v>EPA
United Stales
Environmental Protector
Healthcare Environmental Assistance Resources
Pollution Prevention and Compliance Assistance
for Healthcare Facilities
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DOE/EH-0573
Prepared by:
Office of Environmental Policy & Assistance
U.S. Department of Energy
and
Federal Facilities Enforcement Office
U.S. Environmental Protection Agency
1998
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Contents: Page #
1. Introduction 1
2. Getting Started 6
3. Measuring Performance 14
4. Compliance and Regulations 18
5. Innovative Programs 23
6. Pollution Prevention 30
7. National Environmental Policy Act 36
8. Audits & Certification 39
9. An Invitation to Environmental Leadership 44
Appendix A: Selected Resources 45
Appendix B: NEIC EMS Criteria 52
Appendix C: State EMS Contacts 56
Appendix D: Evaluation Form 58
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Principal Authors:
Andrew Cherry, Federal Facilities Enforcement Office, Environmental Protection Agency
Larry Stirling, Office of Environmental Policy and Assistance, Department of Energy
Thanks to the following for their excellent contributions:
Office of Environmental Policy and Assistance, Environmental Management System Team,
Department of Energy: Jerry Coalgate, Gerry DiCerbo, Ross Natoli, Steve Woodbury,
Jim Sanderson
Joe Cascio, Global Environment and Technology Foundation
Jim Edward, Federal Facilities Enforcement Office, Environmental Protection Agency
Ira Feldman, GT Strategies and Solutions
Will Garvey, Federal Facilities Enforcement Office, Environmental Protection Agency
Richard Green, Office of Oversight, Department of Energy
Ted Hinds, Office of NEPA Policy and Assistance, Department of Energy
Jim Home, Office of Water, Environmental Protection Agency
Mary McKiel, Office of Prevention, Pesticides and Toxic Substances, Environmental Protection
Agency
Dean Monroe, Office of General Counsel, Department of Energy
Judy Odoulamy, Office of General Counsel, Department of Energy
Jane Powers, Office of Environmental Policy and Assistance, Department of Energy
Brian Riedel, Office of Enforcement and Compliance Assurance, Environmental Protection
Agency
Richard Satterfield, Office of Compliance, Environmental Protection Agency
Dan Schultheisz, Pacific Northwest National Laboratory
Jean Shorett, Pacific Northwest National Laboratory
Jeff Short, Office of Environmental Management and Waste Restoration, Department of
Energy
Steve Sisk, National Enforcement Investigations Center, Environmental Protection Agency
Cheryl Wasserman, Office of Enforcement and Compliance Assurance, Environmental
Protection Agency
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1- INTRODUCTION
This guide is designed to help Federal managers who are considering adopting an
environmental management system (EMS). Properly implemented, an EMS can
reduce support costs and improve productivity while advancing environmental
protection and performance. It can put Federal environmental management
practices on the same level as those of America's best-run corporations. And it
can do so in visible ways that will be recognized by stakeholders inside and outside
a Federal agency.
The most familiar form of an EMS is the 14001 Standard recently established by
the International Organization for Standardization (ISO). Although there are
standards for other EMSs, ISO 14001 is becoming widely adopted throughout the
private sector in the United States and internationally. Many agencies of the U.S.
Government are considering its adoption as well, and several have adopted it (at
the local level). Throughout this document, references to EMS encompass ISO
14001 as well as other environmental
management system standards.
This guide is not intended to be a
technical or detailed manual on EMS ment sy!fm ?"!ich !ncludf .
. ... _. .. .. ... organizational structure, planning
implementation. Rather, its goal is to ac?jvjtjeSi responsibilities, practices,
Environmental management systems
are "that part of the overall manage-
procedures, processes and
resources for developing,
implementing, achieving, reviewing
and maintaining the environmental
policy."
- ISO 14001, Environmental
Management System Standard
help Federal managers understand
EMSs and how one can help them
improve environmental management at
their facilities. This Primer also
outlines the elements of an EMS,
offers tips on how to make the case for
an EMS to upper management,
explains how an EMS will benefit an
organization, and places EMSs in the
context of regulations, compliance issues, pollution prevention, and other
government programs.
Each chapter in this Pr/merdeals with a key EMS issue for Federal facilities. At the
end of the document you will find references to Internet web sites, books, reports,
and newsletters for more information.
WHAT IS AN ENVIRONMENTAL
MANAGEMENT SYSTEM?
An EMS is a systematic approach to ensuring that environmental activities are well
managed in any organization. The side box above lists the specific ISO definition
of an EMS. Because an EMS focuses on management practices, it can operate
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at facilities of widely varying size, complexity, and missions, whether they be
offices, laboratories, ships, facilities, programs, or agencies. An EMS can provide
Federal managers with a predictable structure for managing, assessing, and
continuously improving the effectiveness and efficiency of the management of their
environmental activities. An EMS approach builds in periodic review by top
management and emphasizes continuous improvement instead of crisis
management.
The systematic nature of the EMS allows an agency to focus on management
implementation and take a more inclusive and proactive view of environmental
protection. By demonstrating improved environmental performance, an EMS can
open the door to improved relations with regulators, stakeholders, and the public.
But don't expect instant credibility! By itself, an EMS does not guarantee
performance or compliance. Regulators, communities, and environmental groups
must see credible evidence that an EMS is being used to ensure compliance and
advance environmental and mission goals.
Adopting an EMS approach does not mean that "one size fits all." Quite the
contrary. Each agency, facility or program can structure an EMS to address its
particular goals, activities, budgets, missions, conditions, and stakeholders.
The basic elements of an ISO 14001 EMS (see box) should already be familiar to
most Federal managers and are discussed generally in Chapter 2. This familiarity
allows agencies to use and adapt existing environmental management activities.
Adopting an EMS approach
rarely requires beginning from
scratch. Many facilities will find
they have most or all the
elements of an EMS already in
place. Complex sites, such as
those with numerous program
elements or host-tenant
relationships, may be faced
with multiple, inconsistent, or
unrelated elements of
environmental programs. A
formal EMS can help draw
together such elements,
producing a clearly defined
environmental policy statement
and an integrated framework
for environmental activities.
ISO 14001 EMS Elements
1.
2.
3.
4.
5.
A Policy Statement endorsed by top
management.
Planning: identifying how operations
impact the environment, setting goals
and targets for reducing impacts,
tracking legal and other requirements,
and developing systems for
environmental management.
Implementation and Operation:
assigning roles and responsibilities,
training, communication,
documentation, and emergency
preparedness.
Checking and Corrective Action:
establishing ways to monitor, identify
and correct environmental problems.
Management Review focused toward
continuous improvement.
Unlike a regulation, an EMS is
voluntary. Hopefully, though, it
will change the way your site,
program or agency does
business, engage the senior leadership of your organization, and help get the right
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information to the right people at the right time. Of course, having an EMS in place
does not by itself guarantee the competence or abilities of those responsible for
compliance activities. Appropriate training and assignment of responsibilities are
also needed and should be identified as components of the EMS.
EMS IN THE CONTEXT OF OTHER INITIATIVES
Federal facilities face a complex array of statutory and executive mandates, and
operate in a dynamic context. EMSs offer new challenges and opportunities for
integration with other initiatives. For example, EPA has developed several
programs to test regulatory innovation and flexibility. Both the Environmental
Leadership Program (ELP) and Project XL (excellence and Leadership) involve the
use of EMSs and are open to Federal participation. Furthermore, a thoughtfully
implemented EMS can help integrate management practices for environment,
safety, and health (ESH) programs. Other statutory and programmatic
requirements which relate to an EMS include:
> National Technology Transfer and Advancement Act of 1995 (NTTAA): With
passage of NTTAA, Federal agencies are required to consider using technical
standards. This includes standards for "related management practices" developed
by voluntary consensus bodies, unless inappropriate or illegal. However, NTTAA
does not expressly require adoption of EMS or other standards. Agencies may use
self-developed standards if approved by OMB or, if necessary, retain agency-
specific standards.
> Government Performance
and Results Act of 1993
(GPRA): GPRA requires
Federal agencies to report on
their goals and how well they
achieved them. GPRA does a) goals and objectives
GPRA Mandates:
Agencies must have strategic plans prior
to FY 1998:
b) plans for meeting goals and
objectives
c) resources necessary
d) key external factors
Agencies must submit annual plans
describing their goals and comparing
performance to goals
not require agencies to include
environmental measures.
However, should an agency
choose to do so, performance
indicators used to meet EMS
goals and targets could be
combined on an agency-wide
basis and included in an
agency's GPRA measures
(e.g., reducing toxic emissions, conserving energy or water, or decreasing solid
waste).
> National Environmental Policy Act fNEPA): Federal agencies are required
under NEPA to evaluate the environmental impacts of their proposed activities.
The outcome of the evaluation can range from a Finding of No Significant Impact,
to a Categorical Exclusion, to a Programmatic Environmental Impact Statement
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CEMP Principles
1. Management Commitment: The agency makes a written top-management
commitment to improved environmental performance by establishing policies that
emphasize pollution prevention and the need to ensure compliance with
environmental requirements.
2. Compliance Assurance and Pollution Prevention: The agency implements
proactive programs that aggressively identify and address potential compliance
problem areas and utilize pollution prevention approaches to correct deficiencies
and improve environmental performance.
3. Enabling Systems: The agency develops and implements the necessary
measures to enable personnel to perform their functions consistent with
regulatory requirements, agency environmental policies, and its overall mission.
4. Performance and Accountability: The agency develops measures to address
employee environmental performance, and ensure full accountability of
environmental functions.
5. Measurement and Improvement: The agency develops and implements a program
to assess progress toward meeting its environmental goals and uses the results
to improve environmental performance.
covering many sites. The NEPA process requires public notification and
participation, and can be lengthy. An operating EMS can contribute to fulfilling
NEPA requirements by drawing on EMS data for the NEPA scoping and analysis
efforts. Conversely, existing NEPA data can be used in identifying the
environmental aspects and impacts of a site's activities and provide the
management system framework to ensure effective implementation of mitigation
measures.
> Code of Environmental Management Principles fCEMP): The CEMP is a set
of five management principles developed by EPA to provide Federal agencies with
a framework for developing EMSs at government facilities. EPA modeled the
CEMP on common elements found in a number of EMS standards but with a
stronger emphasis on sustainable development and regulatory compliance. EPA
recognizes the similarities between the CEMP principles and ISO 14001, and has
accepted ISO 14001 as an option for Federal agencies to use in implementing the
CEMP. Sixteen Federal agencies have endorsed principles of the CEMP and
several are using ISO 14001 at the facility-specific level. The CEMP (published on
October 16,1996, 61 Federal Register 54062) was developed in coordination with
other Federal agencies, as required by Executive Order 12856, "Federal
Compliance with Right-to-Know Laws and Pollution Prevention Requirements."
>• Contract Reform: An EMS can aid Federal managers in translating
environmental risk management into common performance terms, allowing all
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facility elements (and their contractors and vendors) to "plug into" a set of general
structures and performance expectations. Performance-based contract language
that references use of an EMS allows Federal managers to define acceptable
management practices and environmental outcomes for their operations, while
providing cost-saving flexibility to contractors and vendors. This lets the
government harness the legitimate commercial interests of contractors and
suppliers, consistent with productivity and mission goals at Federal facilities.
OBTAINING RESOURCES
Because an EMS builds upon existing programs, fewer new costs are incurred in
adopting an EMS than in designing a whole new system. Nevertheless, obtaining
the resources needed to put the system in place can be a hurdle in any Federal
office facing budget constraints. It is worth noting, therefore, the many benefits
that an EMS can provide that yield tangible returns on an EMS investment:
— Provides an agency-wide environmental management framework: cuts costs
associated with each site developing its own programs from scratch
— Reduces support costs: integrates site contractors and activities
— Supports risk management: reduces risk profile and diminishes liability
— Supports performance-based contracting: defines acceptable management
practices and environmental outcomes for Federal facility operations, and
provides cost saving flexibility to contractors
— Helps avoid gaps and overlaps: improves cost-effectiveness as well as
performance
— Shows due diligence: demonstrates to regulators objective, documented,
systematic procedures to prevent, detect, and correct violations
— Integrates related ES&H activities (e.g., pollution prevention and worker
safety)
— Improves recognition of pollution prevention opportunities: saves on storage
and disposal costs and reducing liability
— Eases deployment of new technologies: avoids high start-up and transition
costs.
WHAT THIS DOCUMENT CONTAINS
This Primer reviews key EMS issues affecting Federal agencies and facilities.
Following this introduction, Chapter 2, Getting Started, provides suggestions for
accessing information and understanding and applying EMS elements. Chapter
3 addresses Measuring Performance. Chapters 4 through 7 discuss the
relationship of EMS to key environmental institutions: Compliance and Regulations,
Innovative Programs, Pollution Prevention, and NEPA issues. Chapter 8 deals with
Audits and Certification, and Chapter 9 is An Invitation to Environmental
Leadership. Appendices provide reference materials and state EMS contacts. As
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understanding of EMS issues expands, periodic updates to this document are
planned and will be posted on the Internet.
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2 - GETTING STARTED
Federal facilities have a wide range of missions, activities, locations, resources,
organizations, and environmental track records. Some have highly sophisticated
environmental protection and compliance assurance programs, including most or
all elements of a fully-functioning EMS. Others may have few environmental
capabilities, fewer resources, and little representation of environmental issues at
senior levels within their agency. Between these two extremes are most Federal
managers who may be considering use of an EMS.
This chapter is designed to
help Federal facility managers
get started in planning and
implementing an EMS. This
includes gaining access to
information, as well as
understanding the basic EMS
elements.
"Years ago, if you asked organizations,
especially large ones, if they had an
environmental management system, they
would usually respond 'of course.' Most of
these organizations in fact had systems for
compliance, for waste management, for
permitting, etc. So, naturally, we thought
we had systems. But, did we have a system
as defined, complete, coherent and
structured as ISO 14001? Now, I would say
no, we did nOot. I don't think we even knew
enough then to know that we didn't have
one."
- Joe Cascio, Chair,
U.S. Technical Advisory Group to ISO
GAINING ACCESS
Learning more about EMS
approaches such as IS014001
can be straightforward for
anyone with Internet access. A
rapidly expanding set of World
Wide Web sites provide a
wealth of information, contacts,
tools, services, organizations,
meetings, and conferences.
Federal managers can also join
Web site discussions on EMS
topics and rapidly learn from
the experience and opinions of
others. Once you feel
grounded and comfortable with
EMS issues, you can make
informed choices about buying books, subscribing to newsletters, or engaging
consultants.
This Primer includes a substantial bibliography, emphasizing ease of access and
applicability to Federal facilities. Web sites listed are generally accessible without
cost and can help narrow down your own range of interests. A selected list of
books, reports, and newsletters is also included in the bibliography. While many
of these materials are business oriented, in addition to this Primer there are a
"(ISO) 14001 doesn't call for environmental
performance and certainly doesn't call for
environmental performance improvement. It
calls for systems improvement. We think
the result is going to be a smarter way to
approach environmental management that
leads to environmental improvement."
