause of the
emergency situations and minutes of the meeting shall be maintained.
DD-SEOP 4.4.7 June 2003
Emergency Preparedness and Response Rev 1
MWWD WWC Division 2
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4.4.3 The I&OS Department and WWC ERT Rep shall meet to discuss the occurrence of an
emergency situation. An investigation shall be compiled for an occurrence of an
emergency situation to be submitted to the authority or/and management.
4.4.4 The above mentioned applicable documents shall be reviewed and revised according after
each emergency drills or occurrence of emergency situation.
4.5 Mitigating Environmental Impacts.
4.5.1 Relevant Emergency Plan procedures have been established to handle emergency
situations.
4.5.2 Fire fighting equipment and spill kits are made available to handle fire and spill
emergency situations respectively. First aid supplies are also made available in the event
of emergency situations. Procedures have been established for maintenance of fire
fighting equipment.
4.5.3 If there is an emergency and after bringing under control, employees will be able to go
back to their workplace to inspect for any damages upon clearance and instruction from
ERT Coordinator(s).
4.5.4 Appropriate Section Managers shall arrange for contractors to clear the debris and to
clean up the area. All debris shall be disposed appropriately according to legislated
requirements.
4.5.5 Appropriate Section Managers shall decide whether to form an inquiry committee to
investigate into causes and recommend remedial actions to prevent future occurrence.
5.0 REFERENCES
MWWD Departmental Health and Safety Manual
MWWD Major Incident Response Plan
City of San Diego Emergency Operations Plan
City of San Diego Employee Emergency Handbook
City of San Diego Hazardous Waste Management Guide
WWC Sewer Overflow Response and Tracking Plan
Section-specific emergency contingency response plans
DD-SEOP 4.4.7 June 2003
Emergency Preparedness and Response Rev 1
MWWD WWC Division 3
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SAMPLE EMS DOCUMENTATION
MONITORING AND MEASUREMENT
Charleston CPW- Monitoring and Measuring Key EMS Characteristics Procedure
City ofGastonia WWTP - Monitoring and Measuring Procedure
City of Eugene WWTP - Monitoring and Measurement Procedure
City of San Diego WWC - Calibration of Environmental Measurement
and Test Equipment
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CPW ENVIRONMENTAL MANAGEMENT SYSTEM
PROCEDURE
The on-line version and secured hardcopy are the controlled documents. The secured
hardcopy will be identified by an "Official Document" stamp giving date of distribution.
Any and all other documents are uncontrolled. Contact EMS Program Manager for
revision level status.
Effective Date: October 1,2000 Page 1 of 2
Revision: 0 Identification Number: EMS - 4.5.1 (A)
Title: Monitoring and Measuring Key EMS Characteristics
Prepared By: EMS Procedures Subcommittee
Reviewed By: EMS Management Steering Committee
Approved By: William E. Koopman, Jr., General Manager
John Cook PE, Assistant General Manager
Date Approved; August 25, 2000
0.0 Requirement ISO 14001 1996-E, Sub Clause 4.5.1 Monitoring and Measuring
1.0 Purpose
This procedure describes the process for the scheduled monitoring and measurement of key
characteristics of the organization's environmental management system activities.
2.0 Scope
This procedure addresses collection of environmental data associated with operations and
activities that have the potential to have a significant environmental impact.
3.0 Responsibility and Authority
3.1 The department head is responsible for submitting a monthly operating report (MOR)
which describes the key characteristics of the EMS and the status of the objectives and
targets and associated improvement programs.
3.2 The department supervisor(s) are responsible for generating environmental monitoring
and measurement data to be submitted in the Monthly Operating Report (MOR).
3.3 Executive management shall review the monthly operating reports to assure continuing
suitability and effectiveness of the EMS.
4.0 DEFINITIONS AND ACRONYMS
EMS Environmental Management System
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Effective Date: October 1,2000 Page 2 of 2
Revision: 0 Identification Number: EMS - 4.5.1 (A)
Title: Monitoring and Measuring Key EMS Characteristics
Environmental Key Characteristics - an element of an operation or activity that includes a
measurement or an inspection process the results of which supports evaluation of environmental
performance of objectives and targets.
Monitoring - a systematic process of watching, checking, observing, inspecting, keeping track
of, regulating or otherwise controlling key parameters and characteristics of a department's
management activities to determine conformance with a specific standard or other performance
requirement, or to measure progress toward its environmental objectives and targets.
Measurement - a systematic method for estimating, testing, or otherwise evaluating key
parameters and characteristics of a department's management activities to determine
conformance with a specific standard, other performance requirement.
5.0 Procedure
5.0.1 Monthly Operating Report (MOR)
A monthly report shall be established for department heads/supervisors to submit
monitoring and measuring information to support performance of the EMS. The
report is to be structured as a minimum to:
Provide status of environmental management programs designed to fulfill
environmental objectives and targets,
Provide status of performance indicators as related to targeted timeframes,
Provide compliance status of environmental operating permits issued by
environmental regulatory agencies.
5.0.2 Performance Tracking
Environmental data collected to reflect environmental performance is to be maintained in
such a manner to allow the evaluation of progress toward realizing environmental objectives
and targets.
6.0 Related Documents
Environmental Aspects,
Objectives, Targets, and Improvement Programs
Legal and Other Requirements
Operating Permits
7.0 RECORDS
Monthly Operating Report
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Standard Operating Instruction - EMS-0100.013
Name: Monitoring and Measuring
Prepared By: Beth Eckert, EMS Coordinator
Approved By: Beth Eckert, EMS Coordinator
Corresponding
Requirements:
ISO Standard: 4.5.1
NBP Element: 13
EMS Manual: 4.5.1
Revision Date: 8/11/03
Revision #: 6
Effective Date: 8/1/00
Signature: Page 1 of 3
EMS Monitoring and Measuring
Standard Operating Procedure
1.0 Purpose
1.1 The following procedure provides guidance for preparing quarterly reports which will be
reviewed during quarterly Management Review Board meetings in order to monitor and
measure the Division's significant impacts on the environment, biosolids program
performance at critical control points, compliance, progress on objectives and targets, and
results of compliance and EMS audits. During the Management Review Board meeting the
Division Manager WWT and Director of Public Works and Utilities shall use all provided
information to ensure the continuing suitability, adequacy and effectiveness of the EMS.
2.0 Associated Equipment
2.1 None
3.0 Associated Reference Material
3.1 Data Trend data base
3.2 Spill reports
3.3 Incident Reports
3.4 Division utility bills
3.5 Compliance Audits
3.6 Summary of Activities and NPDES Permit Limit/SOC Violations (EMS-0101.009)
3.7 SIU notices of violations
3.8 Hazardous waste manifests
3.9 Biosolids bills
3.10 Laboratory data
3.11 External communications logs
3.12 EMS Audits
3.13Training matrix (EMS-0101.002B)
This is an uncontrolled copy of a controlled document printed 8/20/2004 at 10:15 AM
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Name - Number: Monitoring and Measuring - EMS-0100.013
Revision #: 6
Revision Date: 8/11/03
Effective Date: 8/1/00
Page 2 of 3
3.14 Corrective and Preventative Action reports (EMS-0101.004) (reviewed at C/PAR meetings
by MRB which are held at least bi-monthly)
3.15 Monitoring and Measuring Forms (as MRB Reports on the Read-only drive)
EMS-0101.013A EMS Status Report
EMS-0101.013B Long Creek Operations
EMS-0101.013C Crowders Creek Operations
EMS-0101.013D Long Creek Laboratory
EMS-0101.013E Crowders Creek Laboratory
EMS-0101.013F Biosolids
EMS-0101.013G Pretreatment
EMS-0101.013H Facility Maintenance
4.0 Procedure
4.1 During each management review board meeting, data will be presented to track the
performance of the environmental management system.
4.1.1 At a minimum this review will track the division's performance regarding the
significant environmental impacts in each area, biosolids program performance at
each critical control point, compliance, objectives and targets, compliance audits,
EMS audits, operational controls, and the suitability, effectiveness, and adequacy of
the EMS.
4.2 Each area supervisor or designated personnel shall complete the appropriate monitoring
and measuring forms (EMS-0101.013_), by utilizing necessary resources as identified
above.
4.3 All forms shall be submitted to the EMS coordinator or other designated personnel via
e-mail prior to the management review board meeting. The EMS coordinator or designated
personnel shall compile all data provided into a single report to be provided at the
management review board meeting.
4.3.1 The quarterly report shall be provided to members of the MRB at least 5 days prior to
the meeting to ensure that each member has sufficient time to review the information.
4.4 Supervisors will be responsible for providing an oral presentation regarding the status in
their area. The EMS Coordinator or designated personnel shall be responsible for
reporting on the status of EMS activities.
This is an uncontrolled copy of a controlled document printed 8/20/2004 at 10:15 AM
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Name - Number: Monitoring and Measuring - EMS-0100.013
Revision #: 6
Revision Date: 8/11/03
Effective Date: 8/1/00
Page 3 of 3
4.4.1 The EMS Coordinator or designated back-up shall issue periodic updates via e-mail,
memo, or bulletin board regarding updates to EMS level documentation, EMS
training, and status of EMS audits.
4.5 The EMS Coordinator or designated personnel shall document the MRB meeting with
meeting minutes. The minutes of this meeting shall be filed along with a copy of the
Quarterly report in the EMS Coordinators files and maintained on the U: drive.
4.5.1 The EMS Coordinator will create C/PARs for any actions, which are requested during
the MRB meeting to ensure follow-up.
5.0 Revision History:
Revision
Date
5/20/02
5/20/02
10/14/02
10/14/02
1/21/03
8/11/03
#
3
3
4
4
5
6
C/PAR #
EMS-0074
EMS-0084
EMS-0116
EMS-0119
29
171
Reason for
Revision
External Auditor
C/PAR
C/PAR-NBP
External auditor -
C/PAR
MRB
CPAR
Description of Revision
Removal of Deviations statement from Level II procedures
Added a modification history section
Added NBP requirements and element number
Include a time frame to have the MRB report to members
to ensure enough time to properly review the document
Requires EMS Coordinator of designee to issue EMS
updates monthly to include audit status. Allowed for less
restrictive time frame on C/PAR meetings to at least bi-
monthly instead of monthly.
Changed EMS Update to periodically instead of monthly.
Added Facility Maintenance Monitoring & Measuring Form
This is an uncontrolled copy of a controlled document printed 8/20/2004 at 10:15 AM
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CITY OF EUGENE - WASTEWATER DIVISION
Procedure
Deleted:
Subject:
Last Reviewed By:
Approved By:
Monitoring and Measuring
Management Team
Original Date:
8/8/00
Management Team
Document No:
Revision No:
Date Approved:
VWV-0001 5
2
7/17/03
Purpose
The purpose of this procedure is to outline how the Division will ensure appropriate methods are in place to monitor and
measure performance against the environmental objectives and targets of the management system.
Scope
This procedure covers methods to ensure the reliability of data, calibration of relevant equipment and instruments, and
compliance with the management system.
Definitions
QA/QC
EMS Program Coordinator
Safety Requirements
All specific safety requirements will be included or referred to in specific work instructions.
Procedure (Include reporting requirements and precautionary steps in this section)
Accountablitv: Responsibility:
Management Team Supervisors Track performance of environmental monitoring and measurement activities that
are applicable to the Division's management system.
EMS Team
Management Team
EMS Manager
Laboratory Supervisor
Environmental Data Analyst
Identify appropriate environmental performance indicators for the Division that are
relevant to the Division's activities, consistent with our environmental policy,
practical, cost effective and technologically feasible.
Develop process to periodically evaluate compliance with relevant environmental
and legislative regulations.
Analyze results of measuring and monitoring systems to determine areas of
success and to identify activities requiring corrective action and improvements.
Review Quality Assurance Plan annually.
Procedure
Monitoring and Measuring
Page 1 of 2
Document No.: WW-00015; Rev No. 2
Last Revised: 7/17/03
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Deleted:
Supervisors
Ensure that relevant work section QA/QC procedures are consistent with the
approved QA/QC plan.
Develop and maintain appropriate processes and instructions to ensure reliability
and documentation of data such as calibration of instruments, test equipment and
software or hardware sampling.
EMS Program Coordinator
Division Staff
Environmental Data Analyst
Develop and maintain work instructions for relevant monitoring and measurement
activities to document performance related to the Division's environmental
objectives and targets.
Inform supervisors of any activities or irregularities that may have an impact on
monitoring or measuring requirements related to the environmental management
system.
Perform calibration of instrumentation and test equipment, confirms hardware and
software sampling is functional.
Assist in the development of work instructions for monitoring and measurement
activities.
Perform monitoring and measurement activities such as :
Measure mercury level in influent
Measure paper goods purchased
Measure vehicle fuel usage and mileage
Monitor purchased paper goods for recycle content
Measure annual power consumption
Monitor quantities of non-recyclable waste
Review and interpret environmental data.
References
Quality Assurance Plan
Procedure
Monitoring and Measuring
Page 2 of 2
Document No.: WW-00015; Rev No. 2
Last Revised: 7/17/03
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DD-SEOP 4.5.1
CALIBRATION OF ENVIRONMENTAL MEASUREMENT AND TEST EQUIPMENT
1.0 PURPOSE AND SCOPE
This procedure applies to the major sections that comprise the Wastewater Collections (WWC)
Division of the City of San Diego's Metropolitan Wastewater Department (MWWD). It
describes a controlled process for calibrating and maintaining those environmental measurement
and test equipment (EM&TE) items that are used specifically for the gathering of data to directly
support monitoring and measurement requirements that are invoked as permit conditions or as
other legal or regulatory requirements, or that support MWWD initiatives related to beneficial
use of waste byproducts. In addition, processes for monitoring and calibration of equipment
used in support of EMS performance measurement are covered by this procedure. This procedure
does not apply to measurement or test devices used for other routine operational or process
monitoring or measurement purposes.
Calibration and maintenance of EM&TE is required so that the accuracy and precision of the
environmental data collected (and potentially, the calculations based on the data) are known and
defensible.
2.0 DEFINITIONS
2.1 Calibration
Calibration is defined as the periodic comparison of an instrument or measurement device to a
standard of known and greater accuracy, in order to assure the continuity and accuracy of
measurements or data. If no calibration standards meeting the definition in Section 2.2 exist,
then the basis or justification of calibration methods must be separately documented as noted in
Section 4.
2.2 Calibration Standard
A calibration standard is defined as a device or reference used as a means of comparison for
quantitatively determining the accuracy, precision, and repeatability of instruments or
measurement devices. Calibration standards must have a known and traceable relationship to
nationally recognized standards such as those maintained by the National Institute of Standards
and Technology (NIST).
3.0 RESPONSIBILITIES
3.1 S ecti on El ectri cal Supp ort
Staff assigned to major WWC Division operations have primary responsibility for the
development of section-specific EM&TE calibration/maintenance requirements matrices, and for
implementation of the calibration and maintenance program requirements defined by this
procedure.
DD-SEOP 4.5.1 June 2003
Monitoring/Measurement Rev 1
MWWD WWC Division 1
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3.2 Environmental Management Representative (EMR)
The EMR is responsible for monitoring the development of section-specific EM&TE
calibration/maintenance requirements matrices, and for providing technical assistance to
individual Section Managers where necessary.
3.3 S ecti on Managers
Section Managers or their designees are responsible for review and approving applicable section-
specific EM&TE calibration/ maintenance requirements and for ensuring that appropriate
resources are made available to ensure that calibration and maintenance are performed within
their established intervals.
4.0 PROCEDURE
The procedure consists of the following steps:
4.1 Individual Section Managers shall, with the assistance of the EMR, and the Operations
and Inspection Section prepare a section-specific inventory of EM&TE for which
calibration and maintenance under this procedure is required.
4.2 For each equipment item so identified, calibration and maintenance requirements (i.e.,
establishment of equipment identifier, calibration/maintenance interval,
calibration/maintenance procedure or process, and source of calibration or maintenance,
if performed externally) shall be developed and documented in the WWC Division's
Computerized Maintenance Management System (CMMS). Requirements are described
further in the following paragraphs.
4.3 Unique numerical identifiers shall be assigned to all EM&TE items. All EM&TE with
expired calibration or maintenance due dates shall, where practicable, be tagged with an
"Out of Service" tag pending calibration, maintenance, or withdrawal from the EM&TE
inventory.
4.4 The required calibration and/or maintenance intervals shall be established, based on the
manufacturer's recommendations, the level of projected use, the usage environment, and
usage history. Maintenance intervals may be less than or equivalent to, but not greater
than, calibration intervals.
4.5 The recall date shall represent the date by which the EM&TE items must be withdrawn
from service for calibration and/or routine maintenance.
4.6 Specific calibration and maintenance instructions shall be provided, based, upon the
EM&TE manufacturer's recommendations. Calibration standards to be used should be
identified; if no calibration standards exist, then the basis or justification of the
calibration methods must be separately documented
Any limitations on use shall be specifically defined.
DD-SEOP 4.5.1 June 2003
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4.7 The completed EM&TE Calibration Measurement Requirements shall be presented to the
Section Manager or their designee for review and approval; all comments shall be
resolved to the reviewer's satisfaction.
4.8 The Section Manager shall coordinate the calibration and/or maintenance of all EM&TE
identified with Electrical Support and Planner/Scheduler staff. Where practicable, a
calibration tag shall be physically attached to the device indicating calibration recall date
and the equipment asset number. Calibration may be performed under the direction of
the section manager, either internally or externally (by qualified calibration service
subcontractors). Regardless of whether the calibration is performed internally or
externally by a subcontractor, all reference standards shall be traceable to nationally
recognized standards. If no standards exist, written justification of the calibration method
shall be documented in the "step description" column of the CMMS procedures.
4.9 The EM&TE Calibration Measurement Reports shall be used by the Section Managers to
track ongoing EM&TE calibration/maintenance status. A record copy shall be forwarded
to the EMR, when requested, for information and retention in the environmental records
in compliance with Section 5.3 of the EMP.
4.10 The Electrical Support staff shall notify Section Managers in advance of any calibration
and maintenance activity to allow for the planning of any required system downtime or
instrument changes. Environmental Coordinators may initiate internal Corrective Action
Requests (CPAR see DD-SEOP 4.5.2, "Non-Conformance and Corrective and Preventive
Action") or purchase orders as appropriate to control specific equipment recall,
calibration, and maintenance activities.
Failure to complete schedule calibration or maintenance within the interval defined on the
section's EM&TE Calibration Measurement Requirements Procedures shall be
considered to be a nonconformance, subject to the corrective and preventive action
processes defined by DD- SEOP 4.5.2, "Non-Conformance Corrective and Preventive
Action."
5.0 REFERENCES
WWC Division Environmental Management Plan
Section 4.6.1, Environmental Action Requests
Section 5.1, Monitoring and Measurement
Section 5.2, Control of Non-conformance's and Corrective and Preventive Action
Section 5.3, Records
DD-SEOP 4.5.2, Nonconformance and Corrective and Preventive Action
DD-SEOP 4.5.1 June 2003
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TABLE 1 (DD-SEOP 4.5.1)
ENVIRONMENTAL MEASUREMENT AND TEST EQUIPMENT CALIBRATION AND MEASUREMENT MATRIX
Section:
Approved By: _
Approval Date:
Equipment Name
Control No.
In Service Y/N
Calibration
Interval
Maintenance
Interval
Recall Date
Calibr/Maint.
Date
Limitation on
Use
Calibr/Maint.
Instructions
* may not be greater than calibration interval
Form #DD-F-012.0
Form Rev. Date: 6/02
DD-SEOP 4.5.1
Monitoring/Measurement
MWWD WWC Division
June 2003
Revl
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SAMPLE EMS DOCUMENTATION
EMS INTERNAL A UDIT
City of Eugene WWTP - Internal EMS Audit Procedure
City of San Diego WWC - Internal EMS Audit and Compliance Verification Procedure
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CITY OF EUGENE - WASTEWATER DIVISION
Procedure
Subject:
Last Reviewed By:
Approved By:
Compliance Audit
Management Team
Management Team
Date Prepared:
Date Approved:
8/8/01
8/17/01
Document No:
Revision Date:
Next Review Date:
WW-00465N
8/8/01
2/1/05
Purpose
This procedure describes the process used by the Division to schedule and complete regulatory compliance audits.
Scope
Procedure applies to all Division facilities and activities. Compliance audits will evaluate the Division's compliance with
relevant environmental legislation and regulations.
Definitions
Audit
Safety Requirements
All specific safety requirements will be included in specific work instructions.
Procedure (Include reporting requirements and precautionary steps in this section)
Accountablity:
EMS Manager
Management Team
Responsibility:
Schedule compliance audit. An external consultant will perform audits every five
years at a minimum.
Manage process to identify external consultant to perform compliance audit in
accordance with City purchasing procedures.
Manage contract with external consultant.
Review compliance audit report. Initiate any necessary corrective action in
accordance with Non-Conformance and Corrective Action Procedure.
References
Non-Conformance and Corrective Action Procedure
Procedure
Compliance Audit
Page 1 of 1
Document No.: WW-00465N
Last Revised: 8/8/01
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DD-SEOP 4.5.4
ENVIRONMENTAL MANAGEMENT SYSTEM AUDITS
AND COMPLIANCE VERIFICATION
1.0 PURPOSE AND SCOPE
This procedure establishes minimum requirements for planning, performing, and documenting
periodic internal audits of the ISO 14001-based environmental management system (EMS)
established for the City of San Diego's Metropolitan Wastewater Department (MWWD),
Wastewater Collections (WWC) Division.
2.0 DEFINITIONS
2.1 EMS Audit
An EMS audit is defined as a planned and documented investigation performed in accordance
with written procedures or checklists for the purpose of verifying, by examination and evaluation
of objective evidence, that applicable elements of an ISO 14001-based EMS have been
developed, documented, and effectively implemented in accordance with specified requirements.
2.2 Lead EMS Auditor
A Lead EMS Auditor is a qualified and trained individual who is authorized to plan, organize,
and direct EMS Audits of WWC Division section and activities; to report findings and
observations; and to evaluate the adequacy of corrective and preventive action. At a minimum,
WWC Division Lead EMS Auditors shall have received ISO 14001 internal EMS Auditor
training and have participated in an internal audit, as an auditor.
2.3 EMS Auditor
An EMS Auditor is defined as a qualified and trained individual who is authorized to perform
specific EMS Audit functions under the direction of a Lead EMS Auditor. At a minimum, each
auditor must attend a documented training session conducted by the Lead EMS Auditor that
presents the detailed requirements of this procedure and discusses their roles in the planned
audit.
2.4 EMS Audit Observer
An EMS Audit Observer is an EMS audit team member assigned to observe audit activities
under the direction of the Lead EMS Auditor. At the Lead EMS Auditor's discretion, technical
observers may be requested to perform specific audit functions in relation to their area of
expertise. At a minimum, each observer must attend a documented training session conducted
by the Lead Auditor that presents the detailed requirements of this procedure and discusses their
roles in the planned audit.
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2.5 Finding
A finding is defined as a deficiency or lack of compliance with any element of an EMS. All
findings must be formally resolved to assure effective correction of the observed condition and
the adoption of system improvements or preventive measures to reduce or preclude the
likelihood of recurrence.
3.0 RESPONSIBILITIES
3.1 Environmental Management Representative
The Environmental Management Representative (EMR) is responsible for establishing audit
schedules and for designation or selection of Lead EMS Auditors who are independent of the
day-to-day management of the plant functions to be audited. The EMR shall also review and
approve EMS audit plans and reports.
