An Environmental Management
System (EMS)  Primer for Ports:
                    Advancing Port
           American Association
           of Port Authorities
    Alliance of the Ports of Canada, the Caribbean, latin America and the United States
    April 2007

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                 U.S. Environmental Protection Agency

       An Environmental Management System
                Primer for Ports:  Advancing Port
                                               April 25, 2007
Prepared for:
U.S. Environmental Protection Agency
Office of Policy, Economics, and Innovation
Sector Strategies Division
Kathleen Bailey, Port Sector Liaison
Tel 202-566-2953

In partnership with:
American Association of Port Authorities

Prepared by:
ICF International
9300 Lee Highway
Fairfax, VA 22031
(703) 934-3000

In cooperation with:
Global Environment & Technology Foundation

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An EMS Primer for Ports: Advancing Port Sustainability

Table of Contents

List of Acronyms	iii
Introduction	1
Overview of EMSs	1
How an EMS Advances Port Sustainability	3
Elements in Developing an EMS	4
Primer Layout	5
Element 1: Define Scope of EMS and Assign Responsibilities	6
Element 2: Create Environmental Policy Statement	9
Element 3: Identify Relevant Legal  and Other Requirements	13
Element 4: Identify Environmental Aspects & Significant Environmental Aspects	15
Element 5: Establish Objectives, Targets, and Action Plans	19
Elements: Develop Operational Controls	22
Element 7: Develop Emergency Preparedness and Response Program	24
Element 8: Set Up a Training Program for Competence and Awareness	26
Element 9: Create a Communications Strategy	28
Element 10: Set Up Documentation forthe EMS	30
Element 11: Monitor, Measure, Evaluate, and Record Performance	32
Element 12: Conduct Audits and Correct Problems	35
Element 13: Conduct Management Review	36
Security Management Systems (SMSs) Based on the Plan-Do-Check-Act Model	37
Conclusion	39
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An EMS Primer for Ports: Advancing Port Sustainability
List of Acronyms
AAPA         American Association of Port Authorities
BMP          Best management practice
C&M          Construction & maintenance
CAA          Clean Air Act
CEO          Chief executive officer
CERCLA      Comprehensive Environmental Response, Compensation, and Liability Act
CFR          Code of Federal Regulations
GIF           Continual Improvement Form
CFT          Cross-functional team
COO          Chief operating officer
COOP         Continuity of operations
CWA          Clean Water Act
DVD          Digital versatile disc or digital video disc
EA            Environmental aspect
EBIT          Earnings before interest & taxes
EH&S         Environmental, health, and safety
El            Environmental impact
EMP          Environmental management plan
EMR          Environmental management representative
EMS          Environmental management system
EO            Executive order
EPA          U.S. Environmental Protection Agency
EPCRA       Emergency Planning & Community Right-to-Know Act
EP&R         Emergency preparedness and response
FEMA         Federal Emergency Management Agency
FRP          Federal Response Plan
FSP          Facility security plan
GETF         Global Environment & Technology Foundation
GHG          Greenhouse gas
GRI           Global Reporting  Initiative
ha            hectare
HMTA         Hazardous Materials Transportation Act
HNE          Harbors, Navigation, and  Environment [AAPA Sustainability Working Group]
HVAC         Heating,  ventilating, and air conditioning
ICP           Integrated Contingency Plan
ILO           International Labour Organization
ISO           International Organization for Standardization
ISPS          International Ship and Port Security
JRRF         James River Reserve Fleet
LEED         Leadership in Energy and Environmental Design
MARAD       Maritime Administration
MARSEC      Maritime Security
MFM          Marine Facility Management
MOA          Memorandum of agreement
MTSA         Maritime Transportation Security Act
NIT           Norfolk International Terminals
NOV          Notice of violation
NOx          Nitrogen oxides
NRAMP       Natural resources assessment and implementation plan
PAS          Publicly available specification
PDX          Portland  International Airport
PM            particulate matter
RCRA         Resource Conservation & Recovery Act
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An EMS Primer for Ports: Advancing Port Sustainability

                                    List of Acronyms
SAFE         Security and Accountability for Every [Port Act of 2006]
SEA          Significant environmental aspect
SMS          Security management system
SOLAS        Safety of Life at Sea
SOP          Standard operating procedure
SPCC         Spill Prevention, Control and Countermeasure
3Es           Economic, environmental, and social (equity)
3Ps           Profit/prosperity, planet, and people
TSCA         Toxic Substances Control Act
USAGE        U.S. Army Corps of Engineers
USGC         U.S. Coast Guard
VIT           Virginia International Terminals
V-REMS       Virginia Regional Environmental Management System
VPA          Virginia Port Authority
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An EMS Primer for Ports: Advancing Port Sustainability

Waterborne commerce is increasing rapidly and presenting ports with challenges that could not have
been imagined even two decades ago. By 2020, the total volume of cargo shipped by water is expected
to be double that of 2001 volumes.1 At the same time, lifestyle changes have made the cruise industry the
fastest growing segment of the travel industry - achieving more than 2,100 percent growth since 1970.2

To accommodate increases in trade volume, increases in the size of cargo and cruise ships, and new
security requirements, many U.S. ports are investing billions of dollars in infrastructure improvements
such as deeper channels, larger cranes, and other facility and property enhancements. While many of
these investments facilitate improvements in the operational efficiency of existing port operations, many
ports also need to physically expand to meet business demands. Even the ports that have traditionally
viewed themselves as environmental stewards of coastal resources are finding it challenging to balance
economic, environmental, and social issues, i.e., to grow sustainably.

To ensure that this growth is executed responsibly, many ports have proactively addressed their
environmental and related socio-economic responsibilities through the development of Environmental
Management Systems (EMSs). The purpose of this primer is to help ports develop EMSs and understand
how an EMS can advance port sustainability.

Overview of EMSs

An EMS is a formal system for proactively managing the environmental footprint of a port. It incorporates
environmental considerations and decision making into a port's day-to-day operations and into its
strategic planning. Additionally, an EMS provides a structured framework designed to achieve continual
environmental improvement beyond regulatory compliance. An EMS can help ports to improve efficiency,
reduce costs, and minimize  negative impacts on human health and the environment.

Over the last several years,  the U.S. Environmental Protection
Agency (EPA) has been  involved in a wide range of voluntary
activities to facilitate adoption of EMSs, including the Sector
Strategies Program, which promotes the use of EMSs at ports as
well as a dozen other economic sectors nationwide.3 EPA also has
EMSs at its own facilities and assists other government agencies in
developing  theirs.4

While each EMS is unique to an organization's culture and priority
issues, most follow the Plan-Do-Check-Act model. This model
establishes a framework to examine and prioritize the environmental
aspects of an organization, then develop, implement, monitor,
review, and revise environmental programs and procedures to
     1 See, accessed March 30,

     2 See www.cruisinq.orq/press/sourcebook2006-midvear/profile cruise industry.cfm, accessed March 30, 2007.

     3 See www.epa.qov/sectors/ports/index.html for information on port participation in EPA's Sector Strategies

     4 On October 16, 2006, EPA restated its commitment to integrating and utilizing EMS at its own facilities
nationwide; see "Commitment to the Integration and Utilization of Environmental Management Systems," a copy of
which is available at:, accessed  March 30, 2007. For more
information on EPA's progress in implementing EMSs at its laboratories and offices nationwide, please visit: One way that EPA assists other federal agencies develop EMSs  is by
providing information through the Fedcenter website (, which helps federal agencies better
address their environmental needs.
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An EMS Primer for Ports: Advancing Port Sustainability
continually promote sound day-to-day management and improvement. Many ports already have
components of an EMS in place, such as written and unwritten procedures, best management practices
(BMPs), and regulatory compliance programs. An EMS naturally leverages and builds upon existing good
practices and the practical knowledge base of employees throughout the organization.

U.S. ports with an EMS in place include:

•   Massachusetts Port Authority (Massport),  Port of Boston;5
•   Port Authority of New York and New Jersey;   __^^^^^^^^^^^^^^^^^^^^^^^^^_
•   Port of Corpus Christ! Authority, TX;
•   Port of Houston Authority, TX;
•   Port of Los Angeles, CA;
•   Port of Portland, OR;
•   Port of Seattle, WA;
.   Port of Vancouver, WA; and
•   Virginia Port Authority.
  "We see the EMS as a valuable tool to help us meet the
  environmental challenges facing our port." — Ralph G.
  Appy, Ph.D., Director of Environmental Management,
  Port of Los Angeles

  Source: EPA, AAPA, & GETF. Environmental
  Management Systems: Systematically Improving your
  Performance: Ports Sector, September 2004.
Domestic ports developing an EMS include:

•   Maryland Port Administration, Port of Baltimore;
•   Port Everglades, FL;
•   Port of Cleveland, OH;
•   Port of Everett, WA;
•   Port of Freeport, TX;
•   Port of Long Beach, CA;
•   Port of New Orleans,  LA; and
•   Port of Oakland, CA.
These and other ports worldwide have found
important benefits from developing EMSs:

•   Improved environmental awareness,
    compliance, and performance;
•   Reduced costs and improved operational
    efficiency through more efficient use of
    materials, operational streamlining, and
    strategic direction setting;
•   Reduced risk and liability, and improved
    security and emergency response
•   Improved internal communication and
    cooperation, including those between port
    authorities and terminal operators; and
•   Enhanced credibility, public image, and
    public confidence, as ports monitor and
    report performance and position
    themselves as leaders in environmental
    protection and management.
        Common Principles of Sustainability

    Dealing transparently & systemically with risk,
    uncertainty, & irreversibility
    Ensuring appropriate valuation, appreciation, &
    restoration of nature
    Integration of environmental, social, human, &
    economic goals in policies & activities
    Equal opportunity & community participation
    Conservation of biodiversity & ecological integrity
    Ensuring inter-generational equity
    Recognizing the global integration of localities
    A commitment to best practice
    No net loss of human capital or natural capital
    The principle of continuous improvement
    The need for good governance
Source: Hargroves, K. and M. Smith (Eds.) 2005. The
Natural Advantage of Nations: Business Opportunities,
Innovation and Governance in the 21st Century.
    s Massport has also developed an EMS for its airport facilities.
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An EMS Primer for Ports: Advancing Port Sustainability
How an EMS Advances Port Sustainability

In addition to environmental compliance requirements, ports continue to face daunting challenges in this
time of significant growth. Among other realities, heightened community concern about port expansion
plans, the magnitude of anticipated resource and capital investments, and rising costs of energy
resources and management of waste byproducts have left many ports looking for an all-inclusive,
systems-based, management approach to operations. Increasingly, ports are looking holistically at their
overall business practices with a view toward "Sustainability."
                                                          Sustainable Ports Keep Things Moving
Since first introduced in the mid-1970s, the concept of
Sustainability as a business concern has evolved to
equate to the "Triple Bottom Line" or "Sustainability trinity,"
i.e., an organization's performance in three areas:

•   3Es - Economic, Environmental, and social (Equity);
•   3Ps - Profit/Prosperity, Planet, and People.6

The Global Reporting Initiative (GRI), for example, has
developed a 3E framework for Sustainability reporting that
is now used by nearly 1,000 organizations from over 60
countries.7 Acknowledging lessons learned from the GRI
efforts and other Sustainability initiatives, the American
Association of Port Authorities (AAPA) is also working to
develop and implement a Sustainability framework for its
members. AAPA represents the 80+ largest public ports in
the United States and is a partner in EPA's Sector
Strategies Program.

A key tenet of Sustainability is that it is not limited to environmental stewardship. Rather, Sustainability
focuses on understanding the interconnections among the economy, society, and environment, and the
equitable distribution of resources and opportunities - both now and in the future. Sustainable ports look
at their operations in an all-inclusive manner, enhancing their profitability while existing responsibly within
the larger community. They are able to meet today's global economic, environmental, and social  needs
without compromising the ability of future generations to meet theirs.

Ports are beginning to define broader Sustainability policies that extend beyond environment stewardship.
The Port of New York and New Jersey has developed the following Triple Bottom Line statement:

        Success won't be measured by simple market-based metrics like cargo volume or market
        share alone. In  fact, as it serves its maritime customers, the Port of New York and New
        Jersey must also meet a Triple Bottom Line. It must be: 1) an engine of regional
        prosperity; 2) secure and environmentally sustainable; and 3) financially self-sustaining.
        Those are key components of the region's quality of life - and that is the benchmark of
        success for the bi-state Port.8
    6 In its 1987 Report, Our Common Future, the United Nations-convened Brundtland Commission dealt with
sustainable development, which it defined as "development that meets the needs of the present without
compromising the ability of future generations to meet their own needs." See
environment/brundtland.html for an easy-to-read version of the Brundtland Report; accessed April 2, 2007.