- Mary McKiel (EPA), Vice Chair,
U.S. Technical Advisory Group
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number of government sites and sources of information. This Primer does not
endorse particular references; like any growing literature, the sources exhibit a
range of quality and applicability.
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Facility managers can also look for EMS working groups within their agencies and
across the Federal complex. The EMS Interagency Work Group currently includes
representatives from 18 Federal agencies. It is co-chaired by Mary McKiel
(mary.mckiel@epamail.epa.gov) of EPA and Larry Stirling (John.stirling@eh.doe.
gov ) of the Department of Energy. Regular meetings focus on developing and
sharing information and addressing common issues, and detailed notes are
available to Federal employees.
UNDERSTANDING THE EMS ELEMENTS
This section generally discusses the five major elements of the ISO 14001 EMS
Standard and suggests helpful ways of implementing an EMS.
(1) Policy Statement
The first essential element in developing a successful EMS is obtaining top
management commitment. The importance of obtaining buy-in of agency or facility
leaders cannot be over-emphasized. Strategies for engaging upper management
by linking use of an EMS to mission priorities are discussed later in this chapter.
When senior managers have been engaged, work can accelerate on preparing an
environmental policy statement. The policy must eventually be endorsed by senior
managers, should reflect the nature and scale of the organization's activities, and
must embody the organization's commitment to:
> Compliance with laws and applicable requirements
> Prevention of pollution
> Continuous improvement.
Following (or concurrently with) development of a policy statement, facility
managers should evaluate their existing environmental programs and capabilities.
Some experts recommend that an initial review be done even before the policy
statement is developed. That way, managers can better tie the facility's policy
statement to the planning stage. Once the policy statement has been endorsed by
senior managers, it needs to be communicated to all staff and made available to
the public.
(2) Planning
Planning is the next key element in developing a successful EMS. Managers may
find it useful to review existing planning and budget documents as they reflect on
the organization's missions, location, activities, and history. Using existing system
elements, terminology, and concepts wherever possible will save time and
resources and allow the EMS to fit more naturally into the organization's culture.
Key questions to ask during this phase include the following:
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> Environmental Interactions: How do the organization's activities (aspects)
interact with the environment? Do they produce waste? Are hazardous materials
involved? Are operations located in ecologically sensitive areas? How much water
and energy are used?
> Environmental Impacts: How are the significant impacts of environmental
activities currently identified? What effect could an accident have on the
environment? Can a risk assessment strategy be used to identify the most
significant impacts?
> Applicable Regulatory Requirements: How does the organization track laws
and regulations relating to its activities? Is there a list of applicable requirements?
Is a specific person in charge of updating that list? How are new regulations
communicated?
> Other Requirements: Has the agency (or facility) made commitments beyond
compliance, such as endorsing the EPA Code of Environmental Management
Principles (CEMP) for Federal agencies? Are there ways to support other strategic
agency priorities or initiatives? For example, could an EMS help streamline NEPA
actions, integrate risk management, or facilitate implementation of new
technology? Could it aid in integrating Environment, Safety and Health protection?
This thorough examination of activities and practices that affect the environment
should help facilities improve their compliance profiles and identify and prioritize
environmental risks which then are addressed by an EMS.
Environmental Objectives and Targets
The next step is to identify environmental objectives and targets. Objectives
describe the organization's goals for environmental performance. Examples
include emissions goals, pollution prevention, use of raw materials, or incidence of
non-compliance. Targets are specific and measurable intermediate steps that can
be measured in terms of obtaining the objectives. An example is "Achieving a 50%
reduction in releases of certain toxic substances within two years."
Performance indicators can give a sharper focus to goal-setting (see Chapter 3).
Developing performance indicators allows managers to assess compliance status,
manage environmental liability, evaluate risk, track progress and meet the
challenge of continuous improvement.
(3) Implementation and Operation
Successful implementation of an EMS requires clear articulation of environmental
responsibilities across the various elements of organization. Environmental
responsibilities cannot be confined to the environmental office or a designated
bureau; they must be recognized as a prime responsibility of all employees,
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including line management. Top management has two important contributions to
make at this stage:
— Top management must designate a specific management representative
with authority and responsibility for implementing the EMS.
— Top management must provide adequate resources (including an
operational infrastructure) to ensure proper implementation of the EMS.
Other important parts of the implementation and operation element of an EMS,
discussed in more detail below, include training, communications, documentation,
operational control, emergency preparedness, and monitoring and measurement.
> Training, Awareness, and Competency: Everyone in the organization should
receive some form of training in environmental responsibilities, tailored to the
nature and extent of the potential environmental impacts of the employee's job.
Contractors working on site must be able to demonstrate that their employees have
the necessary environmental training. All employees should be able to identify and
explain the environmental consequences of failing to properly conduct their jobs.
The necessary knowledge, skills and abilities (competencies) needed to achieve
environmental goals must be identified and developed. Finally, the organization
should be able to document that employees have received the type and level of
environmental training appropriate for their jobs.
> Communication and Reporting: Effective communications are necessary to
motivate and direct employees, and build confidence and acceptance with the
public and other Federal, state, and local regulators. Some important questions to
ask include:
— What is the process for communicating an organization's environmental
policy?
— Is the process working well? Do communications typically run smoothly or
in "crisis" mode?
— Are the right audiences being reached, internally and externally? How
broadly has the net been cast? Typically, there are more interested parties
than first meets the eye!
— How are the concerns of internal and external parties received and
addressed?
— How much of the organization's communications are "one-way" rather than
"two-way" dialogues?
— How are employees and contractors informed of management initiatives
and other directives?
— How is feedback from management reviews, external audits, etc.
incorporated into decision-making?
— How are the results of corrective actions communicated to appropriate
audiences, internal and external?
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How can continual improvement in environmental issues be effectively
communicated?
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Communication can include a wide variety of techniques and venues, such as
written directives, electronic messages/bulletin boards/reports, regular employee
meetings, public meetings, citizens advisory boards, ad-hoc work groups, press
releases, periodic reports, newsletters, etc. The bottom line is to be open, honest,
fair, accurate, and factual.
> EMS Documentation: There are no hard and fast rules about what should be
documented in implementing an EMS. What should be included depends on the
needs of the organization. Keep documentation simple and to a minimum, but do
include the core elements of the EMS: the environmental policy statement; the
means of achieving the environmental objectives and targets; key roles,
responsibilities and procedures; organizational charts links or references to related
documents, site emergency plans; and EMS procedures. Some questions to
consider include:
— Are document management procedures in place to ensure that documents
are kept current at all locations where they are needed?
— Does your organization have a process for maintaining EMS documents?
— Are the EMS documents integrated with existing documentation?
— How are documents made available to current and new employees?
— Does the documentation demonstrate how the EMS supports your
organization's mission goals?
> Operational Control: Operational control refers to procedures that help an
organization implement its environmental policy, objectives and targets. Managers
should start by looking at existing procedures and asking questions such as:
— Are existing procedures adequate to control the significant environmental
impacts? Do they need to be strengthened, re-focused?
— Are existing procedures adequately documented? Are they up-to-date?
— Are personnel aware of existing procedures and using them? Do new
procedures need to be developed instead?
All activities that have significant environmental impacts should be addressed by
an appropriate operational control. This may encompass a larger universe than a
traditional compliance-based analysis. Again, keep the procedures as simple as
possible, and involve the people who work on each process in developing or
modifying the operational controls. Operational controls should be easy to
understand and relevant to the process.
> Emergency Preparedness and Response: Organizations should develop plans
and procedures to prevent accidents from occurring in the first place, and to
respond to emergencies when they occur. These plans should be site-specific,
addressing the unique hazards posed by each facility. An emergency
preparedness and response plan could include:
— A hazard assessment
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— Emergency organization and responsibilities
— Key personnel, their areas of expertise and contact numbers
— Plans for responding to emergencies (including first responders such as fire
and rescue departments, chemical response teams, U.S. Coast Guard)
— A communications plan
— Actions to be taken in various types of emergencies
— Information on hazardous materials, potential human health and
environmental impacts, response measures
— Periodic testing, training and evaluation.
Many Federal agencies are already addressing emergency preparedness. The
Emergency Planning and Community Right To Know Act (EPCRA) of 1986 and
Executive Order 12856 require Federal agencies with quantities of hazardous
substances above specified thresholds to submit Material Safety Data Sheets
(MSDS) and Hazardous Chemical Inventory reports (Tier I or Tier II) to the Local
Emergency Planning Committee (LEPC), the State Emergency Response
Commission (SERC), and the local fire department. The EMS should build on and
complement these systems.
> Monitoring and Measurement: An organization should measure and monitor
its environmental performance against its objectives and targets. Monitoring can
help managers identify and evaluate the root causes of problems and implement
appropriate corrective actions. Meaningful performance indicators should also be
developed. These performance indicators should be objective, verifiable, and
reproducible, and they should be relevant to the organization's activities and linked
to the environmental policy, objectives, and targets. Key processes, especially
those that have significant impacts on the environment, should be measured, and
monitoring equipment calibrated.
(4) Checking and Corrective Action
As an EMS is implemented, managers may find various system deficiencies. This
is normal and to be expected. No system is perfect. The important thing is to
establish a procedure to assess the root causes of the deficiency, and
to take corrective actions to remediate the problem. It is important to assess the
corrective actions as well, to determine if they are effective in remedying the
deficiency. If not, the problem itself may not have been accurately diagnosed.
Continuing or multiple deficiencies may indicate some fundamental, systemic
deficiencies that warrant further examination and response. Checking and
corrective action are typically ongoing activities.
(5) Management Review
Management must periodically step back and evaluate the performance of the EMS
as a whole. Managers should ask questions such as:
— Is the EMS is working? Is it adding value?
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— Is the EMS cost-effective?
— Does the EMS adequately respond to changing external conditions or
requirements?
— Is the EMS contributing to achieving the mission of the organization?
There are no set requirements regarding the frequency and extent of the
management review. These will vary according to the size and nature of your
organization and how stable or dynamic your external influences are. Managers
should be encouraged to make public some form of the results of the management
review. All decisions and corrective actions should be documented and
communicated to the appropriate employees, and progress in implementing the
action items should be tracked and evaluated. Management may wish to use the
management review as a vehicle to revise organizational goals, targets, policies
and plans.
SPECIAL TIPS
Even at complex installations, adopting
an EMS need not be complicated and
expensive. Here are some tips to make
the process go smoothly:
> Link the EMS to Management
Priorities: How do you obtain the
strong upper-management
One way is to
necessary
support for an EMS?
show managers that an EMS can help
achieve agency priorities in addition to
improving environmental performance.
For example, an EMS can demonstrate
world-class management at a facility competing for new agency missions or
expedite the use of cost-saving cleanup technologies.
Summary of Special Tips:
Link EMS implementation to
management priorities
• Fully use existing capabilities
• Include stakeholders from the
start
• Focus on EMS as a framework
• Defer decisions on third-party
registration
"Look for the choke-points... An
EMS won't be able to fix them all
but it may be able to knock corners
off things that are driving everyone
crazy..."
- Department of Energy contractor
> Use a Gap Analysis and Maximize Use of
Existing Capabilities: Adopting an EMS
should not require throwing out systems and
starting over. To get the greatest value out of
existing capabilities and systems, conduct a
"gap analysis." This involves determining where
there are gaps between current operating systems
and specifications of the EMS standard. Of
course, a gap analysis conducted with boilerplate checklists or by people with little
direct knowledge of the facility will not help much. The gap analysis can be made
more effective by gathering facility managers responsible for systems, and asking
them to decide which existing systems can be best adopted, extended, integrated
or adapted. Worker input is especially valuable, and should also be solicited.
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> Include Stakeholders from the Start: Federal facilities usually have multiple
regulators and stakeholders — often with different views and priorities. Involving
stakeholders (including regulators) in implementing an EMS shows respect for their
views and can provide valuable input. The degree of stakeholder involvement will
vary with the mission, history of the facility, and current stakeholder relations. Both
internal and external stakeholders will appreciate early inclusion in the
implementation process, particularly in areas with outcomes they consider
important.
> Focus on EMS as a Framework: An EMS should be seen as a facility's
environmental management framework, rather than a set of activities. As missions,
budgets, priorities, and staff continue to change, the structure of the EMS
framework will remain predictable while particular applications change. Thus new
activities, contractors, or suppliers can be "plugged into" (or unplugged from) this
commonly understood framework with minimal disruption, downtime, overlaps, and
errors.
> Defer Decisions on Third-Party Registration: Federal facilities implementing
the ISO 14001 EMS standard can "self-declare" when they reach full
implementation of the standard. Alternatively, they can be formally reviewed by an
independent or "third-party" registrar. The benefits and costs of third-party
registration for ISO 14001 are unclear at this time for both private and public sector
organizations (see Chapter 8 for more discussion). Federal managers can simplify
their choices by deferring consideration of third-party registration. Unless there is
a compelling reason to register your facility, you may want to focus instead on
implementing a fully-functioning EMS.
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3 - MEASURING PERFORMANCE
Performance measurement is critical to the success of an EMS, and for this reason
has a chapter devoted to itself. This chapter describes some of the ways of
measuring performance in the Federal sector, and gives basic guidelines for
managers in developing performance measures. Guidance on setting up a
measurement process is available from IS014031 and a growing body of literature
(see Appendix A for selected listings).
Performance measures translate organizational goals and targets into operational
terms. They can be pivotal in an organization's ability to define and demonstrate
progress toward meeting its goals. When appropriately developed and effectively
communicated, performance measures can be understood and supported by
everyone in the organization, facilitating the feedback needed for continuous
improvement. Furthermore, involving the public in developing a facility's EMS can
be an a valuable opportunity to build community support for facility missions and
programs.
With passage of the Government Performance and Results Act of 1993, measuring
performance in the Federal government assumes an even greater importance.
GPRA requires Federal agencies to prepare annual plans setting performance
goals beginning in fiscal year 1999, and to report annually on actual performance
compared to performance goals. Performance in environmental impacts and
compliance, and in worker and public safety will need to be reflected in GPRA
reports.
WHAT GETS MEASURED?
"What gets measured gets
managed" goes the saying.
But defining what should be
measured - and at what
organizational level it will be
measured — is crucial to the
success of an EMS. EMS
measures appropriate for one
organizational level may be
inappropriate at another.
Performance measures enable
organizations to:
• Focus on progress toward goals
• Benchmark with best-in-class
• Identify what is and is not working
• Aid internal & external communication
• Demonstrate accountability
• Evaluate program costs
• Identify opportunities for improvement
General EMS performance
measures are often appropriate
for higher levels within the organization or for an agency-wide effort. A research
lab within a larger installation, on the other hand, might need more specific
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measures, such as an EMS performance measure for pollution prevention to
reduce the risks from storage and transfer of hazardous materials. It is important
to ensure that the more specific EMS performance measure remain tied to the
high-level measures. This will help ensure an integrated approach to managing
environmental performance.