3.2 Lead EMS Auditor
The Lead EMS Auditor is responsible to the EMR for the organization, planning, and direction
of EMS audits, as well as the selection, training, and supervision of the audit team. The Lead
EMS Auditor prepares audit plans and reports, and is responsible for evaluating and
recommending any required corrective and preventive action responses resulting from audit
findings.
3.3 EMS Auditors or Observers
Auditors are responsible for assisting in audit preparation, conducting audit investigations, and
reporting results in compliance with this procedure, under the direction of the Lead EMS
Auditor. When requested, audit observers shall assist in audit preparation and in conducting
audit activities in areas in which they have specific expertise.
3.4 S ecti on Managers
Section Managers of audited section or group shall provide time, work space, and personnel as
necessary to support the performance of EMS audits, and are responsible for supervising the
prompt and effective resolution of any audit findings.
4.0 PROCEDURE
The audit process is described in the following steps, and is summarized in the flowchart
presented in Figure 1:
4.1 Audit Scheduling: EMS Audits shall be conducted at least annually. Audit frequency
may be increased at the discretion of the EMR or when specifically requested by upper
management.
4.2 Audit Notification: The Lead EMS Auditor shall notify the managers or section heads of
the audited organization at least ten days prior to the projected audit date. The
DD-SEOP 4.5.4 June 2003
EMS Audit Rev 1
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notification shall set the date, time, location, and method of the opening meeting, and
shall request that appropriate section personnel participate. Audit notification, opening
and closing meeting requirements may be met via e-mail communication.
4.3 Audit Plan: The Lead EMS Auditor shall prepare an audit plan. At a minimum, the audit
plan shall include the following:
the audit number (consecutive, by calendar year);
a statement of the audit objectives; an identification of the specific section areas
being audited;
a discussion of any special emphasis or focus; references to appropriate plans,
procedures, or requirements documents;
the date(s) of the audit; and an identification of the audit team and the members'
assigned roles.
Records of previous audits and corrective and preventive action requests for the audited
organization shall be reviewed prior to preparation of the audit plan. Identification of
trends or repeated problems identified during the review shall be reflected in the scope of
the audit, as appropriate. Any areas of special emphasis shall also be noted in the audit
plan.
Audit team selection shall be based on consideration of the particular areas of emphasis
for the audit and the qualifications and capabilities of the prospective team members.
Audit team members should be sufficiently independent of the day-to-day management
of the audit areas that they are responsible for so that the potential for a conflict of
interest is minimized. Completed audit plans shall be submitted to the EMR and affected
section managers for review and comment prior to the audit.
4.4 Audit Checklist Preparation: The Lead EMS Auditor shall prepare or direct the
preparation of an audit checklist based on the elements of the ISO 14001 standard. EMS
auditors or observers may be assigned the preparation of specific checklist sections,
especially in areas for which they will assume auditing responsibilities. Checklist content
shall be consistent with the scope of the audit presented in the Audit Plan. Copies of the
checklist, the audit plan, and any required reference specifications, procedures, or plans
shall be distributed to the audit team prior to the audit. The Lead EMS Auditor shall brief
the audit team on the general scope of the audit and the details of the audit plan, and shall
discuss audit checklist assignments prior to the pre-audit opening meeting.
4.5 Opening Meeting: The pre-audit opening meeting shall be conducted by the Lead EMS
Auditor, and shall be attended by the audit team members and appropriate representatives
of the audited section. Participation shall be documented. The scope of the audit and
duties of the auditors or any technical observers shall be briefly presented. Questions
from the audited organization shall be answered, proper lines of communication
established, and a time set for the closeout meeting. These requirements may be met via
e-mail communications.
DD-SEOP 4.5.4 June 2003
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4.6 Conducting the Audit: Each auditor shall proceed with the investigations required by
their assigned portion of the checklist. General guidance on auditing methods is provided
in Attachment 1 of this procedure. Auditing methods may include records review,
interviews with individual WWC Division staff members, and/or direct observation of
plant activities.
The audit team shall meet and report on audit progress as directed by the Lead EMS
Auditor. Observed conditions that require immediate corrective action shall be promptly
reported to the management of the audited group or organization. Demands on resources
and time may not be increased beyond the level presented in the opening meeting without
first discussing and obtaining approval of such requests from the affected section
manager.
When the checklist items have been completed, the audit team shall meet and present
their potential findings to the Lead EMS Auditor. The Lead EMS Auditor shall review
the auditors' input, obtain additional clarification where required, and prepare or direct
the preparation of a draft list of potential findings.
4.7 Closing Meeting: A draft list of potential findings and observations shall be presented to
representatives of the audited organization in a brief post-audit closing meeting.
Participation shall be documented. Discussion shall generally be limited to the
presentation of findings and the clarification of any misunderstandings. These
requirements may be met via E-Mail communications.
4.8 Audit Report Preparation: After the post-audit meeting, the auditors shall prepare final
copies of their completed checklist sections and submit them to the Lead EMS Auditor.
The Lead EMS Auditor shall prepare a formal audit report, which shall include the
following items: a brief description of the audit scope; the identification of the audit team
and key personnel contacted from the audited organization; a general statement
summarizing the effectiveness of the EMS; and a brief discussion of any findings.
Each finding shall also be recorded on a Corrective/Preventive Action Request (C/PAR)
form in compliance with the requirements of DD-SEOP 4.5.2, Non-Conformance and
Corrective and Preventive Action The audit report and any C/PAR forms shall be
submitted to the management of the audited organization for appropriate action, with
copies provided to the EMR and the Deputy Director, WWC Division.
4.9 Review of Corrective/Preventive Action Responses and Audit Closeout: The Lead EMS
Auditor shall participate in the development of corrective and preventive actions as
necessary to ensure that each finding or observation has been adequately addressed.
When proposed corrective actions have been determined to be acceptable, the Lead EMS
Auditor shall notify the EMR and the affected section managers that the audit is
considered to be closed.
4.10 Audit Documentation: Once the audit has been closed, the Lead EMS Auditor shall
forward a complete copy of the audit documentation to the environmental records in
compliance with Section 5.3 of the WWC Division EMP. At a minimum, audit
DD-SEOP 4.5.4 June 2003
EMS Audit Rev 1
MWWD WWC Division 4
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documentation shall include copies of the audit notification memo, the audit plan, audit
opening and closing meeting participation sheets, the completed audit questionnaire, the
audit report, copies of any closed C/PAR forms, and an audit closeout memorandum.
4.11 External Audit/Compliance Verification
Audit Requirements
4.11.1 The Management Representative or assigned person is to administer the
compliance audit activities. Notification must be sent to personnel in the WWC,
and he/she shall hold a meeting with the External Auditor to clarify the purpose of
the Audit, and areas or functions to be inspected.
4.11.2 The type of External Audits are listed as follows and is not exhaustive:
a. ISO 14001 certification and surveillance audits.
b. Internal City Initiated Audit.
c. External Compliance Audit.
4.11.3 During the course of the audit, an area representative shall accompany the
Auditor(s), and answer general questions about the section activities, processes
and services.
4.11.4 During the audit and exit meeting, the WWC Division representative(s) should
neither agree nor disagree to carry out any recommendations or requirements
necessitating a capital appropriations request or budget approval process prior to
implementation.
4.11.5 The Auditing parties will submit their findings in writing. Findings should be
written in a factual manner that does not reflect conjecture, supposition or
unwarranted conclusions. Findings should be marked "Confidential," and
forwarded to respective WWC Section Heads who will ensure that distribution is
limited to only those persons with a specific need for the information. A copy of
the report must be forwarded to the EMR.
4.11.6 After the site receives a written audit report from the auditor, and any clarification
needed, the respective WWC Section Heads, EMR and other MWWD
representatives will discuss the recommendations and requirements with affected
site management. A corrective action plan, which addresses all findings, should
be developed by responsible departments. The Corrective/Preventive Action
Report (C/PAR) shall be raised as per DD-F-006.0 accordingly.
4.12 All External audit reports and corrective action plans shall be retained as required.
DD-SEOP 4.5.4 June 2003
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MWWD WWC Division 5
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5.0 REFERENCES
WWC Division Environmental Management Plan
Section 5.2, Control of Non-conformances and Corrective and Preventive Action
Section 5.3, Records
Section 5.4, Environmental Management System Audit
DD-SEOP 4.5.2, Non-Conformance and Checking Corrective and Preventive Action
DD-SEOP 4.5.4 June 2003
EMS Audit Rev 1
MWWD WWC Division 6
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Figure 1
EMS Audit Process
Prepare audit
notification memo
V
Lead EMS
Auditor
Select and train
audit team
Lead EMS
Auditor
Resolve
comments
Prepare audit plan
and checklist
Lead EMS
Auditor
Lead EMS
Auditor
EMR/Facility
Sup's
Prepare audit report,
C/PARs as required
Lead EMS
Auditor/
Audit Team
Lead EMS
Auditor
EMR/Facility
Sup's
Resolve
comments
i
i
*-
No
^*
Prepare corrective/
preventive action
responses as required
EMR/Facility
Sup's
EMR/Records Clerk
Advise EMR and
Facility Superintendents
of closure
^
File records per
EMP 5.3
C/PAR - Corrective/Preventive Action Request
EMP - (WWC Division) Environmental Management Plan
EMR - Environmental Management Representative
EMS - Environmental Management System
DD-SEOP 4.5.4
EMS Audit
MWWD WWC Division
June 2003
Revl
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(DD-SEOP 4.5.4)
ATTACHMENT 1:
SUPPLEMENTARY GUIDANCE FOR CONDUCTING EMS AUDITS
1.0 GENERAL CONSIDERATIONS
This attachment provides general guidance that should be considered by the Lead EMS Auditor,
individual auditors, and the audit team as a whole during the onsite portion of an EMS audit.
1.1 Audit Team Behavior
The overall demeanor of the audit team must be perceived as ethical, professional, objective, and
fair. The Lead EMS Auditor is responsible for monitoring the activities of the audit team;
unacceptable behavior by any audit team member should not be permitted. The Lead EMS
Auditor should take whatever action is necessary in response to unacceptable behavior, up to and
including removing the responsible individuals from the audit team.
1.2 Overcoming Negative Perceptions
Even in the best situations, an auditor may encounter a certain amount of distrust, anxiety, anger,
fear, or obstinacy on the part of the audited organization or section. These kinds of negative
responses will hinder the progress of the audit and will detract from the usefulness of the
information obtained, unless an effort is made to establish a positive (or at least neutral) setting
for the audit. The Lead EMS Auditor must make a concerted effort to establish a productive
setting for the audit, from the first verbal contacts, through the opening meeting, daily
debriefings, and closing meeting. Because the audit team's primary mission is to obtain reliable
information about the performance relative to specific written standards, audit team members
must work to gain a functional level of cooperation in order to gain access to objective evidence.
1.3 Negative Situations
Extremely negative responses by audited personnel in an audited organization are rare, but they
can occur, and can be difficult to handle when they do. If such a situation should occur, audit
team members should politely break off the line of inquiry and bring the matter separately to the
attention of the Lead EMS
Auditor, who should attempt to resolve the issue with the section manager. Regardless of the
situation, audit team members must never show anger.
If a situation is truly unresolvable, the Lead EMS Auditor should cancel the remainder of the
audit, hold a brief closeout meeting with the audited section manager or superintendent to
explain the reasons for cancellation, and advise that the audit will be rescheduled after
negotiating a new audit date. If at this time the management representative asks the Lead EMS
Auditor to continue the audit, the Lead EMS Auditor should state the conditions that are
necessary. If the conditions are accepted, then the audit team should resume the audit. If no
DD-SEOP 4.5.4 June 2003
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request to continue the audit is made, or if the conditions for continuing the audit are not
accepted, then the Lead EMS Auditor should direct the audit team to cease its activities.
1.4 Preconceptions
To the extent possible, audit team members must set aside any preconceptions about the audited
section capabilities, regardless of whether they are good or bad. No matter how justifiable such
assumptions might be, the audited section strengths and weaknesses must express themselves as
part of an objective process. Audit team members must never go into an auditing situation with
the intention of finding something (or nothing) wrong. If the auditing process is not open and
objective, areas of significant strength or weakness may be missed and the accuracy of the
information gained from the audit may be compromised.
1.5 Flexibility
The Lead EMS Auditor should be free to redirect the emphasis of the audit in process, as
necessary to concentrate the audit team's resources on critical areas of investigation that may
come to light in the audit. The areas of emphasis in the audit plan and the checklists should be
followed to the extent possible, but if, in the Lead EMS Auditor's judgment, the situation
warrants redirection, it is appropriate to concentrate on specific areas of the checklist and not
investigate others; another audit may be performed at a later date to investigate other areas of the
program.
1.6 Documentation
The audit checklist should be formatted to facilitate inquiries and note-taking, but each audit
team member should use the note-taking methods that they are most comfortable with.
Reference copies of the WWC Division EMP and its supporting SEOPs and other documents
should be readily available to the team.
2.0 AUDITING METHODS: "DO'S" AND "DON'TS"
Audit team members should:
be prepared; the EMP sections and procedures associated with assigned area of
inquiry should be read and understood beforehand;
stay in charge of any interviewing situation, and steer conversations away from
long monologues or irrelevant discussions;
recognize that the presence of the audit team is by nature disruptive;
listen and observe more than they talk;
thank audited personnel for their assistance when there are no more questions;
take good notes that accurately describe the individuals contacted, the documents
reviewed, and the observations made;
verify or qualify the extent of potential problems by increasing the sample of
records evaluated, or by conducting additional interviews;
frame audit questions in language that the audited organization or department will
understand;
keep questions brief and focused;
DD-SEOP 4.5.4 June 2003
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clarify questions if they seem to be misunderstood;
complement the audited Section when particular strengths are observed;
ask open-ended questions to open up lines of inquiry or to gain access to
additional information; such questions should be phrased using "who", "what",
"when", "where", "why", "how", and "which" (none of which can be answered
"yes" or "no"); and
ask closed questions to confirm a point; closed questions should be phrased using
words like "is", "do", "has", "can", "will", and "shall", which will result in a "yes"
or "no" answer.
Audit team members should not:
talk too much, argue, use profanity, or discuss personalities or the results of other
audits;
criticize personnel from the audited Section, especially in front of their co-
workers or supervisors;
disagree with other audit team members or the Lead EMS Auditor in front of the
audited Section staff; any such discussions should be reserved for the audit team
members only;
permit representatives of the audited Section to see the audit team's working
notes or checklists;
obtain records or documents without the permission or participation of the audited
Section;
identify a problem in front of the audited section personnel as anything other than
something that should be looked at further; notes should be taken and specific
concerns verified by reviewing a larger sample of information;
discuss the decision regarding whether the problem requires more investigation or
represents a finding without first discussing the issues separately with the Lead
EMS Auditor first; or
make comments regarding the inadequacy of the audited section' EMS processes
or procedures, unless objective evidence suggests that audited section' written
requirements are not being fulfilled.
DD-SEOP 4.5.4 June 2003
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SAMPLE EMS DOCUMENTATION
NONCONFORMANCE AND CORRECTIVE ACTION
City of Gastonia WWTP- Corrective/Prevents tive Act/on Procedure
City of San Diego WWC - Nonconformance and Corrective/Preventative Action Procedure
City of Eugene WWTP - Nonconformance and Corrective Action Procedure
-------
Standard Operating Instruction - EMS-0100.004
Name: Corrective/Preventative Action Report
Prepared By: Beth Eckert, Environmental /Administrative Manager
Approved By: Beth Eckert, Environmental /Administrative Manager
Corresponding
Requirements:
EMS Manual: 4.5.2
ISO Standard: 4.5.2
NBP Element: 14
Revision #: 7
Revision Date: 3/9/04
Effective Date: 3/9/04
Signature: Page 1 of 3
Corrective / Preventative Action
Standard Operating Procedure
1.0 Purpose
1.1 This procedure is to develop and implement a corrective and preventative action program to monitor, report,
investigate and mitigate any impacts caused by the occurrence of non-routine incidents and/or near misses
and nonconformance with the Division's environmental policy or any related procedures.
2.0 Associated Equipment
2.1 None
3.0 Associated Documents
3.1 Corrective/Preventative Action Report EMS-0101.004
3.2 Document Control Procedure EMS-0100.002
3.3 City of Gastonia: EMS Manual EMS-0100.000
3.4 City of Gastonia EMS Manual: EMS-0100.000 and Policy
3.5 ISO 14001 Standard: ANSI/ISO 14001-1996 Environmental management systems - Specifications with
guidance for use
3.6 National Manual of Good Practice for Biosolids
3.7 National Biosolids Partnership Biosolids EMS Guidance Manual
4.0 Procedure
4.1 Corrective/Preventative Action Reports (C/PAR) will be used to identify potential needs for corrective and/or
preventative actions identified during EMS review, external and internal regulatory audits, internal and external
EMS audits, and following the occurrence of an event that may have a significant environmental impact or a
deviation from a current procedure.
4.2 All Corrective/Preventative Action Reports should be completed within 5 working days following first
knowledge of an incident or near miss.
4.3 Any employee is empowered to create a C/PAR following an incident or near miss or at any other time the
employee wishes to make recommendations for changes to existing procedures or policies and/or to identify
the need for addition policies and/or procedures.
4.4 Area supervisors or trained internal auditors are required to develop Corrective/Preventative Action reports for
incidents or near misses reported by employees or identified by other means unless an employee has already
done so.
4.5 While completing the C/PAR the author should use the following guidance (If another report form such as the
state spill report, the internal supervisor's report, or any other detailed report form is required that completely
'Controlled copies of this document have a blue signature are on green paper or are on the computer network U drive*
-------
Name - Number: Corrective/Preventative Action Procedure - EMS-0100.004
Revision #: 7
Revision Date: 3/9/04
Effective Date: 1/1/00
Page 2 of 3
satisfies the intent of any of the following sections you may complete that section by typing or writing "See
attached form" and attaching a copy to this report):
4.5.1 List personnel who identified the problem.
4.5.2 Describe the problem. If procedure or EMS documents and/or procedures are a focus of the findings
then they should be identified by their document control #, when possible. If prompted by an audit the
auditor must specify which section of the ISO Standard and/or NBP EMS Guidance Manual the finding
is related to.
4.5.3 Provide a root cause analysis, which identifies the source of the problem.
4.5.4 Describe Corrective/Preventative Action.
4.5.4.1 If unable to determine what corrective or preventative actions must be taken to resolve the
problem, skip this section. If it's an emergency issue, the supervisor must contact the appropriate
personnel to immediately resolve the problem.
4.5.4.2 If able to determine what corrective or preventative actions must be taken to resolve the problem,
take appropriate actions. If long-term action is required submit report without completion date for
this section.
4.5.5 The author must submit the completed corrective action report to the EMS Coordinator, or designee,
along with any and all support data for submittal to the Management Review Board (MRB) at the CPAR
meeting.
4.6 MRB will determine if the corrective action that has taken place is sufficient.
4.6.1 Internal auditors will determine if proposed corrective actions are sufficient for C/PARs generated as a
result of audit findings.
4.6.2 If sufficient and completed, the report will be signed and returned to the EMS Coordinator for proper
filing.
4.6.3 If insufficient or not completed, the Division Manager or designee may assign a new or revised
corrective/preventative action to take place, establish a desired completion date, and assign necessary
resources i.e. staff time, funds, etc...
4.6.4 CPARs will continue to be reported on during each CPAR meeting until the corrective actions have
been completed to the satisfaction of the MRB.
4.7 While modifying a procedure, as a result of a C/PAR, if additional changes are determined to be needed, it is
not necessary to write an additional C/PAR if the changes do not change the intent of the procedure. These
changes include grammar, re-wording for clarification, spelling, updating of names, phone numbers, and/or
references.
4.8 The EMS Coordinator will report final actions to MRB and record completed corrective/preventative action
reports on the read-only drive. Any required changes in the documented procedures as a result of the
corrective/preventative action will be completed by area supervisors per the Document Control procedure
(EMS-0100.002).
'Controlled copies of this document have a blue signature are on green paper or are on the computer network U drive***
-------
Name - Number: Corrective/Preventative Action Procedure - EMS-0100.004
Revision #: 7
Revision Date: 3/9/04
Effective Date: 1/1/00
Page 3 of 3
5.0 Biosolids Contractor
5.1 The Biosolids contractor shall be an active participant in the CPAR process.
5.2 The contractor, or its representative, shall be trained on and is expected to comply with the requirements of the
CPAR procedure.
5.3 The contractor will also be trained on how to generate a CPAR and/or provided a City contact to assist with the
generation of necessary CPARs.
5.4 In addition, when notified by City Staff that Biosolids issues are going to be discussed at a CPAR meeting the
Contractor or its representative shall be in attendance.
5.0 Revision History:
Revision
Date
3/14/02
8/7/02
11/18/03
3/9/04
#
4
5
6
6
7
C/PAR #
EMS-0074
EMS-0084
EMS-0103
EMS-0116
258
Reason for
Revision
External Audit
C/PAR
C/PAR
C/PAR
External Audit
Internal Audit
Internal Audit
Description of Revision
Removal of the section that states that deviations from this
procedure must be documented in a C/PAR, the statement
appears to give approval to deviate from the procedure.
Added a modification history section
Added section stating that additional C/PARs are not
required to make minor changes when already revising a
procedure as a result of a C/PAR.
Added the National Biosolids Partnership (NBP) EMS
element number to the header for linkage purposes and
document control requirements. Also, added verbiage to
include NBP requirement section on C/PAR if applicable.
Streamlined the auditing and cpar process to complement
one another. And for all findings during an audit to be
tracked through the CPAR process.
Included a requirement for MRB to designate resources for
complete corrective actions.
Inclusion of Biosolids Contractor into the CPAR program.
'Controlled copies of this document have a blue signature are on green paper or are on the computer network U drive*
-------
DD-SEOP 4.5.2
NON-CONFORMANCE AND CORRECTIVE AND PREVENTIVE ACTION
1.0 PURPOSE AND SCOPE
This procedure describes a controlled process for initiating corrective and preventive action in
response to externally or internally reported non-conformances that relate to the implementation
of the ISO 14001 conforming environmental management system (EMS) established for the
Wastewater Collections (WWC) Division of the City of San Diego's Metropolitan Wastewater
Department (MWWD).
2.0 DEFINITIONS
2.1 Non-conformance
For the purposes of this procedure, a non-conformance is defined as a demonstrated lack of
conformance to the environmental policy commitments and other mandatory provisions of the
WWC Division EMS, as documented by the WWC Division Environmental Management Plan
(EMP) and the supporting plans and procedures referenced therein.
Non-conformance with planned arrangements (including deviations from established procedures)
can be identified by EMS Internal Audits (DD SEOP 4.5.4, Environmental Management System
Audits and Compliance Verification), management reviews (DD-SEOP 4.6.1), or may
be brought to the EMR's attention through internal and external communications (DD-SEOP
4.4.3), Communication of Environmental Information (Internal/External). Corrective action
requests may be issued following non-conformances identified by the WWC Division's third-
party ISO 14001 registrar during pre-assessments, registration audits, or follow-up surveillances.
2.2 Corrective and Preventive Action Request Forms
Corrective and Preventive Action Request (C/PAR) forms shall be initiated by the
Environmental Management Representative (EMR) to facilitate the investigation of
non-conformances, the determination of the root causes of non-conformances, the correction of
non-conforming conditions, and the specific preventive actions that are deemed necessary to
reduce or preclude the likelihood of recurrence.
3.0 RESPONSIBILITIES
3.1 WWC Division Staff and Section Managers
WWC Division staff are responsible for bringing suspected non-conformances to the attention of
their assigned Section Managers, or to the EMR.