    7 See for additional information on GRI's Reporting

    8 Statement provided by Joseph Monaco, March 8, 2007, email to AAPA's Harbors, Navigation,  and
Environment (HNE) Sustainability Working Group.
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An EMS Primer for Ports: Advancing Port Sustainability
Other ports, including the Port of Oakland, also define sustainability in terms of the "3E trinity" of
economic, environmental, and social equity.

These and other examples suggest that ports worldwide are working toward and committed to
sustainability, with promising potential and possibilities.

Clearly, senior management support and leadership are crucial - both for an EMS and its environmental
stewardship activities, and for broader sustainability principles and practices. The decision to implement
an EMS entails a commitment of time and monetary resources. On average, it takes a year to set up an
EMS, although individual systems can vary from three months to two years depending on project scope
(i.e., its "fenceline") and resources.9 Senior management plays an active role in the EMS, continually
assessing the organization's progress toward its goals, looking for ways to improve management and
performance, effectively allocating  resources and personnel, and sustaining commitment to the system
through annual reviews and revisions. Costs vary, but ports that have implemented an EMS have found
they are able to recover their upfront costs quickly through early identification of pollution prevention
initiatives, potential liabilities, and opportunities to reduce risks.10
Elements in Developing an EMS
Within the Plan-Do-Check-Act approach, there               Port Sustainabmty is Wor|dwjde
are a number of elements that comprise an
EMS. The most commonly used framework for
an EMS is the one developed by the
International Organization for Standardization
for its ISO 14001 Standard. For ease of
presentation, several ISO elements have been
combined in this primer, resulting in a set of 13
elements:                                      „     ...  .  , D . ,       ...
                                               Source: Port of Brisbane website,
                                               "We are committed to sustainable development on port
                                               land. Our EMS is central to all decision making regarding
                                               environmental performance and sustainability. Simple
                                               design solutions help create healthy buildings and
                                               promote a sustainable approach to development." — Port
                                               of Brisbane, Australia
                                               environmental management systems
1.   Define scope of EMS and assign
2.   Create environmental policy statement;      ====^^
3.   Identify relevant legal and other
4.   Identify environmental aspects and significant environmental aspects;
5.   Establish objectives, targets, and action plans;
6.   Develop operational controls;
7.   Develop emergency preparedness and response program;
8.   Set up a training program for competence and awareness;
9.   Create a communications strategy;
10. Set up documentation for the EMS;
11. Monitor, measure, evaluate, and record performance;
12. Conduct audits and correct problems; and
13. Conduct management review.

From Element 1, determining the scope of the effort, to Element 13, performing a management review,
there are opportunities for ports to integrate broader sustainability concepts into their EMSs. Ports have
     ' Conversation with EPA Sector Strategies Program staff, April 2, 2007.
     10 EPA, AAPA & GETF. Environmental Management Systems: Systematically Improving your Performance:
Ports Sector, September 2004. Also see 1st Ports EMS/SMS Assistance Project, Final Report, May 2006, for
information on average resource commitments over a 2-year project period at 11 ports.

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An EMS Primer for Ports: Advancing Port Sustainability
begun to plan and implement sustainable, "green port" policies that build on, but extend beyond, their
environmental stewardship initiatives. In fact, it can be hard to distinguish between actions resulting from
implementation of an EMS and actions taken to improve a port's sustainability. It may be helpful to think
of this range of activities on a continuum.

Primer Layout

Efforts by ports to improve their sustainability can be documented and captured within the Plan-Do-
Check-Act EMS framework. To help ports understand EMS and sustainability, this primer provides the
following information on each EMS element:

•   A brief overview of the element in the context of an EMS to provide ports with general EMS concepts;
•   One or more  real life examples of how ports have implemented the element within their operations;
•   A discussion  of how each element can be extended to include facets of broader sustainability.

Many of the examples in this primer come from the 1st Ports Environmental Management
Systems/Security Management Systems Assistance Project (January 2004 - December 2005),n
developed by AAPA in  partnership with EPA's Sector Strategies Program and the Global Environment &
Technology Foundation (GETF). Through this project,  nine ports and two federal maritime facilities
worked together over two years to develop EMSs. In addition, the Port of Houston Authority, which had
previously developed an EMS,  applied the  management systems approach to develop a Security
Management System (SMS). Following the discussion of EMS elements, this primer provides an overview
of how Houston and other ports are using the Plan-Do-Check-Act approach to address security issues
through SMSs.

A 2nd Ports EMS/SMS Assistance Project began in February 2006 with four of the seven participating
ports developing  EMSs and three using the management systems approach to develop SMSs. This 2nd
round of EMS/SMS assistance  will be completed by March 2008.12

Additional examples of ports that are working on EMSs, SMSs, and broader sustainability programs come
from AAPA members and from ports located outside the Americas. Information on AAPA's EMS
Assistance Projects and its Harbors, Navigation, and Environment Committee can be found at www. a a pa- To begin developing  your port's own customized EMS, refer to numerous online resources,
including a list of Technical Assistance Providers, sample documents, and other EMS tools, by visiting and For more information about the port-related activities of
EPA's Sector Strategies Program, visit
    11 See Final Report, May 2006,, accessed March 30,
2007. Contacts at each of the participating ports are listed on p.1 of that publication.
      See press release on 2  round participants
accessed March 30, 2007.
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An EMS Primer for Ports: Advancing Port Sustainability
                                                              Zones of Port Control, Influence, and Interest
Element 1: Define Scope of EMS and Assign Responsibilities

                A first step in EMS planning is to establish the "fenceline" by documenting the scope of
                port facilities and activities that the EMS will address. As shown in the accompanying
                graphic, there are facilities and activities over which a port has direct control. There are
                other facilities and activities that a port does not directly control but over which it has
          V   some  influence (e.g., tenant operations).
                Finally, there are facilities and activities within a
                port's  zone of interest that could be brought
into its zone of influence if the port is proactive (e.g., regional
intermodal transportation planning). Most ports start with facilities
and operations over which they  have direct control; then, they
later expand their EMS to address broader areas of influence.
When defining the scope of its EMS, a port should also consider
practical constraints and timing.

EMS responsibilities should be assigned to individuals who can
competently complete and fulfill their roles. At a minimum, you
should describe responsibilities  for Core EMS Team members,
designate people for these roles, establish lines of authority,
and create an organization chart for your EMS. Documentation
and communication of roles, responsibilities, and authority
throughout the port will facilitate effective EMS implementation
and management.
                                                       Typical EMS Core Team Members

                                                  Environmental Management Representative (EMR):
                                                  Project Manager &/or member of port's top
                                                  EMS Coordinator Leads the Team, ensures support
                                                  for the EMS, & makes sure all EMS tasks are
                                                  Cross-Functional Team (CFT): Comprises members
                                                  who represent each major operation within the port &
                                                  serve as an information resource; may include risk
                                                  management, public affairs, operations, human
                                                  resources, etc.
Resources are essential for implementation
and control of an EMS. They include training,
human resources, specialized skills, financial
resources, and technical and informational
services. Port management must ensure the
availability of such resources to the EMS.

Element 1 in the Field

Ports have selected their EMS fenceline based
on many considerations. For example, the
Maritime Administration (MARAD) selected the
James River Reserve Fleet (JRRF), a federal
anchorage on the James River Fort Eustis
Army Transportation Center in Newport News, VA, as the fenceline for its 1st EMS/SMS Assistance
Project. MARAD  believed that an EMS could enhance its credibility as a federal environmental steward
on the James River. Over the last couple of years, National Defense Reserve Fleet ships at JRRF
awaiting disposal and/or reefing had been under intense scrutiny by regulatory agencies, including the
Virginia Department of Environmental Quality and the U.S. Coast Guard (USCG). A number of ships built
in the 1950s, 1960s, and 1970s contained fuel and oil that could pose a threat to the James River
ecosystem if an oil spill were to occur. JRRF was chosen as the EMS site because of its diverse
environmental consequences,  including its position as a tenant at Fort Eustis.13

Ports across the country have developed EMS Core Teams that are right-sized for their situations,
accessing staff from across operations and divisions within their fencelines.14
    13 Example from the 1st Ports EMS/SMS Assistance Project Final Report, May 2006.

    14 Unless otherwise indicated, these examples are from the 1st Ports EMS/SMS Assistance Project Final Report,
May 2006.
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An EMS Primer for Ports: Advancing Port Sustainability
•   Port of Virginia: Because of its size, operational impact on the environment, and public presence,
    Norfolk International Terminals (NIT), one of four facilities comprising the port, was chosen as the
    facility for an EMS assistance project. This facility is owned by the Commonwealth of Virginia and
    operated by Virginia International Terminals (VIT), an operating affiliate of the Virginia Port Authority
    (VPA). The EMS Core Team included six staff: two members from VPA (Chief Engineer, and Director
    of Environmental Affairs as EMR) and four members from VIT (Director of Engineering and
    Maintenance, Facilities Maintenance Supervisor, Vehicle Maintenance Supervisor, and Crane and
    Straddle Carrier Supervisor).

•   Portland District, U.S. Army Corps of Engineers (USAGE): The Corps' Portland District selected the
    U.S. Government Moorings shipyard (which includes a number of maintenance facilities and offices
    for personnel who  operate and maintain the ships), two hopper dredges  (the ESSAYONS and
    YAQUINA), and associated survey and support vessels as the fenceline for its EMS assistance
    project. The EMS Core Team comprised 11 members: the Environmental Compliance Coordinator as
    EMR, as well as plant maintenance and dredge operations chiefs, four dredge captains, the shipyard
    superintendent, two senior port engineers, and the lead hydrographic survey technician.

•   Port of Los Angeles: The port selected the Construction and Maintenance (C&M) Division as the
    fenceline for its EMS assistance project. C&M provides maintenance services to all port-owned
    facilities and consists of offices, equipment storage, and shops for each craftspeople, including
    electricians, equipment operators, gardeners, painters, laborers, mechanics, machinists, plumbers,
    roofers, crane mechanics, pile drivers, and carpenters. The EMS Core Team included 25 C&M
    personnel, 4 representatives from the Environmental Management Division, 1 representative from
    Public Affairs, and 1 representative from Risk Management.

•   Port of Seattle: The Port of Seattle is currently piloting  an EMS at its Fishermen's Terminal. Wayne
    Grotheer, Director of Seaport Finance and Asset Management, noted, "We decided to pilot this
    program at Fishermen's Terminal because it is a microcosm of the larger port. At Fishermen's we
    have large and small moorage customers, retail, office and industrial tenants and open public access.
    If a more systematic and formalized approach to managing environmental issues works at
    Fisherman's Terminal, the port may adopt a similar approach at other  facilities." Seattle established
    an  EMS Core Team that includes a cross-section of staff members from its Harbor Services, Health &
    Safety, Risk Management, and Environmental Divisions.15
One way for a port to incorporate sustainability into its EMS is to widen the scope of the EMS to include
more facilities and activities. Rather than focusing solely on its own operations, a port can include the
environmental impacts of all entities over which the port exercises control or significant influence with
regard to financial and operating policies and practices.

•   As part of its Green Port Policy,16 the Port of Long Beach is developing a tiered Sustainability
    Implementation Plan, which is taking a step-wise approach to defining the port boundary for the
    purposes of sustainability:

    o   First, considering areas that are within the port's direct control;
    o   Then, extending to tenants; and
    o   Finally, extending to the region in which the port is located.
    15 Intranet newsletter entitled "New Environmental Program Tests the Waters (And More) At Port Of Seattle's
Fishermen's Terminal," Port of Seattle, submitted by Wayne Grotheer to EPA's Sector Strategies Program via email,
May 10, 2006.

    16 See  port policy.asp, accessed March 28, 2007.
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An EMS Primer for Ports: Advancing Port Sustainability
    Long Beach has identified, institutionalized, and budgeted fora Sustainability Practice Manager to
    coordinate development and implementation of its Sustainability Implementation Plan. This
    management position cross-cuts port operations.