TYPES OF MEASURES
Identifying measures that
meaningful in improving
Identifying measures that are Performance measures should be:
Goal driven
management a n d / o r . Appr0priate to the organizational level
Able to measure results rather than
activities
Able to track trends
Understandable to all
Within the span of control
environmental performance
can be a daunting task.
Potential pitfalls include
overreaching (trying to
measure everything), or
focusing on activities that are
easy to quantify rather than on
desired results directly keyed to organizational goals. It is also important to avoid
measures outside the span of control of the managing organization. This can lead
to frustration by individuals charged with achieving results outside their control and
can undermine overall effectiveness of efforts to measure performance.
In an EMS approach such as ISO 14001, performance can be evaluated and
measured in several ways: by using environmental attributes, by gauging how well
the EMS itself is functioning, or by benchmarking against the performance of other
organizations.
>- Measuring Environmental Attributes: Traditionally, measuring environmental
attributes has focused on quantitative measures of regulated pollutants (e.g., tons
of emissions, gallons of effluent, or volumes of generated waste). These
measures help identify when certain regulatory thresholds have been met or track
activities that can have direct impacts on the environment. As an example,
factories may measure, control, and reduce emissions of sulfur dioxide consistent
with the provisions of the Clean Air Act. Traditional measures such as this continue
to be important because they can translate directly into environmental
performance.
>- Measuring EMS Performance: Measuring the performance of an EMS and the
interaction of EMS components is very important and it can be a challenge. One
approach to selecting appropriate system measures is to consider how the system
responds to changing conditions. For example, in evaluating how elements of an
EMS respond to a regulatory change, possible measures could include how the
system:
— Determined the regulation's applicability
— Incorporated it into training
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— Communicated it throughout the organization
— Incorporated it in operating procedures
— Incorporated it in self-assessment protocols
— Used it for pollution prevention and continuous improvement and
compliance
— Used it to adjust objectives and targets.
> Metrics and the Multi-State Working Group: A number of State environmental
regulators are participating in a Multi-State Working Group on EMS to explore the
utility of EMS, especially those based substantially on ISO 14001. The effort is
becoming a partnership with Federal regulators, with the goal being to gather
credible and compatible information of known quality. The idea is to have
adequate information to address key public policy issues such as the effect of EMS
environmental performance, environmental conditions, compliance with
environmental requirements, stakeholder involvement, pollution prevention
activities, and the costs and benefits of environmental activities. The primary
mechanism to generate this information will be pilot projects wherein entities
implement an EMS.
In an effort to coordinate the work of the State and Federal-based groups, EPA has
issued a Statement of Common Purpose with the Multi-State Working group on
EMS to ensure that the data gathered through both the State and Federal pilot
projects can be quantified, compared, and used to create a common data base.
A guidance document is under development which describes the general
categories of information and data that will be gathered through the pilot projects.
This guidance is a companion document to more specific data protocols (also
under development) which will contain the specific questions and categories used
by the individual facilities to gather data and information regarding EMS
performance.
> "Benchmarking" is a term often used for the comparison of one organization
against others. Benchmarking allows the organization to see how it compares with
those whose performance it wishes to emulate, and allows the organization to
benefit from the experience of peak performers. Measures might include trend
data, goals and targets, accepted norms, professional standards, intra-program
comparisons, and external comparisons with entities doing similar work. A baseline
to which progress can be compared must be established; as always, it is important
to measure the baseline accurately because it will affect the interpretation and
findings of the performance measures. There is a growing literature on
benchmarking environmental management systems (see Appendix A).
In the Federal facility context, EPA engaged in a benchmarking exercise and found
that despite a movement towards management system auditing by the larger
Federal agencies, most of the smaller Civilian Federal Agencies (CFAs) still were
focused on compliance audits and had no system in place to examine their
environmental management program. EPA's survey of these CFAs resulted in the
1994 report entitled Environmental Management System Benchmark Report: A
Review of Federal Agencies and Selected Private Corporations (EPA Document
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Number EPA-300R-94-009), which compared environmental management
programs at CFAs to those at the Department of Defense (DOD), the Department
of Energy (DOE), and three private corporations. What EPA generally discovered
was that there was weak management support for environmental compliance at
many Federal agencies, as well as a lack of formality to the environmental
compliance programs, especially at CFAs. EPA also discovered that training
programs were inadequate at many Federal agencies, and that performance
measures and accountability were lacking.
Measures vs. Outcomes
Measures are elements an organization
will want to track as a trend over time,
such as:
volume of a key hazardous material
purchased, BTUs of energy consumed,
or concentration of a residual in
wastewater discharged.
Outcomes are levels the organization
wants to achieve, such as: a 5 percent
reduction in volume of hazardous
material purchased, installation of high-
efficiency lighting in 50 percent of office
space, or zero discharge of process
wastewater.
Performance measures should be both quantitative and
qualitative. Measures should evaluate the final
outcome and how long it took to reach it. For example,
it may take only hours to inform staff of a new
regulation (say, via electronic mail), but if the
information simply consists of a reference to a Federal
Register notice, the effectiveness of the communication
aspect of the system will be diminished.
Effective EMS performance measures can be a
tremendous asset to Federal managers in navigating
ongoing change. However, these same changes can
impact performance measures themselves. Thoughtful
interpretation is required and unexpectedly strong or
poor performance results should be carefully reviewed.
Poor results do not necessarily indicate poor execution.
Poor results can signal unrealistic expectations or
changed conditions or inadequate definitions of the ^^^^^~^^^^^~
performance measures. Conversely, apparently terrific
results can result from both strong performance or a change of mission, budget,
or activity. The periodic management review that Federal managers will implement
as part of an EMS must include a review of the appropriateness of the performance
measures to help chart agency and facility progress toward meeting organizational
goals.
Because measurements only approximate the actual program, the old cliche,
"garbage in, garbage out" can be especially striking when tracking EMS
performance. Most everyone has a favorite example of performance measures
gone haywire, which actively undermine the very goals the measures were
designed to advance. To avoid this scenario, and the turmoil and
underperformance that can accompany it, Federal managers should evaluate
performance measures in the full context of their operations.
> EPA Position Statement on EMS and Request for Comment on Data
EPA recently published its Position Statement on EMS and ISO 14401 and a
Request for Comments on the Nature of the Data to be Collected from EMS/ISO
14001 Pilots (63 FR 12,094, March 12, 1998). EPA supports and will help promote
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the development and use of EMSs, including those based on the ISO 14001
standard, that help an organization achieve its environmental obligations and
broader environmental performance goals. EPA encourages the use of EMSs that
focus on improved environmental performance and compliance as well as source
reduction (pollution prevention) and system performance. EPA supports efforts to
develop quality data on the performance of any EMS to determine the extent to
which the system can help bring about improvements in these areas. The Federal
Register Notice also solicits comment on the categories of information and data
that will be gathered through the pilot projects including environmental
performance, compliance, pollution prevention, environmental conditions,
costs/benefits to implementing facilities, and stakeholder participation and
confidence.
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4- COMPLIANCE AND REGULATIONS
What can an agency or facility expect from regulatory authorities in return for
adopting an EMS? What weight should an EMS be given by regulators and
inspectors in evaluating compliance? Will external stakeholders, especially those
directly affected by a Federal facility's environmental performance, accept the use
of an EMS as a complement to more traditional approaches for achieving
environmental protection? How do regulators view EMSs in the context of
compliance? These are important questions with no simple answers. This chapter
focuses on the relationship of EMSs to regulatory compliance.
THE REGULATORY PERSPECTIVE
Regulations and enforcement
have driven most improvements
in environmental performance
for the past 25 years. Until the
last decade, the idea that
Federal facilities had sovereign
immunity from penalties,
enforcement, and certain
governmental regulations was
widely held. Since then, the
Federal Facilities Compliance
Act of 1992 has changed the
nature of Federal facility
compliance and enforcement by
expressly waiving sovereign
immunity in the RCRA context.
Subsequent reauthorizations of
statutes like the Safe Drinking
Water Act have continued this
trend of waiving sovereign
immunity.
"[ISO 14001 may] may foster improved
environmental compliance and sound
environmental management and
performance. ISO 14001 is not, however, a
performance standard. Adoption of an EMS
pursuant to ISO 14001 does not constitute
or guarantee compliance with legal
requirements, and will not in any way
prevent governments from taking
enforcement action where appropriate."
- North American Commission for
Environmental Cooperation Resolution,
June 12,1997
"Be prepared for potential stiff resistance
from internal environmental advocates.
Some may incorrectly believe ISO is a
mechanism companies will use to avoid
[compliance with] environmental laws."
- Department of Energy (DOE)
Management & Operations Contractor
Federal facilities have made ^^^^^^^^^^^^^^^^^^^^^^™
substantial strides toward
attaining and maintaining compliance in recent years. With improvements in
compliance, dramatic environmental gains are less likely to be seen. Regulatory
authorities are exploring new alternatives and innovative approaches to improve
performance.
An environmental compliance system focusses on compliance with Federal, State
and local requirements. An EMS is not fundamentally a compliance system. An
EMS focusses on management systems. However, an effective EMS can be an
important part of a compliance system, and can reasonably be expected to ensure
and improve environmental compliance.
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In this context, the question is often framed whether organizations adopting an
EMS (such as ISO 14001) have "earned" some form of decreased regulatory
oversight. There are a number of reasons why regulatory authorities are cautious
about offering decreased oversight as an incentive for EMS implementation.
These reasons include:
> Limited Empirical Data: The international EMS movement has gained influence
over the past decade, but the number of organizations in the United States with a
comprehensive EMS is still relatively small. Some of the systems that have been
implemented have suffered from a lack of common definitions regarding the
elements of a complete EMS. The rise of ISO 14001 is expected to change that,
but the track record of EMSs in improving performance is not yet well established.
Additionally, Federal facilities often answer to multiple regulators who don't
necessarily speak with one voice. More empirical data should become available
as more EMSs are implemented and as more lessons are learned and shared.
> Compliance Orientation:
The basic mission of any I „,, " ~ ~~
. . .. .. . / If you can systematize your approach to
regulatory authority is to environmental regulation, and beyond
regulation, you have a better chance of
having consistency when those of us in the
regulatory community knock on your door."
- Mary McKiel, EPA Standards Network
ensure compliance. The
compliance approach to
environmental protection has
paid great dividends. Many in
the regulatory arena are
understandably reluctant to
abandon such a successful approach, and may not have the discretion or authority
to do so. Regulators do not want to be seen as abdicating their responsibilities or
risking their credibility. Therefore, innovations that encourage a softened approach
to compliance will generally be subject to a heavy burden of proof, and
implementing an EMS should not be thought of as an alternative to an
environmental compliance system. An EMS can, however, provide the basis for
negotiating flexibility in certain areas where regulators have discretion.
> Accountability and Verification: EMS certification under ISO is performed by
an independent third party, not by a regulator. Some have voiced the concern that
it might be possible to "shop around" for an agent willing to certify a facility's EMS.
Although the certifying agent must be trained and accredited, the process is
continually being improved and strengthened as experience grows. Regardless,
regulators need to have confidence in the certification process. Given that
registration and certification do not guarantee performance or compliance,
regulators feel uncomfortable with the process because they will be held
accountable by the public for any resulting decline in performance at the facility.
But remember that an EMS can help improve the accountability of people in
regulated entities, and should support a management framework for improving
performance and compliance.
Until EMSs build a track record of performance, the regulatory stance toward EMSs
will remain unclear. Certainly, adopting an EMS solely to secure 'regulatory relief
is a wrong reason to adopt an EMS and is guaranteed to be a disappointment.
Over time, however, it is possible that EMSs may replace certain elements of
regulatory oversight (such as inspections or permits) where regulators have the
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discretion. A more cautious view holds that an EMS has the potential to harmonize
and complement regulatory oversight.
An EMS can, however, help improve ongoing relations with regulatory authorities
and stakeholders by making the management structure and procedure more visible
to regulators. EMSs provide the opportunity not only for specific types of
improvements — reduced emissions, initiating self-reporting and correction
programs, stakeholder participation in setting pollution prevention goals, or fewer
unplanned releases — but also a framework that gives outside parties an
understanding of how environmental issues are being managed.
By the same token, adopting an EMS can also indirectly reduce regulatory
requirements. This may sound surprising, but it is actually quite simple. The
structure of an EMS, and the self-examination it encourages, can help to reveal
hidden opportunities for the kinds of operational changes that will yield reductions
in the number of regulatory requirements that are applicable. The fewer the toxic
inputs used, for example, the fewer regulatory requirements apply. Federal
facilities may reduce permitting or reporting requirements, as well as waste
management costs, through the substitution of regulated chemicals or process
changes arrived at through the self-examination encouraged by an EMS.
Facilities can also use an EMS to reduce overlaps in existing compliance systems
as well as to seek cost-effective pollution prevention measures. (See Chapter 6.)
For example, a facility may be able to eliminate some internal reporting
requirements or duplicate
permit requirements or
inspections. Other incentives
for adopting an EMS can
include lower support costs for
integrated environmental,
safety, and health (ESH)
programs. Properly
implemented, an integrated
ESH program can improve
internal efficiency, provide
better risk management (due to
identification and closure of
gaps in assuring compliance),
and allow greater agility of ESH
operations during times of rapid
change. Each of these has the
potential to directly reduce
regulatory obligations, without speculating about responses from regulators,
because fewer regulations will apply.
"At a meeting of the Management
Committee in mid-1992, a committee
member passed out a 'Special Report' from
a periodical, saying: 'These are new
sentencing guidelines. There is a section
that allows for a reduction in a monetary
fine if the company has a compliance
program to prevent and detect violations of
law. Show me that we have such a
formalized program or do what is necessary
to develop one.' This formed a catalyst in
the development of Ocean State Power's
environmental management system."
- Ocean State Power, Burrillville, Rhode
Island
If a facility's environmental programs are currently in compliance, its managers may
not realize that some form of an EMS is already in place, or may not see the
advantage of adopting a more formal EMS. Some managers may question
whether
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making any changes might risk falling out of compliance. Hopefully, managers
can be educated to understand an EMS as managing applicable requirements
more cost- and mission-effectively.
EMS AS A COMPLEMENT TO COMPLIANCE
Ensuring that a facility is in compliance with environmental laws and regulations is
an essential component of an EMS. Given that compliance with environmental
requirements is a baseline, an EMS can and should be viewed as a complement
to a "command and control" compliance approach. Although an EMS focusses on
management systems and not legal compliance per se, an EMS can be an
important tool in an agency's compliance system by improving the management of
activities and programs that
have significant environmental
impacts. As a practical matter,
an EMS should be integrated
with a compliance system. An
EMS is consistent with, and
should not diminish or interfere
with, a facility's compliance
management system.