3.2 Environmental Management Representative (EMR)
The EMR is responsible for evaluating potential non-conforming conditions noted in internal or
external communications, EMS audits, management review, or third-party registrar audits and
surveillance activities, and for initiating the C/PAR process where non-conformances are
DD-SEOP 4.5.2 June 2003
Corrective Action Rev 1
MWWD WWC Division 1
-------
determined to exist. The EMR shall actively participate in the resolution of the
non-conformance and shall work with the responsible Section manager or section supervisor to
identify appropriate corrective and preventive actions. The EMR is responsible for preparing
corrective and preventive action requests, verifying completion, and logging of the issuance and
closure. The EMR shall prepare and present a report to management on a monthly basis
identifying the current status and resolution of all C/PAR's.
3.3 Responsible Section Manager or Supervisors
Section Managers or Supervisors determined to have primary responsibility for a
non-conformance shall participate with the EMR in the evaluation of the non-conformance,
determination of the root cause of the non-conformance, determination of appropriate measures
to be taken to correct the immediate situation, and the determination of appropriate preventive
measures that could reasonably be taken to reduce or preclude the likelihood for recurrence of
the non-conformance. It is the responsibility of the Section Manager, Supervisor or assigned
management to ensure these corrective and preventive actions are completed within the
determined time frame or report the progress and the revised completion dates to the EMR, prior
to the original completion date.
4.0 PROCEDURE
The procedure consists of the following steps:
4.1 Upon receipt of environmental communications that indicate a potential non-conforming
condition, or upon review of internal or external EMS audits, or management review
reports that indicate a potential non-conforming condition, the EMR shall make a
preliminary determination of whether or not a non-conformance exists.
4.2 For conditions identified through internal or external communications, and for which no
non-conformance is determined to exist, the EMR shall make an appropriate verbal or
written response to the originator through the processes defined in DD-SEOP 4.4.3,
Communication of Environmental Information (Internal/External), and forward
documentation of such action to the environmental records in compliance with Section
5.3 of the WWC Division EMP . If a nonconformance is determined to exist, go to
step 3.
4.3 The EMR shall document the nonconformance on a C/PAR form (DD-F-006.0), assign
the C/PAR a unique identifier (2 digit year/sequebntial number), and enter basic C/PAR
information on the C/PAR Status Tracking Log (form DD-F-007.0).
4.4 The EMR and responsible Section Manager or supervisor shall discuss the non-
conforming condition and its fundamental or root causes, and jointly develop appropriate
measures that can be taken to correct the near-term condition, as well as preventive
measures that could reasonably be expected to reduce or preclude the likelihood of the
DD-SEOP 4.5.2 June 2003
Corrective Action Rev 1
MWWD WWC Division 2
-------
recurrence of the nonconformance. The EMR shall forward a copy of the open C/PAR to
the Section Manager with primary responsibility for the nonconforming condition, and
jointly develop appropriate corrective and preventive actions.
4.5 Root cause determination and proposed corrective and preventive actions shall be briefly
summarized on the C/PAR form. Approval signatures are required by the Section
Manager, with appropriate implementation signatures and dates upon completion of the
corrective action.
4.6 Due dates for completion of the proposed corrective and preventive actions shall be
established, and the C/PAR updated as appropriate to document the EMR and
Responsible Section manager or supervisors recommendations. Completion dates may
be extended as determined necessary by the Section Manager or Supervisor with EMR
approval. These extended dates will be noted on the C/PAR in addition to an explanation
for the extension.
4.7 The EMR shall track the progress of corrective and preventive action completion using
the C/PAR Status Tracking Log, and verify completion of all required actions. Once
completion has been verified, the EMR shall indicate C/PAR closure by signature, and
the completed C/PAR, with any attachments, shall be forwarded to the environmental
records for retention in compliance with Section 5.3 of the WWC Division EMP.
5.0 REFERENCES
WWC Division Environmental Management Plan
Section 4.3, Communication
Section 4.6, Operational Control
Section 5.1, Monitoring and Measurement
Section 5.2, Control of Non-conformances and Corrective and Preventive Action
Section 5.3, Records
Section 5.4, Environmental Management System Audit
Section 6, Management Review
DD-SEOP 4.4.3, Communication of Environmental Information (Internal/External)
DD-SEOP 4.3.2, Regulatory Tracking and Analysis
DD-SEOP 4.5.4, Environmental Management System Audits and Compliance Verification
DD-SEOP 4.6.1, Environmental Management Review
DD-F-006.0, CPARForm
DD-F-007.0, CPARLog
DD-SEOP 4.5.2 June 2003
Corrective Action Rev 1
MWWD WWC Division 3
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CITY OF EUGENE - WASTEWATER DIVISION
Procedure
Subject:
Last Reviewed By:
Approved By:
Nonconformance and Corrective Action
Management Team
Management Team
Date Prepared:
Date Approved:
6/26/00
2/6/03
Document No:
Revision Date:
Next Review Date:
WW-00016R3
2/6/03
2/1/05
Purpose
This procedure describes the process to ensure that the Division establishes, maintains and uses a system to
identify nonconformances from regulations or requirements and to specify a process to identify and track
corrective and preventive actions.
Scope
This procedure applies to all nonconformances requiring corrective or preventive action by staff. These will
typically identified by the following methods:
Internal and external audits
Environmental Compliance Audits
Safety Audits
Inspections
Incident Reports
Complaints
Compliance Inspections
Permit Inspections
Definitions
Audit Team
Corrective Action Request (CAR)
Environmental Compliance Assessment
EMS
EMS Manager
External Auditors
Nonconformance
Safety Requirements
All specific safety requirements will be included or referred to in specific work instructions.
Procedure (Include reporting requirements and precautionary steps in this section)
Accountability: Responsibility:
Division Management Team Provide appropriate resources to ensure nonconformances are corrected.
Procedure
Nonconformance and Corrective Action
Page 1 of 2
Document No.: WW-00016R3
Last Revised: 2/6/03
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Audit Team
Audit Team
Staff
Audit Team
Lead Auditor
EMS Manager
Division Staff
EMS Manager
Division staff
EMS Manager
Internal Auditors
Conduct conformance audit/internal or external assessment.
Identify potential nonconformance and notify supervisor and Audit Team member
by e-mail.
Determine whether the potential nonconformance meets the criteria for a
nonconformance or an observation.
Enter nonconformance or observation information into CAR Database. Select
either "finding" or "observation."
Submit CAR information to EMS Manager by e-mail.
Review corrective or preventive action request information and inform Division
Management Team of any identified nonconformance that involves a potential
regulatory or legal noncompliance.
Determines appropriate staff to take corrective or preventive action. Enters
appropriate staff name into CAR Database, and request corrective or preventive
action.
Identify the cause of the nonconformance.
Identify appropriate corrective or preventive action. Complete Corrective Action
Approval Request in CAR Database and forward electronically to EMS Manager,
with copy to work section supervisor (if supervisor does not complete form).
Reviews Corrective Action Approval Request. Requests additional information if
necessary. Consults with Division Management Team prior to approving .
recommended corrective or preventive action.
Implement the necessary corrective or preventive action.
When corrective or preventive action is completed, fill out Corrective Action
Completion Details form in CAR Database. Forward by e-mail to EMS Manager.
Closes corrective or preventive action.
Include review of completed corrective or preventive actions in scope of audits.
References
ISO 14001 Standard, 4.5.2 Non-conformance and Corrective and Preventive Action
EMS Manual, Nonconformance and Corrective Action Policy
Internal Audit Procedure
Monitoring and Measuring Procedure
Procedure
Nonconformance and Corrective Action
Page 2 of 2
Document No.: WW-00016R3
Last Revised: 2/6/03
-------
SAMPLE EMS DOCUMENTATION
MANAGEMENT REVIEW
City of Eugene WWTP - Management Review Procedure
City of San Diego WWC - En vironmental Management Review Procedure
-------
CITY OF EUGENE - WASTEWATER DIVISION
Procedure
Subject:
Last Reviewed By:
Approved By:
Management Review
Management Team
Date Prepared:
8/8/00
Management Team
Document No:
Revision No:
Date Approved:
WW-00019
3
2/13/04
Purpose
The purpose of this procedure is to define the minimum requirements for conducting management review of the Division's
Environmental Management System.
Scope
This procedure applies to management reviews performed by the Division Management Team and the EMS Team.
Management reviews will consist of comprehensive annual evaluations to determine the adequacy of the:
Division's environmental policies and procedures
Current environmental objectives and targets
Overall effectiveness of the EMS in facilitating achievement of environmental objectives
Definitions
Division Management Team
EMS
Environmental Objective
Environmental Target
Safety Requirements
All specific safety requirements will be included or referred to in specific work instructions.
Procedure (Include reporting requirements and precautionary steps in this section)
Accountablity: Responsibility:
EMS Manager At least annually, coordinate and conduct management reviews.
Procedure
Management Review
Page 1 of 2
Document No. WW-00019; Rev. No. 4
Last Revised: 2/13/04
-------
Supervisors
EMS Teams
EMS Manager
Division Management Team
EMS Manager
Document Control Specialist
Supervisors
Division Staff
Summarize data from:
EMS audits
objectives and targets information
correspondence from interested parties
significant changes to the EMS
other relevant documentation concerning the EMS
Manage production of Division Annual Environmental Report
Review work section's activities semi-annually in relation to EMS objectives and
targets, training, and aspect management.
Provide summary and recommendations for improvements to EMS Team.
Document any observations, conclusions and recommendations for improvement.
Prioritize needed EMS conclusions and recommendations for improvement and
report to EMS Manager.
In management review, evaluate the above information to assess the
effectiveness of the EMS, and if it is contributing to continual improvement of the
Division's environmental performance.
Assign responsibility and deploy resources to facilitate changes to EMS.
Distribute findings of semi-annual reports to Division Staff.
Create record of management review meeting(s), and forward to Document
Control Specialist
File record of management review.
Implement necessary changes, or assign responsibility for necessary changes.
Follow Documentation/Document Control Procedure.
Communicate any policy and procedural changes to staff.
Comply with changes to the EMS.
References
ISO 14001 Standard, 4.6 Management Review
EMS Manual, Management Review Policy
Documentation/Document Control Procedure.
Procedure
Management Review
Page 2 of 2
Document No. WW-00019; Rev. No. 4
Last Revised: 2/13/04
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DD-SEOP 4.6.1
ENVIRONMENTAL MANAGEMENT REVIEW
1.0 PURPOSE AND SCOPE
The purpose of this procedure is to define the minimum requirements for conducting annual,
independent management reviews of the ISO 14001-based environmental management system
(EMS) established for the City of San Diego's Metropolitan Wastewater Department (MWWD)
Operations and Maintenance (WWC) Division. This review will be conducted in order to ensure
the effectiveness, sustainability and adequacy of the EMS with the objective of continual
improvement. This procedure covers all personnel affecting WWC's operations, activities, and
products
2.0 DEFINITIONS
2.1 Management Reviews
Management reviews are defined as comprehensive evaluations performed by or at the direction
of the Deputy Director, WWC Division in order to determine the adequacy of
the WWC Division's environmental policy;
current environmental objectives and targets relative to the WWC Division's
overall policy goals; and
the overall effectiveness of the EMS in facilitating the achievement of
environmental policy goals and specific environmental objectives.
Management reviews should not be confused with periodic EMS Management Team briefings,
internal EMS audits (see DD-SEOP 4.5.4, "Environmental Management System Audits") or
third-party ISO 14001 EMS registration audits. However, management reviews should consider
the results of recent internal and third-party EMS audits, along with 1) the extent to which
objectives and targets have been met; 2) changing operational or regulatory conditions; 3) the
concerns of interested parties; or 4) future needs or other external factors which may affect the
necessary structure and content of WWC Division's EMS.
2.2 Interested Party
An interested party is defined as any individual or group concerned with, interested in, or
potentially affected by the environmental performance of the WWC Division. Examples of
interested parties may include regulatory agencies or authorities; community groups;
environmental organizations; the press; or employee organizations.
DD-SEOP 4.6.1 June 2003
Environmental Management Review Rev 1
MWWD WWC Division 1
-------
3.0 RESPONSIBILITIES
3.1 Deputy Director, WWC Division
The WWC Division Deputy Director is responsible for performing or supervising the
performance of independent, documented, annual management reviews of WWC Division's
EMS, as described in this procedure.
3.2 Environmental Management Representative
The Environmental Management Representative (EMR) is responsible for assisting the Deputy
Director, WWC Division or his designee in the performance of management reviews by
providing audit reports, environmental performance data summaries, environmental
communications records, third party audit correspondence, or other information as may be
requested. The EMR is also responsible for the planning and execution of any mandatory action
items that may be established as a result of the management review.
4.0 PROCEDURE
The management review process is described in the following steps and is summarized as a
flowchart in Figure 1:
4.1 Management review shall be conducted at least once a year, however, may be more
frequent depending on internal or external audit activities.
The management review team shall consist of the following members:
Deputy Director (or designee)
EMS Management Representative
EMS Steering Committee members i.e. Section Managers and designees
4.2 If for any reason an EMS Steering Team member cannot attend the meeting, he/she
appoints an alternate person to represent his/her function at the meeting. At least 75% of
the EMS Steering Team shall be in attendance to meet the management review
attendance requirement.
4.3 The EMS Management Representative is responsible for:
setting up management review meetings;
assigning responsibility for taking the meeting minutes to one of the meeting
attendees;
publishing the meeting minutes; and
ensuring the meeting minutes and attendee list are retained according to record
retention procedural requirements.
4.4 The EMS Management Representative prepares and issues the meeting agenda in
advance that may include some or all of the topics listed in Figure 1.
DD-SEOP 4.6.1 June 2003
Environmental Management Review Rev 1
MWWD WWC Division 2
-------
4.5 The EMS Management Review Team shall discuss the agenda items and assess the
effectiveness, suitability and adequacy of the management system. Some or all of the
following shall be used in the assessment process:
progress of objectives and targets
overall program results
internal and external audit results
closure of C/PARs
risk assessment results
other policy and procedure modifications relative to operational changes
4.6 Assessment results, decisions, and action items from the meeting are recorded in the
Management Review Meeting Minutes Summary Form. The EMS Management
Representative shall keep these minutes according to DD SEOP 4.5.3, "EMS
Recordkeeping"..
4.7 The EMS Management Representative or his/her designee shall monitor progress to
ensure that action items raised during the management review are promptly addressed.
Areas needing improvement shall be planned into the next internal audit.
5.0 REFERENCES
WWC Division Environmental Management Plan,
Section 2, "Environmental Policy";
Section 3.3, "Objectives and Targets";
Section 5.3, "Records";
Section 5.4, "Environmental Management Systems Audits";
Section 6, "Management Review".
DD-SEOP 4.3.3, "Establishment of Environmental Objectives, Targets and Programs"
DD-SEOP 4.4.3, "Communication of Environmental Information (Internal /External)"
DD-SEOP 4.3.4, "Environmental Action Requests"
DD-SEOP 4.5.4, "Environmental Management System Audits and Compliance
Verification".
DD-SEOP 4.6.1 June 2003
Environmental Management Review Rev 1
MWWD WWC Division 3
-------
FIGURE 1
MANAGEMENT REVIEW PROCESS
(DD-SEOP 4.6.1)
FIGURE 1A - SAMPLE EMS MANAGEMENT REVIEW MEETING
Month, Date, Year
Agenda
To meet WWC's commitment to continual improvement of the EMS, a discussion of the
continuing suitability, adequacy and effectiveness of the EMS topic(s) discussed will be carried
out through a review of the EMS. The EMS topics(s) discussed during the EMS Management
Review meeting, findings, and any action items assigned must be recorded on the EMS
Management Review Minutes Summary Form (See Doc. No. DD-F-010.0). Example agenda
items are listed below:
Review overall EMS system
Review Environmental Policy
Review significant aspects/hazards and impacts/risks
Review and approve EMS objectives, targets, and programs (versus program
results)
Review environmental compliance performance
Review environmental training system
Review internal and external communications processes, including
communication of significant environmental issues
Review EMS internal and external audit findings
Consider possible improvements in the EMS as it has been developed
Discuss budgets and expenditures since last management review
Discuss site preparations for any up-coming third party EMS audits
Other agenda items
The following must be addressed and documented on the EMS Management Review Meeting
Minutes Summary:
Is the EMS topic/issue discussed suitable, adequate, and effective? If not,
indicate proposed changes and/or improvements.
Are changes to policy, objectives, or other areas of the EMS necessary? If so,
indicate change(s) and proposed implementation method.
Any additional action items/areas for improvement
DD-SEOP 4.6.1 June 2003
Environmental Management Review Rev 1
MWWD WWC Division 4
-------
FIGURE 1A
SAMPLE EMS MANAGEMENT REVIEW MEETING
Agenda (Continued)
In order for management to effectively carry out their review, the following documents/items
listed below are examples of reference materials that may be used during the EMS management
review meeting. Additional reference materials not listed below may also be used. All
applicable documents or other information utilized during the meeting must be attached and/or
referenced in the EMS Management Review Minutes Summary Form (See Doc. No. DD-F-
010.0) and/or meeting minutes.
A review of previous EMS Management Review meeting minutes/action items
Applicable environmental incidents, non-conformances and corrective action
plans/reports
Applicable employee suggestions and safety committee meeting minutes
A review of applicable WWC EMS metrics
New or changed legislation
Changes in applicable technology, including work processes
Changes in business environment or WWC' s financial and/or competitive
position that may influence policy, objectives and targets
DD-SEOP 4.6.1 June 2003
Environmental Management Review Rev 1
MWWD WWC Division 5
-------
FIGURE 2A
EMS MEETING ATTENDANCE SHEET
DD-SEOP 4.6.1 June 2003
Environmental Management Review Rev 1
MWWD WWC Division 6
-------
DD-F-010.0
MANAGEMENT REVIEW MEETING MINUTES SUMMARY FORM
Meeting Date:
Item#
1
2
3
4
EMS Topic Discussed
QJ
^
c3
'3
GO
(L)
ctf
3
o
<^
(L)
>
-M
fl^
ta
p-i
(Y/N)
>-,
o
"o
ex
'Tn
(L)
.Si
O
(L)
0
"S
(L)
(L)
w
^H
(L)
J3
6
Change
Necessary? (Y/N)
Action Item(s)/Notes
Target Date
* Use additional forms or attachments as necessary
City of San Diego MWWD
Wastewater Collection Division
Standard Environmental Operating Procedure
DD-SEOP 4.6.1, Revision -0-, 8/20/2004
Environmental Management Review
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Appendix B
EMS Supplemental Toolbox
I. EMS Presentation
II. Communication
III. Gap Analysis Checklist
IV. EMS Software
V. Compliance Checklist
VI. Training
VII. EMS Internal Audit
-------
EMS SUPPLEMENTAL TOOLBOX
EMS PRESENT A TION
Gastonia Wastewater - EMS Implementation and Development
-------
r
City of Gastonia
Wastewater Treatment Division
Environmental Management
System Development and
mplementation
Presented By: Donald E. Carmichael, P.E.,
Director of Public Works and Utilities
V Beth Eckert, Industrial Chemist/'
Coordinator
-------
r
Overview of the City of
Gastonia's Wastewater
Treatment Division
Two wastewater treatment facilities
Approximately 11.0 million gallons of
wastewater treated daily
Treatment facility staff of 51 employees
23 significant industrial users; 6 general
permits issued
-------
r
How Gastonia Became
Interested in an El\
Attended NCDPPEA - ISO 14001 seminar
Spoke with our Industries who were seeking
ISO 14001 certification
Recognized how it could benefit our
organization by helping us to:
Minimize and potentially eliminate noncompliance
Minimize our impact on the environment
Provide consistency over time within the operation
Became a pilot program with the State of North
Carolina
-------
Approval from
Gastonia's City Council
several memoers were ousinessmen, wno were
familiar with ISO standards, the consistency of
application and policy it brings to an organization
and recognized the benefit to the City
Good environmental stewardship
Above and beyond compliance with laws and
regulations
Proactive - not reactionary
Recognized intangibles, such as improved public
image
-------
r
Who will Develop
the EMS?
Management selected the following personnel
EMS Coordinator
EMS Team
Staff Member from NC Div. of Pollution
Prevention and Environmental Assistance
assisted the City
Ideas and suggestions were sought from all
employees
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r
EMS Coordinator
EMb Coordinator was trained by an external
source on ISO 14001.
Responsibilities include:
Training the rest of the WWTD staff on ISO 14001
Environmental Management Systems
Guiding development and ensuring that progress was
being made on the EMS
Ensuring conformance to the ISO 14001 standard
-------
r
EMS Team
Responsibilities include:
Being the core group of people who develop
the EMS
Developing and reviewing aspect and
impacts
Developing and reviewing procedures
Training of personnel in their respective
areas
-------
r
NC DPPEA Staff Member
John Burke helped in every step.
He had previous experience in EMS
development, which provided the City with a
starting point for each step.
He helped with training, procedure
development, form development, etc...
He also helped to ensure that our procedures
and programs conformed to the ISO 14001
standard
-------
' Gastonia Began
EMS Development
Kick-off meeting was held February 2,
1999.
ISO 14001 EMS training of the EMS Team
Development of a strategy and timeline for
EMS implementation
-------
EMS policy is developed, signifj
requirements identified, and
O 14001 Elements
agement Review
Djectives and targets establish
ISO 14001 Elements
Requirements; 4) Objectives and Targets
rv
nagement reviews various
ts at regular intervals to
ne the need for changes to
)olicy, eectives, and/or procedures
To carry out the policy and objectives, employees are
trained on procedures relevant to their worlSactivities and
consequences of departure from thosepftcedures.
Employees are made aware of their^HK and
responsibilities.
ISO 14001 Elements
1)Roles and Responsibilities; 2) Training, M/areness, and
Competence; 3) Operational Control; 4/lnternal and
External Communication; 5) EmergencyJfrepared ness an
Response; 6) Document
A monitorin^^Drogram is established to evaluate environmental performanca^mployees can
report problems^o management through corrective action reports^Aujjjt^ire conducted to
evaluate EMS effectiveness
1) Corrective and Preventative Action Program; 2) EMS Auditing; 3) Monitoring and Measuring
Program; 4) Record Keeping
-------
Policy and Objectives
-------
Environmental Policy
An environmental policy was
developed by the EMS team
Approved by City Council on March
16, 1999.
The policy is located on Gastonia's
website at www.citvofqastonia.com
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r
Aspects and Impacts
An aspect and impact procedure and forms
were developed
Aspects and impacts were:
identified
rated high, medium, or low for severity and
frequency
significance was determined
The EMS Team took approximately 3 months
to determine significance - done by June,
1999.
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r
Legal and Other Requirements
Identified and made a list of all legal and
other requirements for the VVWTD:
Permit effective and expiration dates
Compliance report due dates
Contract dates, etc...
Determined a procedure for keeping them
current
C/PAR resulted in adding EMS review dates
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r
Objectives and Targets
The EMS team developed a list of
objectives and targets for the division
based on:
Significant aspects and impacts
Legal requirements
Interested third parties
Economical concerns
concerns
-------
Structure and
-------
Who had Responsibilities under
the EMS?