•   The Virginia Port Authority is participating in the Virginia Regional Environmental Management
    System (V-REMS), a partnership of over 50 federal, state, and local public and private organizations
    that collaborate to address regional community and environmental issues. Through the V-REMS
    partnership, participants leverage the collective knowledge and best practices of over 45 public and
    private organizations that are all working to improve their environmental performance and cost-
    efficiency. Accordingly, by serving as a  crucial resource for information and collaborative
    opportunities, the V-REMS partnership helps its participants save time and money while they
    contribute to a  cleaner regional environment.17
      See accessed April 24, 2007.
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An EMS Primer for Ports: Advancing Port Sustainability
Element 2: Create Environmental  Policy Statement

                Once your port has its Core EMS Team trained and in place, the next step is to define,
                develop, and communicate your facility's environmental policy. As your Team moves
     Continual       forward, the policy will:
                •  Serve as the foundation for implementing and improving the EMS;
                •  Provide a unifying vision of environmental commitments and principles that will
                   guide the actions of employees and top management; and
•   Demonstrate your port's proactive environmental performance commitments to your workforce,
    customers, and the public.
                                              Minimum Port Commitments in EMS Policy Statement

                                              •   Compliance with legal requirements & voluntary
Many ports have developed environmental            commitments
policy statements to guide their EMS efforts.       *   P°"fon Preventlon
The following example comes from theWginia     •   ^
^olUto°rJySP    Pn tl°nmlhe1  .P°rtS        •   Communications with your community about the
EMS/SMS Assistance Project;18 note its              port,£ environmental performance & the operation of   I
references to commonwealth laws and the            trie EMS                                     II
inclusive nature of its list of port stakeholders.                                                     I

        The  Virginia Port Authority and Virginia International Terminals, Inc., are committed to
        conducting Port operations and managing resources in an environmentally sensitive and
        sound manner, as prescribed by Article XI,  Section 1 of the Constitution of Virginia. It is
        the intent of each organization to:

        1.   Meet or exceed all applicable Federal, State, and Local environmental laws and
        2.   Employ management systems and procedures specifically designed to prevent
           activities and conditions that pose a threat to human health, safety,  and the
           environment through proactive environmental leadership and compliance.
        3.   Integrate environmental costs, risks, and impacts into port project development and
           facility improvements and to continually evaluate and improve operational efficiency
           and practices to achieve our established environmental and business objectives.
        4.   Promote pollution prevention and environmental awareness through communications
           with employees, customers, tenants, suppliers, contractors, other terminal users,
           regulatory agencies, neighboring communities and environmental organizations.

        The  Virginia Port Authority and Virginia International Terminals, Inc., are committed to the
        spirit and intent of this policy and the laws and regulations, which give it foundation.

        REF: Constitution of Virginia, Effective July 1, 1971 with Amendments - January 1, 2005.

        Adopted 24 May 2005, Virginia Port Authority, Board of Commissioners

Massport's environmental policy is available on the  Internet; it, too, addresses a broad set of stakeholders
and also promotes sustainable design principles:19

        Massachusetts Port Authority (Massport) is committed to operate all of its facilities in an
        environmentally sound and responsible manner.
    18 See Final Report, May 2006.

    19 See envmqmt.pdf. accessed March 28, 2007.

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An EMS Primer for Ports: Advancing Port Sustainability
       Massport will strive to minimize the impact of its operations on the environment through
       the continuous improvement of its environmental performance and the implementation of
       pollution prevention measures, both to the extent feasible and practicable in a manner
       that is consistent with Massport's overall mission and goals. To successfully implement
       this policy Massport will develop and maintain management systems that will:

       •   Ensure that the environmental management policy is available to staff, tenants,
           customers and the general public.
       •   Ensure compliance with all applicable environmental laws and regulations.
       •   Ensure that environmental considerations are included in business, financial,
           operational, and programmatic decisions, including feasible and practicable options
           for potentially exceeding compliance with applicable regulatory requirements.
       •   Define and apply sustainable design principles in the planning, design, operation and
           decommissioning of its facilities.
       •   Define and establish environmental objectives, targets and best management
           practices and monitor performance.
       •   Provide training to and communication with staff and affected tenants regarding
           environmental goals, objectives and targets and their respective roles and
           responsibilities in fulfilling them.
       •   Incorporate monitoring of Massport and Massport tenants' environmental activities.
       •   Include the preparation of an annual environmental performance report which will be
           made available to staff, tenants, customers and the general public.
One way ports have combined both environmental and social goals is to make policy information readily
available in more than one language. To that end, the Port of Corpus Christ! Authority has published its
environmental policy statement in both English and Spanish, so it could be understood by its native
Spanish-speaking employees and by the community.20

Other ports are developing sustainability mission statements or value statements. For example, in
January 2005 the Board of the Port of Long Beach adopted a Green Port Policy that serves as a guide for
decision making and establishes a framework for environmentally friendly port operations. The policy's
five guiding principles are:

•   Protect the community from harmful environmental impacts of port operations;
•   Distinguish the port as a leader in environmental stewardship and compliance;
•   Promote sustainability;
•   Employ best available technology to avoid or reduce environmental impacts; and
•   Engage and educate the community.21

Outside the U.S., the Port of Brisbane, Australia, has posted its environmental policy statement on the
Internet.22 This statement addresses broader port sustainability, including economic resources and
stakeholder involvement:
      To read the port's environmental policy statement in Spanish, please refer to the 1s Ports EMS/SMS
Assistance Project, Final Report, May 2006.

    21 See port policy.asp, accessed March 28, 2007.

    22 See accessed March 30, 2007.
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       Our environmental policy is to develop and implement best-practice strategies and
       systems to minimize the environmental impacts of our operations and promote the
       development of a sustainable port.

       The Port of Brisbane Corporation is a commercial port operator whose corporate purpose
       is to be a world class facilitator of integrated solutions for the logistics and business
       development requirements of its customers. To achieve this its prime objectives are:

       •   Adopting leading planning principles and management systems;
       •   Working cooperatively to ensure a safe and secure port environment;
       •   Providing world-class infrastructure; and
       •   Behaving at all times in line with our corporate values.

       A successful port is an essential part of the economic resources of the national,  regional
       and local communities. In operating as a successful port business, the Port of Brisbane
       Corporation is committed to ensuring that the activities of the Corporation are conducted
       in an ecologically sustainable manner with a high standard of environmental
       performance. This will be achieved while ensuring that the needs of the community and
       the values attached to natural and physical resources are taken into account in
       corporation planning and the way in which business is conducted.

       To achieve environmental performance consistent with this policy, the Port of Brisbane
       Corporation will employ the following principles:

       •   To include environmental considerations in the Corporation's decision making.
       •   To provide adequate resources for employees at all levels to fulfill their
           responsibilities as directed under this policy.
       •   To implement procedures to enable activities to be carried out in an environmentally
           responsible way.
       •   To set environmental objectives and targets for Corporation activities and to review
           these on an annual basis.
       •   To conduct regular review of the Corporation's environmental performance and act
           on the results.
       •   To continuously improve the environmental performance of the Corporation.
       •   To continuously improve the environmental management system of the Corporation.

       •   To meet environmental standards in the Corporation's key activities.
       •   To assess the environmental impacts of the Corporation's activities.
       •   To plan, design, operate and complete any operation in a manner that reduces
           environmental risks.
       •   To monitor environmental compliance in a professional manner.
       •   To abide by and comply with the Environmental Protection Act 1994 and all other
           applicable environmental laws, regulations, policies,  standards and codes of practice.
       •   To comply with the codes of practice of appropriate industry representative
       •   To prevent pollution from Corporation activities

       •   To appoint staff and contractors on criteria which include that they have the
           appropriate skill and experience to carry out work in a way that is compatible with
           good environmental performance and this policy.
       •   To train staff to have the appropriate skill and experience to ensure that operations
           are completed with the utmost respect for the  environment.
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       •   To specify the need for all contractors to carry out their work in accordance with this
           Environmental Policy and to supervise such compliance.
       •   To communicate with affected individuals, community and Government bodies about
           the Corporation's activities as relevant.
       •   To give due consideration for local culture and custom.

       The Port of Brisbane Corporation will hold employees and contractors accountable for
       their implementation of this Environmental Policy.

       This Policy will be reviewed annually.

       JeffColeman, Chief Executive Officer
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An EMS Primer for Ports: Advancing Port Sustainability
Element 3: Identify Relevant Legal and Other Requirements

                Compliance with legal requirements is one of the main pillars upon which your
                environmental policy (Element 2) should be based, because the potential costs of non
                compliance (e.g., possible damage to the environment, revenue loss, and impact on
                public image) can be very high. Therefore, your port should develop a procedure to
                identify, access, analyze, and communicate applicable legal and other requirements
                and ensure that these requirements are factored into the organization's management
                efforts. In addition to federal    ,,^^^^^^^^^^^^^^^^^^^^^^^^^^^_.
regulations, be sure to check with your state
and local authorities to determine other
applicable requirements and permitting
conditions. Other requirements might include
industry or trade group codes of practice, or
                                                Commonly Applicable Federal Environmental Laws
neighborhood or community association
requirements. Because legal and other
requirements change overtime, your process
should ensure that you are working with up-to-
date information.
Many ports are controlled by cities and
localities - for example, the City of Houston,
the Harris County Commissioners Court, the
Harris County Mayors and Councils
Association, and the City of Pasadena govern
the Port of Houston Authority; the City of Long
Beach has control over the Port of Long
Beach. Additionally, some states, such as
Massachusetts and Maryland, require their
agencies to have EMSs. Thus,  Massport/Port
of Boston was one of the first agencies to
develop and implement an EMS; the Maryland
Port Administration/Port of Baltimore is
currently participating in the 2nd Ports
EMS/SMS Assistance Project.
Clean Air Act (CAA): Establishes ambient & source
emission standards & permit requirements for
conventional & hazardous air pollutants
Clean Water Act (CWA): Establishes ambient &
point source effluent standards & permit
requirements for water pollutants; also includes storm
water management requirements
Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA, or
Superfund): Establishes a program for cleaning up
contaminated waste sites, establishes liability for
cleanup costs, & provides reporting requirements for
releases of hazardous substances
Emergency Planning & Community Right-to-
Know Act (EPCRA): Establishes a program (the
"Toxic Release Inventory") to inform the public about
releases of hazardous & toxic chemicals
Hazardous Materials Transportation Act (HMTA):
Establishes standards for the safe transport of
hazardous materials
Resource Conservation & Recovery Act (RCRA):
Establishes regulations  & permit requirements for
hazardous waste management; creates standards for
underground storage tanks that hold oil or hazardous
Toxic Substances Control Act (TSCA): Regulates
the use, development, manufacture, distribution &
disposal of chemicals
Many states, cities, and localities have issued sustainability statements or have construction requirements
that may impact port development.

•   Oregon has issued several Executive Orders (EOs) regarding sustainability for the 21st century,
    including its most recent EO 06-02.23 Oregon ports, including the Port of Portland and USACE-
    Portland District, operate with full awareness of these state-level EOs. The state also established
    Toxics Use and Hazardous Waste Reduction Program requirements; USACE-Portland District's EMS
    facilitated compliance with these newly mandated requirements.24
    23 See www.oreqon.qov/ODOT/SUS/Sustainability Mandates.shtml, accessed March 28, 2007, for additional
information on Oregon's sustainability mandates.

    24 From 1st Ports EMS/SMS Assistance Project, Final Report, May 2006.
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•   Sustainable Seattle is a non-profit organization dedicated to enhancing the long term quality of life in
    the Seattle/King County area. Senior staff at the Port of Seattle serve on Sustainable Seattle's Board
    of Directors and Advisory Council.25

•   In 2006, the Baltimore City Green Building Task Force recommended that Baltimore establish green
    building standards for city-funded construction and offer incentives to private developers of
    commercial buildings to build to green building standards.26 Although these recommended standards
    would not directly apply to the Port of Baltimore, the growing interest of the community in green
    buildings could easily manifest itself in calls for the port to adhere to similar standards.

Overtime, the federal government has also issued a number of EOs to "green" the government's
operations. Most recently, EO 13423 of January 24, 2007, Strengthening Federal Environmental, Energy,
and Transportation Management, sets goals for the federal government in the areas of energy efficiency,
acquisition, renewable energy,  toxics  reductions, recycling, renewable energy, sustainable buildings,
electronics stewardship, fleets, and water conservation. In addition, this EO requires more widespread
use of EMS as the framework in which to manage and continually improve these sustainable practices.