Due Diligence
As a mitigating factor, due diligence
includes numerous elements consistent
with an EMS:
• Developing standards and procedures
to prevent noncompliant behavior that
is not in conformity with the
management program.
• Allocating responsibility to oversee
conformance to these management
standards and procedures.
• Training to communicate the standards,
procedures and roles.
• Using appropriate disciplinary
mechanisms to encourage consistent
enforcement of the standards.
• Monitoring and auditing systems to
implement the standards.
• Correcting the nonconformance and
prevent future nonconformance.
Source: U.S. Sentencing Commission
Policies such as the 1991 U.S.
Sentencing Commission
Sentencing Guidelines have
had an enormous impact in
encouraging development and
implementation of compliance
management systems. The
Guidelines cite the existence of
"an effective program to
prevent and detect violations of
law" as the basis for substantial
reductions in criminal sentences
for those convicted. Further,
they state that "the hallmark of
an effective program to prevent
and detect violations of law is
that the organization exercised due diligence in seeking to prevent and detect
criminal conduct by its employees and other agents."
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An EMS is also consistent with the 1995 EPA Self-Policing Policy which sets forth
conditions for reductions in civil penalties and limited liability for criminal
prosecution. Systematic discovery of violations through a compliance management
system (due diligence) or environmental audit is a condition for elimination of
gravity-based penalties. EPA has applied the Self-Policing Policy in many cases,
most of which resulted in substantial moderation or waiver of penalties.
EPA continues to emphasize the important role of a compliance management
system, and recognizes that an effective EMS can complement the compliance
management system. EPA's Code of Environmental Management Principles
(CEMP) has a strong specific emphasis on compliance, and, since the late 1980s,
civil multimedia compliance investigations conducted by the National Enforcement
Investigations Center (NEIC) have made a special effort to identify causes of
noncompliance. Noncompliance is most often caused by the lack of an EMS or an
EMS that doesn't work. By participating in follow-up enforcement actions, NEIC
developed 12 detailed criteria (shown in the accompanying box) for a compliance-
focused EMS. The first five criteria are the most critical in assuring compliance.
The last seven serve to sustain and improve the system. A complete description
of the NEIC EMS Criteria is provided in Appendix B.
NEIC EMS Criteria
1. Management Policies and Procedures
2. Organization, Personnel, and Oversight
of EMS
3. Accountability and Responsibility
4. Environmental Requirements
5. Assessment, Prevention, and Control
6. Environmental Incident and
Noncompliance Investigations
7. Environmental Training, Awareness,
and Competence
8. Planning for Environmental Matters
9. Maintenance of Records and
Documentation
10. Pollution Prevention Program
11. Continuing Program Evaluation
12. Public Involvement/Community
Outreach
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5 - INNOVATIVE PROGRAMS
EPA is exploring several innovative programs to encourage improved
environmental performance. This chapter describes these and other programs and
explains how adopting an EMS can make your facility a better candidate for the
innovative programs and flexible approaches that are being offered.
THREE INNOVATIVE EPA PROGRAMS
EPA has developed three innovative programs to encourage environmental
improvements. They are: the Environmental Leadership Program (ELP), Project
XL, and Environmental Management Reviews (EMRs). Each of these programs
can provide technical assistance and useful ideas to facilities chosen to participate.
The ELP and Project XL also require a substantial level of commitment by an
agency or facility.
>• Environmental Leadership Program (ELP): The ELP recognizes and
encourages innovation and improved environmental performance. ELP facilities
must still comply with the same regulations as non-ELP facilities. However, they are
eligible for fewer inspections
and a self-correcting period for
violations. Other benefits can
include expedited permitting,
longer permitting cycles, and
others deemed appropriate by
EPA and States.
Puget Sound Naval Shipyard
ELP demonstrated that disposal of certain
waste materials at the shipyard should not
be restricted under the Toxic Substances
Control Act (TSCA). Benefits to the shipyard
include:
Annual recycling of 2,500 tons of steel
currently covered by TSCA
Eliminating up to seven tons of solvent
emissions resulting from TSCA analysis
Establishing a process to evaluate
innovative pollution prevention
measures.
Under the ELP, a facility must
have a fully-implemented EMS
and conduct periodic EMS and
compliance audits. Audits
encourage facilities to look for
ways to go "beyond
compliance." Two Federal
facilities, McClellan Air Force
Base in Sacramento,
California, and the Puget
Sound Naval Shipyard in Bremerton, Washington, participated in ELP's pilot phase.
In addition to the EMS requirement, an ELP facility must participate in community
outreach and employee involvement programs to foster a more collaborative
atmosphere. Facilities are also expected to participate in a mentoring program
designed to transfer knowledge and innovation to smaller or less advanced
facilities. ELP has been adopted as the "Model Installation Program" described in
Executive Order 12856, and parent Federal agencies must endorse EPA's Code
of Environmental Management Principles (CEMP).
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> Project XL: Project XL (excellence & Leadership) is a national pilot program of
50 projects selected by EPA for testing innovative ways of achieving more effective
health and environmental protection. Several of the projects selected include use
of an EMS as an important element of their approach.
Project XL is similar to the ELP in encouraging innovation. However, Project XL
differs in one important respect: a facility accepted for Project XL may receive
permission to go outside the current regulatory structure in order to achieve a
superior result at a lower cost than could be achieved by strict adherence to
regulation. In addition to superior results and lower cost, Project XL projects
involve:
— Less reliance on paperwork
— Stakeholder support
— Innovative approaches and preference for multi-media pollution prevention
— Capability of transfer to other facilities/sites
— Technical and administrative feasibility
— Clear performance objectives and data requirements
— No shifting of risk/pollution to other population/media.
XL Projects are undertaken through a negotiated agreement among the facility,
state, EPA region, EPA program office (e.g., Air, Water, etc.), and other
stakeholders.
> ENVVEST: The Department of Defense (DOD) and EPA have jointly sponsored
the ENVVEST initiative, which is DOD's program to implement regulatory
reinvention activities such as Project XL. ENVVEST allows regulators to grant
relief from requirements that provide little additional health protection or
environmental improvement. In return, the installation commander, in coordination
with the regulator, funds high payback pollution prevention projects with the money
originally programmed to satisfy the "waived" requirements.
*• Environmental Management Reviews: An
Environmental Management Review (EMR) is an
evaluation of a Federal facility's program and
management systems to determine how well the
facility has developed and implemented specific
environmental protection programs to ensure
compliance. EMRs are consultative technical
assistance visits intended to identify root causes of
environmental performance problems. EMRs are
voluntary and are usually initiated by the recipient
agency or facility. They generally focus on one or
two components of a fully developed EMS, such
as:
"Very positive experience. The
EMR helped tremendously. It was
a great learning experience. EPA
identified the positives and the
areas needing improvement. The
EMR energized our Environ-
mental Program."
- Federal Facility Environmental
Manager, EPA Region 1
— Organizational structure
— Environmental commitment
— Formality of environmental programs (e.g., P2, auditing, compliance)
— Internal and external communication
— Staff resources, training, and development
— Program evaluation, reporting, and corrective action
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— Environmental planning and risk management.
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An EMR is not a compliance audit or an inspection, but any violations observed
during the EMR are communicated to the facility separately from the EMR report.
Facilities generally have 60 days to correct the violations, and are eligible for
substantial penalty relief.
OTHER PROGRAMS
> Department of Enemy's Integrated Safety Management System. As part of
its program to improve and standardize the Department of Energy's management
of environment, safety, and health efforts, the Secretary of Energy issued Safety
Management Policy, P 450.4 on October 15, 1996. This policy established the
Integrated Safety Management System which provides a formal, organized process
to plan, perform assess, and improve the safe conduct of work in the Department
of Energy (DOE). The system encompasses all DOE facilities. Throughout the
policy statement the term safety is used synonymously with "environment, safety
and health" to encompass protection of the
public, the workers, and the environment.
Implementing an Integrated Safety Management
System is a requirement for contractors
operating DOE sites, per DOE procurement
regulations at 48 CFR (DEAR) 970.2303-2(a).
DOE senior management has recognized that an
environmental management system, such as
ISO 14001, can play an important role in
articulating the environmental component of the
Integrated Safety Management System.
The Seven Guiding Principles of Integrated
Safety Management at DOE
1. Line Management Responsibility For Safety.
Line management is directly responsible for the
protection of the public, the workers and the
environment. As a complement to line
management, the Department's Office of
Environment, Safety and Health provides safety
policy, enforcement, and independent oversight
functions.
2. Clear Roles and Responsibilities. Clear and
unambiguous lines of authority and responsibility
for ensuring safety shall be established and
maintained at all organization levels within the
Department and its contractors.
"An important aspect of
integrated safety management
is protection for the
environment and for public
health. To achieve this at DOE
sites, DOE's Office of
Environment, Safety and
Health provides technical
assistance to sites to
encourage use of voluntary
standards, such as the ISO
14001 Environmental
Management Systems
Standard. Meeting this
standard requires a systematic
approach to managing the
Department's environmental
liabilities and holds promise of
improving environmental
protection at lower costs."
-Peter Brush, DOE Acting
Assistant Secretary,
Environment, Safety and
Health
3. Competence Commensurate with Responsibilities. Personnel shall possess the
experience, knowledge, skills, and abilities that are necessary to discharge their
responsibilities.
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4. Balanced Priorities. Resources shall be effectively allocated to address safety,
programmatic, and operational considerations. Protecting the public, the workers,
and the environment shall be a priority whenever activities are planned and
performed.
5. Identification of Safety Standards and Requirements. Before work is performed,
the associated hazards shall be evaluated and agreed-upon set of safety
standards and requirements shall be established, which, if properly implemented,
will provide adequate assurance that the public, the workers, and the environment
are protected from adverse consequences.
6. Hazard Controls Tailored to Work Being Performed. Administrative and
engineering controls to prevent and mitigate hazards shall be tailored to the work
being performed and associated hazards.
7. Operations Authorization. The conditions and requirements to be satisfied for
operations to be initiated and conducted shall be clearly established and agreed-
upon.
Core Functions of Integrated Safety Management at DOE
1. Define the Scope of Work. Missions are translated into work, expectations are
set, tasks are identified and prioritized, and resources are allocated.
2. Analyze the Hazards. Hazards associated with the work are identified,
analyzed, and categorized.
3. Develop and Implement Hazard Controls. Applicable standards and
requirements are identified and agreed-upon, controls to prevent/mitigate hazards
are identified, the safety envelope is established, and controls are implemented.
4. Perform Work Within Controls. Readiness is confirmed and work is performed
safely.
5. Provide Feedback and Continuous Improvement. Feedback information on the
adequacy of controls is gathered, opportunities for improving the definition and
planning of work are identified and implemented, line and independent oversight
is conducted, and , if necessary, regulatory enforcement actions occur.
Other DOE Initiatives
Implementation of Integrated Safety Management, including a variety of
environment, safety and health initiatives, is ongoing at most DOE sites. Several
sites are integrating EMS concepts or principles into their ISMS programs, including
Hanford, Brookhaven, and Lawrence Livermore National Lab. Other sites have
implemented third-party-certified EMSs which are compatible with and supportive
of the ISMS; these include Savannah River, the Kansas City Allied Signal Plant and
the Waste Isolation Pilot Project. Other facilities, such as the Idaho National
Engineering and Environmental Lab and Oak Ridge's Office of Waste Management
are developing EMSs which will be compatible with and supportive of their site's
ISMS when completed.
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> Compliance Agreements: Sometimes Federal agencies or facilities negotiate
a legal agreement with regulatory authorities concerning environmental conditions
at a facility. Site contractors may also be party to the agreement. These
agreements generally address a particular state or Federal regulation, specify
actions to be taken to address the conditions that led to the agreement, and lay out
milestones to be met by the agency operating the site.
Some agreements, however, are broader in scope and address an agency's overall
management of a facility. For example, the Department of Energy (DOE) has a
number of Federal Facility Agreements or Tri-Party Agreements (the parties
consisting of DOE, EPA, and the state regulatory agency). Negotiations for these
agreements can be very lengthy and consider conditions unique to Federal
facilities, such as:
— Status as an extension of the Federal government, including Congressional
oversight and budgetary responsibilities
— Size, scope, and complexity of operations
— Use of uncommon materials, such as munitions and radionuclides
— Mission, particularly when it involves national security issues.
An EMS can increase the confidence of regulators,
and provide the agency with the flexibility to
efficiently address its environmental performance.
Inclusion of EMS language in an agreement with
regulatory authorities may become a basis for
demonstrating improved environmental performance,
and for negotiating legitimate flexibility in applying
regulations.
> Environmental Process Improvement Center
(EPIC): In 1991, McClellan Air Force Base, EPA
Region 9, and California EPA formed the
Environmental Process Improvement Center (EPIC)
as a means of improving relationships and environ-
mental performance. EPIC has alliances with private
industry, government offices, academia, and the
public. It conducts projects and research in the areas of technology, research,
training, and support.
EMS Partnerships
Consider developing an EMS
partnership with another
agency, a university, or a
private sector company!
Recently, the National Oceanic
and Atmospheric
Administration (NOAA)
expressed an interest in
having DOE conduct EMS
audits at their facilities, similar
to those conducted at DOE's
own facilities.
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Multi-
State
Worki
Examples of Some State EMS Activities
A number of states have been actively exploring EMS in various pilot studies and
cooperative efforts. Examples include:
• California is exploring opportunities to use ISO 14001 for permit consolidation
zones, individual pilots, technology validation, and in partnership with other
states and countries.
• Colorado is including EMS as one of several criteria for "Environmental Leader"
status in a proposed program that would reduce oversight and provide financial
incentives to companies who excel in environmental performance.
• Indiana is co-sponsoring with U.S. EPA a series of pilot projects for small- and
medium-size thermoset plastic manufacturers in Indiana. Each pilot project will
facilitate implementation of a verifiable EMS and look at possible regulatory
flexibility along the lines of EPA's "cleaner, cheaper, smarter" approach.
• ISO may be one of several criteria to become a Michigan Clean Corporate
Citizen. Being a CCC will entitle companies to certain regulatory flexibility.
• North Carolina has developed a state-wide ISO 14000 working group to review
issues related to regulatory relief, policies, and linkages with other activities.
• Pennsylvania DEP's P2 & Compliance Assistance Web site has a section
devoted to ISO 14000.
• Washington is testing a pilot program in which an approved EMS may substitute
as an alternative to pollution prevention planning requirements. Draft criteria for
the EMS are being developed and will be pilot tested at several facilities.
• Wisconsin has held workshops around the state on ISO 14000 and EMS. A
statewide advisory committee convened by the Department of Natural
Resources is looking at changing regulatory approaches to companies that
become ISO-14000 certified.