Successful EMS must involve every level of
personnel from Trades Helper to City Council
Member
EMS Team developed a document entitled
Roles and Responsibilities
Lists every position and their responsibilities as they
pertain to the EMS
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r
Structure of the EMS
EMS manual which outlines the City's EMS
Procedures both for the operation of the
management system and the operational
controls of the facilities
Awareness and procedural training
Development of forms and supporting
documentation
-------
r
EMS Manual
Format based on the ISO 14001 standard to
assure the EMS was structured to meet the
requirements of the standard
Written by EMS Coordinator, reviewed by the
EMS team and approved by the Superintendent
of the WWTD
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EMS Procedures
Created as a direct result of the ISO 14001
standard, like the following:
Document Control
Training
Aspect & Impact
Corrective / Preventative Action
EMS Auditing
External Communication
Monitoring and Measuring
Standard only requires 3 documented
procedures: monitoring and measuring,
compliance audits, and operational controls
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r
Document Control
Document numbering system
Divisional documents have EMS numbers
Site specific documents are identified as such by a
specific prefix
Procedures and forms are listed on the Document
Control Matrix
Signatures on original documents are blue
Controlled copies
Green paper
Computer (read-only drive)
All other documents are uncontrolled
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r
Document Control Matrix
Document Title
Document #
Revision
Retain
Frequency
Controlled Copy Locations
ENVIRONMENTAL MANAGEMENT SYSTEM DOCUMENTS
Procedures for Environmental Management System
Environment Management
System Manual
EMS Review Procedure
Document Control Procedure
EMS-01 00.000
EMS-01 00.001
EMS-0100.002
0
0
0
As
Needed
As
Needed
As
Needed
As Needed
As Needed
As Needed
ป U: Drive
1 . Long Creek Operations
2. Crowders Conf. Room
3. PW Director's Office
4. Pretreatment Office
5. Superintendent's Office
ป U: Drive
1 . Long Creek Operations
2. Crowders Conf. Room
3. PW Director's Office
4. Pretreatment Office
5. Superintendent's Office
ป U: Drive
1 . Long Creek Operations
2. Crowders Conf. Room
3. PW Director's Office
4. Pretreatment Office
5. Superintendent's Office
-------
r
Training
Training for Everyone
EMS policy
EMS awareness
Corrective/preventative Action
External Communication
Supervisors determine who is to be trained
on specific operational control procedures
Training is documented and listed on the
training matrix
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r
Training Matrix
Document Title
Document #
Rev
EMS Management Procedures
Awareness Training
Environment Management System Manual
EMS Review Procedure
Document Control Procedure
Aspects and Impacts Procedure
Corrective/Preventative Action Report
Procedure
Training Procedure
Roles and Responsibilities Listing
Objective and Targets - Improvement Plan
Summary
External Communications Procedure
Environmental Management System Audit
Sewer Overflow /Reporting Procedure
(Press Release);Media List; Distribution list;
Emergency Phone list
Monitoring and Measuring Procedure
Legal and Other Requirements
N/A
EMS-01 00.000
EMS-01 00.001
EMS-01 00.002
EMS-01 00.003
EMS-01 00.004
EMS-01 00.005
EMS-01 00.006
EMS-01 00.007
EMS-01 00.008
EMS-01 00.011
EMS-01 00.01 2
EMS-01 00.01 3
EMS-0101.001
N/A
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6/28/00
NR
5/9/00
2/14/00
2/14/00
2/14/00
2/14/00
5/9/00
12/18/00
2/14/00
6/28/00
NR
NR
8/11/00
8/30/00
8/30/00
8/11/00
9/1/00
8/29/00
8/29/00
8/29/00
8/29/00
8/29/00
NR
NR
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NR
NR
NR
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NR
NR
NR
NR
NR
NR
5/9/00
4/10/00
4/10/00
5/10/00
5/9/00
4/10/00
4/10/00
6/28/00
5/12/00
8/28/00
1/27/00
6/29/00
9/11/00
9/11/00
9/11/00
5/12/00
8/30/00
8/30/00
5/12/00
8/30/00
8/30/00
5/9/00
5/8/00
5/8/00
5/8/00
5/9/00
12/18/00
5/8/00
8/4/00
5/8/00
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5/11/00
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3/8/00
3/8/00
3/8/00
5/9/00
12/18/00
3/8/00
6/28/00
9/1/00
-------
r
Operational Controls
Developed as a result of what the EMS Team
determined to be significant to the Gastonia
WWTD
Developed to help achieve an Objective and
Target set by the Gastonia WWTD
-------
Checking and
Corrective Action
-------
Checking / Corrective Action
The EMS is designed to continually improve
itself through the following programs:
Monitoring and measuring
Corrective/Preventative Action Reports
Internal Audit Program
Management Review
-------
r
Monitoring and Measuring
Procedures for tracking and documenting the
impacts the VWVTD is having on the environment
Measurements are taken and records are
maintained for each area related to the impacts
determined to be significant
proper calibration is required and documented of all
equipment related to these measurements
Audits are conducted and documented
-------
r
Corrective/Preventative Action
All employees are encouraged to complete
C/PARs, as the result of:
system failure
procedure deviation
recommendation for improvement, etc...
C/PARs are reviewed by the management review
board
C/PARS remain open until it is determined by the
Superintendent that sufficient action was taken and
completed
-------
r
Audit Program
Auditors trained by an external source in
ISO 14001 Auditing
Auditors from each area of the WWTD
Each area audited biannually and audit reports
generated
Responses are received from the area
supervisor
Follow up is done to assure all findings have
been corrected.
-------
Management Review
-------
Management Review Board
Monthly review of C/PARs
Quarterly review of:
Status of the EMS procedures and training
Results of the monitoring and measuring
actions
Progress on objectives and targets
Audit results
-------
r
Benefits of the EMS
Enhanced cooperation among staff
Within the WWTD as well as with other Divisions in the
City
Consistency in applications, despite employee turnover
Public awareness of the City's commitment to
environmental excellence
Improved relationships with State authorities
Controlled documented procedures
EPA accepted the EMS documentation and/or
descriptions as the WWTD's portion of the
OM-pr.ogr.aiM
-------
r
Plans for our EMS
Become Certified
Why?
Third party confirmation that our EMS conforms
to the standard
Positive recognition for the City's efforts
Expand to other areas of the Public
Works Department
-------
r
Summary
The City of Gastonia has taken the position that
we would like to consistently go above and
beyond compliance.
We feel that ISO 14001 is a large step in that
direction because:
Establishes a framework for an EMS
By design it provides for continual improvement
Maintain a proactive approach to compliance
Provides a systematic progressive solution to current
and future problems
-------
EMS SUPPLEMENTAL TOOLBOX
COMMUNICA TION
Clark County, Washington Public Works - Questions for Frontline Employees
City of San Diego WWC- Quarterly EMS Newsletter
City of Eugene WWTP - News Article
City of Charleston CPW EMS Policy and Commitment Statement
City of Charleston CPW- WCD Associate Recognition Program
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Environmental Management System (EMS)
Introductory Questions for the Shop Floor
1. Are you aware of the positive environmental work being done by Equipment
Services? What?
2. In your mind what are the top 3 things the shop does that can or does negatively
impact the environment?
3. What is the shops greatest opportunity for environmental improvement?
4. Do any environmental regulations affect the shops? If yes, what are they and how
do they apply to you?
5. If you have concerns about a product or a material where do you go for information?
6. Is the environment important to you? How or why?
7. Does this environmental policy work for you?
C - Compliance with Regulations
C - Continuous Improvement
P - Pollution Prevention
W - Working Together toward Sustainability
8. What do we need to get the buy-in from your fellow employees to make this EMS
project a success?
9. Can you think of something this EMS project can do for you to make your job more
rewarding?
10. What could management provide you to be a better environmental shop supporter?
-------
Did You Know?
Environmental Management System -ISO 14001
Wastewater Collection Division
STANDARD OPERATOR PROCEDURES (SOP):
* WWCD has currently incorporated 36 new SOPs into the MWWD/WWC Operations and
Policy Manual
<ป Where are these located?
All Section Managers (GWUS, Project Manager, Senior Civil Engineer, And Senior
Management Analyst) have controlled copies in their office.
<ป Who is responsible for complying with these SOPs?
Every employee of the Wastewater Collection Division
<ป Who is responsible for training on SOPs?
You 're Immediate Supervisor
WHO IS YOUR ENVIRONMENTAL MANAGEMENT TEAM (EMT)?
Jose Oropeza - Construction
Terrell Powell - ROW
Bert Seldura - SPSIOM
Nabeel Qawasmi - Engineering
MikeWhelan-CCTV
Rick Donahue
Gary Neel - NROW
Angela Salah - Administration
Pashant Pandya - Maintenance Coordinators
Knsten Ikeda - FEWD
Johnny Mitchell
WHO IS YOUR. ENVIRONMENTAL MANAGEMENT SYSTEM STEERING
COMMITTEE (EMSSC)?
Chris Toth, Deputy Director
Rick Donahue, Environmental Management Rep.
Alex Acosta Mathis, Senior Management Analyst
Leroy Davis, G.W.U.S.
Isam Hireish, Senior Civil Engineer
Bill Denhart, Assistant Deputy Director
Johnny Mitchell, Alternate Environmental Management Rep.
Mike Bedard, G.W.U.S.
Kevin Gensler, G.W.U.S.
Mike Giehl, FEWD Program Manager
TIPCOMINGEVENTS:
September 8, 9, 10,2003
November!, 3,4, 2003
ISO 14001 Internal Audit
ISO 14001 Final Assessment Audit
9/2/2003
Environmental Informational Publication
ISO 14001
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City of Eugene
CityNews
News from people at the City of Eugene
April 4, 2002
As part of its on-going effort to keep the community informed and involved, the
City of Eugene publishes this weekly newsletter highlighting the work being done
to make Eugene a better place.
Click here to see a listing of this week's Public Meetings Calendar
Past City News Pages
Table of Contents
FIRE DEPARTMENT EARNS RENEWAL OF STATE EXEMPTION
ENVIRONMENTAL MANAGEMENT SYSTEM SAVES TREES. WATER. POWER
AROUND THE CITY
Fire Department Earns Renewal of State Exemption
Oregon State Fire Marshal Bob Garrison has granted the City of Eugene a renewal of its
exemption from adhering solely to fire safety codes adopted by the State, and from oversight of
the City's fire prevention programs by the State office. With the exemption, the City is free to
adopt codes and code amendments that address specific local issues. This has been done on a
number of occasions, and the option remains open to the City as an exempt jurisdiction should
other issues arise.
A jurisdiction can be granted an exemption by meeting certain criteria in the area of fire
prevention; that is, the local fire department must assume responsibilities including code
enforcement, fire investigation, public education, juvenile firesetter counseling, and others. At this
time, only nine Oregon jurisdictions including Eugene have the exemption. Mr. Garrison will come
before the City Council on April 8 to present Eugene's certificate of exemption. For more
information, please contact Acting Fire Marshal Reggie Augsburger at 682-5411.
Environmental Management System Saves Trees, Water, Power
The new Environmental Management System at the Wastewater Division helped save more than
half a ton of paper in the past year using simple reduction strategies.
Wastewater's Environmental Management System established targets to reduce paper use and
increase the post-consumer content of paper products that are used. The division has employed
-------
a number of simple strategies over the past year in an effort to accomplish these goals. These
strategies include reducing the default margins for printed documents, using duplex options on
the division's printer, reformatting reports to use less paper, and installing cloth towel dispensers
in restrooms. In addition, the division has written guidelines for the use of paper and established
purchasing requirements for post-consumer content. Staff is encouraged to use electronic media
for correspondence, and computers or overheads are used at meetings instead of handing out
paper copies of agendas and informational materials. These efforts have been supported with
reminder stickers on equipment and training for all employees on paper reduction targets and
objectives.
The division's goal for last year was to reduce overall consumption of paper goods by 30%. A
monitoring report shows that the actual reduction was approximately 20%, and the 30% target will
be retained as next year's goal. In terms of specific reductions, the amount of paper used was cut
by 0.6 tons or around 120,000 sheets of paper. The goal for using recycled paper was that 70%
of the gross amount of all paper goods purchased would be made from recycled material with a
minimum of 30% post-consumer content. The Wastewater Division exceeded this goal by using
97% recycled paper and will change the goal for the next year to 99%. The environmental
benefits from these efforts can be stated in the following terms: ten 50-foot-tall trees saved,
12,300 gallons of water saved, 6,470 kilowatt-hours of electricity saved, and 2.6 cubic yards of
landfill space that did not have to be used. Using recycled content also saves water and power
since each ton of paper made with recycled fibers saves 7,000 gallons of water and 4,100
kilowatt-hours of electricity. For more information, contact Peter Ruffier, Wastewater Division
Director, at 682-8606.
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COMMISSIONERS OF PUBLIC WORKS
CITY OF CHARLESTON, SOUTH CAROLINA
ENVIRONMENTAL MANAGEMENT SYSTEM POLICY
POLICY STATEMENT:
The Charleston Commissioners of Public Works (CPW) is committed to the supply, treatment, and delivery of safe potable water and the collection, treatment, and disposal of wastewater in an environmentally sensitive and responsible manner. This policy establishes the commitment to
meeting all applicable federal, state, and local laws, regulations, and statutes. In addition, it establishes the commitment, working cooperatively and openly, to meet customer and community water quality and environmental expectations. It establishes the commitment to improving cost
and resource efficiencies. Further, this policy establishes the framework for setting and reviewing environmental objectives and targets with the intent of preventing pollution, protecting the environment, and continually improving environmental performance for present and future
generations.
POLICY IMPLEMENTATION:
Recognizing that many aspects of operations carried out at CPW can impact the environment, this policy establishes the directives for all associates. This policy shall be formally communicated and explained to all CPW associates and made available to the public. It shall be centrally
maintained and updated as necessary to reflect the changing needs and goals of CPW.
The CPW Environmental Management System (EMS) established by this policy, shall pursue and measure continual improvement in performance by establishing and maintaining documented environmental objectives and targets that correspond to the mission, vision, and core values
adopted by CPW. In addition, CPW shall conduct its operations to:
Emphasize environmental vigilance over CPW resources, processes, products, wastes, contamination and prevention of pollution.
Develop management and associate commitment to the protection of the environment and prevention of pollution. Set clear environmental objectives and targets with clear assignment of accountability and responsibility and implement Environmental Improvement Programs.
Commit to compliance with the letter and spirit of all applicable, federal, state, and local laws and regulations.
Plan, design, develop, construct, operate, and maintain facilities to encourage resource-efficiency and the protection and improvement of the quality of the environment.
Encourage integration of environmental planning into the strategic business plan.
Establish a management process for achieving targeted environmental performance by routinely monitoring and reporting on significant environmental aspects.
Implement a process of continual quality improvement for environmental management with the goal of achieving and maintaining third party certification for the EMS.
Establish an effective environmental communication program with external environmental stakeholders such as the South Carolina Department of Health and Environmental Control (SCDHEC), community groups, and other interested parties as needed.
The Environmental Management System shall undergo review by the CPW officers on an annual basis. The effective date of this Environmental Policy is the 15th day of October, 1998.
Committed to by the associates of the Water Distribution Department for the Commissioners of Public Works of the City of Charleston, South Carolina.
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Commissioners of Public Works
of the City of Charleston, SC
Wastewater Collection Department
Associate Recognition Program
Prepared By:
the WWCD Employee Recognition Committee
and the
Employee of the Quarter/Year Committee
Approved by:
Adrian Williams, Superintendent
Revision: 2002-0; Effective Date: September 01, 2002
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Wastewater Collection Department
Associate Recognition Program
Page 2 of 9
Revision: 2002-0
Effective Date: September 1, 2002
Prepared By: Asso. Recognition Committee
and the EOQ/EOY Committee
Approved By: Adrian Williams,
Superintendent
Award Program Index
I. Employee of the Quarter (EOQ) Award Page 3
II. Employee of the Year (EOY) Award Page 6
in. Productivity Management Program (PMP) Awards Page 8
IV. Associate/Crew of the Month Award Page 9
V. Excellent Performance Award (Spot Award) Page 10
Committee Members:
WWCD Employee Recognition Committee:
Rick Bickerstaff
Letty Clay
Rodney Cromwell
Larry Ferguson
Ronnie Inabinet
Robert Simmons
W.C. Swain
Employee of the Quarter /Year Committee:
Ronnie Inabinet
Chris Hendricks
JeffTisdale
Solomon Wade
Earnest Washington
Susan Roberts
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Wastewater Collection Department
Associate Recognition Program
Page 3 of 9
Revision: 2002-0
Effective Date: September 1, 2002
Prepared By: Asso. Recognition Committee
and the EOQ/EOY Committee
Approved By: Adrian Williams,
Superintendent
Employee of the Quarter:
The recommended procedure for recognizing an associate as the Employee of the Quarter
(EOQ) is as follows:
Recommendation Procedure:
The EOQ Chairperson will initiate a reminder for nominating associates for this
award. Reminder will be forwarded via e-mail, interoffice memo or verbally during a
scheduled department meeting.
Any associate within the WWCD may be recommended for this award by any other
associate within the department.
Recommendation forms are available at the Ballot Box (Suggestion Box) located
under the WWCD bulletin boards at the rear of the facility.
All nominations must be placed in the Ballot Box by the time and date specified by
the EOQ Chairperson.
Eligible Associates:
All full-time departmental associates are eligible. New associates become eligible at
the end of their orientation period.
No associate who has been chosen within the past 6-month period is eligible.
Associate(s) become ineligible if they have received a disciplinary action, i.e., written
warning, days off, etc., for policy violation during the quarter.
EOQ/EOY Recognition Committee:
The Recognition Committee will be comprised of employees chosen by their peers or
established through volunteering. The committee will equitably represent all sections and
levels of the department.
Recognition Committee Members:
Chairperson, chosen by the committee members, will serve a 2-year term.
Committee members, either appointed or as volunteers, will serve a 1-year term.
One representative from each section of the department is required.
When possible past winners may be chosen to serve as committee members.
Advisor(s) - as required.
At the end of a Chairperson's term, the existing committee members and new members
will nominate and appoint a new Chairperson. The new Chairperson may be one of the
existing committee members nearing the end of their term.
Committee members will seek their own replacement at the end of their term. A
committee member's replacement should be from their current section unless otherwise
approved by the Superintendent.
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Wastewater Collection Department
Associate Recognition Program
Page 4 of 9
Revision: 2002-0
Effective Date: September 1, 2002
Prepared By: Asso. Recognition Committee
and the EOQ/EOY Committee
Approved By: Adrian Williams,
Superintendent
The Superintendent or Assistant Superintendent may act as an advisor to the committee,
but will carry no vote.
EOQ Selection Process:
The Recognition Committee will meet on the third week of the last month of each
quarter.
The committee members will review all nomination forms and the details included on the
forms, and will discuss the following:
^ Excels in general productivity
^ Willingness to assist associates throughout the department
Contributes to the goals of the department
Commendable customer service
Team oriented
Positive attitude
/
/
The committee will vote on the nominees, and the nominee with most votes will be
awarded EOQ.
In the case of a tie vote, the Superintendent will make the final decision.
All associates' personnel information is to be kept confidential
Award Package for the "Employee of the Quarter"
The EOQ award will be presented at the following departmental meeting.
An "Employee of the Quarter" plaque will be presented to the associate.
The associate's name will be engraved on a brass plate, which will be affixed to the EOQ
plaque. The plaque will be displayed in the front lobby area.
An EOQ certificate will be presented to the associate and a copy placed in the associate's
personnel file.
A letter of appreciation will be presented to the associate and a copy placed in the
associate's personnel file.
A fifty dollar ($50) non-cash gift card to the retail store or other establishment (as
available) of their choice will be issued to the associate.
The associate will have the privilege of parking in the designated "Employee of the
Quarter" parking space located at the front of the associate parking area, for the duration
of the year.
The associate will have their choice to attend lunch with their supervisor, Senior
Supervisor, Assistant Superintendent, Superintendent or an Officer of the company,
whomever they choose.
The associate's name will be sent within 5 working days to Human Resources for
recognition in a CPW news publication.
Special Note: The Committee Chairperson will be responsible for coordinating the above
recognition and awards.
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Wastewater Collection Department
Associate Recognition Program
Page 5 of 9
Revision: 2002-0
Effective Date: September 1, 2002
Prepared By: Asso. Recognition Committee
and the EOQ/EOY Committee
Approved By: Adrian Williams,
Superintendent
Employee of the Year:
Eligible Associates:
All associates who were nominated as Employee of the Quarter through the duration of
the year are eligible.
Associate(s) become ineligible if involved with negligent loss or damage of equipment,
or have received a disciplinary action for policy violation.
EOY Selection Process:
Each associate in the department will be given a ballot sheet listing the eligible
associates.
Departmental associates will mark their selection on the ballot sheet. Voting will be done
by secret ballot and tabulated by the EOQ/EOY Committee.
Voting may occur during a departmental meeting.
In case of a tie vote, the Superintendent will be asked to cast the deciding vote.
EOQ/EOY Recognition Committee:
The EOQ/EOY Committee will preside over EOQ/EOY awards. See section on EOQ.
Award Package for the "Employee of the Year"
The EOY award will be presented at the following departmental meeting and/or the
Safety and Service Awards luncheon held each year.
An "Employee of the Year" plaque will be presented to the associate.
The associate's name will be engraved on a brass plate, which will be affixed to the EOY
plaque. The plaque will be displayed in the front lobby area.
An EOY certificate will be presented to the associate and a copy placed in the associate's
personnel file.
A letter of appreciation will be presented to the associate and a copy placed in the
associate's personnel file.
A one hundred twenty-five dollar ($125) monetary gift will be issued to the associate.
The associate will have the privilege of parking in the designated "Employee of the Year"
parking space, located at the front of the associate parking area, for the duration of the
year.
The associate will have their choice to attend lunch with their supervisor, Senior
Supervisor, Assistant Superintendent, Superintendent or an Officer of the company,
whomever they choose.
The associate's name will be sent within 5 working days to Human Resources for
recognition in a CPW news publication.
An "Award Notification Form" must be forwarded to the Accounting Dept. with awards
over fifty dollars ($50). Per state and federal compensation laws the associate must be
taxed on awards over fifty dollars ($50).
Special Note: The Committee Chairperson will be responsible for coordinating the above
recognition and awards.
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Wastewater Collection Department
Associate Recognition Program
Page 6 of 9
Revision: 2002-0
Effective Date: September 1, 2002
Prepared By: Asso. Recognition Committee
and the EOQ/EOY Committee
Approved By: Adrian Williams,
Superintendent
Productivity Management Program (PMP) Awards:
This award is based on monthly cumulative PMP points for the entire department.
Eligible Associates:
All permanent associates in the department receive this award when the department's
productivity points from the PMP program exceed 100%.
Part-time or temporary employees who work the entire quarter will also be eligible.
Award Package:
Each associate will receive a non-cash gift card/certificate worth eight dollars ($8).
The individual awards can be combined to finance a department-wide event, i.e.,
department-wide luncheon, breakfast, baseball game, etc. Each associate will vote on
combining the awards prior to final approval. The majority will rule.
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Wastewater Collection Department
Associate Recognition Program
Page 7 of 9
Revision: 2002-0
Effective Date: September 1, 2002
Prepared By: Asso. Recognition Committee
and the EOQ/EOY Committee
Approved By: Adrian Williams,
Superintendent
Associate/Crew of the Month Award:
Eligible Associates:
All associates that measure their level of production through the Productivity
Management Program (PMP).
Associates that accumulate points based on a "team" approach, i.e., designated crew,
will be considered one unit.
In consideration of crewmember shifting, the crew that the associate spent the
majority of their time with during the month will be the crew that they are measured
with.
Associate(s) become ineligible if they have received a disciplinary action, i.e., written
warning, days off, etc., for policy violation during the month.
Selection Criteria:
PMP points accumulated by each crew, technician, administrative personnel, etc. will
be calculated to establish an average for each month.
The PMP average for each section will be compared to determine the section winner.