These and other EOs27 impact port facilities managed by federal agencies, such as MARAD, USAGE, and
USCG operations. For example, USAGE began integrating EMS into its civil works operating facilities in
response to EO 13148.28 Portland District's Channels and Harbors Project was selected, along with 11
other Corps projects, to be among the first to begin implementing an EMS.29 MARAD was also proactive
in setting its Strategic Plan and vision of implementing EMS at facilities under EO 13148.30

To the extent that a  port extends its EMS to look at links between  environmental and security, labor, or
social equity issues, additional  requirements may apply. For example, the Maritime Transportation
Security Act of 2002 (MTSA) defines a "transportation security incident" as a "security incident resulting in
significant loss of life, environmental damage, transportation system disruption, or economic disruption in
a particular area." MTSA, USCG Regulations 33 CFR Part 105 (regarding USCG's jurisdiction and
responsibilities for security planning and execution in and round U.S. waterways), and the general
provisions of Chapter XI-2 of the International Convention for the Safety of Life at Sea (SOLAS) and the
International Ship and Port Security Code (ISPS Code) address security considerations at ports.
    25 See www.sustainableseattle.orq for additional information on Seattle Seattle's mission, vision, and history, as
well as its staff, Board of Directors, and Advisory Council members; accessed March 28, 2007.

    26 Baltimore City Green Building Task Force, Report on Sustainable Building Guidelines and Standards for
Public and Private Construction and Renovation Projects, April 2006,, accessed April 20, 2007.

    27 EO disposition tables are found at www.archives.qov/federal-reqister/executive-orders/disposition.html.
accessed March 28, 2007.

    28 EO 13148, Greening the Government through Leadership in  Environmental Management, available at:

    29 From 1st Ports EMS/SMS Assistance Project, Final Report, May 2006.

    30 From 1st Ports EMS/SMS Assistance Project, Final Report, May 2006.
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Element 4: Identify Environmental Aspects & Significant
Environmental Aspects

                In Element 1 you defined the scope of your port's EMS (including entities over which
                the  port exercises control/significant influence), in Element 2 you wrote your port's
     continual       environmental policy (including commitments for continual improvement and prevention
    improvement      Of pollution and waste), and in Element 3 you made sure to identify all relevant legal
                and other requirements - at the federal, regional, state, and local levels. In Element 4,
                you use all that information as guideposts to (1) identify environmental aspects (EAs)
                of operations that fall within the scope of the port's EMS; (2) list their actual or potential
environmental impacts (Els), quantified to the extent possible; and (3) determine the subset of aspects
that have significant impacts.

•   EAs are characteristics of a facility's activities, products, or services that either impact the
    environment or could potentially impact the environment. These impacts could occur during normal,
    abnormal, accidental, or emergency situations.
    Air emissions from a tug boat are an example of   |    categories Commonly Used to Determine
    an EA, with the impact being degradation of air    j              Significance of EAs
    quality. Similarly, spills from chemical storage     j .   Regulatory concerns
    facilities are also an EA, with the impact being     \ .   Pollution
    degradation of air or water quality. Such EAs      ] •   Risk, including: effects of chemicals & materials
    may also be significant environmental          |     on workers, impacts on the surrounding
    aspects (SEAs) due to legal requirements, port   j     community, and impacts on the environment,
    goals or policies, community concerns, potential   j     safety, and noise
    release to the environment, pollution prevention   j •   Natural resource use
    potential, or other rationale. Once selected,
    SEAs form the basis for the rest of the EMS.
Many ports have catalogued their EAs (e.g., by diagramming their inputs, outputs, or processes),
determined associated Els, developed and applied significance determination methods using a variety of
ranking criteria, and selected SEAs on which to target their EMS. Prioritizing their EAs has helped port
management focus on controlling those aspects that have the greatest current or potential negative
impact on human health and the  environment.  For example, many U.S. ports are in counties that are in
non-compliance with air quality standards for ozone and particulate matter (PM). For those ports, and
others that want to be proactive, diesel emissions from both ships and landside sources are likely an

Common aspects and impacts within typical marine transportation fencelines (e.g., marine terminals and
maintenance shops) address not only air quality, but also impacts on land and water quality from ships
and shore-side operations. Typical activities within the fenceline may include electrical repair, building
maintenance, painting, boat building/repair, truck and fleet maintenance, fueling operations, waste
disposal, recycling, snow removal, wharf repair, plumbing, pavement repair, equipment maintenance,
roofing, landscape maintenance, property renovation, and storm water management.
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For example, after selecting its wellhead protection area as its fence line, key operations and
maintenance staff at the Port of Vancouver brainstormed activities that occur within this area and ranked
those individual activities according to the following factors to determine the level of perceived impact:
•   Human health;
•   Natural resources;
•   Frequency;
•   Volume;
•   Toxicity;

Following this ranking the port selected the
following SEAs:
   •   Public perception;
   •   Costs;
   •   Probability; and
   •   Legal requirements.
    Proximity of existing contamination to
    wellhead area;
    Illegal dumping within wellhead area;
    Tenant chemical use;
    Proximity of rail tracks (and potential for
    spills and leaks);
    Chlorine transportation, storage, and
    changing tanks;
    Installation  of backflow prevention devices; and
    Drinking water operational procedures.
"Our port's EMS is helping us identify and prioritize
environmental issues, especially those with the greatest
impact. It is also helping us document procedures and stay
on top of every regulation out there." — Gary P. LaGrange,
President & CEO, Port of New Orleans

Source: EPA, AAPA, & GETF. Environmental Management
Systems: Systematically Improving Your Performance: Ports
Sector, September 2004.
Massport, which operates the Port of Boston as well as major airports, bridges, and commercial areas,
identified the following activities that could impact the environment and were deemed to be significant or
occur at all Massport facilities:
    Vehicle/equipment maintenance;
    Administrative activities;
    Snow removal;
    Pavement maintenance;
       Building maintenance;
       Civil/site construction;
       Deicing; and
       Oil/water separator maintenance.
Massport then identified the following environmental aspects of those activities:
    Hazardous and solid waste disposal;
    Paper and office supplies/equipment;
    Fuel for vehicles;
    Salt/sand runoff;
    Vehicle emissions;
    Snow melter water discharge,
       Runoff and wastewater;
       Fuel for HVAC;
       Miscellaneous materials;
       Construction debris;
       Contaminated soil;
       Chemical deicer and runoff from deicer; and
       Stormwater discharge.31
      From 1  Ports EMS/SMS Assistant Project, Final Report,. May 2006.
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Massport then identified the following potential environmental impacts:
•   Resources for maintenance fluids and parts;
•   Resources for electricity;
•   Water use;
•   Land for hazardous and solid waste disposal;
      Resources for paper and office supplies; and
      Pesticide/herbicide disposal.32
Some examples of environmental aspects and impacts the Port of Brisbane, Australia, identified in its
audit of all work sites and activities include the following:33
Environmental Aspect
Hosing down the deck of a vessel resulting in the
discharge of sediments, oils and greases into the
Spills of fuels and oils from parked vehicles entering the
waterway or paved areas through stormwater flows
Purchase of materials and equipment without due
consideration for environmental sustainability (i.e.,
excessive packaging, hazardous waste by-products,
excessive noise generation)
Environmental Impact
Contamination of the waterway through increased turbidity
and contaminants
Contamination of the soil, groundwater, and surface
Depletion and inappropriate use of natural resources
Environmental aspects and their indicators may cover universally accepted performance related to inputs
(e.g., materials, energy, water) and outputs (e.g., emissions, effluents, and waste), as well as
performance related to biodiversity, environmental compliance, environmental expenditures, transport,
and the impacts of products or services.

For example, the Gijon Port Authority, Spain, participated in a 2006 research study assessing the port's
"ecological footprint" as a macroindicator of sustainability.34 Until that time, this macroindicator had been
applied to cities, regions, or countries, but not entities such as ports. Ecological footprints account for the
consumption of natural resources by converting them into hectares (ha) of "nature" or consumed
productive land. Parameters analyzed included consumption of energy, fuel, material, paper, wood,
water,  built land, and green areas, and residues generated by the port. The results showed a net
ecological footprint of 3,279.84 ha, comprising primarily construction works and electricity usage. Studies
of this  kind may enable ports to design sustainable development plans to reduce consumption as well as
develop green services and create "natural capital," as the scope of impact is better understood.

The Port of Portland developed and implemented a  natural resources assessment and  management plan
(NRAMP), a management and planning tool that provides port staff with a single source of all natural
resource data (including inventories and maps) about port and surrounding properties.  In addition,
NRAMP contains modeling, alternatives analysis, monitoring, and adaptive management features that
allow port staff to evaluate the potential effects of management actions on the resources.35
    32 Massachusetts Port Authority Sustainability Plan, October 2004;
pdf/massport sustainability  plan.pdf, accessed March 28, 2007.

    33 See, accessed March 30, 2007.

    34 See abstract on second to last link on the following web page: www.pubsindex.trb.orq/document/view/
multi.asp?pub=1&recordlist=792675%7C, accessed March 30, 2007.

    35 See AAPA award to this port at www.aapa-ports.orq/Proqrams/content.cfm?ltemNumber=
748&navltemNumber=696: accessed April 2, 2007.
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Other broader aspects of sustainability may
also already be captured through an EMS. For
example, social aspects, such as occupational
health and safety, training and education,
security practices, community
relations/involvement, and compliance, may be
addressed within an EMS (e.g., through
Element 2, Environmental Policy Statement, or
through subsequent elements).
  Under the Global Reporting Initiative Framework,
  Sustainability Common Denominators Include the
 Following Economic & Social Aspects or Indicators:

•   Flow of capital among different stakeholders
•   Main economic impacts of the organization
    throughout society (e.g., economic performance,
    market presence, indirect economic impacts)
Social: Labor Practices & Decent Work
•   Employment
•   Labor/management relations
•   Occupational health & safety
•   Training & education
•   Diversity & equal opportunity
Social: Human Rights
•   Investment & procurement practices
•   Non-discrimination
•   Freedom of association & collective bargaining
•   Complaints & grievance practices
•   Security practices
Social: Society
•   Community
•   Corruption
•   Public policy
•   Anti-competitive behavior
•   Compliance
Social: Product Responsibility
•   Customer health & safety
•   Customer privacy
•   Compliance

Source: Global Reporting Initiative website,
nline/Performancelndicators/, accessed April 20, 2007.
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Element 5: Establish Objectives, Targets, and Action Plans

                Once you have identified your SEAs, you are also ready to set environmental objectives
                and targets. Objectives and targets help your port continuously improve its
                environmental performance. An environmental objective is an overall environmental
                goal arising from your port's environmental policy statement (Element 2). Environmental
                targets are detailed performance requirements that are based on an environmental
                objective and are quantified whenever practicable. While all SEAs need operational
                controls, not all need objectives and targets. In setting objectives and targets, the port
should consider its environmental policy commitments to  __^^^^^^^^_^^^^^^^^^^^	T;
prevent non-compliance, prevent pollution at its source,
minimize cross-media pollutant transfers, and
continuously improve its environmental performance.
                                                   In Setting Objectives & Targets, Keep Your
                                                  Environmental Policy Commitments in Mind
                                                     While Also Considering the Following
Action plans document SEAs, operational controls,
objectives, and targets. Action plans, also known as
Environmental Management Plans (EMPs) or
Implementation Plans, translate your policy
commitments into concrete actions - they form the
bridge between concept and application.  EMPs should
define: (1) the responsibilities for achieving the
objectives (i.e., who will do it?); (2) the means for
achieving objectives (i.e., how will they do it?); and  (3)
the timeframe for achieving the objectives (i.e., when?).
Keep in mind that EMPs should be dynamic. For
example, consider modifying your programs when
objectives and targets are modified or added; relevant
legal requirements are introduced or changed;
substantial progress in achieving your objectives and targets
your services, processes, or facilities change; or other issues
                                                      Legal and other requirements
                                                      Statewide environmental initiatives
                                                      External trends & influences
                                                      Stakeholder concerns/views
                                                      Business/operational needs & financial
                                                      Organizational considerations
                                                      Technological options
                                                      Port's ability to control, track, & measure
                                                      Cost to track & measure
                                                      Progress reporting
                                                  has been made (or has not been made);
                  Considerations for Developing Objectives and Targets
       Views of
     Potential for
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Targeting their SEAs and considering other factors, ports have developed general objectives (e.g.,
minimize impacts to air quality, minimize impacts to water resources, reduce waste generation and
hazardous materials use, minimize impacts and seek opportunities to enhance natural resource, reduce
energy consumption, purchase energy from sustainable sources) as well as detailed, specific targets.
Three examples are provided below from the 1st Ports EMS/SMS Assistance Project.