14001. Some
overall effort is
of these activities are generally described in the box above, and the
becoming a partnership with Federal regulators.
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> Municipality Demonstration Project: EPA's Office of Water (OW) has undertaken
a demonstration project to assess the effectiveness of EMS for municipalities and
counties. As part of the OW project, ISO 14001 EMSs are being implemented at the
municipal level, encompassing public works projects, corrections facilities, electric
generating facilities, waste management, municipal government, and Publicly Owned
Treatment Works (POTWs - municipally owned waste water treatment facilities). EPA
will use the final reports and data generated by the two-year demonstration projects
to determine if and how the EMS improved environmental performance, increased the
use of pollution prevention, and improved compliance.
EMS MAKES YOU A BETTER CANDIDATE
Having an effective EMS can make an agency a better candidate for innovative
programs and flexible approaches because it will address important concerns
regulators may have about your operations. These concerns include:
> Commitment to Responsible Environmental Protection: An EMS can help an
agency show that it is forward-thinking, proactive, and not dependent on crisis
management in its environmental programs. An EMS can also be a critical factor in
establishing and demonstrating due diligence in the event of non-compliance.
> Opportunity to be a Leader in the Public and Private Sectors: An agency with
an EMS can become a leader by allowing one or more of its facilities to be used as
pilots/models, and hosting observers whose organizations want to improve their
performance.
> Clear Accountability: An EMS clearly assigns responsibility and accountability
within the organization. Demonstrating such accountability is more persuasive to
regulatory authorities than simply referring to an organizational chart. An EMS allows
agencies to get out of the "trust us" business because responsibility and accountability
are demonstrated.
> Commitment to Continuous Improvement and Pollution Prevention: The EMS
emphasis on continuous improvement and pollution prevention means that the basis
for EMS effectiveness never declines. This point may be useful in justifying the
resources needed for agency programs including pollution prevention.
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6 - POLLUTION PREVENTION
In many ways, an EMS represents the alliance between the "green" ethic of pollution
prevention and the "quality" ethic of management systems. Both incorporate concepts
such as long-range planning, continuous improvement, system control, well-being of
workers and customers, avoidance of "crisis management," importance of innovation,
and measurement of results.
During the past decade, the
Federal government has made
pollution prevention a way of doing
business. Federal agencies are
demonstrating leadership in the
adoption and application of
pollution prevention policies and
methods. A number of
environmental policies, statutes,
and executive orders bolster this
commitment to pollution prevention
(see box on next page).
Pollution Prevention:
"...any practice which reduces the
amount of any hazardous substance,
pollutant, or contaminant entering
any waste stream or otherwise
released into the environment
(including fugitive emissions) prior
to recycling, treatment or disposal;
and any practice which reduces the
hazards to public health and the
environment associated with the
release of such substances,
pollutants, or contaminants."
- Pollution Prevention Act of 1990
For many Federal agencies and
facilities, pollution prevention is
recognized as a vital element of
environmental management.
Nevertheless, pollution prevention
often takes place in localized and small-scale efforts within individual facilities. This
chapter describes how Federal facilities can capitalize on the relationship between
EMSs and pollution prevention (P2) to enhance the effectiveness and success of their
environmental programs.
EMS AND P2: A STRONG PARTNERSHIP
The benefits of pollution prevention can be significantly enhanced through an EMS
framework. By incorporating pollution prevention concepts into day-to-day operations,
a facility can more easily extend its pollution prevention program to all elements of
facility management. This approach can ensure broad awareness of pollution
prevention issues, enhance relevant training and communication, and strengthen the
facility's ability to recognize and capitalize on pollution prevention opportunities. Some
of the benefits of integrating pollution prevention and management systems are:
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P2 in the Federal Government
- Pollution Prevention Act of 1990: Establishes P2 as national environmental
policy. Codifies the pollution prevention hierarchy of approaches to waste
management: source reduction is the preferred approach, followed by recycling,
treatment, and disposal as the last resort.
- Executive Order 12856: Federal Compliance with Right-to-Know Laws and
Pollution Prevention Requirements: Directs Federal agencies to develop
pollution prevention strategies that commit each agency to incorporate P2
through source reduction in facility management and use P2 as the primary
means of achieving and maintaining compliance. Requires preparation of facility-
specific P2 plans for reducing releases and transport of toxic chemicals by 50% by
2000. Establishes the Federal Government Environmental Challenge Program,
under which EPA developed the Code of Environmental Management Principles
for Federal Agencies (CEMP).
- Other Executive Orders on ozone-depleting substances, energy efficient
computers, energy and water conservation, and recycling and waste reduction
(see Executive Orders 12843,12844, 12845,12873, and 12902) promote Federal
leadership in pollution prevention and environmental stewardship.
> Regulatory and Other Commitments Including CEMP: Sixteen Federal agencies
have committed to using pollution prevention as the primary means of achieving
regulatory compliance. Many of these agencies and their individual facilities have set
specific pollution prevention, energy efficiency, or water conservation goals in addition
to regulatory requirements with which they must comply. An EMS that integrates
regulatory requirements with additional pollution prevention goals helps the facility
identify or create opportunities for improvement, make their evaluation more systematic
and predictable, and sustain improvements once they are implemented. The facility
will meet both sets of goals more swiftly and effectively. For agencies that have
endorsed the CEMP, which stresses pollution prevention as a core principle, tying
P2 into an EMS can help show that the agency is meeting its voluntary obligation under
the CEMP.
> Health and Risk: Federal managers do not knowingly put their workers in danger,
but too often it takes an accident or injury to uncover the risks associated with the use
of hazardous materials. P2 meshes with risk reduction because the most dangerous
materials are often the most difficult to dispose of. The EMS framework requires that
a facility examine all of its environmental activities, products, and services (not just
those that are regulated) to identify the ways in which those activities affect the
environment, including workers, the public, and ecosystems. Incorporating this review
in an EMS can help a facility lower its risk profile and manage liabilities before crisis
situations arise.
36
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One way to highlight pollution prevention is
to "map" each process, identifying the
factors that control the work and assigning
costs to each contributing activity, even if it
is just for paperwork. An adhesive
manufacturer found that losses from
production shutdowns during certain
training activities were many times the
amount of the small training budget.
Experimenting with material handling
processes allowed the facility to eliminate
its storage tanks and associated training
courses entirely.
> Cost-Effectiven ess: The
prospect of not having to pay direct
and indirect costs associated with
waste disposal, permitting, and
environmental reporting has
always offered a strong incentive
for pollution prevention. Still,
facility-specific pollution prevention
efforts are often localized, small-
scale, reactive, and not
coordinated with other
organizational activities. In many
cases the costs of waste
management are charged to
general overhead costs, so their
impact is not fully appreciated by
managers of individual activities. Combining pollution prevention with an EMS can help
to ensure that pollution prevention considerations are identified and considered
throughout a facility's waste management process. Through integration and improved
efficiency, a well-designed EMS can enhance savings, as well as remove
environmental management costs from overhead.
> Public Confidence: Federal facilities operate on the basis of public trust.
Unfortunately, in the past, that stewardship was sometimes forgotten, resulting in a
legacy of contamination at Federal sites and shaken public confidence. A pollution
prevention ethic shows a
commitment to responsible waste
management and limiting
additional environmental damage.
An EMS further builds public
confidence by demonstrating that a
facility understands the connection
between its management practices
and activities that affect the
environment. It helps demonstrate
that an agency's primary mission
can be fully compatible with
environmental stewardship
responsibilities. An effective EMS
also contains elements of public outreach, encouraging facilities to be more open in
communicating with the public.
With an EMS, DOE can "provide
stakeholders and customers with real
evidence of performance in the
environmental management arena that won't
be subject to second-guessing or
gainsaying. We're going to be very effective
stewards of the environment under our
control and our stakeholders will see that."
- Dr. Tara O'Toole, DOE Assistant Secretary
> Sustainable Development: Although it may be difficult for any agency or facility to
precisely measure its contribution to sustainable development, robust pollution
prevention programs can improve management of natural environmental resources.
Judicious use of resources is also in keeping with the public policies which encourage
husbanding of resources to ensure their continued availability to future generations.
An EMS can help facilities maintain focus on these long-term considerations.
37
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USING EMS TO EXTEND POLLUTION PREVENTION
How can an EMS be used to integrate pollution prevention more thoroughly with other
environmental activities? Several EMS elements can be particularly useful in
strengthening pollution prevention
programs. In addition, it can be
easier to transfer successful
"We view pollution prevention as our best
.. .. .. . approach to compliance."
pollution prevention approaches _PMPcC|e||an Ajr FPrce B Sacramento
from one site to another if a
unifying management framework is
established. The EMS provides
just such a framework. With an EMS, facilities will be able to identify more quickly
those approaches that could be adapted to their unique conditions. This benefit can
also apply to private-sector innovations, which agencies will be able to evaluate for
applicability to their own sites. The potential for incorporating pollution prevention into
each EMS element is described in more detail below. Federal managers should keep
in mind that adopting an EMS approach does not — and should not — require building
programs from scratch. It should encourage adapting existing programs to work within
the EMS framework to the fullest extent possible.
> Environmental Policy: Adopting an EMS can make an agency's commitment more
powerful by institutionalizing pollution prevention as a priority concern. All too often,
pollution prevention gets "lost in the shuffle" when circumstances demand more
attention for items deemed mission- or time-critical. By emphasizing pollution
prevention as a basic foundation, an EMS can raise the profile of pollution prevention
and help ensure that a P2 approach is adopted throughout an agency's activities.
> Identifying Environmental Activities and Impacts: Agencies can take advantage
of the process of identifying environmental interactions and impacts to seek out and
conduct pollution prevention opportunity assessments in areas that may not have been
targeted previously for such assessments. Similarly, opportunities for advancing
sustainable development and reducing use of energy and natural resources can be
pursued.
> Identifying Legal and Other Requirements: By tracking environmental legislation
and other requirements, agencies can better integrate pollution prevention with
environmental program activities. Early consideration of forthcoming regulatory
changes allows facilities and agencies to respond with pollution prevention solutions
and perhaps avoid regulatory thresholds and reporting requirements. Because many
agencies already have internal networks that provide for review and comment on both
internal and external (e.g., regulatory) requirements, pollution prevention issues can
be incorporated into agency protocols.
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> Setting Environmental Objectives and Targets: This EMS element encourages
setting specific, measurable environmental performance measures (e.g., emission
levels), which is already the policy of many Federal agencies. Facilities can use this
element to more thoroughly integrate pollution prevention measures into their overall
environmental program goals.
> Developing and Implementing Environmental Management Programs: This
element provides agencies with an opportunity to examine their environmental
programs, including pollution prevention. Agencies should ensure that these activities
are integrated and that communication is maintained across the program. In addition,
measures should be included that allow new activities to be assessed for their
environmental aspects and impacts. Facilities should consider incorporating pollution
prevention-related concepts such as life cycle analysis, total cost accounting, and
design for the environment into their analyses.
> Assigning Responsibility and Accountability: Clear lines of responsibility need to
be established so that everyone knows who has the authority to make decisions, and
who is accountable for those decisions. Having a clear line of responsibility for
pollution prevention can encourage suggestions for improving the program. Assigning
responsibility and accountability should be consistent with agency policy.
> Monitoring and Measurement: Accurate and reliable performance measures are
needed to assess the effectiveness of an organization's environmental performance
and the effectiveness of the EMS. Similarly, adequate performance measures are
essential to evaluating the performance of pollution prevention programs. Evaluating
the performance of both the pollution prevention program and the EMS is needed to
ensure there is a good fit between the two. Program Improvements can be driven by
the feedback obtained through performance evaluation, so personnel should be
encouraged to consider innovative ways to improve both the pollution prevention
program and the EMS. Many Federal agencies and facilities already perform periodic
self-assessments and thus already have a foundation upon which performance
evaluation can be conducted.
ISO 14001 AND POLLUTION PREVENTION
The ISO 14001 EMS Standard supports pollution prevention. However, there are
differences in the definitions of P2 in ISO 14001 and the Pollution Prevention Act. ISO
includes recycling and treatment in its definition of preventing pollution, while the
Pollution Prevention Act defines pollution prevention as essentially equivalent to
source reduction, with recycling and treatment considered less desirable alternatives.
39
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Federal agencies and facilities should be aware of this distinction, as adherence to the
ISO version of P2 may not be considered effective enough to be the "primary means
of achieving and maintaining
compliance," as required under
Executive Order 12856.
Another potential discrepancy is
that ISO requires organizations to
consider "significant" impacts in
setting goals, but does not define
what "significant" impacts are.
Federal agencies should be aware
that what an organization
considers as a "significant" impact
for ISO purposes may not be the
same as a facility's activities and
impacts that are subject to
regulatory requirements. In light of
this, a Federal agency EMS should
assume compliance as a baseline,
and consider compliance with legal
and regulatory requirements to be
a "significant" impact when setting
goals.
An Example of Linking EMS and
Pollution Prevention: The Washington
State Department of Ecology (DEQ) is
implementing an Environmental
Management System Alternative to
Pollution Prevention Planning (EMS
Alternative). Facilities required to
prepare a State-required Pollution
Prevention Plan or Five Year Plan
Update can meet these requirements by
submitting documentation that they have
an operating EMS in place that meets a
set of pre-defined pollution prevention
criteria. A facility in conformance with
ISO 14001 qualifies for the EMS
Alternative, but must address pollution
prevention as defined by DEQ/Pollution
Prevention Act.
Despite these distinctions, ISO and other EMS approaches can be powerful tools in
augmenting pollution prevention programs. ISO 14001 reaches beyond the single
facility level by highlighting environmental stewardship -- concern for the goods and
services that it both uses and produces. An organization is expected to communicate
with its suppliers and contractors regarding the environmental standards and
requirements that accompany the purchase of those products. ISO is also developing
standards for life-cycle assessments (ISO 14040,14041,14042,14043) that can help
in the procurement of environmentally-friendly products.
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7 - NATIONAL ENVIRONMENTAL POLICY ACT
Federal managers already have in place a set of tools to intended to identify the
environmental impacts of Federal activities, to consider these impacts fully in
decisionmaking, and to reduce these impacts. These tools (including procedures,
data, and methods of analysis) have been developed over the past 25 years in
response to the requirements of the National Environmental Policy Act of 1969
(NEPA). In developing an environmental management system, Federal managers
have the opportunity to build on the strengths of these tools, and to address some of
their shortcomings.
Understanding the strengths and limitations of NEPA
Since the National Environmental Policy Act was signed in 1970, Federal agencies
have increased their analyses of the impacts of proposed actions and of alternatives
to those actions. Public involvement in agency decisionmaking has increased.
Numerous analytic tools have been developed, and an extensive environmental
database has been developed. At the same time, the requirements of NEPA are
perceived by many managers a hurdle to be overcome, rather than an opportunity for
improved decisionmaking.