Section winners will be as follows:
Administrative Section (if participating)
Construction Section
Maintenance Section
Pump Station Section
Technical Section
For an associate/crew to win in consecutive months, the associate/crew must exceed
their previous month's productivity percentage by 5%.
Award Package:
ACMA award certificate will be given to the individual or to all associates on a crew.
The individual or all associates on a crew will receive a ten dollar ($10) non-cash gift
card or certificate.
Presentations shall be made monthly at a department gathering: i.e., departmental
meeting, skills based training, safety training, etc.
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Wastewater Collection Department
Associate Recognition Program
Page 8 of 9
Revision: 2002-0
Effective Date: September 1, 2002
Prepared By: Asso. Recognition Committee
and the EOQ/EOY Committee
Approved By: Adrian Williams,
Superintendent
Excellent Performance Award (Spot Award):
Eligible Associates:
All WWCD associates are eligible.
Selection Criteria:
Supervisory level associates may recommend an associate or crew worthy of
recognition directly to the Superintendent or Assistant Superintendent.
Selection will be made based on the significance of a "job well done", operational
improvement suggestion, safety suggestion, project or program implementation, etc.
The award must be verbally approved by the Superintendent or the Assistant
Superintendent, and an Officer of the company.
Award Packages:
Bronze Award:
This award is given to any associate whose suggestions or performance has impacted
the WWCD in a positive manner.
Justification for the award includes but is not limited to:
I Going "above the call of duty".
I Performing job requirements with significant productivity under abnormal
circumstances.
I Implemented safety improvement suggestions.
I Implemented operational improvement suggestions.
I Receipt of "letters of recognition" from supervisors, associates, internal or
external customers, etc.
Monetary value range: $10 to $ 49
Monetary award will consist of non-cash gift cards/certificates.
Upon evaluation the Superintendent or Assistant Superintendent, and an Officer of
the company will determine the actual award value.
A Bronze Award certificate will be presented to the associate and a copy placed in the
associate's personnel file.
Silver Award:
This award is given to any associate whose suggestions or performance has impacted
the WWCD in a highly significant manner.
Justification for the award includes but is not limited to:
I Going well "over and above the call of duty".
I Performing job requirements with significant productivity under abnormal
circumstances with a substantial outcome.
-------
Wastewater Collection Department
Associate Recognition Program
Page 9 of 9
Revision: 2002-0
Effective Date: September 1, 2002
Prepared By: Asso. Recognition Committee
and the EOQ/EOY Committee
Approved By: Adrian Williams,
Superintendent
I Implemented safety improvement suggestions with significant operational
effects.
I Implemented operational improvement suggestions with a significant outcome.
Monetary value range: $50 to $99
Per state and federal compensation laws the associate must be taxed on awards over
fifty dollars ($50).
An "Award Notification Form" must be forwarded to the Accounting Dept. with
awards over fifty dollars ($50).
Gold Award:
This award is given to any associate whose suggestions or performance has impacted
the WWCD in a tremendously significant manner.
Justification for the award includes but is not limited to:
I Performance, actions, operational suggestions and/or improvements resulting
in an extraordinarily significant outcome.
I Performance, actions, operational suggestions and/or improvements resulting
in a significant cost-savings to the department and/or company.
Monetary value range: $100 to $200
Per state and federal compensation laws the associate must be taxed on awards over
fifty dollars ($50).
An "Award Notification Form" must be forwarded to the Accounting Dept. with
awards over fifty dollars ($50).
The Superintendent has the authority to alter the monetary value range as appropriate
to the operational improvement.
Special Note: An associate can receive a maximum of three hundred dollars ($300) per year in
awards.
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EMS SUPPLEMENTAL TOOLBOX
GAP ANALYSIS CHECKLIST
Global Environment & Technology Foundation - Gap Analysis Checklist
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Gap Analysis
EMS Check List
Answer the following questions. After completing the questions, review the questions for which
you answered No. These are some of the areas you will pay special attention to when developing
your Environmental Management System.
Reference - refer to the ISO 14001 Section that applies and identify and reference the
procedures, policies, materials, etc. that you have at your Port that partially or fully meet the
EMS (ISO) requirement.
Left to do - activities/actions (e.g., draft the procedure, update a current procedure with
additional language, maintain this record, etc.) required to fully implement the EMS requirement.
Responsibility - for identifying and assigning action items to organization personnel who will
assist in ensuring the EMS requirement is met.
POLICY
1. Does your organization have a documented environmental
policy?
Yes D No D
Partial D
Reference:
Notes:
2. Does the policy include commitments to a) continual
improvements, b) prevention of pollution and c) compliance to
relevant laws and other requirements to which the organization
subscribes?
Yes D No D
Partial D
Reference:
Left to do:
Responsibility:
Notes:
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Gap Analysis Checklist
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3. Is the policy communicated to all employees and made available
to the public?
Yes D No D
Partial D
How is it made available to all employees?
How is it made available to the public?
Reference:
Left to do:
Responsibility:
Notes:
4. Has the policy been endorsed and signed by Top Management?
Yes D No D
Partial D
Reference:
Left to do:
Responsibility:
Notes:
PLAN
1. Has a procedure to identify the significant environmental aspects
of your operations been established and implemented?
Is the procedure documented?
Yes D No D
Partial D
Yes D No D
Partial D
Reference:
Left to do:
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Gap Analysis Checklist
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Responsibility:
Notes:
2. Has a procedure to identify, track and communicate (to
applicable employees) applicable laws and regulations and other
requirements to which the organization subscribes been
documented, established and implemented?
Yes D No D
Partial D
Reference:
Left to do:
Responsibility:
Notes:
3. Have documented environmental objectives and targets been
established that:
identify responsibilities, schedules and the means by which the
objectives and targets will be met
take into account the significant environmental aspects, laws,
regulations, legal and other requirements and policy
commitments
consider the views of interested parties
Yes D No D
Partial D
Yes D No D
Partial D
Yes D No D
Partial D
Reference:
Left to do:
Responsibility:
Notes:
Global Environment & Technology Foundation
Gap Analysis Checklist
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DO
1. Have defined roles, responsibilities and authorities, including the
appointment of a specific management representative in charge of
the EMS been established?
Yes D No D
Partial D
Reference:
Left to do:
Responsibility:
Notes:
2. Have sufficient financial, technical and human resources been
made available to implement the EMS?
Yes D No D
Partial D
Reference:
Left to do:
Responsibility:
Notes:
3. Are all employees and contractors aware of the requirement of
the EMS, their roles in it, and potential consequences of departure
from operating procedures?
Are training records maintained?
Yes D No D
Partial D
Yes D No D
Partial D
Reference:
Left to do:
Responsibility:
Notes:
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Gap Analysis Checklist
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4. Has the organization identified training needs and methods for
providing general awareness of the EMS to all employees and
managers?
Yes D No D
Partial D
Reference:
Left to do:
Responsibility:
Notes:
5. Are all employees whose work involves significant
environmental aspects competent by training, experience and/or
education? Are training records maintained?
Yes D No D
Partial D
Reference:
Left to do:
Responsibility:
Notes:
6. Have internal communications procedures regarding EMS issues
been established and implemented?
Yes D No D
Partial D
Reference:
Left to do:
Responsibility:
Notes:
Global Environment & Technology Foundation
Gap Analysis Checklist
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7. Has the organization established procedures for communicating
relevant requirements to suppliers and contractors regarding
significant environmental aspects of services?
Yes D No D
Partial D
Reference:
Left to do:
Responsibility:
Notes:
8. Has the organization considered procedures for external
communication of its significant environmental aspects?
Yes D No D
Partial D
Reference:
Left to do:
Responsibility:
Notes:
9. Are the core elements of the EMS documented, including all of
the required procedures?
Yes D No D
Partial D
Reference:
Left to do:
Responsibility:
Notes:
Global Environment & Technology Foundation
Gap Analysis Checklist
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10. Is there an implemented and documented procedure for
managing documents and records to ensure that it is current,
accurate and readily retrievable?
Reference:
Left to do:
Responsibility:
Notes:
1 1 . Have documented
maintenance manuals,
environmental aspects
operational controls (e.g., work instructions,
etc.) for activities associated with significant
been developed and implemented?
Yes D No D
Partial D
Yes D No D
Partial D
Reference:
Left to do:
Responsibility:
Notes:
12. Have emergency identification, preparedness and response
procedures/plans been established, implemented and tested?
Yes D No D
Partial D
Reference:
Left to do:
Responsibility:
Notes:
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Gap Analysis Checklist
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CHECK & ACT
1. Have procedures been documented and implemented that are
associated with significant environmental aspects, operational
controls and objectives & targets being monitored and measured?
Yes D No D
Partial D
Reference:
Left to do:
Responsibility:
Notes:
2. Are operations associated with significant environmental aspects,
operational controls and performance toward objectives and targets
being monitored and measured (e.g., calibration, record reviews,
performance observations, trend analyses, etc.)?
Are relevant records maintained?
Yes D No D
Partial D
Yes D No D
Partial D
Reference:
Left to do:
Responsibility:
Notes:
3. Have procedures for evaluating compliance (e.g., audits, reviews,
or inspections) with legal requirements been established and are
they being implemented?
Yes D No D
Partial D
Reference:
Left to do:
Responsibility:
Notes:
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4. Are there procedures in place and being implemented for
handing EMS nonconformances and corrective and preventative
actions?
Are records maintained?
Yes D No D
Partial D
Yes D No D
Partial D
Reference:
Left to do:
Responsibility:
Notes:
5. Is the information from the monitoring & measuring, auditing
programs and training being recorded and reported on a regular
basis?
Yes D No D
Partial D
Reference:
Left to do:
Responsibility:
Notes:
6. Is there a procedure for EMS audits and is it being implemented?
Yes D No D
Partial D
Reference:
Left to do:
Responsibility:
Notes:
Global Environment & Technology Foundation
Gap Analysis Checklist
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MANAGEMENT REVIEW
1. Is senior management, on a regular basis, reviewing the structure
and performance of the EMS to determine the appropriateness and
effectiveness of the EMS and identify potential opportunities for
improvement?
Yes D No D
Partial D
Reference:
Left to do:
Responsibility:
Notes:
2. Is the management review documented and are management
recommendations for continual improvement documented and
tracked?
Yes D No D
Partial D
Reference:
Left to do:
Responsibility:
Notes:
Global Environment & Technology Foundation
Gap Analysis Checklist
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EMS SUPPLEMENTAL TOOLBOX
EMS SOFTWARE
Global Environment and Technology Foundation (GETF) - EMS Software Assessment
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Environmental Management System Software
EMS SOFTWARE ASSESSMENT
March 15, 2004
Revised June 23, 2004
Cooperative Agreement # 82886901
Global Environment & Technology Foundation
2900 South Quincy Street, Suite 410 Arlington, VA 22206
(703) 379-2713 Fax: (703) 820-6168
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EMS SOFTWARE COMPARISON
As part of the U.S. Environmental Protection Agency (U.S. EPA) and American Association of
Port Authorities (AAPA) supported Ports Environmental Management System (EMS) Assistance
Project, GETF conducted a neutral analysis of "off the shelf software products specifically
designed to support an organization's development, implementation, and subsequent
management of its EMS. The assessment focused primarily on managing environmental issues;
however, the analysis also considered the software's capability for integrating quality,
environment, security, and safety and health into a single management system approach. An
integrated management system approach may be very well suited to the complex, overlapping
issues and pressures faced by Ports. While the assessment was conducted specifically with Ports
in mind, the assessment may be useful to other public sector businesses and organizations
considering the use of software to support their EMS. GETF was specifically selected to conduct
this software assessment due to its unique synergy of in-house skills and expertise in both EMS
development and technical assistance, and its knowledge of leading information technology
applications.
EMS implementers are seeking tools that allow them to efficiently manage EMS implementation
and maintenance tasks, such as project scheduling and management, training and training
records, documentation management, and internal auditing and corrective/preventative actions.
EMS software packages can offer the following key implementation management and EMS
maintenance tools:
Better communication between environmental and project staff at multiple installations
Easy access to routine environmental and EMS documents and records
Access to regulations and other requirements; enhanced management of permits,
reporting, and compliance
Database query, reporting, and updating
Document repositories
Enhanced project management
E-mail based notification systems with escalation functions
Calendar and EMS milestone and progress functions
EMS report generation tools
Information access security controls
Assessment Approach
The software assessment entailed collecting factual information via interviews, product demos,
message exchanges, and web research on sixteen EMS-focused software products currently
available. The products were identified through working knowledge and past experience,
colleague referrals, and general research. Each of the identified products were assessed against
specific criteria (see evaluation criteria descriptions below) as deemed critical to implementing a
viable computer-based management system. Example criteria included: ISO compliance,
platform dependencies/adaptability, email notification capability, template provision, licensing
requirements, access controls/security features, training, product support, and price. The products
were also assessed for manageability of fundamental EMS elements, including: document
control features, procedure writing, sample documentation database, environmental aspect and
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risk assessment, tracking regulatory compliance, record management, corrective and preventative
action, and auditing. Potential users should subsequently ensure a selected product is compatible
with the organization's existing IT infrastructure prior to purchasing an EMS software system.
GETF utilized every effort to maintain a neutral disposition and to provide factual information as
gathered through product marketing materials, product vendor interviews, and web-based demos.
GETF did not have the ability, due to time and logistics, to demo each individual product. Based
upon the information collected, GETF subjectively divided the software products into two tiers
based on capabilities and specific relevance to the Port EMS Assistance Project. The following is
a breakdown of the software products by tier (products are listed alphabetically):
Tierl
Amadeus Environment Expert eQRP
Entropy International Envoy
Enviance
GreenWare ISO 14000 Implementation Software
GreenWare ISO 14000 Software Suite
IBS America QSI System for Environmental Management
Integrum ISOft 14000
Intelex ISOsoft 14001
Prism Equation
ZMH2 EMS-EZ (Graduate research project, included due to potential leveragability)
Tier 2
Dakota Auditor EMS
EMAServer Module ISO 14001 WES
Gage EMSTutor - ISO 14001 Expert System
IsoTop GP ISO 14001 TimeSaver Software
ISYS International ISO 14001 Expert-Ease
Oxegen - Oxegen EMS
Solution Foundry EMSolution Web
Evaluation Criteria Descriptions
Software Functionality
Documentation Templates: Software includes sample document templates (i.e.,
procedures, policies, manual, etc.) that can be used in the development of an
organization's relevant EMS-related documents and/or easily customized to fit the needs
of an organization.
Document Creation/Integration: The degree of product flexibility for creating and/or
integrating relevant EMS documents into the management system varies greatly. This
element is commonly a "sticking point" with products being too prescriptive with regards
to document format. Some products are based upon readymade documents/procedures
that drive the overall system allowing minimal flexibility on the part of the user, whereby
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other products allow a high degree of flexibility with the user able to choose between
provided templates, creating documents from scratch, and/or incorporating existing
external documents from varying application programs (e.g., Microsoft Word, PDF,
etc...).
Document Control/Review Functions: Software includes a document management
function, with the ability to track controlled documents, provide a review process, and
archive documents. Documents are linked in some format to other relevant components
of the EMS (i.e. activities, tasks, responsibilities, training, etc...).
Document Archive/Library: EMS documentation is maintained to accommodate
adequate record control and all records and documents are indexed and easily locatable.
Many providers offer a library type structure, similar to Microsoft Windows Explorer,
with documents linked to relevant activities within the EMS.
Data Compilation and Report Preparation: Software has tools to provide
environmental analysis in summaries and graphical reports to determine trends, etc...
Calendar Management: Software has a viewable calendar function to track upcoming
EMS implementation and management tasks and deliverables. Products also may have
the capability to integrate email notifications/reminders.
Milestone/Task Management and Tracking: Software includes a management tool that
produces automatic reminders/notification to individuals and/or groups, such as
reminders of projects, tasks, and permit requirements. This function may be linked to
calendar management tools.
Regulatory Compliance Management: Compliance management tools to assist with the
tracking and compliance of legal and other requirements, including permit deadline
reminders, regulatory updates, roles and responsibilities, etc...
Gap Analysis Tool: Software includes a tool that allows an organization to assess their
EMS against the ISO 14001 requirements either at the beginning of EMS implementation
activities and/or at a specific time of their choosing (e.g., prior to an audit).
Aspect/Impact Analysis Tools: Software has an environmental aspect analysis tool to
identify, rank, and prioritize a user organization's most significant environmental
impacts.
Audit Component/Tools: Software includes information relative to audit requirements
and procedures enabling internal and/or external auditors to verify and document whether
the organization's EMS is in conformance with the audit criteria set out in ISO 14010 and
14011. This component may include a comprehensive set of audit procedures, tests,
checklists and sample questions, as well as requisite audit documentation and reporting
abilities.
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Training Management: Software has tools to manage training requirements and training
records relevant to environmental management.
Context-specific ISO 14001 Text: Includes ISO 14001 Standard language and direct
references to the relevant elements.
Public Entity Clients
Public Entity Clients: Software caters to public entities specifically or as a significant
portion of their client base. Public entities have been identified that utilize the software.
Integrated System Capability
Integrated System Capability: Software is designed for integration with other systems,
such as quality management, safety and health, etc...
System Architecture
Client Server Solution / Stand-alone PC Version: Software is installed directly on the
user's hard-drive and/or hosted internally and purchased through individual licenses.
Web-enabled/Hosted by Provider (ASP): Software can be accessed via web browser,
hosted by the software vendor, and does not require software to be installed on individual
user's desktops. In addition, web-enabled software is Internet and Intranet capable and
platform independent. Software can be linked to other applications and websites to
provide up-to-date information.
Database: The software's back-end database and query platform (e.g., Microsoft SQL,
Oracle, etc...).
Client Operating System: The different operating systems the software supports (e.g.,
Windows 98/ME/XP, MS Office, Internet Explorer 5.0 or higher, etc...).
Security Features/Multi-level Access: The software allows for multiple levels of user
access, limited by defined roles and responsibilities. The access is determined by an
individual user's log-in information. This feature serves two purposes: 1) provides
security through limiting access to important information and documents; and 2)
simplifies the system by only providing access to information and features (i.e., clears the
clutter) necessary to the individual/group user.
Product Cost
Single Desktop License: The software's available cost and options on licensing of their
product.
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Training: Software includes access to training, either included within the software
package or available through a classroom structure. Additional costs are denoted.
Product Support: Technical assistance/product support offered by the software provider
as part of the purchase price. Additional costs (i.e., annual support fees) and description
denoted. Often this aspect is negotiated and customized at time of purchase.
Unique Software Needs and Characteristics of Public Sectors
Historically, EMS software tools have targeted private sector organizations and corporations;
however, several providers have recently focused significant attention on the growing pool of
public entity EMS implementers. Due to the initial focus of product development on the private
sector, many of the existing products do not meet public sector-specific needs and organizational
characteristics (i.e., technological capabilities, scalability to small organizations, operational
sectors such as wastewater, etc...). Although an organization's approach to EMS implementation
may be similar (i.e., plan-do-check-act, 17 elements of the ISO 14001 Standard, etc...), there are
fundamental, organizational differences between public and private sector entities. EMS
implementation experience has revealed that the needs, level of requisite support, and
capabilities of private versus public sector EMS implementers can vary considerably.
Research and feedback has shown that many existing products, originally created for use in the
private sector, are too prescriptive in regards to the structure and implementation of an EMS for
use by many public entities. Many of these products are driven by the immediate goal of
"achieving ISO certification" as quickly as possible, not a goal necessarily held by public
entities. Therefore, many products offer a "cookie-cutter" type approach that strives for turn-key
implementation of an EMS. In addition, for an EMS to be successful in driving effective
environmental management for public organizations, documents, procedures, policies, and the
like must be adaptable to different educational levels and technical capabilities and specific for
the site and operational sector (e.g., fleet maintenance) in question. While initially the
prescriptive nature of some software is comforting and supportive, overcoming inflexibility in
later stages of EMS development and implementation is often extremely time consuming, labor
intensive, and counter-productive.
It should also be noted that many public entities implementing EMSs have found that a lot of
EMS software packages include many more functions and capabilities than are actually utilized
or necessary in practice. The needs of a particular organization can differ widely depending upon
organizational size, internal capabilities and resources, and approach to EMS. The central
component of a software tool for EMS implementation and maintenance is its ability to control
and manage documentation and records. For many organizations this is the sole driver for
purchasing an EMS software product, resulting in the organization only utilizing a portion of the
software's overall capabilities. In fact, some organizations have realized that all they need is a
tool to help manage the documentation and have either developed this in house or hired an
external consultant to do so. Therefore, one alternative to consider, dependent upon an
organization's specific needs, is to develop or purchase an EMS document management tool.
To our knowledge, the commercial market for such focused products is currently limited with
most developed for internal purposes only. GETF was able to demo one such product during this
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research, which was produced by the University of Massachusetts - Lowell, a participant in the
U.S. EPA-supported 2nd EMS Initiative for Public Entities program. This product is currently
being fine-tuned for marketability, but incorporates a very user-friendly interface and
capabilities. Additional information on this product can be found at www.uml.edu/epaems.
Public-sector Focused Software
Currently, two EMS software providers have focused significant amounts of time and effort in
customizing their products to fit the unique needs of public sector clients, having distinguished
themselves, at least for the present time, from other competitors: Greenware
(www.greenware.com) and Intel ex (www.intelex.com). Both of these products have been
procured and utilized by participants in the EMS Initiatives for Public Entities pilot projects and
have secured contracts with a larger and more diverse range of public entities than similar
competitors. As part of this software comparison effort, GETF participated in software demos
and conducted interviews with selected users to assess the components and practical application
of both software products.
Overall, both products were of similar quality and scope. Participants in the EMS Initiatives, as
well as other relevant GETF clients that have utilized each of these products, have been generally
satisfied that the products greatly enhance their ability to implement and manage their respective
EMSs. However, a common thread throughout the user feedback has been that the Greenware
product does not offer the degree of flexibility with regards to document creation and integration
and significant aspect prioritization that was originally desired. Most organizations have learned
to accommodate this limitation with resulting success. During the product demo, Greenware
representatives expressed that their company is working diligently to increase the flexibility of
their product.
Although GETF strived to maintain a neutral assessment of the available EMS software
products, it was clear from research and demonstration that Intelex stands out when assessing
software effectiveness strictly for public entity EMS use. Other vendors within the Tier 1 listing
also offer outstanding management products; however, several expand beyond the scope of
EMS, most notably the Amadeus Environment Expert eQRP product. GETF's experience and
research clearly identified Intelex as a more user-friendly EMS-specific software package with a
simple, straightforward user interface and direct applicability to public entity characteristics and
requirements. The Manager's Dashboard, a unique feature to Intelex, was a great overall project
management tool and offered a tremendous sense of comfort and control in managing the day-to-
day activities of an EMS, a product capability especially valuable to public entity Environmental
Management Representatives, as often they are expected to be the lone EMS expert within an
organization providing leadership for implementation. In addition, the software maintains format
consistency throughout every component, is exceptionally well linked throughout the
management system, and offers tremendous, personalized product support. One weakness that
was identified in the comparison to other products was that Intelex was among the highest in
product cost.
Conclusion
It has become increasingly evident that more and more public entities are interested in software
products to better manage their environmental impacts, especially with the implementation and
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maintenance of EMSs. This follows a similar trend to that which occurred within the private
sector over the last decade. GETF has witnessed this transition firsthand through the current
EMS Initiative for Public Entities project in which over half of the participants have purchased
or are considering the purchase of EMS-focused software. The Ports, due to the relative
complexity of operations and issues as compared to the various public entity sectors, can
significantly benefit and essentially implement and maintain more robust EMSs with the
assistance of software products.