The Port of New York and New Jersey selected public berthing areas, maintenance facilities, and
dredging operations as its fenceline; identified 10 SEAs within the fenceline; developed operational
controls for all 10 (see  Element 6); and set objectives and targets for 3:

1.   Reduce water loss at the Public Berthing facilities in NY and NJ in volume and cost by 20% by
    December 2006. Due to the nature of the water distribution system configuration at NJ Marine
    Terminal, the scope of this effort was expanded to cover the entire NJ facility.
2.   Reduce solid waste from fender system repairs at the public berthing facilities in NY and NJ by 25%
    by May 2007 by specifying the use of more structurally resilient material and recycling old fenders.
3.   Reduce NOx emissions from dredging  operations for the Harbor Deepening Project to a net zero on
    an annual basis starting June 2005 and ending by December 2014.

The Port of Portland, which selected two facilities for its fenceline - Marine Facility Management (MFM)
and Portland International Airport (PDX)  General Maintenance - established the following objectives and
targets for 2004/2005 maintenance operations:

1.   Objective: Minimize Impacts to Air Quality. Targets: Reduce idling/transaction time by 50% at PDX
    parking toll plaza by June 2005; take five actions by June 2005 to reduce diesel particulate
    emissions; and identify air quality improvements through energy source changes for PDX gate &
    ground service equipment by completing  preliminary engineering & economic evaluations by June
2.   Objective: Minimize Impacts to Water Resources. Targets: Complete water efficiency evaluations for
    three port water systems by June 2005; and reduce the amount of treated timber chocks at T6
    container yard by 20% by June 2005.
3.   Objective: Reduce Waste Generation and Hazardous Materials Use. Targets: Assess environmental
    and safety impacts of chemical products used  at Aviation  and Marine maintenance facilities and
    eliminate or substitute at least six products at PDX by June 2005 and another six at MFM by March
4.   Objective: Minimize Impacts and Seek Opportunities to Enhance Natural Resources. Targets:
    Organize a weekend event for Port staff to clean up Port-owned shorelines by June 2005.
5.   Objective: Reduce Energy Consumption. Targets: Evaluate new technology to determine financial
    and technical viability and of the Eco-start motor energy controller [placeholder target until evaluation
    is completed]; and conduct three building energy audits at port facilities and implement viable projects
    by June 2005.
6.   Objective: Purchase Electric Energy from Sustainable Sources. Targets: Purchase 3% of PDX's, 5%
    of Marine's, and 5% of the Port Building's electric power from sustainable wind-generated sources in

The Port of Virginia identified 45 SEAs and then chose to address its remote fueling operations,
corrective and preventive maintenance processes, container/strad wash area operations, and the
facilities' lighting replacement program at Norfolk International Terminals (its fenceline) as follows:

1.   Objective: Reduce potential for fuel spills from  remote fueling operations. Target: Upgrade remote
    fueling equipment and implement procedures with the target of reducing spill frequency by 10%.
2.   Objective: Reduce use of energy inefficient F-40 lamps and magnetic ballasts in office areas. Target:
    Replace 75% of all F-40 light fixtures with T-8 fixtures by 2007.
3.   Objective: Establish methods to decrease the waste products from performing corrective and
    preventive maintenance and to ensure these by-products are properly disposed of or recycled.
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    Target: Benchmark the amount of recyclable waste and develop goals that will increase recycling
    efforts by June 2006.
    Objective: Reduce the zinc level in waste water from container and straddle carrier wash down
    operations. Target: Reduce the monthly sampled zinc levels in the waste water stream by 25% from
    calendar year 2005 average level at the Container and Straddle Carrier Wash Area by December
In developing its Green Port Policy, the Port of Long Beach conducted a gap analysis to document what it
was doing as well as what more it needed to do, and then used that information to set objectives and
targets. The resulting Green Port Policy includes six basic program elements (four specific environmental
elements as well as broader social and overarching sustainability elements), each with an overall goal:

•  Wildlife - Protect, maintain or restore aquatic ecosystems and marine habitats;
•  Air - Reduce harmful air emissions from Port activities;
•  Water - Improve the quality of Long Beach Harbor waters;
•  Soils/Sediments - Remove, treat, or render suitable for beneficial reuse contaminated soils and
   sediments in the Harbor District;
•  Community Engagement - Interact with and educate the community regarding Port operations and
   environmental programs; and
•  Sustainability - Implement sustainable practices in design and construction, operations, and
   administrative practices throughout the Port.

In addition to overall principles and the goals for each  component, the policy includes metrics (scientific
measurements of the port's environmental progress), and a commitment to regular reporting. The port
has been developing metrics for various elements; those that have been developed are presented in
periodic updates as well as the 2005 Green Port Annual report.36 Note that the port has not developed
numerical goals or metrics for either community engagement or sustainability; rather, progress on those
two elements is reported as it occurs.

Massport has also developed Sustainable Design goals that address:

•  Asset Management - Increase value and revenue generating potential of projects, demonstrating to
   developers/investors that port is a competent partner;
•  Environmental Benefits/Permitting Strategy - Reduced impacts and permitting time;
•  Citizenship - Positive community impact by demonstrating that port is actively reducing
   environmental impacts; and
•  Design Excellence - Innovative, aesthetic and responsible design.37

In 2006, Massport achieved LEED Certification for the world's first LEED-certified airport terminal, Boston
Logan International Airport's Terminal A.38 The Leadership in Energy and Environmental Design Green
Building Rating System™ is the nationally accepted benchmark for the design, construction, and
operation of high performance green buildings.
    36 See port annual.asp, accessed March 28, 2007.

    37 Why Build Green? ACI-NA Environmental Affairs Committee Meeting, May 15, 2005; www.aci-
na.orq/docs/41%20SAN%2005%20Catherine%20Wetherell%20Massport%20LEED.pdf: accessed March 28, 2007.

    38 See news taleed.html. accessed March 28, 2007.
Interim Final Draft, April 2007                         21                   U.S. Environmental Protection Agency

An EMS Primer for Ports: Advancing Port Sustainability
Element 6:  Develop Operational Controls
     Continual  *•
    Improvement tj
                Operational controls are
                documented procedures,
                work instructions, BMPs,
                posted placards, and action
                plans that ensure that
                operations and activities
                (such as wastewater
discharge monitoring, waste management, and
environmental performance improvement) are
carried out effectively. At least one operational
control should be in place for each SEA
identified in Element 4 to ensure compliance
with legal requirements and company policies
or to achieve improvement objectives.
Ports may already document most of the
operational controls needed at the facility, so it
is likely you would not have to start from
scratch. Ports that have implemented EMSs
have documented operational controls to
address compliance assurance and
environmental improvement objectives.  The
following examples are from the 1st Ports
EMS/SMS Assistance Project.
             Sample Activity Areas &
          Operational Controls for a Port

Water quality management:
•   Connect floor drains to sanitary sewer or dead-end
•   Provide adequate space for storage of chemicals and
    waste products.
•   Provide oil/water separators on floor drains.
•   Pave fueling areas with concrete rather than asphalt.
•   Design fueling areas to prevent the run-on of storm
    water and the runoff of spills.
•   Use sand filters to capture spills and runoff of paint
    stripping operations.
•   Ensure adequate secondary containment for
    catastrophic failures of bulk liquid storage facilities.
Air quality management:
•   Install and maintain vapor recovery systems for
    fueling operations and for storage and handling of
    bulk liquids.
•   Install dust suppression mechanisms for dry bulk
    storage and handling  activities.
•   Provide paint booths to contain overspray and treat
    air emissions when painting equipment.
•   Cover painting/stripping area.
•   Minimize the quantity of soil exposed at one time
    during construction activities.
                                              Source: AAPA. Environmental Management Handbook.
                                              September 1998. http://www.aapa-
•   The Port of Los Angeles, for example,
    developed operational controls as part of
    its EMS, establishing standard operating
    procedures (SOPs) for SEAs.
    Documenting these operational controls promoted "buy-in" from all employees into the EMS,
    ownership from employees of the significant activities, transfer of institutional knowledge from long-
    time staff to new employees, and assurance that all shifts conduct the activities under SOPs.

•   The Port of Vancouver also saved operator institutional knowledge by clearly documenting through its
    EMS procedures for drinking water system operation and compliance management. Formalizing
    previously informal processes ensures that institutional knowledge of long-time port employees is

There are a number of ways that ports can ensure that operational controls are implemented by those
with whom the port does business.

•   The Port of Houston Authority is putting environmental performance expectations for air emissions in
    construction  contracts and in tariffs with stevedores. The port also has documented "roll down"
    clauses in  its contracts; if tenants, vendors, or contractors cause a notice of violation (NOV), they may
    be fined or fired by the port.

•   The Port of Seattle has a memorandum of agreement (MOA) with the cruise industry, which is now
    using low-sulfur fuel and shore-side electric power for cruise ship auxiliary power needs at dock.

•   The Ports of Los Angeles and Long Beach have supplemented the requirements in their tenant
    leases. While it is common practice for ports to articulate in their leases that their tenants must
Interim Final Draft, April 2007
                     U.S. Environmental Protection Agency

An EMS Primer for Ports: Advancing Port Sustainability

    comply with applicable environmental laws     ™~
    and regulations, these two ports have used
    additional "green lease" language with
    some of their marine terminal tenants.
    These ports are in a position to do this
    because  of the scarcity of highly desirable
"Morale is high. When we presented the EMS initiative to
our maintenance and facility personnel, we stressed that
the suits are not coming down and telling you what to do.
We all work side-by-side, and when we start identifying
procedures, everyone is involved in the process." — Rick
Larrabee, Director, Port Commerce Department, Port
    land available for marine terminals in the     I  Authority of New York & New Jersey
    country's busiest import market, and
    because of severe air pollution and            f°urce: EPA; ^A & GETf- Environmental
                     ,        , .       .        i  Management Systems: Systematically Improving your
    extreme pressure from regulators and        j  Perforymance: Pyorts Sectoyr] September 2004.
    other stakeholders to reduce the human
    health risk of port-related operations.39 The
    lease agreement signed by the Port of Los Angeles and P&O Nedlloyd in January 2006 requires that
    the following operational controls be used:

    o  Switch to low sulfur (1.5% or less) fuel in main and auxiliary engines of container ships when 40
       nautical miles of the port;
    o  Reduce vessel speed when within 40 nautical miles of the port;
    o  Outfit ships for Alternative Marine Power (AMP), i.e., ship to shore-side power - 30% by the end
       of the 2nd year, 70% by the end of the 3rd year;
    o  Use alternative fuel, e.g., liquefied natural gas (LNG), in yard tractors;
    o  Use emulsified fuel and Diesel Oxidations Catalysts (DOC) on older yard equipment, where
    o  Use on/near dock rail;
    o  Use non-ozone depleting compounds in refrigerated containers; and
    o  Use housekeeping/maintenance procedures that limit water use and minimize discharges.40
Operational controls extend to other sustainability measures, including community relations. For example,
reporting a release or oil spill to the federal, state, or local government (see Element 7) entails following
documented procedures. A port may also develop BMPs to convey such information to the public as well
as crisis communication plans to address media inquiries (see Element 9).41
     39 For further information, see the San Pedro Bay Port Clean Air Action Plan, the most comprehensive strategy
to cut air pollution and reduce health risks ever produced for a global seaport complex; air.htm.

     40 Port of Los Angeles press release entitled, Port of Los Angeles Harbor Commissioners Certify Environmental
Impact Report with Landmark Environmental Measures, dated January 19, 2006, BHC%20Approves%20206-209%20EIR.pdf. accessed April 25, 2007.

     41 See www.aapa-ports.orq/search/browseResults.cfm?MetaDatalD=27 for several presentations on
communications and the media; AAPA's 2006 seminars. The Port Manatee Crisis Communications Plan is also
provided as a best practice manual on AAPA's web site; see
lssueDetail.cfm?itemnumber=1146. Both sites accessed March 28,  2007.
Interim Final Draft, April 2007                          23                   U.S. Environmental Protection Agency

An EMS Primer for Ports: Advancing Port Sustainability

Element 7: Develop Emergency Preparedness and Response

                Despite a port's best efforts, accidents and other emergency situations may occur.
t                Effective preparation and response can reduce injuries, prevent or minimize
                environmental impacts, protect employees, and neighbors, reduce asset loss, and
                minimize downtown. An effective emergency preparedness and response program
                (EP&R) should include provisions for (1) assessing the potential for accidents and
                emergences;  (2) preventing incidents and their associated Els; (3) responding to
                incidents through emergency plans and procedures; (4) testing of emergency plans and
procedures periodically; and (5) mitigating impacts associated with accidents and emergencies. Like
Element 6, Operational Controls, this is another area where you should not have to start from scratch,
since several environmental, health & safety (EH&S) regulatory programs require emergency plans
and/or procedures, for example:

•   Clean Air Act Amendments: Risk Management Program;
•   Clean Water Act: Spill Prevention, Control and Countermeasure Plan (SPCC) and Storm Water
    Pollution Prevention  Plans;
•   Emergency Planning and Community Right-to-Know Act: Community Right-to-Know Reporting and
    Coordination with Local and State Emergency Response Committees;
•   Oil Pollution Act: Facility Response Plan (portions of port not subject to USCG contingency plan
    requirements) and SPCC;
•   Resource Conservation and Recovery Act: Contingency Plan (for large quantity generators) and
    Preparedness and Prevention Plans (for large quantity and small quantity generators); and
•   USCG: Facility Response Plan (FRP).