The National Environmental Policy Act opens with a broad environmental policy
statement recognizing "the profound impact of man's activity on the interrelations of all
components of the natural environment."
NEPA also identifies requirements for Federal agencies. Federal agencies are
directed to integrate the natural sciences, the social sciences, and the environmental
design arts in planning and decisionmaking, through a "systematic, interdisciplinary
approach" (section 102(2)(A)). And for major Federal actions, agencies are directed
to prepare a detailed statement on the impact of the proposed action, and of
alternatives to the proposed action (section 102(2)(C )). It is this latter requirement,
and the substantial case law derived from it, which has led to the preparation of
thousands of Environmental Impact Statements over the years.
This "action-forcing" mechanism in section 102(2)(C) is focussed on decisionmaking
on major proposed Federal actions. NEPA does not require - nor was it intended to
when it was written- the creation of a system to manage, in an environmentally sound
way, ongoing activities.
So while NEPA does not provide a full-blown environmental management system for
Federal agencies, it does provide analytical tools and data which will be invaluable in
developing an management system. How can you take advantages of these existing
resources?
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*• Fully integrate your existing NEPA activities into your Environmental
Management System.
Use Existing Staff Expertise. Your agency has staff who have developed expertise in
analyzing and documenting environmental impacts under NEPA, and who know your
agency NEPA policies and procedures. Involve them in the development and
implementation of your EMS. Educate them about how an EMS differs from NEPA,
and let them apply their existing skills and knowledge.
Use Existing Procedures. Build into your EMS your agency's procedures for
identification of Federal actions, for identification of potential impacts, and for
identification and analysis of alternatives.
Incorporate Your Public Involvement Activities. Federal agencies are committed (by
law and policy) to involve the public in decisionmaking. Your management system will
describe how decisions get made, and how things get done; incorporate your existing
public involvement activities into the system.
> Build on your past NEPA analyses.
Identify Impacts. Review the environmental impact statements and environmental
assessments covering your facilities and activities, to help identify your environmental
aspects and impacts. These won't be the only sources you will need, but they should
give you a big head start.
Use Existing Impact Assessment Tools. Build on the skills and methodologies
developed in NEPA analyses over the past 25 years to establish relationships between
actions and potential effects.
A "Significant" Caution. "Significant impacts" are a key concept in both NEPA and the
ISO 14001 standard. Under NEPA, if potential impacts are "significant," then an
environmental impact statement is required. Under ISO 14001, the organization must
identify which environmental aspects have "significant" impacts, and consider these
impacts when they establish their objectives and targets. But the threshold for
"significant"is not necessarily the same. Under NEPA, there is extensive case law and
guidance addressing when impacts are "significant." Under ISO 14001, the
organization makes the determination. As a practical example, a Federal agency may
have a project or activity for which it has made a formal "Finding of No Significant
Impact" but it may still identify "significant" impacts to address in its environmental
management system.
While the threshold may be different, some of the factors to be considered in
assessing significance are common to both NEPA and ISO 14001, including: direct
and indirect impacts, cumulative impacts, and pollution prevention.
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> Use the development of your EMS to streamline and enhance your NEPA
processes.
Mitigation. Enhance the follow-through on commitments you have made to mitigate
environmental impacts. Identify the assumptions about mitigation in your NEPA
analyses, and the commitments to mitigation made in your Records of Decision.
Reflect these in your goals, your performance measures, or your monitoring as part of
your ongoing environmental management system.
Streamlining and Integration. As you integrate your NEPA procedures and activities
into your EMS, you may discover opportunities for improving them. Do so! It would be
far more work to start from scratch to invent new ones.
Top Management Involvement. NEPA was intended to lead to better decisions, and
a better environment. Integrating NEPA into your environmental management system
can ensure that the right information gets to top management in a timely way to ensure
that it is considered when important decisions are made.
Conclusion
As a result of their long experience with conducting analyses under NEPA, Federal
agencies already have in place many elements which will constitute part of their
environmental management system. By incorporating these, they will enhance their
emerging environmental management system. And in turn, the incorporation of NEPA
into an integrated management system, with top management support, can only
enhance the achievement of NEPA's lofty goals.
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8- AUDITS & CERTIFICATION
The use of audits is familiar to every Federal agency. Simply stated, an audit is a tool
with which an organization can examine its performance. Audits are often a means to
identify any violations of procedure or regulation, while collecting information to
determine performance trends. Although audits are conducted in many areas of
operation (e.g., finance, quality, documentation) and can take a variety of forms, this
chapter focuses on the use of audits within the context of an EMS. System audits are
a common element of EMS standards and critical to the goal of continuous
improvement.
ISO 14001 AND EMS AUDITS
Guidelines for
Environmental Auditing
• ISO 14010-General
Principles of
Environmental Auditing
• ISO 14011-Audit
Procedures - Auditing of
Environmental
Management Systems
• ISO 14012 - Qualification
Criteria for Environmental
Auditors
The ISO 14001 EMS Standard specifically requires
periodic EMS audits (for the internal information of
the organization) as a condition of conformance with
the standard, indicating the importance placed on
system evaluation by ISO. In addition, a facility that
wishes to be registered as conforming to the ISO
standard must undergo a formal audit by a
recognized, independent auditor who conducts a
thorough review comparing the facility EMS to the
ISO standard.
No Federal agency has required (or, as of this
publication date, announced plans to require) third-
party certification of its facilities. The Department of
Defense (DOD) has specifically stated that it does
not endorse nor support payment for third-party certification of ISO 14001. Although
DOD is not pursuing/funding third-party certification, one of the goals of the DOD ISO
14001 EMS pilot cost/benefit study is to determine if the benefits of implementing an
ISO EMS outweigh the costs (including third-party certification). On the other hand, the
Department of Energy has left decisions regarding third-party certification up to facility
managers.
Generally, the common practice has been for individual facilities (and/or contractors)
to decide that adopting IS014001 meets their mission, environmental, and productivity
goals. Federal facilities that do decide to seek third-party certification when
implementing ISO 14001 will need to include provisions for periodic EMS audits.
Agencies or facilities may also want to consider encouraging their contractors and
suppliers to become ISO-registered. Such encouragement might take the form of
offering performance incentives in negotiating contracts or giving preference to
registered bidders in contract awards. In both cases, Federal managers and
procurement officers will need to clearly and precisely define such terms as "consistent
with," "conforming to," or "principles of" ISO 14001. These details may be especially
44
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important in engaging contractors and vendors who must compete on price to win
Federal contracts. Therefore, it can be to a Federal agency's considerable advantage
to understand how EMS audits work, what they evaluate, and when they are being
performed properly.
WHATS IN AN AUDIT? £MSAudi,
Federal agencies considering .. a systematic and docun)ented verification
process to objectively obtain and evaluate
evidence to determine whether an
organization's environmental management
system conforms to the environmental
management system audit criteria set by the
organization, and communication of the
results of this process to management."
-ISO 14001
implementing an EMS at their
facilities need to be aware of the
differences between EMS audits
(and management audits in
general) and other types of audits
(e.g., compliance audits).
Management system audits
concentrate on managerial tools
and structures (systems,
procedures, policies, trained
personnel, lines of communication, etc.) that support the organization's activities, rather
than on the performance of the activities themselves.
Because an EMS focusses on management systems, the fact that an EMS audit does
not directly measure environmental performance can make it seem less valuable to a
budget-strapped Federal facility manager. However, this is precisely why an EMS
audit can be so important. The EMS itself can improve efficiency and cost-
effectiveness by providing a reliable, predictable framework in which to carry out
environmental activities. By incorporating systematic procedures for diagnosing
weaknesses in environmental performance and taking corrective action, an EMS audit
serves as preventive maintenance.
Keeping underlying management systems running smoothly is important in avoiding
breakdowns in any management system. Breakdowns often have immediate, serious,
and unpredictable consequences, undermining hard-won relationships with regulators
and stakeholders, and costing much more than periodic audits would have involved.
An EMS audit is not a regulatory compliance audit. There is a wealth of information
available on compliance audits, and these are familiar to Federal managers active in
the environmental field. Compliance audits focus on activities that are required by
regulation, such as:
— Required procedures and plans (e.g., spill response), and documentation
relating to on-site procedures
— Permit conditions and whether discharges or emissions are within those
conditions specified by law
— Waste storage areas to examine labels and segregation of incompatible wastes
— Hazardous waste characterizations and manifests
— Laboratory samples to ensure that proper test methods are used
— Monitoring wells and other field sampling operations
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Training records for hazardous site operators
Use of hazardous materials in daily operations
Status of enforcement actions or consent orders.
46
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An EMS audit looks at the facility from a different perspective, concentrating on the
management systems that support the activities examined during a compliance audit.
For example, the EMS auditor might look at:
— Procedures that address: updating of permits;
— monitoring of discharges and emissions;
— handling of hazardous waste and materials;
— handling of laboratory samples; and
— sampling and other field
activities
— Facility training program
— Environmental aspects
identified by the facility
(should include a
multimedia examination of
all emissions and waste
streams that affect the
environment)
— Procedures for addressing
noncompliance,
enforcement actions, or
consent orders
— Assignment of
responsibility for each area
examined.
"You don't get continuous improvement if
you don't have a way to check. The (ISO
14001) Standard requires that you have an
internal check. You could call upon people
in your own organization, you could call
upon an external source for doing an
internal check. You need to be able to see
where is the system working and, perhaps
more importantly, where at any given time is
the system not working. Management, then,
has to have a review of the whole thing."
- Mary McKiel, Vice Chair, U.S. Technical
Advisor Committee
EMS and compliance audits can thus be thought of as complementary. The EMS
furnishes the blueprint. The EMS audit verifies the blueprint. The compliance audit
examines how regulatory requirements were addressed. (It is likely that the
procedures developed for conducting compliance audits will also be evaluated during
the EMS audit.)
Compliance audits, which focus more closely on regulatory requirements, can lead to
enforcement actions. This does not mean that agencies should view EMS breakdowns
as insignificant because they don't have major regulatory implications. First, even
though implementation of an EMS is not required by law, discovery of noncompliance
requires prompt disclosure and correction. Second, an EMS can help to make
regulatory compliance more sustainable and predictable through program integration,
eliminating the "crisis management" approach to compliance. Therefore, any
breakdown identified by an EMS audit may be seen as early warning of potential
compliance problems.
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"Even though environmental liabilities are
widespread throughout the Federal sector,
most agencies - aside from the Department
of Energy and the Department of Defense -
do little or no environmental auditing.
Obstacles and disincentives impede the
further development of environmental
auditing in civilian agencies. GAO's
work...indicates that environmental auditing
at civilian agencies is hampered because
many agencies lack the necessary
environmental expertise."
— General Accounting Office
FEDERAL AGENCY AUDIT PROGRAMS
Some Federal agencies have
internal environmental audit
capabilities. The U.S. Postal
Service's Environmental
Compliance Quality Assessment
Reviews (QAR), the U.S. Air
Force's Environmental Compliance
and Management Program
(ECAMP), and DOE's
Environmental Management
Assessment program are just a few
that have been implemented over
the past decade. As might be
expected, EMS auditing among
civilian Federal agencies is more ^^^^^^^^^^^^^^^^^^^^~
limited, with audit programs more
focused on regulatory compliance issues rather than management practices.
EPA has incorporated evaluations of management practices into both volumes of its
Generic Protocol for Conducting Environmental Audits of Federal Facilities (EPA 300-
B-96-012A&B). The first volume addresses regulatory compliance. The second
volume discusses a more holistic approach to auditing management practices, and
includes protocols for EMS audits. There is also a companion guidance document,
Environmental Audit Program Design Guidelines for Federal Agencies (EPA 300-B-96-
011). DOE's Protocols for Conducting Environmental Management Assessments of
DOE Organizations (DOE/EH-0326) includes eight disciplines which are based on key
characteristics and elements of effective environmental management systems.
Several related environmental codes and programs, while not EMS standards, also
stress the importance of EMS evaluation. For example, the Chemical Manufacturers
Association (CMA) Responsible Care (R) program has developed a Management
Systems Verification component. The Global Environmental Management Initiative's
(GEMI) Total Quality Environmental Management (TQEM) approach stresses audits
as a core element of the "Plan-Do-Check-Act" cycle. GEMI has also developed a self-
assessment checklist for implementing ISO 14001.
Federal facilities can use any of these sources in evaluating their environmental
systems. However, the EPA and DOE documents are specifically targeted to Federal
facilities and can complement the more general ISO Standards 14010, 14011, and
14012.
CERTIFICATION: SELF-DECLARATION VS. THIRD-PARTY
Federal facilities implementing the ISO 14001 EMS standard have several options for
certification. They may announce or "self-declare" when they reach full implementation
of the standard. Alternatively, they may be formally reviewed by an independent or
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"third-party" registrar trained and accredited by ISO or one of its member bodies (e.g.,
the American National Standards Institute (ANSI)). A facility qualifies to be ISO 14001
registered if it can demonstrate that its EMS conforms to the standard. (The term
"conformance" is distinguished from "compliance," reflecting comparison to a voluntary
standard rather than a regulatory requirement.) Choosing between the options of self-
declaration or third-party certification can depend on credibility and cost:
> Credibility: Many people
believe that an objective
independent assessment of "We generally tell our clients that a single
, ... major non-conformance or five minor non-
conformance with an conformances within a sing|e e,ement of the
[ISO] Standard will be sufficient to deny
certification."
- Brent Backus, TUV Rheinland of North
America, Inc.
internationally recognized standard
will go further in persuading
Congress and the public that an
agency is committed to
responsible environmental
protection than will internal
assurances. This may eventually be true. However, it is not fully clear at this point
how much value ISO 14001 certification carries. A facility's stakeholders, regulators,
and Congressional authorizers and overseers will need to be convinced of the value
added by third-party certification. Regardless whether self-declaration or third-party
certification (or neither) is pursued, having an EMS audit build upon a compliance
audit should improve credibility with the public and other stakeholders.
> Cost: Hiring an independent third-party to conduct an assessment will cost some
money. Exactly how much is not clear, but would depend on the size of the facility and
the nature of its activities. EMS auditors can provide estimates based on information
provided to them. Certification will also need to be revisited periodically.
Managers should be aware that there are some significant concerns regarding the
confidentiality of information gathered during conformity assessments. Forthis reason
and because the benefits and costs are not yet clear, Federal managers may want to
defer a decision concerning third-party certification. Managers may also, however,
decide it is appropriate and prudent to conduct an EMS audit and implement an EMS
irrespective of issues concerning confidentiality and decisions regarding third-party
certification.
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9 - AN INVITATION TO ENVIRONMENTAL
LEADERSHIP
Environmental management systems offer a unique opportunity for Federal
facilities to step forth as environmental leaders. EMSs hold promise for both
internal and external benefits. Internally, an EMS can help establish a
systematic, cost-effective approach to the management of environmental
interactions. Externally, an EMS demonstrates the seriousness and
commitment of the Federal agency to improved environmental performance.