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ISO 14001 Software Comparison Matrix - Tier 1 Products
criteria ^S^
Entropy
International Envoy
GreenWare ISO 14000
Enviance Implementation
Software
GreenWare ISO 14000
Software Suite
IBS America QSI System
for Environmental Integrum ISOft 14000
Management
Intelex ISOsoft 14001
Prism Equation
ZMH* EMS-EZ
Software Functionality
1. Document Control :
a. Documentation !
Templates |
b. Document
Creation/Integration
c. Document Review
Process
d. Document Archive
Allows you to easily
access and view the
latest version of each
relevant document.
Review, approval and
distribution sequences
are electronically
managed. Distribution
is instantaneous.
Grants access only to
documents linked to
your duties, personal
needs and
preferences.
Yes, document
access controlled by
user entitlement.
YesTutiiizes a data
iwarehouse structure
! ensuring that records
e. Document Library
(linked)
are easily accessible.
All documents are
organized in one place
through a Windows
Explorer-type
structure and can be
accessed easily and
quickly. Documents
are linked to
keywords, references
to other documents
and physical
locations.
Yes, the product
includes a variety of
ISO 14001 templates
(procedures, policies,
checklists, etc...)
The product allows
the user to link to or
upload external
electronic files,
diagrams, and other
applications. In
addition, the software
includes a range of
templates.
Automatically
denotes author,
creation date, issue,
version number,
revision date, and
approver. Controlled
through the user
access and privileges
tools
Yes, documents are
maintained and
stored within a
central document
library.
Yes, documents,
diagrams,
audio/video, and
other applications are
all linked and stored
within a central
library, thereby
ensuring adequate
document control.
YesT The System JNoTcan be i purchased
includes document iseparate ($250).
templates that facilitate I
preparation of and I
revisions to required
documents.
Yes. The System
supports an unlimited
number of documents
in the Document
Manager. These
documents may be
externally created or
created through the
Template described
above. All documents
(files of any type) can
be associated with
specific components of
the user's model.
Yes. The System
includes a Document
Manager
Yes, the Document
Documents can be
easily created from
scratch, linked to
templates, or linked to
existing documents (i.e.,
Word, PDF, etc...).
Several users have
expressed that the
product utilizes
verbatum ISO language
and is at times inflexible
resulting in longer format
documents. Green ware
has recently focused
upon increasing
flexibility.
Yes, customizable views
for draft, final, etc.
Diagnostic features that
automatically evaluate
completion and status,
including a digital
signature function and
sign off/review
checkbox.
YesT Procedures can be
easily created from
scratch, linked to
templates, or linked to
existing documents (i.e.,
Word, PDF, etc..)
Documents can be easily
created from scratch,
linked to templates, or
linked to existing
documents (i.e., Word,
PDF, etc...). Several
users have expressed
that the product utilizes
verbatum ISO language
and is at times inflexible
with document creation,
resulting in longer format
documents. Greenware
has recently focused
upon increasing flexibility.
Yes, customizable views
for draft, final, etc.
Diagnostic features that
automatically evaluate
completion and status,
including a digital
signature function and
sign off/review checkbox.
Yes, via a record registry Yes, via a record registry
Manager function iensuring proper
controls and archives imaintenance for audits.
previous versions.
Documents are
associated with the
various components of
the EMS and controlled
through specific
security settings.
Yes, all documents are
accessible through a
set of folders with an
unlimited number of
subfolders allowed, with
access controlled
through security
settings.
Yes, aspects (both sign
and non-sign) are
automatically linked to a
relevant series of
worksheets. All
information entered into
the worksheets are
linked to the EMS
manual, including
operational controls and
procedures. Structure
closely resembles
Windows Explorer.
ensuring proper
maintenance for audits.
Yes, aspects (both sign
and non-sign) are
automatically linked to a
relevant series of
worksheets. All
information entered into
the worksheets are linked
to the EMS manual,
including operational
controls and procedures.
Structure closely
resembles Windows
Explorer.
YesTthe mo"dule i includes Tes7linฅedtoTelevanT
all of the templates and implementation steps
examples needed to create of the established plan
procedures, work
instructions, etc...;
however, these
components are based
upon ISO 9000.
Yes, revision control and Yes, via e-mail system
automated document
status updates. Includes a
temporary storage function
for approved but
unreleased documents in
order to give users the
opportunity to train
themselves on these
documents prior to official
release.
Yes, each document Yes
contains a complete,
automatically generated
history and is
automatically archived.
Yes, reference module of Yes, generated docs
current documentation are linked to various
indexed via the creation of components through a
an EMS Policy Manual and central library.
Tier 1 documentation.
Yes, each implementation
step is linked to appropriate
samples and templates
Yes, users can take
advantage of provided
templates, create new
documents from scratch, or
incorporate existing
documents in nearly any
format.
Yes, document manager
creates a list of reviewers,
whom are sent an email
with the document w/ a link
to approve, reject, or edit.
Only released revisions are
available to general staff w/
built in controls for paper
versus electronic
distribution. Only document
managers can access the
advanced document
management functions.
Yes, past revisions and
revision information are all
archived.
Yes, controlled per ISO
requirement and accessible
through an Intranet Index.
Documents can also be
accessed from outside of
Yes, best practice templates
searchable by key word/topic,
including ISO explanations.
Also documents can be
created with any application
software.
Document templates are
provided in off the shelf
Microsoft software and can
be used as is or edited
appropriately. Documents
can be created in any
software format used and
uploaded or linked to
equationASP. Documents
can be grouped so that
related documents are stored
together in folders.
Documents are circulated for
review and approval via
notices that automatically
generate emails to those who
need to review the document.
Reminder and escalation
notices help users complete
the review on-time. Parallel
document approval allows
multiple users to review a
document at the same time.
Approved and rejected votes
are recorded online. System
automatically remembers
who approved the document
from its previous version.
equationASP keeps all
versions of every document
uploaded. Document owners
can access the archive while
other user only access the
current approved versions of
documents. Records of
approval, changes, etc. are
maintained for every version.
The equationASP document
library allows users to browse
the library to locate
documents or search by key
word, document owner,
This product was
developed through
the University of
South Carolina's
Technology
Incubator Program.
The product was
included here due to
the potential ability
to be modified and
adapted to meet Port
specific EMS needs.
The product has a
minimal initial costs
and is currently
being examined for
commercial viability
enhancements. The
product was
originally developed
for the sole purpose
of certifying the
University to ISO
14001.
Yes
jthe system by utilizing a tool Irevision date, document
to generate a URL.
Reference library linked with
ISO Standard descriptions,
document
samples/templates,
PowerPoint Training
Courses, and other tools.
status, and other criteria
about the documents.
-------
ISO 14001 Software Comparison Matrix - Tier 1 Products
Evaluation Criteria
2. Data Compilation and
Report Preparation
Amadeus
Environment Expert
Yes, a report
generator for
extraction,
manipulation, and
presentation of
information related to
the EMS. Graphics
and statistical tool
included.
3. Calendar Management !Yes, implementation
! schedule with target
! dates for activities,
tasks, monitoring and
measuring, etc..
47MiJestohe/fask !Yes7 "tasks ;can i be
Management and Tracking iassigned to
iemployees via an
JEMPtree structure,
5. Regulatory Compliance
Management (non-
conformance notification)
which allows you to
see at a glance what
stage each EMS is at
along with respective
objectives, targets,
and tasks. Each
employee accesses
only the information
relevant to his/her
responsibilities.
6. Gap analysis tool I
Entropy
International Envoy
Yes, users can
instantly generate
both standard and
filtered reports for
single, multiple, or all
sites
Yes, create action
plans and an
implementation
schedule, with
milestones and
task/completion date
reminders.
Yes, individual sites
can be managed with
unique users, system
access, and
responsibilities
defined. Roles and
responsibilities
management tools,
including individual,
team, and site task
lists. Reminder
function for
completion dates and
reviews, including a
report function.
Yes, compliance
management tools
(update
capacity /assistance
unknown) with
automatic non-
con formance plans
and records.
establishing and
maintaining a
register of legislation
and "anticipating the
requirements and
impacts of new
legislation and
standards."
No, not a specific
tool, audit checklist
included
Enviance
Yes. The System has
an ad hoc reporting tool
that allows compilation,
analysis and reporting
of EMS components,
compliance data, and
records of audits,
incidents, accidents,
etc, including process
time dependent
parameters and
graphical display
GreenWare ISO 14000
Implementation
Software
Yes, the product has
many reporting/data
compilation options,
including time/cost (by
individual), status,
training, corrective
action, etc... Exportable
to Microsoft Word or
HTML.
formats.
YesT The System JYesTthe EMS f Calendar
includes a set of iprovides a summary of
calendars organized by jail document due dates,
user and by EMS tasks and actions,
component w/ Email including key monitoring
reminders of scheduled and document review
actions or milestones dates. Automatic email
including a direct link to responsibility
the task completion notifications and links to
page. relevant documents.
Yesjhe i System's Task ^lYesreachuser will have
Manager allows Ian individual calendar
individual and/or group Nisting tasks, activities,
task assignments. idue dates, etc... Email
Reminders and
escalators are standard
and are delivered via
email with a link to the
task completion page.
Tasks are shown in
calendars with
completion information
linked to report
functions.
Yes. The System
includes automatic data
warnings, tasks, follow
up (missed deadline or
parameter
exceedance), and
emails to facilitate
regulatory compliance.
classification of the non-
con formance into
predefined categories
such as "Reportable",
"Permit Compliance
Deviation", "Exempt",
etc. Regulatory tracking
is also connected to
report functions.
notification functions
must be manually
imputted and are not
automatic.
Yes, legal and other
requirements are linked
to relevant aspect
worksheets, which is
linked to a CD, website,
or other source of
information. Legal and
Other worksheet
responsibility, review
date, and future review
dates.
Yes, the System iYes, clause-by-clause
includes a predefined igap analysis
report of gaps in the
EMS.
GreenWare ISO 14000
Software Suite
Yes, the product has
many reporting/data
compilation options,
including time/cost (by
individual), status,
training, corrective action,
etc... Exportable to
Microsoft Word or HTML.
Yes,The i EMS Calendar
provides a summary of all
document due dates,
tasks and actions,
including key monitoring
and document review
dates. Automatic email
responsibility notifications
and links to relevant
documents.
Yes,"each user will have
an individual calendar
listing tasks, activities,
due dates, etc... Email
notification functions
must be manually
imputted and are not
automatic.
Yes, legal and other
requirements are linked to
relevant aspect
worksheets, which is
linked to a CD, website,
or other source of
information. Legal and
Other worksheet includes
review date, and future
review dates.
Yes, clause- by-clause
gap analysis
IBS America QSI System
for Environmental
Management
Yes, real-time reporting
and analysis
Yes "via "an i email
escalation function. Not
clear whether the product
has the ability to develop a
project implementation
plan.
Yes," includes Tan
escalation function to alert
management of missed
deadlines with message
automatically generated
and distributed by
modules. The product
maintains a record of all
escalation mail messages
for review.
Yes, legal register which
must be populated by the
user with all current
environmental regulatory
information.
Yes, internal assessment
tools for gap analyses
and/or internal audits
Integrum ISOft 14000
Intelex ISOsoft 14001
Yes, Ad Hoc Reporting iYes, including compliance
tool to create reports
and charts from data
contained within
Integrum and other
data sources.
Yes7linkedto"to"do"
lists and responsibility
(including regulatory)
notification function.
Yes, automatic
notifications and task
reminders (via email),
including a notification
calendar and schedule
Yes, all applicable
requirements must be
populated and updated
by the user. Software
includes a hot-spot link
tool for updates, allows
electronic documents
(i.e. permits) to be
system, and critical
dates can be entered
into the calendar for
personnel reminders.
Yes ISO Navigator tool
for users, readers, and
auditors
(and cost of compliance),
significant aspect,
monitoring and
measurement activities, and
general EMS progress
reports.
Yes, including a custom
implementation plan that
creates a step-by-step
process for implementation
with progress measures anc
milestones.
es7 automatic email
otification with direct link to
ctivity and relevant
ocuments and customized
ask menu" specific to each
ser. Notification is
scalated if task is overdue
r pending for a specified
mount of time. Operational
quipment maintenance
ctivities may also be
tracked via email
notification.
Yes, complete management
system ensures compliance
to fed, state, and municipal
regulations AND other
requirements (non-
regulatory), but the client is
responsible for identifying
all applicable regulations.
pTnsfor^mftrompTm
Manages the review,
update, and implementation
of requirements and tracks
associated reporting
requirements. Compliance
status is displayed through
a graphical "Dashboard" by
facility, division and
department, or organization-
wide. Ability to feed in
outside update services
drectly into the EMS
software.
"EMS Status" tool that
provides an instant
assessment of EMS
conformance. Manager's
Dashboard allows and
instantaneous "snapshot" of
the EMS with green and red
checks to show status.
Prism Equation ZMH* EMS-EZ
All areas of equationASP
offer automatic and
customizable reports that
show document, corrective
action, internal audit, survey,
and data collection
information. Reports can be
viewed on-line, printed,
downloaded to Microsoft
Excel, and sent to other users
as notices /emails.
ThT"p7o]ectฅaFagemeht
function provides a pre-
defined EMS implementation
plan that is customizable for
use at the client. The Project
Management system
schedules all EMS
implementation tasks,
assigns to teams, and notifies
users when action items are
due.
"f he "Project Management
function automatically
records the completion of
tasks and provides a variety
of project status reports that
show implementation in
Gantt chart form and in terms
of on-time vs. late and
percent complete.
equationASP offers tools and
worksheets to identify,
record, and track legal and
other requirements related to
the organization. The
Improvement System offers
ability to enter, administer,
assign, and complete
the EMS and notifies all
relevant functions.
equationASP includes a Gap
Analysis tool and worksheet
to assist in conducting a
baselines assessment of the
organization and its current
status and readiness for an
EMS implementation.
-------
ISO 14001 Software Comparison Matrix - Tier 1 Products
Evaluation Criteria
7. Aspect/Impact Analysis
Tools
Amadeus
Environment Expert
Yes, software follows
the format of aspect
identification via
activities, O'sT's, and
establishment of
EM Ps. Performance
follow-ups and
establishment of
monitoring and
measurement
activities. Each aspect
connected directly
with relevant legal and
other requirements,
objectives, training,
ietc...
8. Audit Tools JYes, Audit Module
jorganizes an audit
9. Training Management
schedule enabling the
assignment of
appropriate resources.
Integratable with a
CAR Module and an
Action Module, which
is connected directly
to the personnel
responsible.
^Ye^lbJlityloTderiti^
training needs and
management traininig
activities for personnel
with environmentally-
sensitive tasks.
1 0. Context-specific ISO INot specifically based
Text lupon ISO 14001.
hncludes all the
jelements, but no
preference to the
istandard.
11. Multi-lingual
Yes, each user can
work in his/her own
language
Entropy
International Envoy
Yes, including audit
checklists
Yes, training needs
analysis and
management
Enviance
Yes, the System
includes a means to
identify, rank, prioritize
and re-evaluate
environmental impacts.
Reporting allows
GreenWare ISO 14000
Implementation
Software
Yes, each identified
aspect is manually
linked (via checkbox
function) to applicable
ISO requirements,
documents, reference
links, and activities.
Yes, the System JNo
includes predefined I
questions that guide an
audit. This pertains to
both the development
of the EMS and
regulatory compliance
audits. Audit findings
are tracked to closure
through automatically
created and assigned
tasks. Continuous
improvement can be
evaluated through
summary reports D6
Yes, the System has a
tracking function
allowing training
schedules, automatic
attendance reminders,
and training records by
subject matter,
location, or individual.
Yes, a training
worksheet for general
and specific training
management. Allows a
training plan to be
developed for each
aspect. Does not include
automatic training
notifications.
The product supports Yes. EMS components !Yes, interative
all activities in the
process of
implementing and
maintaining a
managementsystem
certifiable to ISO
14001.
include ISO specific iworksheets address
text. leach individual element
System does not
currently include
languages other than
English. Enviance has
provided estimates to
clients for inclusion of
multiple languages in
the software package.
of the ISO 14001
standard.
GreenWare ISO 14000
Software Suite
Yes, each identified
aspect is manually linked
(via checkbox function) to
applicable ISO
requirements, documents,
reference links, and
activities.
Yes, ISO 14000 Audit
Software for internal and
external auditors and ISO
14000 Audit Pro, which
includes a set of fully
customizable audit
protocols, controls and
tests, and linked audit
report function. Includes
graphical representation
and percentage of
conformance.
Yes, a training worksheet
for general and specific
training management.
Allows a training plan to
be developed for each
aspect. Does not include
automatic training
notifications.
Yes, interative
worksheets address each
individual element of the
ISO 14001 standard.
IBS America QSI System
for Environmental
Management
Yes, an EMS Aspects
Register.
Yes, internal assessment
tools for gap analyses
and/or internal audits. The
original ISO 9000- focused
product includes a
comprehensive audit and
corrective action module,
but is it unclear whether a
similar structure currently
exists for the ISO 14000
product.
Yes, the product is
designed to plan, track,
and record the training of
employees.
Training and
implementation services
offered in English,
Spanish, and French
Integrum ISOft 14000 \ Intelex ISOsoft 14001
JYes, an Env. Aspects and
jlmpacts Module steps users
jthrough the identification
land ranking. The first step is
jidentifying Activities,
I Products, and Services
j(APSs). User-defined
| scoring criteria. Automatic
jlinks between ASPs,
| aspects/impacts, and
^relevant management
I components, and
Subsequently O'sT's and
| EM Ps.
Yes, including an I Yes, via NCR & C/PAR
archived Audit Trail. jforms and management
jtools linked with a complete
jAudit module.
Yes, a training |Yes, via email notifications
database linked to land personalized "my
activities, projects, draining" calendar. Training
tasks, etc. Notifications |"work groups" to target
and training records jemployees with similar
included. Draining requirements. The
Preference library includes
j PowerPoint Training
jCourses and other tools to
lassistwith implementation.
Yes JEach step of the
^implementation project plan
Ms linked to the ISOsoft
preference library and
iincludes in- depth
jdescriptions ofthe ISO
114001 requirements.
iSummarizes conformance
jto all requirements through
la real-time, graphical
!"Dashboard". Terms can be
jmodifiedtofitthe
| organization.
iYes, PC-based systems are
(available in Portuguese,
iMandarin Chinese, German,
iSpanish, Italian, and
! English. Web- based system
I'm French and English w/ a
I Spanish version under
| development.
Prism Equation ZMH* EMS-EZ
equationASP includes
guidance, explanation, tools,
and worksheets for
identifying, recording,
evaluating, and scoring
aspects and impacts up front
and for the long term.
equationASP includes an
Internal Audit system to
schedule all EMS audits,
assign them to auditors, plan
and prepare standard and
customized checklists, enter
audit reports, and generate
corrective actions related to
the audits.
equationASP includes web-
based training courses that
teach users about the EMS in
introductory and intermediate
levels of detail. The system
automatically records those
users who have taken and
completed the courses.
equationASP also offers the
ability to send Training
Notices to staff when they
require training on the EMS
and its documentation.
equationASP breaks the ISO Compliant w/ ISO
standard into manageable 14001
chunks of information and
provides easy to read and
understand explanation ofthe
requirements. The ISO
standard is linked to the
topics that need to be
addressed throughout the
EMS.
-------
ISO 14001 Software Comparison Matrix - Tier 1 Products
Evaluation Criteria
Amadeus
Environment Expert
Entropy
International Envoy
Enviance
GreenWare ISO 14000
Implementation
Software
GreenWare ISO 1 4000
Software Suite
IBS America QSI System
for Environmental Integrum ISOft 14000
Management
Intelex ISOsoft 14001
! Prism Equation
ZMH* EMS-EZ
Applicability
1 . Ports
2. Public Entities (general)
Port of Houston
Authority
Universities, large
government offices,
railway system, and
District Council
Yes. The System
addresses EMS,
compliance
management,
reporting, auditing and
training needs of ports.
Yes. The System
addresses EMS,
compliance
management,
reporting, auditing and
training needs of
various public entities.
Current ly, the System
is used by Universities,
Federal DOE research
labs, The National
Institutes of health,
United States Coast
Guard, United States
Navy, the National
Institute of Standards
and Technology, and a
county sanitation
district.
14 local gov clients
listed, including cities,
counties, and an airport
authority, as well as 40
EPA sites.
14 local gov clients listed,
including cities, counties,
and an airport authority,
as well as 40 EPA sites.
Yes, non-US
A couple of utilities on the No public entity clients
client list, mostly currently. Provided live
industry /manufacturing demos to US Army and
PA DOT which were
well received, but still
under evaluation.
CityofScottsdale, Waterloo
Waste Management facility
(1stinN.A. ISO registered),
York Region Water and
Wastewater departments
(also 1st in N.A.), and
others. City of
Charlottesville and Rivanna
Sewer and Water Authority
(pending).
iDoD including Army
I operations & Chemical
iMaterials Agency,
i Department of Homeland
ISecurity, and others.
Integrated System
1. Health and Safety
2." Quality Control
Yes, as an
integratable module
!____
i integratable module
Yes, as an
integratable module
Yes, as an
integratable module
Yes. The System can
be integrated with
Health and Safety data
management systems.
The System can also
be configured to track
safety incidents and
produce safety
Yesi;tfheSy^erncan
be integrated with
quality control data
management systems.
No
No
No
No"
No Safety statistics and
linked to CAR.
Software complys with
British, Australian, and
ISO safety
management
standards.
YesroSJ bfigihaiiy focused Yฎs
upon ISO 9000 Support
and leveraged existing
products.
Yes, via available module
YesT via available module
;Yes
!Yes7 including i ISO 90017 ISO
1 17025, and others (Lean
I Manufacturing, Continuity of
i Operations Planning).
Yes, the product also
integrates
occupational health
and safety concerns
into the overall
management
system.
System Architecture
1. Client Server
Solution/Stand-alone PC
2TWeb-enabJed/Hosted by
Provider (ASP)
3." Database
4. Client Operating System
5. Security
67SecuHty Features/MuJti-
level Access/Authority
iYes
IWeb-enableS
Nmplementable in
multiple sites.
Available Option;
additional client
server requirements
Available "Option,"
annual subscription
Yes." "t" he i System ils
developed and hosted
by Enviance, Inc. and
can be installed behind
the customer's firewall
and hosted internally.
Available option
Avaiiabie option^
$1000/site/unlimited
users
Available option
Available "option^
$1000/site/unlimited
users
"Microsoft SQL ServefSQl 2000 I
Microsoft Office
JYes
iYes, the Document
iManagement module
igrants access only to
ithe information
necessary for an
individual employee or
defined group.
7, 2000, or Oracle 8i
Windows NT4, 2000,
Me, 98, or 95;
Internet Explorer 5.0
or higher
Yes
Yes, individual user
access and privilege
controls
Internet Explorer. No
software or hardware
purchase is needed.
Yes. Each command
and response is fully
encrypted using Secure
Socket Layer (SSL) 128
bit technology.
Yes. Various
authorization levels are
included for both users
and groups.
Authorizations and
permissions can be set
at the individual EMS
component/data
element level, if
desired.
Windows 95, NT, or
Higher
Yes
Yes, user right settings
and controlled access to
the system w/ several
levels of user controls
including "read only".
Windows 95, NT, or
Higher
Yes
Yes, user right settings
and controlled access to
the system w/ several
levels of user controls
including "read only".
Available Available
Avaiiable optior,7can "Available "option^
include remote compliance annual server and
management software maintenance
fee.
Oracie7DB27Lotus ;Notes7 Totus Notes
SQLServer, ODBC, et...