The Occupational Safety and Health Act also requires Process Safety Management controls.
Some ports address these numerous EH&S requirements through Integrated Contingency Plans (ICPs),
which combine the requirements of numerous regulatory programs into one plan. The federal government
has issued guidance for such a plan, known as the "One Plan." To access information on the One Plan,
use the following website link to EPA - -
and scroll down to the section entitled: "The National Response Team's Integrated Contingency Plan
Guidance (One Plan)."
Following up on enhancements noted in Element 3, Legal Requirements, and FRP requirements noted
above, ports should be in compliance with new USCG security regulations, which are in place to protect
commerce, port assets, and personnel. The federal government is also funding other port security and
supply chain pilot programs. For example, the Ports of Seattle and Tacoma, the Port Authority of New
York and New Jersey, and the Ports of Los Angeles and Long Beach are leaders in Operation Safe
Commerce, a federal program designed to create the knowledge base required for international
standards for containerized shipping.

Regarding lessons learned in recovering economically from natural disasters, including keeping the
community informed:42
    42 See www.aapa-ports.orq/search/browseResults.cfm?MetaDatalD=27 for several presentations on lessons
learned regarding emergency management, disaster recovery, and security; AAPA's 2006 seminars; accessed March
27, 2007.
Interim Final Draft, April 2007                        24                 U.S. Environmental Protection Agency

An EMS Primer for Ports: Advancing Port Sustainability
•   Ports have developed business Continuity of Operations (COOP) plans - advance procedures that
    allow critical business functions to continue during a disaster.43

•   Following Hurricane Katrina, however, the Port of New Orleans noted its comprehensive Hurricane
    Preparedness Plan simply could not envision the extent of the storm's aftermath, which  affected
    96,000 square miles- an area larger than the  British Isles.44 The plan, for example, provided for (1)
    preparation and clean up, but not how to provide housing for employees; (2) communications network
    based on cell phones, but no provisions for 300 cell towers being destroyed; and (3) short evacuation,
    but not for extended evacuation of 90 days or more. Following Katrina port staff improvised by:

    o  Establishing two headquarters: an operational headquarters in New Orleans staffed by key
       personnel led by President & CEO Gary LaGrange, as well as an administrative headquarters in
       Atlanta led by COO Dave Wagner- eventually moved to Ponchatoula, LA, courtesy of Port
    o  Establishing lines of communication with key senior staff;
    o  Remotely accessing main frame computers; and
    o  Arranged housing through MARAD.

    The port summarized  its lessons learned as follows:

    o  Chain of Command - Know where staff are, provide for multi-tasking;
    o  Communications - Establish guidelines for worst case scenarios;
    o  Lines of Responsibility - Back up chains for major catastrophes;
    o  Housing - Establish temporary quarters;
    o  FEMA - As a partner rather than a leader; and
    o  Media Relations - Be accessible, be positive, and lead the way.

•   Shortly after the devastating hurricanes of 2005, AAPA convened a working group that sponsored five
    workshops over six months to collect member  experiences with emergency planning and disaster
    recovery. With the information gathered from these workshops, AAPA has developed an emergency
    preparedness and COOP planning manual for its members.45
    43 See, for example, "Business Continuity Port Operations," Cosmo Perrone, Director of Security, Port of Long
Beach, presentation at 2006 AAPA Emergency Preparation and Response Seminar, www.aapa.files.cms- accessed March 28, 2007.

    44 "Crisis Management and How Hurricane Katrina Changed the Dynamics", J. Robert Jumonville, Sr., Director
of Cruise and Tourism, Port of New Orleans, presentation at AAPA 2006 Cruise Seminar, www.aapa.files.cms-, accessed March 28, 2007.

    45 AAPA, Emergency Preparedness and Continuity of Operations Planning Manual for Best Practices,
http://www.aapa-ports.0rg/lssues/lssueDetail.cfm?itemnumber=1161: accessed March 27, 2007.

Interim Final Draft, April 2007                        25                   U.S. Environmental Protection Agency

An EMS Primer for Ports: Advancing Port Sustainability
Element 8: Set Up a Training Program for Competence and

                Each person and function within a port can play a role in environmental management.
                Employees, tenants, and managers should be aware of the environmental policy, the
                SEAs and related procedures that apply to their work, key EMS roles and
                responsibilities, and the importance of meeting EMS requirements. Employees also
                should understand what might happen if they don't meet EMS requirements, such as
                spills, releases, and fines or other penalties.
All employees will require environmental
awareness training that covers an introduction to
EMSs, the port's environmental policy, SEAs and
environmental goals. Employees whose jobs are
associated with SEAs will also require appropriate
task-specific training and support to be competent
in their work. Training is just one element of
establishing competence, which is typically based on
a combination of education, training, and experience.
                                                Examples of Areas Where Training is Needed

                                                  Legal and other requirements
                                                  Ability to  recognize new problems
                                                  Technical skills needed to solve problems
                                                  Procedures to implement operational controls
                                                  Any new procedures or needs related to SEAs
                                                  Awareness  of the port's environmental policy,
                                                  EMS, and objectives
Improved environmental awareness on the part of employees, as well as tenants and other contractors, is
a benefit of EMS programs. Unless otherwise noted, the following examples are from
Assistance Project.
                                                                          Port EMS/SMS
                                                           Types of Personnel Training
The Port of Los Angeles conducted EMS General
Awareness training sessions, which increased
communication of environmental issues and, in turn,
broadened port-wide awareness of issues within the
fenceline. Its EMS Internal Auditor training also reinforced
the concept that the results of internal audits drive the
continual improvement of an EMS and, as a result,
improve environmental performance.
    The Port of Houston conducts environmental training for its
    tenants twice per year. These sessions started out as
    awareness training, but as the knowledge level of the
    tenants has increased, the training has become more
    detailed and now focuses on changes or potential changes
    to applicable regulations. If the port's tenant audit program identifies any widespread weaknesses,
    the port will arrange training on those topics.46

    The Port of Corpus Christ! conducts  extensive environmental training for its employees and places
    posters and brochures in areas where employees will see them. The port has customized its training
    by type of employee and has also developed wallet-sized cards that list significant aspects for each
    job (e.g., painting crew, welding crew, mechanic).47
                                                                    (All personnel)
                                                                (For personnel
                                                               associated with
 46 Phone conversation with Aston A. Hinds, Environmental Affairs Manager, Port of Houston Authority, April 20,

 47 Phone conversation with Sarah Kowalski, Environmental Compliance Manager, Port of Corpus Christ!
Authority, April 20, 2007.
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An EMS Primer for Ports: Advancing Port Sustainability
•   Under its voluntary Green Ports Tenant Environmental Awareness Program, the Port Authority of
    New York and New Jersey developed and presented an environmental awareness program for the
    port's Seaport tenant community. This program, free of charge to tenants, presented a
    comprehensive review of environmental aspects affecting tenant business operations including legal
    regulatory requirements, BMPs, pollution  prevention, "green" design and construction, permitting
    requirements, and grants and financial incentives.48
Ports are beginning to look more broadly at sustainability training. For example, the Port of Long Beach
has developed a sustainability training DVD for employees at the port. Ports may include LEED
certification in their sustainability training. As previously noted in Element 5, Massport is actively pursuing
LEED certification for many of its green building efforts.

AAPA itself has already started providing training on sustainability for its members. For example, a
session on port sustainability was offered at the June 2006 meeting of AAPA's Harbors, Navigation, and
Environment Committee.49
    48 See AAPA award to the port at www.aapa- accessed April 2, 2007.

    49 The presentations from this session can be downloaded from the AAPA website. Please visit:
Interim Final Draft, April 2007                         27                  U.S. Environmental Protection Agency

An EMS Primer for Ports: Advancing Port Sustainability
Element 9: Create a Communications Strategy
     Continual  |H
    Improvement tj
            An EMS should define the process for proactive, two-way, internal and external

            Internal communication should provide information about environmental requirements
            and voluntary commitments to all employees, on-site service providers, and contractors
            whose work could affect your ability to meet those requirements and commitments.
External communication should provide information on your environmental programs and
accomplishments to other stakeholders and include a way to provide feedback. Stakeholders include
anyone who has a stake in  your facility's environmental performance.
You may appoint a community liaison to
manage external communications concerning
EAs at your facility, for example, responding to
inquiries from interested parties and regulatory
agencies; sending current copies of the
environmental policy to interested parties, and
responding to media inquiries.
                                           Internal Stakeholders Include: Employees,
                                           shareholders, customers, suppliers, investors & insurers,
                                           trading partners, etc.

                                           External Stakeholders Include: Neighbors, community
                                           organizations, environmental groups, other external
                                           companies, the media, the general public,  etc.
Through communications programs, ports are able to convey their EMS policy, objectives, targets, and
progress to date. EMS improves cross-functional communications and cooperation.  The following
examples are from the 1st Ports Ems/SMS Assistance Project:

•   EMS Core Team meetings at the Port of Los Angeles and Port of Portland, for example, created a
    forum where employees from different divisions could come together to discuss specific
    environmental topics. Use of these forums increased the ports' communications on environmental
    issues and, in turn, broadened  awareness of port-wide issues throughout the fenceline.
•   Creation of the EMS at Los Angeles also
    included a Continual Improvement Form
    (GIF) that was widely distributed throughout
    the facility and continues to be available for
    all employees. This form has acted as a
    communications tool for employees to
    identify and record environmental concerns
    as they are observed, and for management
    to respond to issues identified.
                                           "Because a residential area abuts our port, outreach to    ||
                                           the surrounding community is a priority. At Massport, we   ||
                                           strive to be good corporate citizens as well as good       ||
                                           neighbors. Informing the local community about various   |
                                           Massport programs and initiatives at our facilities helps    |
                                           us to accomplish this. Our efforts to implement more      |
                                           sound environmental policies, such as those outlined in   Ij
                                           the EMS, are certainly appreciated and in this case       ]
                                           applauded." — Michael A. Leone, Port Director, Massport  jj
                                               Source: EPA, AAPA & GETF. Environmental
                                               Management Systems: Systematically Improving your
                                               Performance: Ports Sector, September 2004.
The Port of Vancouver increased staff,
tenant, and contractor awareness of
potential impacts to its wellhead protection
area (its fenceline) by preparing voluntary
drinking water quality confidence reports for tenants and other water users, installing wellhead
signage, and creating an Automotive Hazardous Waste Disposal Flyer for tenants.
Some ports are expanding their community relations as part of their ongoing EMS programs.

•   Massport's approach to sustainability includes a goal of developing an EMS for each facility. These
    EMS projects are showing Massport's leadership and corporate citizenship by going beyond 1-way
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U.S. Environmental Protection Agency

An EMS Primer for Ports: Advancing Port Sustainability
    public relations to 2-way dialogues. "By
    pledging our commitment to public service
    leadership, we accept Massport's obligation
    to serve multiple stakeholders, each of
    whom should be considered in the
    development of our policies and our day-to-
    day decision-making. We acknowledge that
    only through open communication and with
    an open mind, weighing equally all sides of
    an issue, can we find resolutions that will
    benefit the greater public good."50

•   Other ports, such as the Port of Long
    Beach, are looking at a tiered approach to
    sustainability communications - first looking
    within their organization (i.e., at their
    employees, over whom they have direct
    control (see discussion of scope in Element
    1)), and then developing a strategy to
    involve tenants and the broader community.

•   The Port of Brisbane, Australia, developed a
    Community Consultative Committee, which
    comprises representatives from              .^^=^^^^^^^^^_^^^=^~^^^^^^^	
    conservation, business, and community groups with an interest in the port's activities and its impact
    on neighboring communities. This committee provides a link to stakeholders and local communities
    through which the port raises awareness about its activities, development, and plans for the future.
    The committee meets quarterly.51

As part of their external communication strategy to engage the community in decisions that affect them,
ports can become  attuned to operational improvements that, while seemingly minor, make a large,
positive difference to the surrounding community.

•   To minimize noise pollution, some ports have  been able to reduce the backup alert beeper on trucks
    and equipment to a level that ensures safety while also reducing decibels.