Over the next few years, reliable data on EMS performance will be forthcoming.
If, as we expect, the data show that EMS implementation leads to improved
performance that equals or exceeds the traditional "command-and-control"
approach, the EMS approach will gain credibility and broad support as a
powerful means to enhance compliance and performance.
The next few years will be an interesting and exciting time for Federal agencies
as the EMS approach gains momentum. In the Federal Government, some
facilities have adopted and implemented an EMS, while other are doing EMS
pilot projects to better determine the impact of a systems approach to
environmental management. Hopefully, this Primer has been helpful in
improving your understanding of EMSs and has pointed out some issues to be
considered. Your input on issues that need more consideration and input on
how useful this document has been are valued. Appendix E is an Evaluation
Form that can be used to provide this feedback. Please take a moment to
complete and return the from. Your assistance and input are appreciated.
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APPENDIX A - SELECTED RESOURCES
Standard-Setting Bodies
Web Sites
www.iso.ch (International Organization for Standardization)
www.nist.gov (National Institute of Standards and Technology)
www.ansi.org (American National Standards Institute)
www.csa.ca (Canadian Standards Association)
www.scc.ca/iso14000 (Standards Council of Canada)
www.quality.org/html/iso14000.html (ASQC Documents)
GETTING STARTED/General Interest
www.epa.gov (EPA) - General EPA Web site with access to environmental
information from all EPA offices. The Office of Water has made available an
implementation guide for Small Business, developed in collaboration with NSF
International. The Implementation Guide for the Code of Environmental
Management Principles for Federal Agencies (CEMP) (EPA-315-B-97-001) is
available from EPA's Federal Facilities Enforcement Office.
www.iso14000.net (ANSI/GETF GlobeNet) This site has considerable
information available. Some information is free; many elements, such as
copies of ISO standards, require payment.
www.iso14000.com (ISO 14000 InfoCenter sponsored by and accessible
through the Environmental Industry Web Site, www.enviroindustry.com) -
background information, lists of certified companies, training and business
opportunities, and links to articles.
www.mgmt14k.com (Management Alliances, Inc.) - provides background on
ISO 14000 and articles on benefits and challenges of the ISO series.
www.isogroup.iserv.net (ISO 9000/QS-9000 Support Group) - offers products
and services for understanding and implementing ISO 9000, QS-9000, and ISO
14000. Publishes a newsletter, Continuous Improvement, and offers a
discussion area. Some products and services are discounted or only available
to members.
www.gemi.org (Global Environmental Management Initiative)
www.cmahq.com (Chemical Manufacturers Association) - provides an
overview of the Responsible Care codes. Also lists CMA member companies,
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some of which have additional detail on Responsible Care implementation on
their own home pages.
www.ends.co.uk (Environmental Data Services)
www.ceem.com (CEEM Publications)
www.dep.state.pa.us/dep/deputate/pollprev/Tech_Assistance/Toolbox/l
SO14001/ISO14000.htm (Pennsylvania Department of Environmental
Protection)
www.stoller.com (S.M. StollerCo.) - one of the first ISO 14000 sites, offers a
significant amount of background on the ISO 14000 series.
Newsletters
CEEM Integrated Management Systems Update, CEEM Information Services.
Business and the Environment ISO 14000, Cutter Information Corp.
ISO 14000 News & Views (S. Wayne Rosenbaum)
Continuous Improvement (ISO 9000/QS-9000 Support Group)
Books & Reports
Bhat, Vasanthakumar, Total Quality Environmental Management: An ISO
14000 Approach, Quorum Books, to be published in 1998.
Block, Marilyn, Implementing ISO 14000, American Society for Quality, 1996.
Cascio, Joseph, Gayle Woodsie, and Philip Mitchell, eds., ISO 14000: The New
International Environmental Management Standards, McGraw Hill, 288 pp.,
1996.
Cascio, Joseph ed., The ISO 14000 Handbook, CEEM Information Services
and ASQC Quality Press, 764 pp., 1996.
Clements, Richard, Complete Guide to ISO 14000, Prentice Hall, 336 pp.,
1996.
GEMI, TQEM: The Primer, GEMI Publications, 25 pp., 1992.
Hemenway, Caroline and Mary McKiel, ISO 14000 Questions and Answers,
CEEM Information Services and ASQC Quality Press, 53 pp., 1997.
Hooks, Craig, EPA's Code of Environmental Management Principles (CEMP)
for Federal Agencies: An EMS Framework for the Federal Sector, Wiley &
Sons, 1997.
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Jackson, Suzan, ISO 14001 Implementation Guide: Creating an Integrated
Management System, Wiley & Sons, 1997.
Johnson, Perry, ISO 14000: The Business Manager's Complete Guide to
Environmental Management, Wiley & Sons, 256 pp., 1997.
Johnson, Perry, ISO 14000 Road Map to Registration, McGraw Hill, 208 pp.,
1997.
Kuhre, W. Lee, ISO 14001 Certification: Environmental Management Systems:
A Practical Guide for Preparing Effective Environmental Management Systems,
Prentice Hall, 378 pp., 1995.
Lamprecht, James, ISO 14000: Issues and Implementation Guidelines for
Responsible Environmental Management, American Management Association
Press, 1997.
Nestel, Glenn ed., Joseph Delrossi, and Andrew Ullman, The Road to ISO
14000, Irwin Professional Publications, 1996.
Puri, Subhash, Stepping Up to ISO 14000: Integrating Environmental Quality
With ISO 9000 and TQM, Productivity Press, 278 pp., 1996.
Richie, Ingrid and Wlliam Hayes, A Guide to Implementation of the ISO 14000
Series on Environmental Management, Prentice Hall, to be published in 1997.
Rothery, Brian, BS 7750: Implementing the Environment Management
Standard and the EC Eco-Management Scheme, Ashgate Publishing
Company, 1993.
Rothery, Brian, ISO 14000 and ISO 9000, Gower Publishing Company, 1995.
Sayre, Don, Inside ISO 14000: The Competitive Advantage of Environmental
Management, St. Lucie Press, 230 pp., 1996.
Tibor, Tom and Ira Feldman, ISO 14000: A Guide to the New Environmental
Management Standards, Irwin Professional Publishing, 237 pp., 1995.
Tibor, Tom and Ira Feldman, eds., Implementing ISO 14000: A Practical,
Comprehensive Guide to the ISO 14000 Environmental Management
Standards, Irwin Professional Publishing, 1996.
U.S. Department of Energy, Guidelines for Strategic Planning, DOE/PO-0041,
January 1996.
U.S. EPA, Federal Facilities Enforcement Office, Implementation Guide forthe
Code of Environmental Management Principles for Federal Agencies, EPA-
315-B-97-001, 42 pp., March 1997.
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Von Zharen, W.M., ISO 14000: Understanding the Environmental Standards,
Government Institutes, 1996.
Wever, Grace, Strategic Environmental Management: Using TQEM and ISO
14000 for Competitive Advantage, Wiley & Sons, 1996.
Willig, John, ed., Environmental TQM, McGraw Hill, 340 pp., 1993.
Willig, John and Phillip Marcus, eds., Moving Ahead With ISO 14000:
Improving Environmental Management and Advancing Sustainable
Development, Wiley & Sons, 304 pp., 1997.
Zottola, Vincent and Vincent Zottola Jr., The ISO 14001 Implementation Tool
Kit, Richard Irwin, 200 pp., 1997.
MEASURING PERFORMANCE
Web Sites
www.llnl.gov./PBM/handbook - DOE handbook of techniques/tools for
measuring performance
labs.ucop.edu/library.html (University of California) - self assessment and
annual review manual
www.nortel.com/habitat (Northern Telecom) - example of industrial site,
contains annual environmental report information, a description of Nortel's
EMS, performance indicators.
www.seattle.battelle.org/p2online/eshweb.htm (Battelle) "Using the Internet
for Environmental Benchmarking" contains a description of corporate sites that
provide environmental information on company practices in pollution
prevention, design for the environment, management systems, and product
stewardship.
www.benchnet.com (The Benchmarking Exchange) - offers information
exchange with organizations in all business sectors.
www.well.com/user/benchmar/tbnhome.html (The Benchmarking Network) -
similar in purpose to The Benchmarking Exchange, but geared more toward
administrative topics and full-service research and consulting.
Books & Reports
Electric Power Research Institute, 1996. Environmental Performance
Measurement: A Framework for the Utility Industry. Prepared by Decision
Focus Incorporated. EPRI TR-106078, Research Project 3006-10; 9030-02.
Palo Alto, CA.
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Epstein, Marc, Measuring Corporate Environmental Performance: Best
Practices for Costing and Measuring and Effective Environmental Strategy,
Irwin Professional Publishing, Chicago, 1996.
Executive Enterprises Publications, Measuring Environmental Performance:
Selecting Measures, Setting Standards and Establishing Benchmarks,
Executive Enterprises Publications Co., New York, 1993.
Kuhre, W. Lee, ISO 14031—Environmental Performance Evaluation, Prentice
Hall, 200pp., 1997.
U.S. General Accounting Office (GAO). 1996. Executive Guide: Effectively
Implementing the Government Performance and Results Act. GAO Report
Number GAO/GGD-96-118, June 1996.
U.S. Department of Energy, Guidelines for Performance Measurement, DOE
G 120.1-5, June 1996.
U.S. Environmental Protection Agency, Environmental Management System
Benchmark Report: A Review of Federal Agencies and Selected Private
Corporations. (EPA-300R-94-009, 1994)
Wever, Grace, Total Quality Environmental Management: An Implementation
Framework and Assessment Matrix Using the Baldrige Categories and Criteria,
Government Institutes, 1995.
COMPLIANCE AND REGULATIONS
Memorandum from Earl E. Devaney, Director, EPA Office of Criminal
Enforcement, "The Exercise of Investigative Discretion," January 12, 1994.
U.S. Department of Justice, Factors in Decisions on Criminal Prosecutions for
Environmental Violations in the Context of Significant Voluntary Compliance or
Disclosure Efforts by the Violator," July 1, 1991.
United States Sentencing Commission, "Chapter 8 - Sentencing of
Organizations," Part A, General Application Principles, United States
Sentencing Commission Guidelines Manual, (effective November 1, 1991).
U.S. Environmental Protection Agency, "Incentives for Self-Policing: Discovery,
Disclosure, Correction and Prevention of Violations Final Policy Statement," 60
FR 66706, December 22, 1995.
INNOVATIVE PROGRAMS
Web Sites and Telephone Services
http://tis-nt.eh.doe.gov/ism/(Integrated Safety Management Program at DOE)
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http://www.explorer.doe.gov:1776/htmlsdirectives.html (DOE Directives)
http://www.pr.doe.gov/dear.html (DOE Procurement Regulations)
www.epa.gov/ProjectXL (EPA web page on ProjectXL, providing an overview,
description of specific projects, legal and policy documents, and points of
contact)
www.epa.gov/docs/region01/steward/elp/index.html (EPA Region 1 Web
site, describing their Environmental Leadership Program)
www.epa.gov/envirosense (EPA's home page from Earth 1, the official
environmental information network for EPA)
www.epa.gov/envirosense/oeca/fedfac/fflex.html (EPA Federal Facilities
Enforcement Office's home page for information on Environmental
Management Reviews (EMRs) and the Code of Environmental Management
Principles (CEMP) for Federal agencies)
www.epa.gov/envirosense/elp/index.html (EPA web page for the
Environmental Leadership Program (ELP))
Forfurther information on Integratetd Safety Management Systems at DOE call
Mr. Richard Crowe, Safety Management Implementation Team Phone: 301-
903-6214
Project XL fax-on-demand: 202-260-8590
ProjectXL Information line: 703-934-3239
POLLUTION PREVENTION
Web Sites
iisd1.iisd.ca (International Institute for Sustainable Development) - information
on sustainable development. Includes the report "Green Standards: IS014000
and Sustainable Development".
Books & Reports
Pacific Northwest Laboratory, A Proposed Framework for Conducting Pollution
Prevention Design Assessments (P2DAs) on U.S. Department of Energy
Design Projects, PNL-10204, , October 1994.
U.S. EPA Federal Facilities Enforcement Office, Pollution Prevention in the
Federal Government: Guide for Developing Pollution Prevention Strategies for
Executive Order 12856 and Beyond, EPA-300-B-94-007, April 1994.
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U.S. EPA Federal Facilities Enforcement Office, Federal Facility Pollution
Prevention Planning Guide, EPA-300-B-94-013, December 1994.
U.S. EPA Federal Facilities Enforcement Office, Federal Facility Pollution
Prevention Project Analysis: A Primer for Applying Life Cycle and Total Cost
Assessment Concepts, EPA-300-B-95-008, July 1995.
U.S. General Accounting Office, Ecosystem Management: Additional Actions
Needed to Adequately Testa Promising Approach, GAO/RCED-94-111, August
1994.
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AUDITS & CERTIFICATION
Books & Reports
Executive Enterprises Publications, Measuring Environmental Performance:
Selecting Measures, Setting Standards and Establishing Benchmarks,
Executive Enterprises Publications Co., New York, 1993.
Chemical Manufacturers Association, Responsible Care Management Systems
Verification Information Kit
Environmental Auditing Roundtable (John Willig ed.), Auditing for
Environmental Quality Leadership: Beyond Compliance to Environmental
Excellence, Executive Enterprises Publications, 331 pp., 1995.
Global Environmental Management Initiative (GEMI), Benchmarking: The
Primer, GEMI Publications, 49 pp., 1994.
Global Environmental Management Initiative (GEMI), Environmental Self-
Assessment Program (ESAP), GEMI Publications, 114 pp., 1992.
Global Environmental Management Initiative (GEMI), ISO 14001 Environmental
Management System Self-Assessment Checklist, GEMI Publications, 54 pp.,
1995.
Kuhre, W. Lee, ISO 14010: Environmental Auditing: Tools and Techniques for
Passing or Performing Environmental Audits, Prentice Hall, 440 pp., 1996.
U.S. Department of Energy, Protocols for Conducting Environmental
Management Assessments of DOE Organizations, DOE/EH-0326, 60 pp.,
1993.
U.S. Environmental Protection Agency, Generic Protocol for Conducting
Environmental Audits of Federal Facilities. (EPA 300-B-96-012A&B, December
1996)
U.S. Environmental Protection Agency, Environmental Audit Program Design
Guidelines for Federal Agencies. (EPA 300-B-96-011, Spring 1997)
U.S. General Accounting Office, Environmental Auditing: A Useful Tool That
Can Improve Environmental Performance and Reduce Costs, GAO/RCED-95-
37, April 1995.
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APPENDIX B - NEIC EMS CRITERIA
The civil multimedia compliance investigations conducted by the EPA National
Enforcement Investigations Center (NEIC) have increasingly involved
identifying causes of observed noncompliance. Where investigated,
noncompliance most often appeared to be caused by dysfunctional EMSs.