Windows Microsoft Windows,
preferably NT or 2000+
Yes ~Yes7rnulti- level
encrypted code
security
Yes ~Yes7rnulti- level
encrypted code
security, including
selective information
distribution to
contractors, suppliers,
and the public.
Yes, can be hosted on
internal servers via a single
installation.
Avaiiable
Oracle and SOircan be
integrated with other
existing databases.
Microsoft NT and Windows
2000 IIS Server 4 or 5; all
major Web Browsers.
Log-in name/password
(multi-level access/abilities)
Yes, inciuding "ieveis of
viewing authority" and
customized security group
settings. These functions
are fully controlled and
applied by the system
administrator. Access and
data management may be
based upon an
organization's structural
hierarchies.
iYes, equationNET can be
i licensed and installed on
! client servers.
!Yes7 equation ASP '"hosted I by
iPrism and accessed via
iinternet and web browser.
iMicrosoft SQL "or" Oracle ""a"
iWindows 95 or higher.
iFirewaO, VeriSign encryption,
iuser name / password
IAN areas of equationASP
^including documents,
icorrective actions, audits,
land other data can be made
iaccessibleto all user or
isecurity can be applied to
idesignate which users have
laccessto different
Idocuments and functions.
Yes
No
Windows 98/ME/XP
and MS Office
-------
ISO 14001 Software Comparison Matrix - Tier 1 Products
Evaluation Criteria
Amadeus Entropy
Environment Expert International Envoy
Enviance
GreenWare ISO 14000
Implementation
Software
GreenWare ISO 14000
Software Suite
IBS America QSI System
for Environmental
Management
Integrum ISOft 14000
Intelex ISOsoft 14001
Prism Equation
ZMH* EMS-EZ
Cost
Note: Costs are dependent
upon the specific needs of
individual clients, as the
majority of products are
scalable in several
variables. This
assessment has attempted
to provide a "ballpark"
comparison.
1. Single Desktop License
2. Training
3. Product Support
Client may select
requisite modules and
pay only for them.
solutions delivered
via the Internet
Yes, support and
upgrades. Additional
price?
Pricing i available Tupon
request by calling 1-866
Enviance
First day included in
license. Additional
daysat$1,200/day for
up to 10 participants.
Yes. Included in
license cost.
$17399 ($700/user 2-9)
($350/user 10+)
$2^479 ($1^239/user 2-9)
($61 9/user 1 0+)
1-day $250/participant; 2-1-day S250; 2-day $350;
day $350/partici pant
25%
Auditor training $350 (All
per participant)
Contact was unable to"
provide cost information,
since their systems are
customized to fit the needs
of individual clients.
Includes a EMS Advisor
module that offers
guidance for development,
implementation, and
checking of the EMS.
Various training options
available.
25%!Yes, via annual
maintenance contract.
Telephone support M-F,
access to technical
website 24 hours per day.
$995
On-line training
database available
24hrs/day at $245/user
Yes, product support
(email and phone) and
upgrades are included
in the annual support
foe.
Price varies from ap"prox:
$2,000 up. Product is
purchased by individual
module with the full package
(quality, safety /health, etc..)
approximately $8,000.
Product is customized for
client organization structure.
Intelex provides a
Installation and
Administration Guide and
the ISOsoft User Manual.
Additional training may be
customized and provided for
an extra cost.
Annual support and
maintenance contract,
utilizing mutually agreed
upon issue severity levels.
TypTcaT format is annual
subscription for designated
number of staff/users, price
starts at $5k annually for up
to 15 users and increases
incrementally for additional
blocks of users with the price
per user going down as more
users are added.
equationASP includes web-
based training courses that
teach users how to use the
system. Live training can be
provided on-site and/or
remotely via on-line meetings
and phone and can be
provided in daily or hourly
formats. Most users only
need a few hours of training
to use the system effectively.
Phone and email customer
support, on-line Help system,
and quarterly upgrades, are
included in subscription /
license fees.
$617/Jicense
No
No
Additional Information
1 . Website Address
2. Available Demo
3. Location of Headquarters
Special Notes
http://amadeus- http://www.entropv-
csi.com/solutions/eQ international.com/ho
mental-
manaqement.asp
Yes, via Yes
Internet/phone combo.
Regularly scheduled
public demos every
Europe and Canada UK
com
Yes. With
teleconference and via
web.
Carlsbad, CA
Based upon Plan-Do-
Check-Act model
with a very similar
breakdown of
activities asGETF's
model.
Cost includes product
upgrades which are
delivered seamlessly
with no actions required
by customer. Enviance
is used by numerous
public entities and
industrial customers.
Annual user conference
is held.
httrj://areenware.ca/soft
ware/iso2.html
Yes, self-guided
Berkeley, CAand
Toronto, Ontario
httrj://areenware.ca/softw
are/iso2.html
Yes, self-guided
Berkeley, CA and
Toronto, Ontario
httrj://www. aualitvsvs.com/
website/website. nsf/0/8c66
deb4c9e6fe7d852568c100
53eaOa?Orjen Document
Available, including a free
analysis of an
organization's software
needs.
Lexington, MA
httrj://www.isoft14000.c
Dm/display. asp ?paqe I
D=2
Yes, online w/
conference call
Australian product,
Trinity Consultants is a
North American
(Dallas, TX) reseller
httrj://www. intelex.com/isoso
ft14001index.htm
Yes, via web conference.
Toronto, Ontario
www.or smeso ut ons.com
Yes, on-line at
www.pr smeso utions.com or
guided demos upon request.
King of Prussia, PA 888-
386-2330
httrj://incubator.rese
arch.sc.edu/
Columbia, SC
Utilized by a Muni II
participant (Tri-Met) and
recently purchased by
Muni III participants
(Kent County and Metro
Waste)
Utilized by a Muni II
participant (Tri-Met) and
recently purchased by
Muni III participants (Kent
County and Metro Waste)
The product has been
used by single site
operations to large
corporations; however,
a desktop product
called ISOmate is also
available with
essentially the same
functionality.
Utilized by a Muni I
Participant (Scottsdale),
very good/responsive
product support. Easy to
navigate, Manager's
Dashboard very useful for
EMR.
Call Mike Reeve at
603-763-4791 or email at
mreeve@prismesolutions.co
m.
Created through the
University of South
Carolina Columbia
Technology
Incubator (USCTI)
business incubator
program.
-------
EMS SUPPLEMENTAL TOOLBOX
COMPLIANCE CHECKLIST
City ofGastonia WWTP - Compliance Sampling/Evaluation Checklist
-------
COMPLIANCE SAMPLING/EVALUATION INSPECTION
WWTP: PERMIT NO.
INSPECTORS:
PERSONS INTERVIEWED:
DATE:
ENTER TIME:
PERMIT:
VERIFY NAME OF PERMITTEE, ADDRESS, TITLE, PHONE NUMBER YES Q NO
COMPARE FACILITY DESCRIPTION WITH ACTUAL YES D NO
ARE ALL PROCESS UNITS BEING OPERATED? YES D NO
DOES PERMIT EXPIRE SOON? YES Q NO
EXPIRATION DATE:
ORC:
IS CERTIFICATION OF ORC ADEQUATE? YES Q NO
IS ORC VISITING FACILITY AS REQUIRED? YES Q NO
WHO IS DESIGNATED BACK-UP?
RECORDS /REPORTS:
ARE SELF-MONITORING RECORDS MAINTAINED ON SITE AND
AVAILABLE? YES Q NO
DISCREPANCIES? YES Q NO
IS ORC LOG MAINTAINED? YES D NO
ARE WHO, WHAT, WHERE, WHEN OF SAMPLING LISTED IN LOG? YES Q NO
Form#: EMS-0101.009A- - 1 Corresponding Procedure : EMS-0100.009A
Revision #: 3
Revision Date: 12/31/02
Effective Date: 4/19/01
-------
ARE INSTRUMENT CALIBRATION RECORDS MAINTAINED? YES
ARE PH METERS CALIBRATED DAILY? YES
ARE 3 BUFFERS USED? YES
IS SLOPE LISTED? YES
ARE BUFFERS DATED WHEN REC'D? YES
ARE BUFFERS DATED WHEN OPENED? YES
ARE DO METERS CALIBRATED DAILY? YES
IS CL TITRATOR CALIBRATED DAILY? YES
ARE ALL THERMOMETERS AND METERS CALIBRATED BY A
NIST TRACEABLE CERTIFIED THERMOMETER?
PH METER THERMOMETER? YES
INFLUENT COMPOSITE SAMPLER ? YES
TEMPERATURE: LAST CALIBRATION DATE:
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
EFFLUENT COMPOSITE SAMPLER?
TEMPERATURE: LAST CALIBRATION DATE:
YES
NO
ARE MAINTENANCE RECORDS KEPT?
YES
NO
FACILITY SITE REVIEW:
EVALUATE PROCESS UNITS.
EVERYTHING OPERATING PROPERLY?
YES
NO
Form#: EMS-0101.009A-
Revision #: 3
Revision Date: 12/31/02
Effective Date: 4/19/01
Corresponding Procedure : EMS-0100.009A
-------
SYMPTOMS THAT SUGGEST PROBLEMS:
SITE WELL MAINTAINED: YES Q NO
GRASS MOWED, ACCESS ROAD MAINTAINED? YES Q NO
DISCUSS ANY SLUDGE WASTING:
ARE CHEMICALS / OPERATING PROC. USED AS "BANDAID"
SOLUTIONS OR TO ENHANCE TREATMENT? YES D NO
EXPLAIN:
ARE SCREENINGS / GRIT CONTAINED AND DISPOSED OF? YES Q NO
WHERE DISPOSED?
IS ROUTINE MAINENANCE APPARENT? YES D NO
FLOW MEASUREMENT:
IS MEASURMENT METHOD CONSISTENT WITH PERMIT
REQUIREMENTS? YES Q NO
IS A NON-CALIBRATED FLOW MEASURING DEVICE USED? YES Q NO
IF RECORDING FLOW METER IS USED, IS RECORDER WORKING? YES Q NO
DETERMINE FREQUENCY OF CALIBRATION AND BY WHOM:
IS COMPOSITE SAMPLER FLOW PROPORTIONAL? YES Q NO
LABORATORY:
ANY ANALYTICAL TEST PERFORMED REQUIRING CERTIFICATION? YES Q NO
ANY PARAMETERS CONTRACTED OUT? YES D NO
Form#: EMS-0101.009A- - 3 Corresponding Procedure : EMS-0100.009A
Revision #: 3
Revision Date: 12/31/02
Effective Date: 4/19/01
-------
LIST:
LAB CERTIFICATION NUMBERS AND EXPIRATION DATES:
SPOT CHECK INSTRUMENT / EQUIPMENT CALIBRATION AND RECORDS:
pH Meters CD
Thermometer Calibration \~\
EFFLUENT7RECEIVING WATERS:
IMPACT OF EFFLUENT ON RECEIVING STREAM:
DOES EFFLUENT HAVE VISIBLE SOLIDS? YES Q NO
FOAMY OR HIGHLY COLORED? YES Q NO
IS UPSTREAM CLEAR? YES Q NO
HOW FAR DOWNSTREAM DOES MIXING OCCUR?
ARE UPSTREAM AND DOWNSTREAM COLLECTIONS CORRECT? YES D NO
COMPLIANCE SCHEDULES:
IS FACILITY OPERATING UNDER SOC/JOC? YES Q NO
WHICH PARAMETERS ARE AFFECTED BY INTERIM LIMITS?
DISCUSS VIOLATIONS OF SOC/JOC SCHEDULED ACTIVITIES:
Form#: EMS-0101.009A- - 4 Corresponding Procedure : EMS-0100.009A
Revision #: 3
Revision Date: 12/31/02
Effective Date: 4/19/01
-------
SELF-MONITORING PROGRAMS:
IDENTIFY NONCOMPLIANCE WITH PERMIT/SOC/JOC LIMITS:
ANY NOVS RECEIVED? YES D NO
ARE MONITORING FREQUENCIES MAINTAINED? YES D NO
ARE DMR'S CORRECTLY COMPLETED? YES Q NO
REVIEW SAMPLE COLLECTION, PRESERVATION, TRANSPORTATION:
ARE HOLDING TIMES CORRECT (6 HOUR FECAL) YES D NO
IF MONITORING IS PERFORMED AT A GREATER THAN REQUIRED
FREQUENCY, IS ALL DATA REPORTED? YES Q NO
OPERA TIONS AND MAINTENANCE:
ESTABLISHED PREVENTATIVE/CORRECTIVE MAINTENANCE YES Q NO
PROGRAM?
IS STAFFING ADEQUATE? YES Q NO
ESTABLISHED PROCESS CONTROL PROGRAM? YES Q NO
ARE ALL SAMPLE JUGS AND BOTTLES CLEANED DAILY? YES D NO
ARE SAMPLES PRESERVED APPROPRIATELY? YES D NO
Form#: EMS-0101.009A- - 5 Corresponding Procedure : EMS-0100.009A
Revision #: 3
Revision Date: 12/31/02
Effective Date: 4/19/01
-------
SLUDGE DISPOSAL:
INVESTIGATE SLUDGE HANDLING AND DISPOSAL, INCLUDING SITE
OF ULTIMATE DISPOSAL.
ARE ANY PERMITS REQUIRED? YES Q NO
DO THEY HAVE THEM? YES D NO
IS ANY MONITORING REQUIRED? YES D NO
ANNUAL REPORTS REQUIRED? YES Q NO
IS DIVISION RECEIVING THEM? YES Q NO
SITE OF DISPOSAL CONSISTENT WITH PERMIT? YES Q NO
OTHER QUESTIONS /NOTES:
Form#: EMS-0101.009A- - 6 Corresponding Procedure : EMS-0100.009A
Revision #: 3
Revision Date: 12/31/02
Effective Date: 4/19/01
-------
EMS SUPPLEMENTAL TOOLBOX
TRAINING
City ofGastonia WWTP - EMS Training Matrix (partial)
City of San Diego WWC-EMS Training Matrix
City of San Diego WWC - Safety and Training Report Template
-------
Training Matrix for EMS Management Procedures
Controlled Version on Computer U: Drive - All printed copies are uncontrolled
EMS Chart #: EMS-0102.005B
Format Revision #: 2
Date Format Updated: 8/4/03
Date Printed: 8/20/2004
Crowders Creek Laboratory Procedures
Document Title
Chemical Hygiene Plan
Quality Assurance Manual
Laboratory Checks and Calibrations
Washing and Preparation of Glassware and Bottles
Sample Bottle Preparation & Allocation
Data Verification
Mercury Spill Clean Up Procedure
Inorganic Acid & Base Spill Clean Up Procedure
Laboratory Waste Chemical Storage/Disaposal
Sample Receiving
Switching Temperature Control Units on
Environmental Rooms at Crowders Laboratory
Procedures for Changing Set-point - Room Too
Warm
Procedures for Changing Set-point - Room Too Cold
Weekend Work Scheduling for Laboratory
Technicians
Microscopic Observation
Conductivity Analysis- Orion Conductivity Meter
Model 128
Alkalinity Analysis
Ammonia-Nitrogen Analysis
Ammonia-Nitrogen Analysis by Orion 720A Meter
Ammonia Nitrogen Distillation Method
Automated Biochemical Oxygen Demand Analysis
Biochemical Oxygen Demand Analysis - Manual
Method
Chemical Oxygen Demand Analysis
Chemical Oxygen Demand Analysis (Using
Shimadzu Spectrophotometer)
Total Cyanide Analysis
Fecal Coliform Analysis
Metals Analysis by ICP-MS
Mercury Analysis - Water Bath Digestion Method
Mercury Analysis - Hot Block Digestion Method
Document #
WCR-0100.100
WCR-0100.102
WCR-0100.103
WCR-0100.104
WCR-0100.105
WCR-0100.106
WCR-0100.108
WCR-0100.109
WCR-0100.110
WCR-0100.111
WCR-0100.112
WCR-0100.112A
WCR-0100.112B
WCR-0100.113
WCR-0100.114
WCR-0100.118
WCR-0100.121
WCR-0100.122
WCR-0100.122A
WCR-0100.123
WCR-0100.124A
WCR-0100.124B
WCR-0100.125
WCR-0100.125B
WCR-0100.127
WCR-0100.128
WCR-0100.130
WCR-0100.131
WCR-0100.131A
Rev
3
5
4
3
7
4
1
1
3
6
5
4
4
1
1
1
3
8
3
5
5
2
3
3
0
10
5
5
3
Revision
Date
05/20/02
10/21/03
06/09/03
09/27/02
10/21/03
03/12/04
02/21/01
02/21/01
07/10/01
10/21/03
02/12/03
02/12/03
02/12/03
05/18/01
04/15/03
04/09/03
02/03/03
10/21/03
10/21/03
10/21/03
09/24/03
01/22/03
05/13/03
05/14/03
04/07/03
02/25/04
12/05/03
02/21/03
02/21/03
Steve Oakley
D)
C
C
ro
I-
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
0> C
C C
C C
C C
C C
C C
C
-------
Training Matrix for EMS Management Procedures
Controlled Version on Computer U: Drive - All printed copies are uncontrolled
EMS Chart #: EMS-0102.005B
Format Revision #: 2
Date Format Updated: 8/4/03
Date Printed: 8/20/2004
Crowders Creek Laboratory Procedures
Document Title
Metals Hot Block Digestion Procedure
Metals Microwave Digestion Procedure
Nitrates Analysis
Nitrate & Nitrite Analysis - FIAS Method
pH Analysis
Ortho Phosphorus
Total Phosphorus Analysis
Residual Chlorine Analysis
40 Day Vector Attraction Analysis
Solids - % Total Solids/% Total Volatile Solids
Analysis
Solids - Total Solids/Total Volatile Solids Analysis
Total Suspended/Total Volatile Suspended Solids
Analysis
Total Kjeldahl Nitrogen Analysis
Volatile Acids Analysis
ADMI Color Analysis
Clean Hood Operation
Document #
WCR-0100.132
WCR-0100.133
WCR-0100.134
WCR-0100.136
WCR-0100.137
WCR-0100.138
WCR-0100.139
WCR-0100.140
WCR-0100.141
WCR-0100.143
WCR-0100.144
WCR-0100.145
WCR-0100.146
WCR-0100.147
WCR-0100.150
WCR-0100.153
Rev
2
2
3
0
4
5
8
5
3
6
4
5
5
3
8
3
Revision
Date
11/13/02
12/05/03
11/06/01
11/26/02
12/31/02
02/20/03
02/19/03
02/19/03
08/04/03
08/04/03
08/04/03
09/18/03
12/31/03
02/03/03
02/20/03
11/14/01
Steve Oakley
D)
C
C
ro
I-
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
0> C
C C
C C
C
-------
Figure 2
Wastewater Collection Occupational Catergories
wwc
WASTEWATER COLLECTION
OCCUPATIONAL
CATEGORIES
Revision April 2003
MWWD Course Numbers
New TIMS Occupational Categories
TRAINING HOURS
FREQUENCY
Administration - Non-Supervisory
Administration - Supervisory
Equipment Operation, W/O Confined Space
Equipment Operation, W7 Confined Space
Equipment Technician I, II, III W/Confined Space
Equipment Technician 1,11, III W/O Confined Space
Engineering - Non-Supervisory (FEWD)
Engineering - Supervisory (FEWD)
Engineering - Non-Supervisory (Non-FEWD)
Engineering -Supervisory (Non-FEWD)
Plant Process Control Electrician W/Conf. Space
Plant Process Contr. Electrician W/O Conf. Space
Plant Process Control - Supervisory
Utilities - Non-Supervisory W7 Confined Space
Utilities - Non-Supervisory W7 Confined Space (NROW)
Utilities - Non-Supervisory W/O Confined Space
Utilities - Non-Supervisory W/O Confined Space (NROV ML
Utilities - Supervisory W7 Confined Space
Utilities - Supervisory W/O Confined Space
Frequency
0 = One Time Training
5 = Repeat every 5 years
Environmental Management Plan
MWWD WWC Division
June 2003
Revision 1
-------
SAFETY AND TRAINING REPORT
*TAILGATE
DATE OF TRAINING
LOCATION
PTL PS1 PS2 PS64 PS65 PENA EMG DRISC
SAFETY TOPIC PRESENTED
REFERENCE MATERIAL USED IN PREPARATION FOR THIS PRESENTATION :_
INSTRUCTOR EMP ID#:
Name of each person in attendance
LAST NAME (PRINT)
SIGNATURE
EMP ID#
LAST NAME (PRINT)
SIGNATURE
EMP ID#
;ELAPSED TIME OF PRESENTATION NUMBER IN ATTENDANCE TOTAL TRAINING HOURS
X
IMPORTANT: ORIGINAL - DEPARTMENT TRAINING SUPERVISOR, MS 901A/MOC 2
COPY - RETAINED BY SENIOR SUPERVISOR SUBJECT TO CAL-OSHA AUDIT
DD-SEOP 4.4.2
Environmental Training
MWWD WWC Division
EHS-F-TR003.0
June 03
Revl
-------
EMS SUPPLEMENTAL TOOLBOX
EMS INTERNAL A UDIT
CityofGastonia WWTP - Internal EMS Audit Checklist
City ofGastonia WWTP - Internal EMS Audit Plan Worksheet
CityofGastonia WWTP - Internal EMS Audit Report Template
-------
Public Works and Utilities Department
Internal EMS Audit
Checklist
Audited Section:
Division:
Scheduled Audit Date:
Audit Location:
Lead Auditor:
Auditors:
Auditors in Training:
Pre-Audit Planning Meeting
Date:
Attendees:
Time:
Location:
Comments
Pre-Audit Talk with Section Supervisor
Supervisor:
Date:
Comments:
Time:
Audit
Start Date:
Finish Date:
Comments:
C/PARs Generated
By:
C/PARs #s:
Date:
Comments:
C/PARs Returned
Date:
Written by:
Comments:
Report Completed
Date:
Written by:
Comments:
Completed Audit Report given to EMS Coordinator
By:
Date:
Form#: EMS-0101.011E
Effective Date: 2-16-2004
Revision Date: 7-2-2003
Revision #: 2
Record ID #: EMS-0101.01 IE-
Corresponding Procedure: EMS-0100.011
-------
Internal EMS Audit
Audit Plan Worksheet
Scheduled Audit Date: Audit Location:
Auditors:
Primary Procedure/Document? DNo D Yes (If yes, the following information is required.)
Document Name: Owner:
Document ID: Revision #:
Pre-Audit Preparation
Support Documentation Reviewed:
Follow-up Issues from previous audits:
Audit Plan
Positions to Interview:
Item/Issue:
Notes:
Item/Issue:
Notes:
Item/Issue:
Notes:
Form#: EMS-0101.011B Record ID #: EMS-0101.011B- -
Effective Date: 2-14-2001 Corresponding Procedure: EMS-0100.011
Revision Date: 2-14-2001
Revision*: 0 Page 1 of2
-------
Internal EMS Audit
Audit Plan Worksheet
(continued)
Scheduled Audit Date: Audit Location:
Audit Plan
Item/Issue:
Notes:
Item/Issue:
Notes:
Item/Issue:
Notes:
Item/Issue:
Notes:
Item/Issue:
Notes:
Item/Issue:
Notes:
Item/Issue:
Notes:
Item/Issue:
Notes:
Item/Issue:
Notes:
Form#: EMS-0101.011B Record ID #: EMS-0101.011B- -
Effective Date: 2-14-2001 Corresponding Procedure: EMS-0100.011
Revision Date: 2-14-2001
Revision*: 0 Page 2 of 2
-------
ENVIRONMENTAL MANAGEMENT SYSTEM
Internal Audit Report
Audit Date: Section(s) Audited:
Supervisor/Contact:
Auditors:
The following is a detailed internal audit report as required and defined by procedure
EMS-0100.0011 of the City's Environmental Management System.