•   To reduce their visual impacts, ports have painted their cranes blue or gray so they blend better in
    with the sky and water; others have  purchased cranes that can partially retract when not in use.

•   Fremantle Ports-Western Australia funded the planting of 4,805 trees over three years in the Lake
    Chinocup catchment area in the Great Southern. Not only are these trees visually pleasing, but also
    they offset the greenhouse gases emitted by the port's vehicle fleet.52
         What Communities Sometimes Fear
             Or Don't Like About Ports

     Air & water pollution, & potential health effects
     Road congestion
     Destruction of wetlands, habitat
     Land contamination, including brownfields
     Noise during construction & operation
     Night lighting & glare
     Visual impacts (e.g., "ugly"  cranes, bright lights)
     Competition with recreational uses of water/land
     Disturbance of cultural resources

        What Communities Want From Ports
              (Besides Jobs & Goods)

     A say in decisions that affect their lives
     A transparent decision-making process, especially
     for new projects
     Monitoring & reporting on environmental issues,
     e.g., ambient air & water quality monitoring
     Objectives/targets for continuous improvement in
     environmental performance
     50 Massport Sustainability Plan, October 2004,
massport sustainabilitv  plan.pdf. accessed March 28, 2007.

     51 See accessed March 30, 2007.

     52 See accessed March 30, 2007.
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U.S. Environmental Protection Agency

An EMS Primer for Ports: Advancing Port Sustainability
Element 10: Set Up Documentation for the EMS
     Continual  *•
    Improvement tj
Documentation is a requirement of an EMS, but it should not be the main emphasis.
Limit your documentation efforts to the minimum necessary. EMS documentation is
different than EMS records. EMS documentation describes what you do and how you
do it, while EMS records demonstrate that you are doing what the documentation said
you would do.
                Some sort of EMS Manual, either electronic or hard copy, can be your EMS
documentation and should:
    Describe the core elements of your EMS
    and how the elements interact; and
    Provide direction to related documentation.
Record keeping and document management
improve port scheduling, tracking, and funding
projections, and establish a systematic record
for tracking environmental initiatives and
developments. As noted in the 1st EMS/SMS
Assistance Project Final Report:

•   Through its documented system, the
    Portland District-USACE has been able to
    share EMS information with other projects
    and USAGE leadership.

•   The Port of Corpus Christ! Authority's EMS
    program has changed the way the Port
    manages its environmental affairs.
    Employees have seen the many benefits of
    the EMS program, including documented
    procedures, and are extending the
    consistent approach of the EMS program
    beyond the EMS fenceline.
                                 Documentation Should Be Available for All EMS
                                           Components, Including:

                                   Environmental policy
                                   Organization chart or lists/tables of key
                                   Description of how the port satisfies the EMS
                                   System-level procedures (e.g., procedures for
                                   corrective & preventive action)
                                   Activity- or process-specific operational controls
                                   (e.g., SOPs, work instructions)
                                   Other EMS-related documents (e.g., emergency
                                   preparedness & response plans, training plans)

                                      Records You Might Maintain Include:

                                   Legal, regulatory, and other code requirements
                                   Results of EA identification
                                   Reports of progress towards meeting objectives &
                                   Permits, licenses, & other approvals
                                   Job descriptions & performance evaluations
                                   Training records
                                   EMS audits and regulatory compliance audit reports
                                   Reports of identified nonconformities, corrective
                                   action plans, & corrective action tracking data
                                   Hazardous materials spill/other incident reports
                                   Communications with customers, suppliers,
                                   contractors,  & other external parties
                                   Results of management reviews
                                   Sampling & monitoring data
                                   Maintenance records
                                   Equipment calibration records
As part of the Ports 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. Ports and other EMS implementers
often seek such tools 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. The results of this 2004 assessment may be found at EMS software packages can offer the following
benefits to users: 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,
     ' "EMS Software Comparison", March 15, 2004, updated April 21, 2004, & June 23, 2004, accessed March 28,
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U.S. Environmental Protection Agency

An EMS Primer for Ports: Advancing Port Sustainability
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; and information access security controls.
Strong documentation and records management should be part of any port's BMPs. Documenting
broader stewardship efforts in the areas of social responsibility and economic prosperity may require new
procedures. Clearly, EMS tracking systems are optimized if they integrate with other management
systems, such as a port's financial tracking software.

The recent San Pedro Bay Ports Clean Air Action Plan, approved  November 20, 2006, by the Port of
Long Beach and the Port of Los Angeles, sets a precedent for documentation.54 San Pedro Bay is
currently in non-attainment with federal air quality standards, and without a comprehensive strategy would
never reach attainment given projected growth in container freight through these two ports. The plan sets
specific goals and targets, with documentation systems and report backs to stakeholders on all elements
of plan implementation. Specific activities include:

•  A truck replacement  program to phase out all "dirty" diesel trucks from the ports in five years,
   replaced with a new  generation  of clean or retrofitted vehicles and driven by people who earn at least
   the prevailing wage;
•  Aggressive milestones with measurable goals for air quality improvements;
•  Recommendations to eliminate emissions of ultra-fine particulates;
•  A technology advancement program to reduce greenhouse gases (GHG); and
•  A public participation process with environmental organizations and the business communities.
    54 For further information, see the San Pedro Bay Port Clean Air Action Plan, the most comprehensive strategy
to cut air pollution and reduce health risks ever produced for a global seaport complex, visit:
www.portoflosanqeles.orq/environment air.htm.
Interim Final Draft, April 2007                        31                  U.S. Environmental Protection Agency

An EMS Primer for Ports: Advancing Port Sustainability
Element 11: Monitor, Measure,  Evaluate, and Record Performance
                                                      "What gets measured is what gets done."
                                                                  Tom Peters
                Building on Element 4 where     jj
                «you identified SEAs, your port    |
     continual       needs to know what it is          j
    mptwement      monitoring and measuring and    j                                               \
    ,.   _^      to have established a solid
   iJ|||pPr    baseline against which to gauge process. Monitoring and measurement helps you to
                manage your port better  by allowing you to measure environmental performance,
analyze root causes of problems, and assess compliance with legal requirements. This element means
that your port:

•   Monitors operations and activities that can have significant environmental impacts and/or compliance
•   Tracks performance (including your progress in achieving your goals);
•   Measures and reports on continuous improvement in environmental performance via the EMS;
•   Calibrates and maintains monitoring equipment; and
•   Periodically evaluates compliance with  applicable  laws and regulations through internal audits.
Ports that have implemented EMSs have
reported substantial benefits through systematic
monitoring and measurement programs.

Earlier in this primer, Element 5 provided
objectives and targets for the Port of New York
and New Jersey, including activities around
water loss and reduced NOx emission. Adoption
of an EMS generated the following quantifiable
benefits at the port:

•   In 2005, repaired several water leaks that
    reduced the average daily water loss by
    640,000 gallons and saved approximately
    $655,000 in cost at NJ Marine Terminals.
    These actions resulted in saving and
    conserving 134 million gallons of water
    during 2005 and will contribute to
    substantial water savings for years to come.

•   Signed  an agreement with New York City
    Department of Transportation to retrofit the
    Staten Island Ferry Fleet and executed
    contracts in the Marine Vessel Engine
    Replacement Program that will achieve substantial air quality improvement. Reduction of NOx
    emissions resulting from these programs could exceed 400 tons per year and exceed that required to
    meet the General Conformity Requirements for the Harbor Deepening project.
                                                        Typical Performance Indicators
                                               •   Training
                                               •   Resource allocation
                                               •   Purchasing
                                               •   Funding
                                               •   Inputs (quantity of materials processed versus
                                                   recycled, or energy or water used, etc.)
                                               •   Operation & maintenance
                                               •   Emergency events & non-routing operations
                                               •   Outputs (e.g., waste, emission, noise, heat, light)
                                               •   Service provide by activity
                                               •   Safety (e.g., frequency of injuries, seriousness of
                                               •   Customer delivery (e.g., complaints, targets met)
                                               •   Production costs
                                               •   Sales & price
                                               •   Environment (e.g., Notices of Violations)
                                               •   Human resources (e.g., training days/employee,
                                                   turnover rates)
                                               •   Financial performance (e.g., earnings before
                                                   interest & taxes (EBIT), working capital)
Other measurable benefits identified by ports that participated in the 1s
Project include the following highlights:55
                                                                Ports EMS/SMS Assistance
      1  Ports EMS/SMS Assistance Project, Final Report, May 2006.
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U.S. Environmental Protection Agency

An EMS Primer for Ports: Advancing Port Sustainability
•   Port of Virginia - Cargo handling equipment purchasing program reduced air emissions by 30% over
    3 year period; received AAPA award;
•   Port of Portland - Reduced vehicle idling at parking gates by 79%; purchased 5% of marine electric
    power from sustainable, wind-generating energy sources; and
•   Port of Corpus Christ! Authority - Through its port-wide recycling program, saved $29K and diverted
    143K  pounds of waste materials from entering the local landfill; received local environmental
    conservation and stewardship award.

Ports have also conducted inventories to estimate emissions from mobile sources such as oceangoing
vessels, harbor craft, cargo-handling equipment, locomotives, and on-highway vehicles.56 An inventory
provides the baseline from which to create and implement emission mitigation strategies and track
performance overtime. Not all of the ports that have conducted these inventories have an EMS.
However,  the ports that do have EMSs in place will be able to systematically use the emissions data to
develop, implement, and monitor emissions  reduction strategies.
Environmental performance indicators are          ,,port Everglades operates in a
flexible enough to address indicators of broader     and in an area that is very dependent on tourist-related
Sustainability.                                  *  dollars. We have to be environmentally proactive. Our
                                                EMS is formalizing our practices and establishing an
•   With regard to economic indicators, for         operating philosophy that will sustain itself." — Ken
    example, Sustainability looks not only at      1  Krauter, Port Director, Port Everglades
    financial performance but also the port's
    contribution to the Sustainability of the larger    f °urce: EPA; ^A & GETf • Environmental           |
    economic svstem (e a  reaional economv)      Management Systems: Systematically Improving your    |
    economic system (e.g., regional economy;.   ,  Performance: Ports Sector, September 2004.           ii
    Ports are major economic drivers in their                                                       |
    localities; many are accustomed to tracking   ==^^
    their market presence and both direct and indirect regional economic impacts.

    Paying more attention to community concerns is a key attribute of a sustainable port. Through public
    outreach and communications efforts, ports also focus on their impacts on the communities in which
    they operate and involve citizens in decisions that affect them. The Ports Corporation of Queensland,
    Australia, for example, produces an annual Sustainability Report, which highlights its commitment to
    a Sustainability framework covering environmental, social, and economic performance.57

    Paying more attention to community concerns is a key attribute of a sustainable port. Through public
    outreach and communications efforts, ports also focus on their impacts on the communities in which
    they operate and involve citizens in decisions that affect them. The Ports Corporation of Queensland,
    Australia, for example, produces an annual Sustainability Report, which highlights its commitment to
    a Sustainability framework covering environmental, social, and economic performance.58 Similarly, the
    Port of Houston Authority publishes an annual Environmental Report that presents data on the port's
    performance in meeting its environmental objectives and targets.59
    56 In January 2006, EPA's Sector Strategies Program released a guide on current methodologies and best
practices for preparing port emission inventories. To see the guide, visit: the EPA Sector Strategies website at:
http://www.epa.qov/sectors/ports/bp  portemissionsfinal.pdf.

    57 See PCQ%20Sustainability WEB3.pdf, accessed March 30, 2007.

    58 See PCQ%20Sustainability WEB3.pdf, accessed March 30, 2007.

    59 To see the Port of Houston Authority's most recent Environmental Reports, please visit:
Interim Final Draft, April 2007                         33                   U.S. Environmental Protection Agency

An EMS Primer for Ports: Advancing Port Sustainability
    Through training, emergency preparedness and response, and other EMS elements, ports may
    already track a number of potential social indicators associated with labor practices.
Interim Final Draft, April 2007                         34                   U.S. Environmental Protection Agency

An EMS Primer for Ports: Advancing Port Sustainability
Element 12: Conduct Audits and Correct Problems
                Through measurement or other activities under Element 11, or through internal audits,
                you can assess whether your EMS is adequate and verify that your EMS plans are
                being followed.
                Internal auditing is a well-defined
                process that ensures:
                 •   Problems are identified and
•   Root causes are identified;
•   Corrective and preventive actions are assigned
    and implemented; and
•   Actions are tracked and their effectiveness is

Audits are pivotal to maintaining a viable system in
the face of accidents, emergencies, changing rules,
staff turnover, etc. By identifying and reporting EMS
nonconformities and deficiencies to your
management, you are able to:

•   Maintain management's focus on the
    environment;                                   •*		
•   Reassess, refine, and improve the EMS and its
    performance, including anticipation and prevention of future problems;
•   Ensure the cost effectiveness of the system.
          Audit Procedures Typically Describe:
         Audit planning
         Audit scope
         Audit frequency
         Audit methods
         Key responsibilities for the audits
         Reporting mechanisms for the audits
         Recordkeeping for the audit results

            EMS Problems Typically Include:
         Poor communication
         Faulty or missing procedures
         Equipment malfunction or lack of maintenance
         Lack of training
         Lack of understanding of requirements
         Failure to enforce rules
         Corrective actions that fail to address root
         causes of problems
Many ports have developed internal auditing
programs as part of their EMSs. EMS Internal
Auditor Training at the Port of Los Angeles, for
example, had the added benefit of reinforcing the
concept that the results of internal audits drive the
continual improvement of the EMS and, as a result,
improve environmental performance.

Ports such as the Port of New York and New Jersey
have used the results of internal audits to improve
the effectiveness of their EMS and enhance
conformity with ISO 14001 Standard. Several ports
have achieved ISO 14001 certification, including the
Falcon Terminal at Massport's Port of Boston, and
the Barbours Cut Terminal and central maintenance
areas at the Port of Houston Authority. Ports
worldwide are also meeting this international
standard, including the Port of Altamira, Mexico, and the Port of Halifax, Canada. In order to receive ISO
certification, organizations must pass audit by an independent third party.
                ISO 14001 Certification

     An organization can receive certification that its
     EMS complies with the requirements of the ISO
     14001 standard by undergoing an audit from a
     qualified, independent third party. When deciding
     whether to have an independent audit of your
     system, a port should consider whether:

     •   It is a contractual, regulatory, or market
     •   It meets customer preferences;
     •   It is part of a risk management program; or
     •   It will motivate your staff by setting a clear goal
         for the development of the EMS.

     Source: International Standards Organization,
     accessed April 24, 2007.
Auditing for broader sustainability measures is an extension of EMS auditing. Ports already conduct or
come under financial audits, for example, in compliance with federal, state, and local requirements.
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U.S. Environmental Protection Agency

An EMS Primer for Ports: Advancing Port Sustainability
Element 13: Conduct Management Review

                Management reviews are critical to continual improvement and ensure the EMS will
                continue to meet your port's needs overtime. A management review answers the
                question, "Is the system working?" (i.e., is it suitable, adequate, and effective, given the
                port's needs?).

                Your port's top management should review and evaluate your EMS at defined intervals,
                such as quarterly. While the scope of the review should be comprehensive, not all
elements need to be reviewed at once. Review of the policy, goals, and procedures should be carried out
by the level of management that defines them. The management review should include:

•   Results from assessment, including internal audits, and status of preventive and corrective actions;
•   Progress in meeting objectives and targets;
•   The continuing suitability of the EMS in relation to changing conditions and information; and
•   Concerns of relevant interested parties;
•   Follow-up actions from previous management reviews; and
•   Recommendations for improvement.

Management involvement ensures that the EMS is integrated not only in the port's  day-to-day operations
but also into its strategic planning process.
Ports involve their top management in         ||  ,,Qne"of the greatest^^ of havjng an—
periodic reviews of EMS projects. The Port of  |  the confidence that it provides. We know we are managing
New York and New Jersey, for example,       ||  Our environmental responsibility and lessening the potential
established a Management Review Team      |  of environmental problems." — John P. LaRue, Executive
comprising nine members who represent top   |  Director, Port of Corpus Christ! Authority
level management: the Directors of Port       ||
Commerce Department and the Office of      II  Source: EPA, AAPA & GETF. Environmental Management
Environmental Policy  Programs &            II  Systems: Systematically Improving your Performance:
Compliance, Assistant Port Commerce        |  P°^^!^^4-
Directors for Operations and Port Planning &   l!==                     ====^^
Development, Managers for Strategic Support Initiatives, Strategic Analysis and Industry Relations,
Regional Programs, and Administration; and the Chief Environmental Engineer. Management reviews
demonstrate full commitment to EMS implementation and may assist a port in going on to achieve ISO
14001 certification for its EMS.
Reviewing systems for broader sustainability is an extension of EMS reviews. Such continuous
improvement evaluations allow a port to improve its day-to-day operations, activities, and services to
achieve all desired objectives and targets. These  reviews can also dove-tail with a port's strategic
planning. Once a port has established this Plan-Do-Check-Act systems approach, its management and
employees are more apt to think more holistically  and "outside the box" about solutions to business
challenges, e.g., using solar or wind as sources of energy for the port and to sell back to the grid; using
porous pavement instead of installing a storm water management system.
Interim Final Draft, April 2007                        36                  U.S. Environmental Protection Agency

An EMS Primer for Ports: Advancing Port Sustainability

Security Management Systems (SMSs) Based on the  Plan-Do-Check-
Act Model

The Port of Houston Authority, having previously implemented an ISO 14001-certified EMS, successfully
tested the use of the Plan-Do-Check-Act framework for managing security risks and vulnerabilities as part
of the 1st Ports EMS/SMS Assistance Project. Similar in general structure to an EMS, an SMS helps ports
identify vulnerabilities, establish action plans,
and ensure continuous monitoring and
measuring - all done in coordination with a
port's strategic objectives and legal
requirements. The following highlights
demonstrate how EMS elements can be
modified to reflect SMS realities.
"The requirements and demands of port security literally
have changed overnight. Using a systems approach
allows us to manage the rapidly changing security
regulations and deadlines. Today, the approach is helping
the Port of Houston identify and prioritize vulnerabilities
and risks so that we can make security better, faster." —
James T. Edmonds, Chairman, Port of Houston Authority

Source: EPA, AAPA & GETF. Environmental
Management Systems: Systematically Improving your
Performance: Ports Sector, September 2004.

"We developed a security management system based on
ISO 14001: 2004. The Plan-Do-Check-Act model has
already verified that we are in compliance with security
requirements, and  provided us with organizational
structure and responsibility for more efficient use of
resources. It has also provided  an ongoing process to
monitor and measure key security parameters, and
guided us to  reallocate resources to highest security
priorities." — Russell Whitmarsh, Chief of Police, Port of
Houston Authority

Source: "U.S. Ports Set Sail for ISO/PAS 28000," ISO
Focus, July/August 2006,
    Plan - Element 1: With regard to scope,
    the SMS fenceline may be set as all
    entities over which the port exercises
    control or significant influence with
    regard to operating policies and practices.
    Thus, in setting boundaries for its SMS,
    Houston selected its Barbours Cut
    Container and Cruise terminals as its SMS
    fenceline, because these facilities were
    managed by the port's Police/Security
    Force and were within the port's direct
    operational  control.

    Plan - Element 5: Ports have already
    incorporated security objectives and
    targets into their action plans. Houston's
    SMS program allowed its police
    department to analyze security risk and
    other significant vulnerabilities for establishing program goals. By establishing these goals, the port
    maintained a method for monitoring and tracking successful implementation and completion of
    security projects.
Security Risk Area
Key control
Vessel stores
Cargo handling
Security equipment
SMS program
Significant Vulnerability
Access control
Vessel stores & bunkers
Cargo handling
Security equipment
SMS implementation
Develop a key control
system at container &
cruise terminal
Develop a vessel stores
communications program
Establish an exit process
for cargo handling
Develop a quality control
program for security
equipment maintenance
Implement SMS program
for container & cruise
50 percent by June 2006
100 percent complete by
June 2006
100 percent complete by
June 2006
50 percent complete by
December 2005
100 percent complete by
June 2006
•   Do - Element 6: Operational controls extend to security. The Security and Accountability for Every
    (SAFE) Port Act of 2006, for example, includes port safety measures that require 100 percent of
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U.S. Environmental Protection Agency

An EMS Primer for Ports: Advancing Port Sustainability
    imported containers to be scanned for radiation, which will entail the deployment of appropriate
    monitoring devices, as well as the creation of standards for operating procedures.

•   Do - Element 7: Re. emergency preparedness and response and SMS implementation, the ISO
    PAS 28000:2005 standard, Specification for Security Management Systems for the Supply Chain,
    specifies the requirements for a security management system, including those aspects critical to
    security assurance of the supply chain. These aspects include, but are not limited to, financing,
    manufacturing,  information management and the facilities for packing, storing and transferring goods
    between modes of transport and locations. Security management is linked to many other aspects of
    business management. These other aspects should be considered directly, where and when they
    have an impact on security management, including transporting these goods along the supply chain.

•   Do - Element 8: As part of its SMS, the police department at the port developed a  comprehensive
    tiered training  program, which was used as a tool to communicate roles and responsibilities,
    regulatory requirements, and appropriate  response actions pertaining to current U.S. Coast Guard
    Maritime Security (MARSEC) conditions. Using a tiered approach allowed the department to
    communicate the SMS program to both internal and external stakeholders - expanding into social
    performance indicators of community involvement.

    o  Tier I Competence Training is provided to  personnel with police/security duties and discusses the
       Facility Security Plans (FSPs) in detail, including MARSEC level response actions.

    o  Tier II Tenant Security Officers are select tenants that are not incorporated  within an FSP. This
       training is provided to ensure the tenant security representative is aware of the federal regulatory
       requirements and the port's programs and policies.

    o  Tier III General Awareness Training is provided to all Port of Houston Authority employees,
       contractors, visitors, and vendors.  This course provides a general overview of security practices
       and general MARSEC level awareness.

•   Do - Element 10: To meet the confidentiality requirements pertaining to the law enforcement
    documents and records, the police department at the port created a document management
    structure. This written procedure describes the SMS document control/approval process for
    monitoring newly developed forms, records, and reports.

•   Check-Act- Element 12: Auditing for security considerations is an extension of EMS auditing. For its
    SMS, for example, the police department  at the Port of Houston Authority developed an internal
    compliance auditing program to ensure regulatory compliance. The department's internal auditing
    team consists of employees from the port's environmental  affairs, engineering,  risk management,
    operations, marine, and port police departments. This diverse team worked together in creating
    auditing protocols, including a written audit plan, a schedule, a questionnaire, a report and corrective
    action  processes. Additionally, the SMS core team worked together in creating  a training program.
    The internal audit was conducted in July 2005, as a preparation exercise for the external USCG audit.
    As a result of this audit, Houston successfully completed the external audit and subsequently
    received noteworthy remarks regarding this proactive management practice.

Additional  ports are now developing SMS as part of the 2nd  Port EMS/SMS Assistance Project, including
the Port of Corpus Christ! Authority, the Port of Long Beach, the Port of Portland, and the Port of New
York and New Jersey. Results from these efforts will be available in early 2008.
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An EMS Primer for Ports: Advancing Port Sustainability
Organizations around the world, both public
and private, are facing increasing scrutiny
regarding their environmental "footprints".
EMSs allow organizations such as ports to
systematically and continuously identify,
measure, and manage the environmental
impacts of their activities. Regulatory
compliance is the foundation of an EMS, not
the end goal. EMSs help organizations go
beyond compliance to become better
neighbors and to make their operations
more sustainable.

Many business  partners in marine
transportation are recognizing the value of
adopting EMSs. Freight carriers such as
Atlantic Container Line, American Presidents
Line, Hanjin Shipping Company, Hapag-
Lloyd Container Line, K Line Matson
Navigation, Mitsui O.S.K Lines, and NYK
Group and  cruise lines such as Holland
America and  Royal Caribbean have received
ISO 14001  certification for EMSs covering
their ships and/or facilities. There is also a
very long list  of shippers with ISO 14001

It is critical  for ports to work with their
business partners and other stakeholders to
find sustainable solutions to increasingly
complex challenges like climate change,
energy, and land use, i.e., to meet today's
economic, environmental, and social needs
without compromising the ability of future
generations to meet theirs.
'We must realize we are no longer unconnected. Our
success — all of us in an integrated global supply and
demand chain — depends on the success of the whole. The
success of the entire world economy and the well-being of all
of the world's people depend on our ability to succeed as
sustainable businesses at this critical juncture in our
industry's history." — Chang Kuo-Cheng, Chairman,
Evergreen Marine Corporation

Source: "Evergreen Chairman Urges Cooperation," Traffic
World, March 6, 2006.
  Steering Toward Sustainable Port Communities
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U.S. Environmental Protection Agency
National Center for Environmental Innovation
April 2007