I. Environmental Policy: D In Conformance D Not in conformance D Not Audited
Findings-C/PAR#s:
Opportunities for Improvements:
Comments:
II. Environmental Aspects: D In Conformance D Not in conformance D Not Audited
Findings-C/PAR#s:
Opportunities for Improvements:
Comments:
III. Critical Control Points: D In Conformance D Not in conformance D Not Audited
Findings-C/PAR#s:
Opportunities for Improvements:
Comments:
IV. Legal &Other Requirements: D In Conformance D Not in conformance D Not Audited
Findings-C/PAR#s:
Opportunities for Improvements:
Comments:
V. Objectives and Targets: D In Conformance D Not in conformance D Not Audited
Findings-C/PAR#s:
Opportunities for Improvements:
Comments:
VI. Structure and Responsibility: D In Conformance D Not in conformance D Not Audited
Findings-C/PAR#s:
Opportunities for Improvements:
Comments:
VII. Training, Awareness, Competence:Din Conformance DNot in conformance DNot Audited
Findings-C/PAR#s:
Opportunities for Improvements:
Comments:
Page I of 3
Effective Date: 4/1/00 Corresponding Procedure: EMS-0100.011
Revision Date: 11/16/03 Form#: EMS-0101.011A- -
Revision #: 4
-------
EMS-lnternal Audit Report
VIM. Communication Programs: D In Conformance D Not in conformance D Not Audited
Findings-C/PAR#s:
Opportunities for Improvements:
Comments:
IX. Public Participation: D In Conformance D Not in conformance D Not Audited
Findings-C/PAR#s:
Opportunities for Improvements:
Comments:
X. EMS Documentation: D In Conformance D Not in conformance D Not Audited
Findings-C/PAR#s:
Opportunities for Improvements:
Comments:
XI. Document Control: D In Conformance D Not in conformance D Not Audited
Findings-C/PAR#s:
Opportunities for Improvements:
Comments:
XII. Operational Control: D In Conformance D Not in conformance D Not Audited
Findings-C/PAR#s:
Opportunities for Improvements:
Comments:
XIII. Emergency Preparedness Response: Din Conformance DNot in conformance DNot Audited
Findings-C/PAR#s:
Opportunities for Improvements:
Comments:
XIV. Monitoring and Measurement: D In Conformance D Not in conformance D Not Audited
Findings-C/PAR#s:
Opportunities for Improvements:
Comments:
XV. Corrective/Preventative Action Program: Din Conformance DNot in conformance DNot
Audited
Findings-C/PAR#s:
Opportunities for Improvements:
Comments:
XVI. Records: D In Conformance D Not in conformance D Not Audited
Findings-C/PAR#s:
Opportunities for Improvements:
Comments:
Page 2
Effective Date: 4/1/00 Corresponding Procedure: EMS-0100.011
Revision Date: 11/16/03 Form#: EMS-0101.011A- -
Revision #: 4
-------
EMS-lnternal Audit Report
XVII. EMS Audit Program: D In Conformance D Not in conformance D Not Audited
Findings-C/PAR#s:
Opportunities for Improvements:
Comments:
XVIII. Biosolids Performance Report: D In Conformance D Not in conformance
D Not Audited
Findings-C/PAR#s:
Opportunities for Improvements:
Comments:
XIX. Management Review-ISO 14001: D In Conformance D Not in conformance D Not Audited
Findings-C/PAR#s:
Opportunities for Improvements:
Comments:
Auditor Signature Date_
Auditor Signature Date_
Auditor Signature Date_
Page 3
Effective Date: 4/1/00 Corresponding Procedure: EMS-0100.011
Revision Date: 11/16/03 Form#: EMS-0101.011A- -
Revision #: 4
-------
Appendix C
Additional Sources of Information
-------
Provided EMS Support to Wastewater Facilities
USEPA
Cal-EPA
Water Environment Federation (WEF)
Association of Metropolitan Sewerage
Agencies (AMSA)
Delaware Department of Natural Resources
and Environmental Control (DNREC)
North Carolina Division of Pollution
Prevention and Environmental Assistance
(NC DPPEA)
North Carolina Department of Environment
and Natural Resources (NC DENR)
North Carolina State University Industrial
Extension Service
(NCSU IBS)
Texas Commission on Environmental
Quality (TCEQ)
Public Agency EMS Group
Registrar Accreditation Board
www.epa.gov and
www.eDa.aov/owm/sectmis.htm
www.calepa.ca.aov/
www.wef.ora/
www.amsa-cleanwater.ora/
www.dnrec.state.de.us/dnrec2000/
www.p2pays.org/ and
www.p2pavs.ora/iso/
www.enr.state.nc.us/
www . ie s .ncsu . edu/
www.tceq.state.tx.us/ and
http://www.tnrcc.state.tx.us/exec/sbea/ems/
This is an informal group of public Oregon agencies that
have, or are interested in, EMS. The group meets
quarterly to share information and discuss EMS practices
and procedures.
http://www.rabnet.com/index.shtml
Wastewater's Favorite Sources of EMS Information
Benchmarking Report: Environmental Management Systems
(http://www.citvofseattle.net/environment/AaendaEMP .htm)
Best Practices Guide: Application of ISO 14000 EMS for Municipalities
(http://www.iie.ora/proarams/enerav/pdfs/Applic%20ISO%2014000%20for%20Municipalities.pdf)
EMS : An Implementation Guide for Small and Medium-Sozed Organizations
(http://www.epa.gov/owmitnet/iso 1400 l/ems200 lfinal.pdf)
EMS: Do They Improve Performance, University of North Carolina, January 2003. (http: //ndems. cas .unc. edu/)
EMS Troubleshooter's Guide for Local Governments (http://www.peercenter.net/troubleshooters.cfm)
Ford Motor Company, ISO 14001 EMS Workbook, June 2000 (http://www.p2pavs.ora/ref/08/07378.htm)
ISO 14001 Answer Book, Dennis Sasseville, 1997
ISO 14001 Environmental Management Systems - Guidance Document, Specialty Technical Publishers
The ISO 14000 Handbook, Edited by Joseph Cascio, ASQ Quality Press
ISO 14001 Standard and related ISO 14000 series documents
Management Systems for Public Utilities Integration Project
(http://www.citvofseattle.net/environment/documents/AnnualReport2000-l.pdf)
Moving Toward Comprehensive Utility Management Systems, Report of Environmental ISO 14001 "PIZZA",
MGMT Alliance Inc. (http://www.mgmt 14k.com/014kpizza.htm)
NBP EMS Guidance Manual (http://biosolids.policy.net/emsauide/manual/)
NSF - ISR Policies for Environmental Management Systems Registration, (http://www.nsf-isr.ora)
TCEQ Environnemental Management System, Interim Evaluation Protocols
(http://www.tnrcc.state.tx.us/exec/sbea/ems/protocols.html)
Don't forget your current organization's O&M Plans and Environmental Policies and Programs as references
and integration opportunities!
-------
Wastewater's Favorite Websites for EMS Information
NC DEPPA (www.p2pays.org)
US EPA (www.epa.gov/owm/iso 14001/index.htm) & http://www.epa.gov/ems/)
US EPA Region IV (http://www.epa.gov/region04/)
PEER Center (http://www.peercenter.net/)
National Biosolids Partnership (http://biosolids.policy.net/)
Kent County EMS Website (http://www.kentcountydpw.com/)
National Database on EMS (http://www.eli.org/isopilots.htm)
Local Government Environmental Assistance Network (LGEAN) Toolbox:
(http://www.lgean.org/html/toolbox.cfm)
Clean Texas (http://www.cleantexas.org)
TCEQ Environmental Management Systems (http://www .tnrcc.state .tx.us/exec/sbea/ems/index.html)
Texas Pollution Prevention Resources (http://www.p2plan.org/)
MGMT Alliances Inc. EMS Homepage (http://www.mgmt 14k.com/)
King County Environmental Links (http: //www .metrokc. gov/environ .htm)
NSF International Strategic Registrations (http://www.nsf-isr.org/)
PEER Center Local Resource Centers (http://www.peercenter.net/resourcecenters/)
In addition, several other organizations offer valuable EMS guidance and information, including, but in
no way limited to, the following:
North Carolina EMS Program (http://www.p2pays.org/iso/)
Multi-State Working Group on EMS (http://www.iwrc.org/mswg/)
National Database on EMS (http://www.eli.org/isopilots.htm)
International Organization for Standardization (ISO) (www.iso.ch)
Registration Accreditation Board (RAB) (www.rabnet.com)
There are also several alternative EMS implementation guidance manuals available:
Continual Improvement in Utility Management: A Framework for Integration
This Guide responds to a defined need within utility management by providing a roadmap showing how a
collective group of management initiatives interrelate and how a utility can best approach integrating them in
the context of a continual improvement management system framework. This Guide was funded through a
cooperative agreement with the U.S. Environmental Protection Agency (EPA), and sponsored by the
Association of Metropolitan Sewerage Agencies (AMSA) and the Water Environment Federation (WEF).
http://www.peercenter.net/ewebeditpro/items/O73F3799.pdf
An Environmental Management System Troubleshooters' Guide for Local Governments
The Environmental Management System (EMS) Troubleshooters' Guide for Local Governments has been
compiled from experiences and lessons learned through various EMS Initiatives for Government Entities. The
practical data and case study material has been extracted from over 23 municipal, state, and local organizations
which implemented EMSs as participants in these initiatives. The document is structured to systematically lead
a facility, by addressing the needs and issues that a facility might encounter, throughout the four phases of EMS
implementation, http://www.peercenter.net/troubleshooters.cfm
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Environmental Management Systems: An Implementation Guide for Small and Medium Sized Organizations
In December 2000, the U.S. EPA, in cooperation with NSF International, completed this revised version of the
original guide intended to offer a plain English, common sense guide to organizations interested in
implementing an EMS, using the basic Plan-Do-Check-Act model.
http://www.epa.gov/OW-OWM.html/isol4001/wm046200.htm
Environmental Management Tools for SMEs (Small and Medium Sized Enterprises) - A Handbook
A guidance document produced by the European Environment Agency intended for small- and medium-sized
enterprises interested in implementing environmental management practices.
http://reports.eea.eu.int/GH-14-98-065-EN-C/en/enviissulO.pdf
Best Practices Guide: Application of ISO 14001 Environmental Management Systems (EMS) for
Municipalities
This guide is for senior and mid-level technical staff (facility managers, directors of engineering or technical
services, directors of capital planning) from municipal agencies, utilities and institutions who are interested in
implementing an EMS. The guide provides enhanced technical, management and analytical tools for the
development of a broader Municipality EMS and a more narrowly structured Municipal Facility EMS.
http://www.iie.org/programs/energv/pdfs/Applic%20ISO%2014000%20for%20Municipalities.pdf
ISO 14001 Guidance Manual
The USA-based National Center for Environmental Decision-making Research has created a document that is
specific enough to set up and implement an EMS, but general enough to allow the flexibility for addressing
unique characteristics. The various sections of the manual describe each element of the ISO 14001 standard and
provide step-by-step procedures and tips for developing and implementing an EMS.
http://www.ncedr.org/guides/iso.htm
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Appendix D
EMS Glossary
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Glossary
American National Standards Institute Registrar
Accreditation Board (ANSI-RAB) - Body that accredits
ISO 14001 Environmental Management Systems (EMS)
registrars and auditors.
Audit Finding - A discovery of lack of conformance to the
requirements of an (ISO 14001-based) EMS
criteria/checklist. All audit findings must be resolved as
found during the internal audit or through a formal EMS
process of corrective and preventative action.
Audit Finding - The discovery of a lack of conformance
to the requirements of an EMS (ISO 14001-based)
criteria/checklist. All audit findings must be resolved as
found during the internal audit or through a formal EMS
process of corrective and preventative action.
Auditor - Person with the qualifications to conduct an
EMS audit.
Baseline - The starting point from which to track the
achievement of an objective. Establish "normalized"
baselines to accurately measure how your facility's
environmental performance could change overtime.
Normalized baselines will measure your actual
environmental performance changes rather than changes
in production, customer demand, or other non-
environmental related factors.
Competency Training - Employees whose work may
create a significant environmental impact must get
appropriate training and be deemed competent based on
education, training or experience. For example, most
wastewater facilities need to have state licensed
operators. The license is a way to demonstrate
competency.
Conformance - To verify an organization's EMS to a
specified standard (ISO 14001).
Continual improvement - The principle of continual
improvement, as fundamental to the ISO 14001 Standard,
is intended to ensure that an organization does not simply
adopt an EMS, or other Plan-Do-Check-Act based
management system, for cosmetic purposes and thereby
remain static. Continual improvement is the process of
enhancing a management system to achieve improvement
in overall performance and effectiveness in line with the
organization's management policies. It is one of the three
main commitments of the EMS. After checking their EMS
through monitoring and measuring, and find and fix audits,
organizations apply the lessons they have learned to
improve their environmental management.
Controlled Documents - Policies, procedures, manuals,
and other documents that are a part of your EMS that
require control or managed. A controlled document is one
that is reviewed for relevance to your activities on a
regular schedule (typically annually) to ensure that
the most current version is being used "in the field."
Corrective Actions -As a result of the audit findings,
corrective action reports (CARs) are assigned to all
nonconformances to correct EMS deficiencies as they
occur. CARs track an audit finding, and assign tasks to be
completed, responsibilities, and timeframes.
Corrective Action Request (CAR) - A report form to
identify, track and manage corrective actions.
EMS Core Team -A cross-functional team made up of
individuals within the organization that helps facilitate EMS
implementation across the organization. Team members
are the EMS experts and cheerleaders.
Environment - Surroundings in which an organization or
facility operates, including air, water, land, natural
resources, flora, fauna, humans and their interrelation.
Environmental Aspect - Element of an organization's
activities, products or services that can interact with the
environment. Aspects = Causes
Environmental Impact -Any change to the environment,
whether adverse or beneficial, that results from an
organization's activities, products or services.
Impacts = Effects
EMS Fenceline - Project scope and/or operational areas
in an organization in which the EMS is implemented. For
example, for wastewater operations, this could include the
pretreatment and the laboratory operations.
External Communication - Providing information and
soliciting input, receiving inquiries and complaints,
responding, and documenting exchanges with interested
parties outside the fenceline of your facility.
EMS Manual - An EMS document that describes your
core system elements and how the different elements are
interrelated. A "roadmap" for your EMS. Auditors find a
manual very useful when verifying your EMS.
EMS Records - Reports, checklists, training, and other
data generated that provides verification that your
organization is following the EMS as intended.
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Work Instruction - Documented work tasks at your
facility that provide a detailed understanding of how
specific work process(es) are accomplished. For example,
an instruction or checklist on the proper disposal of
recyclables (batteries, oils and greases, rags, etc.) in your
auto maintenance shop.
Emergency Situation - Condition (e.g., spills, releases,
fires, etc.) that can have an environmental impact and that
requires an emergency response or action.
Emergency Response -Actions taken to address an
environmental incident.
Emergency Response Plan - A detailed plan that
describes the logistics, procedures, who to contact, roles
and responsibilities, reporting requirements, etc. in the
event of an emergency or spill.
EMS Audit -A planned and documented review
performed in accordance with a documented audit
procedure for the purpose of verifying, through interview
and an evaluation of EMS documents and records,
conformance with the applicable elements of your EMS.
EMS Auditor - A qualified and trained individual who
conducts EMS audits. Each EMS Auditor should attend
documented training that presents the requirements of a
standard (e.g., ISO 14001) EMS and of your organization's
EMS audit procedure and discusses their roles in an EMS
internal audit.
EMS Lead Auditor-A qualified and trained individual
who plans, organizes, and directs your organization's EMS
internal audits. The EMS Lead Auditor is the leader of your
EMS audit team and will report audit findings and
observations to management.
Environmental Management System (EMS) - A system
for identifying environmental and organizational issues and
implementing improvements based on Deming's Plan-Do-
Check-Act model. The EMS has 17 elements that help
organizations achieve environmental policy commitments
and environmental performance improvements.
Environmental Management Representative (EMR) -
The clearly-identified EMS team leader who has the
responsibility and management authority for implementing
the EMS from start to finish.
EMS Core Team -A cross-functional team made up of
individuals within the organization that helps facilitate EMS
implementation across the organization. They are the EMS
experts and cheerleaders.
EMS Audit - A systematic, documented verification
process of objectively obtaining and evaluating an
organization's EMS to determine whether or not it
conforms to the environmental audit criteria pre-defined by
the organization and applicable standards (i.e. the ISO
14001 Standard).
EMS Core Team -A cross-functional team made up of
individuals within the organization that help to facilitate EMS
implementation across the organization. These are the EMS
experts and cheerleaders.
EMS Fenceline - Operational area or areas within an
organization where the EMS is implemented.
EMS Fenceline - Project scope and/or operational areas
within an organization in which the EMS is implemented.
EMS Implementation Team - Individuals within the
organization who are closest to the actual workflow and who
assist the Core Team and the EMR in better understanding
operational activities. Implementation Teams are generally
very involved in designing operational controls, testing
emergency preparedness and response plans, and
identifying the environmental aspects of their daily activities.
Environmental Target - Detailed performance
requirement, quantified where practicable, based on an
organization's defined environmental objectives and that
must be met in order to achieve those objectives.
Environmental Aspect - Element of an organization's
activities, products or services that can interact with the
environment. Aspects = Causes
Environmental Impact -Any change to the environment,
whether adverse or beneficial, that results from an
organization's activities, products or services. Impacts =
Effects
Environmental Objective -An overall environmental goal
based on an established environmental policy, that an
organization sets itself to achieve. Wherever possible,
environmental objectives should be quantified, in order to
facilitate the evaluation of environmental performance and
the measurement of progress towards specific
environmental targets.
Environmental Target-A detailed performance
requirement, quantified where practicable, that arises from
the environmental objectives and that needs to be set and
met in order for the objective to be achieved.
EMS Awareness Training - Training involving an
overview of the basics of your EMS, including your
environmental policy, significant aspects, objectives and
targets, and the importance of operating under specific
procedures and work instructions (operational controls)
required under the EMS.
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Environmental Management Program (EMP) - A structured
program with a set of specific identifiable actions (an "action
plan") providing the direction for EMS objectives and targets to
be obtained and tracked. Your EMP should assign tasks,
resources, responsibilities, and timeframes for achieving your
objectives and targets.
Environmental Management Representative (EMR) - The
clearly-identified EMS team leader who has the responsibility
and management authority for implementing the EMS from
start to finish.
Environmental Management System (EMS) - A system for
identifying environmental and organizational issues and
implementing organizational improvements based on
Deming's Plan-Do-Check-Act model. The EMS has 17
elements that help organizations achieve environmental
policy commitments and environmental performance
improvements.
Environmental Performance - Measurable results of the
EMS related to an organization's control of its
environmental aspects, based on its environmental policy,
objectives and targets.
Environmental Policy -An organization's formal
statement defining its intentions and principles in relation
to its overall environmental performance. It provides a
framework for action and setting environmental objectives
and targets.
Environmental Objective -An overall environmental goal
based on an established environmental policy, that an
organization sets itself to achieve. Wherever possible,
environmental objectives should be quantified, in order to
facilitate the evaluation of environmental performance and
the measurement of progress towards specific
environmental targets.
Environmental Target-A detailed performance
requirement, quantified where practicable, that arises from
the environmental objectives and that needs to be set and
met in order for the objective to be achieved.
"Footprint" - The environmental impact of your facility -
how your operations and services interact with the air,
water, land, resources, local and regional community, etc.
Gap Analysis - Preliminary assessment of an organization's
environmental programs and management practices to see
where they match up with EMS requirements.
Interested Parties ("Stakeholders") - An individual or
group, internal or external to the organization, concerned
with or affected by the environmental performance of your
organization. For example, local residents, citizen groups,
and environmental regulators are all examples of
"interested parties." In addition, consider your own
employees - inside and outside of your fenceline - to be
interested parties.
Internal Communication - Flow of information top-down,
bottom-up, and across your entire EMS fenceline.
ISO 14001 - One of the Environmental Management
Standards developed by the International Organization for
Standardization in Geneva, Switzerland. It is the
requirements document that specifies the seventeen (17)
elements of an EMS. It is the standard protocol
(requirements document) in the ISO 14000 series that
specifies the necessary elements of an EMS.
Key Characteristic -An element of an operation or
activity that can be measured or evaluated for
environmental performance of objectives and targets.
Legal Requirements - The set of rules and legal
regulations that apply to the operations and services of an
organization, including local, state, and federal laws.
Major Nonconformance -Adeficiency in meeting the
requirements of an EMS. One or more of the 17 elements
of the EMS are not addressed (e.g., no system procedure)
or implemented (e.g., not following a system procedure as
written).
Minor Nonconformance -A finding that leads to a failure
to conform completely with an EMS element, but is not
considered to be a breakdown in your system. For
example, a number of employees were overdue on their
EMS refresher train ing.
Observation -A recognition of something done incorrectly
or an area of concern. While not a major or minor
nonconformance with an EMS requirement, if done
correctly it could strengthen the EMS or if done incorrectly,
could potentially cause a system failure.
Other requirements - The rules and guidelines that an
organization follows that are not legally binding under
existing environmental laws, but to which an organization
is committed (e.g., industry standards or voluntary
guidelines). Under an EMS, these requirements require
the same commitment as legally binding requirements.
Operational Controls - Documents that specify the way
to execute a certain activity or operation. Operational
controls are assigned to operations and services involving
significant aspects and are documented through the use of
work instructions, procedures, manuals, programs, etc.
Examples include maintenance work, pretreatment
operations, chemical ordering, etc.
Performance Indicators - Measurement tools, selected
by management that can be used to support the
evaluation of environmental performance in relation to a
specific target. Performance indicators may be adjusted to
meet specific management needs or as necessary to
ensure progress towards specific environmental targets.
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Pollution Prevention -The development, implementation,
and evaluation of efforts to avoid, eliminate, or reduce
pollution at the source. Any activity that reduces or
eliminates pollutants prior to recycling, treatment, control
or disposal.
Preventive Actions -A proactive approach to managing
actions that are assigned to any EMS nonconformance
made that will prevent potential environmental issues
before they occur.
Registrar -A third-party organization that awards the
EMS certification.
Registration -A recognized validation that an EMS has
passed an accredited independent, third-party audit.
Root Cause - Underlying reason that led to or may lead
to an EMS nonconformance. For example, if a group of
employees were not following a procedure, the underlying
cause could be that they were not properly trained on the
procedure or that an updated procedure was not
communicated to them.
Self-Declaration -An internal review of conformance to
all elements of an EMS. EMS self-declaration is an organi-
zation's statement that it conforms with all elements of the
ISO 14001 Standard.
Stakeholders - Groups and organizations having an
interest or stake in an organization's EMS (e.g., regulators,
shareholders, customers, suppliers, special interest
groups, residents, etc.).
Surveillance -A scheduled sampling of EMS elements to
maintain a third-party registration.
System Procedure -An EMS (ISO 14001) required
document that establishes purpose, scope, roles &
responsibilities, the tasks to be completed, and where and
how the associated records and documents are
maintained.
Third-Party -An independent EMS auditor that is quali-
fied to conduct EMS audits.
Top Management - Person or group with executive
responsibility for the organization and the EMS.
Work Instruction -A series of steps and activities
directed to a very specific area or process. Examples
include cleaning the rake at wastewater pretreatment
operations and calibrating a pH meter.
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