Through this work and by participating in followup enforcement actions, NEIC
developed criteria for a compliance-focused EMS that have been used as the
basis for several of the settlement agreements where EMS improvements were
required. To date, NEIC has been directly involved in negotiating five
settlement agreements (mostly consent decrees) that address the facility's
EMS, and provided consultation on several others. The elements of the NEIC
EMS are as follows:
1. Management Policies and Procedures
a. Organization's Environmental Policy - This must clearly communicate
management commitment to environmental performance, including
compliance with applicable Federal, state, and local environmental
statutes and regulations, including permits (hereafter, "environmental
requirements").
b. Site-specific Environmental Policies and Standards
— Body of general policies, rules, and procedures for environmental
principles and practices.
— Includes process for developing, approving, and communicating
standard operating practices for activities having potentially adverse
environmental or regulatory compliance impacts.
— Clearly identifies organizational responsibilities for maintaining
regulatory compliance, including required reporting to regulatory
agencies.
— Includes ongoing means of communicating environmental issues
and information to all organization personnel, on-site service
providers, and contractors, and receiving and addressing their
concerns.
— Describes and establishes processes to ensure sustained
interaction with regulatory agencies, and within the organization
(e.g., between the various divisions, contractors, and the
Environmental Control Department) regarding environmental issues
and regulatory compliance.
2. Organization, Personnel, and Oversight of EMS
a. Describes, organizationally, how the EMS is implemented and
maintained.
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b. Includes organization charts that identify units and individuals having
environmental performance and regulatory compliance responsibilities.
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c. Identifies duties, roles, responsibilities, and authorities of key
environmental program personnel in implementing and sustaining the
EMS (e.g., could include position descriptions and performance
standards for all environmental department personnel, and excerpts
from others having specific environmental program and regulatory
compliance responsibilities).
3. Accountability and Responsibility
a. Specifies accountability and responsibilities of organization's
management, on-site service providers, and contractors for
environmental protection practices, compliance, required reporting to
regulatory agencies, and corrective actions implemented in their area(s)
of responsibility. Also specifies potential consequences of departure
from specified operating procedures, including responsibilities (personal
and organizational) for civil/administrative penalties imposed as a result
of noncompliance.
4. Environmental Requirements
a. Describes process for identifying, understanding, and communicating
environmental requirements to affected organization personnel, on-site
service providers, and contractors, and ensuring that facility activities
conform to those requirements. Specifies procedures for identifying
and obtaining information about changes and proposed changes in
environmental requirements, and incorporating those changes into the
EMS.
5. Assessment, Prevention, and Control
a. Identifies an ongoing process for assessing operations, for the
purposes of preventing and controlling releases, environmental
protection, and maintaining compliance with statutory and regulatory
requirements. This shall include monitoring and measurements, as
appropriate, to ensure sustained compliance. It shall also include
identifying operations and waste streams where equipment
malfunctions and deterioration, operator errors, and discharges or
emissions may be causing, or may lead to, releases of hazardous
waste or hazardous constituents to the environment, or a threat to
human health or the environment. Finally, process shall include
performing root cause analysis of identified problems to prevent
recurring issues.
b. Describes process for identifying activities that could cause adverse
environmental impacts and/or regulatory noncompliance, and where
documented standard operating practices need to be developed [see
element 1.(b)].
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c. Describes a system for conducting and documenting routine, objective,
self-inspections by department supervision and trained staff, especially
at locations identified by the process described in (a) above.
d. Describes process for ensuring input of environmental concerns and
requirements in planning; design; and operation of ongoing; new;
and/or changing buildings, processes, maintenance activities, and
products.
6. Environmental Incident and Noncompliance Investigations
a. Describes standard procedures and requirements for incident and
noncompliance reporting, investigation; and development, tracking, and
effectiveness verification of corrective and preventative actions. The
procedures shall specify testing of such procedures, where practicable.
7. Environmental Training, Awareness, and Competence
a. Identifies specific education and training required for organization
personnel, as well as process for documenting training provided.
b. Describes program to ensure that organization employees are aware of
its environmental policies and procedures, environmental requirements,
and their roles and responsibilities within the environmental
management system.
c. Describes program for ensuring that personnel responsible for meeting
and sustaining compliance with environmental requirements are
competent on the basis of appropriate education, training, and/or
experience.
8. Planning for Environmental Matters
a. Describes how environmental planning will be integrated into other
plans developed by organizational subunits, as appropriate (e.g., capital
improvements, training, maintenance).
b. Requires establishing written goals, objectives, and action plans by at
least each operating organizational subunit, as appropriate, including
those for contractor operations conducted at the facility, and how
specified actions will be tracked and progress reported.
9. Maintenance of Records and Documentation
a. Identifies the types of records developed in support of the EMS
(including audits and reviews), who maintains them and where, and
protocols for responding to inquiries and requests for release of
information. Specifies the data management systems for any internal
waste tracking, environmental data, and hazardous waste
determinations.
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10. Pollution Prevention Program
a. Describes an internal program for reducing, recycling, reusing, and
minimizing waste and emissions, including procedures to encourage
material substitutions. Also includes mechanisms for identifying
candidate materials to be addressed by program and tracking progress.
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11. Continuing Program Evaluation
a. Describes program for periodic, at least annually, evaluation of the
EMS, including incorporating the results of the assessment into program
improvements, revisions to the manual, and communicating findings
and action plans to affected employees, on-site service providers, and
contractors.
12. Public Involvement/Community Outreach
a. Describes a program forongoing community education and involvement
in the environmental aspects of the organization's operations and
general environmental awareness.
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APPENDIX C - STATE CONTACTS
CALIFORNIA: Bob Stephens
Cal-EPA; Dept. Of Toxic Substances Control
510-540-3003
COLORADO: Parry Burnap
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive North
Denver, CO 80222-1530
parry.burnap@state.co.us
INDIANA: Marc Hancock
Indiana Dept. of Environmental Management
Office of Pollution Prevention and Technical Assistance
105 S. Meridian St., P.O. Box 6015
Indianapolis, IN 46206-6015
317-233-1043; 317-233-5627 fax
email: mhanc@opn.dem.state.in.us.
MARYLAND: Mitch McCalmon
Department of Environmental Protection
2500 Broening Highway
Baltimore, MD 21224
410-631-3772; 410-631-3936 fax
MICHIGAN: Marcia Horan
Environmental Assistance Division
Michigan Department of Environmental Quality
P.O. Box 30457
116W. Allegan
Lansing, Ml 48909
517-373-9122
email: horanm@deq.state.mi.us
NORTH CAROLINA: Ravila Gupta
Office of Waste Reduction
P.O. Box 29569
Raleigh, NC 27626
919-715-6507
email: Ravila_Gupta@owr.ehnr.state.nc.us
OHIO: Andrea Futrell
Ohio EPA, Office of Pollution Prevention
P.O. Box1049
Columbus, OH 43216-1049
614-644-2813; 614-728-1245 fax
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e-mail: andrea_futrell@central.epa.ohio.gov
PENNSYLVANIA: ISO 14000 Partnerships
c/o Robert Barkanic
Department of Environmental Protection
P.O. Box 2063
Harrisburg, PA 17105-2063
email: Barkanic.Robert@a1.dep.state.pa.us
VIRGINIA: Harry E. Gregori, Jr.
Director of Policy and Legislation
Virginia DEQ
PO Box 10009
Richmond VA 23240-0009
WASHINGTON: Rob Reuter
Dept. of Ecology
206-649-7086
email: rreu461@ecy.wa.gov
WISCONSIN: Tom Eggert
Wisconsin DNR
608-267-9700
email: eggert@dnr.state.wi.us
University of Wisconsin-Extension
Wayne P. Pferdehirt, P.E., AICP
U. of Ws., Solid & Hazardous Waste Education Center
610 Langdon Street, Room 529,
Madison, Wl 53703-1195
608-265-2361; 608-262-6250 fax
email: pferdehi@epd.engr.wisc.edu
WYOMING: Pat Gallagher
Wyoming P2 Program
122 West 25th Street
Cheyenne, WY 82002
307-777-6105; 307-777-5973 fax
email: pgalla@missc.state.wy.us
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APPENDIX D - EVALUATION FORM
WE VALUE YOUR OPINION
The EMS Primer for Federal Facilities was written to give Federal employees an understanding of Environmental
Management Systems and useful ideas to help implement an EMS. How well did the Primer do this for you?
Please rate understandability and usefulness using the following scale:
1 = not at all 2 = a little 3 = somewhat 4 = a lot 5 = very much X = N/A
Please rate the Primer's chapters Understandability Usefulness
1. Introduction
2. Getting Started
3. Performance Measures
4. Compliance and Regulations
5. Innovative Programs
6. Pollution Prevention
7. NEPA
8. Audits & Certification
In general, chapters
9. Are the right length
10. Cover the right topics
11. Examples clarify the text
12. Will be useful in your job
13. Overall usefulness of the Primer
Updates to the Primer are planned.
What did you like best?
What would you change (e.g., more topics, examples, etc.)?
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And About You:
Are you:
a Federal employee? Y N
a Federal Contractor? Y N
an ES&H Specialist? Y N
a Facilities Manager? Y N
HQ Program staff/manager? Y N
Other
Responsible for:
regulatory compliance? Y N
pollution prevention? Y N
implementing an EMS? Y N
implementing the CEMP?Y N
NEPA? Y N
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If you would like a copy of the updated Primer and other EMS material, please include your name and address
below.
Name Agency/Org.
Address
Telephone Fax Email_
Send to: Environmental Protection Agency
Federal Facilities Enforcement Office
401 M St. S.W.
Washington, DC 20460
Attn: Priscilla Harrington
Fax- 202-501-0069
or
Department of Energy
Office of Environmental Policy & Assistance (EH-41)
1000 Independence Ave. S.W.
Washington, DC 20585-0119
Attn: Carolyn Douglas
Fax - 202-586-0955
68
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Wednesday,
April 26, 2000
Part V
The President
Executive Order 13148—Greening the
Government Through Leadership in
Environmental Management
Executive Order 13149—Greening the
Government Through Federal Fleet and
Transportation Efficiency
Executive Order 13150—Federal
Workforce Transportation
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24595
Federal Register
Vol. 65, No. 81
Wednesday, April 26, 2000
Presidential Documents
Title 3—
The President
Executive Order 13148 of April 21, 2000
Greening the Government Through Leadership in
Environmental Management
By the authority vested in me as President by the Constitution and the
laws of the United States of America, including the Emergency Planning
and Community Right-to-Know Act of 1986 (42 U.S.C. 11001-11050)
(EPCRA), the Pollution Prevention Act of 1990 (42 U.S.C. 13101-13109)
(PPA), the Clean Air Act (42 U.S.C. 7401-7671q) (CAA), and section 301
of title 3, United States Code, it is hereby ordered as follows:
PART 1—PREAMBLE
Section 101. Federal Environmental Leadership. The head of each Federal
agency is responsible for ensuring that all necessary actions are taken to
integrate environmental accountability into agency day-to-day decision-
making and long-term planning processes, across all agency missions, activi-
ties, and functions. Consequently, environmental management considerations
must be a fundamental and integral component of Federal Government poli-
cies, operations, planning, and management. The head of each Federal agency
is responsible for meeting the goals and requirements of this order.
PART 2—GOALS
Sec. 201. Environmental Management. Through development and implemen-
tation of environmental management systems, each agency shall ensure that
strategies are established to support environmental leadership programs,
policies, and procedures and that agency senior level managers explicitly
and actively endorse these strategies.
Sec. 202. Environmental Compliance. Each agency shall comply with environ-
mental regulations by establishing and implementing environmental compli-
ance audit programs and policies that emphasize pollution prevention as
a means to both achieve and maintain environmental compliance.
Sec. 203. Right-to-Know and Pollution Prevention. Through timely planning
and reporting under the EPCRA, Federal facilities shall be leaders and respon-
sible members of their communities by informing the public and their work-
ers of possible sources of pollution resulting from facility operations. Each
agency shall strive to reduce or eliminate harm to human health and the
environment from releases of pollutants to the environment. Each agency
shall advance the national policy that, whenever feasible and cost-effective,
pollution should be prevented or reduced at the source. Funding for regu-
latory compliance programs shall emphasize pollution prevention as a means
to address environmental compliance.
Sec. 204. Release Reduction: Toxic Chemicals. Through innovative pollution
prevention, effective facility management, and sound acquisition and procure-
ment practices, each agency shall reduce its reported Toxic Release Inventory
(TRI) releases and off-site transfers of toxic chemicals for treatment and
disposal by 10 percent annually, or by 40 percent overall by December
31, 2006.
Sec. 205. Use Reduction: Toxic Chemicals and Hazardous Substances and
Other Pollutants. Through identification of proven substitutes and established
facility management practices, including pollution prevention, each agency
shall reduce its use of selected toxic chemicals, hazardous substances, and
pollutants, or its generation of hazardous and radioactive waste types at
its facilities by 50 percent by December 31, 2006. If an agency is unable
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24596 Federal Register/Vol. 65, No. 81/Wednesday, April 26, 2000/Presidential Documents
to reduce the use of selected chemicals, that agency will reduce the use
of selected hazardous substances or its generation of other pollutants, such
as hazardous and radioactive waste types, at its facilities by 50 percent
by December 31, 2006.
Sec. 206. Reductions in Ozone-Depleting Substances. Through evaluating
present and future uses of ozone-depleting substances and maximizing the
purchase and the use of safe, cost effective, and environmentally preferable
alternatives, each agency shall develop a plan to phase out the procurement
of Class I ozone-depleting substances for all nonexcepted uses by December
31,2010.
Sec. 207. Environmentally and Economically Beneficial Landscaping. Each
agency shall strive to promote the sustainable management of Federal facility
lands through the implementation of cost-effective, environmentally sound
landscaping practices, and programs to reduce adverse impacts to the natural
environment.
PART 3—PLANNING AND ACCOUNTABILITY
Sec. 301. Annual Budget Submission. Federal agencies shall place high
priority on obtaining funding and resources needed for implementation of
the Greening the Government Executive Orders, including funding to address
findings and recommendations from environmental management system au-
dits or facility compliance audits conducted under sections 401 and 402
of this order. Federal agencies shall make such requests as required in
Office of Management and Budget (OMB) Circular A-ll.
Sec. 302. Application of Life Cycle Assessment Concepts. Each agency with
facilities shall establish a pilot program to apply life cycle assessment and
environmental cost accounting principles. To the maximum extent feasible
and cost-effective, agencies shall apply those principles elsewhere in the
agency to meet the goals and requirements of this order. Such analysis
shall be considered in the process established in the OMB Capital Program-
ming Guide and OMB Circular A—11. The Environmental Protection Agency
(EPA), in coordination with the Workgroup established in section 306 of
this order, shall, to the extent feasible, assist agencies in identifying, applying,
and developing tools that reflect life cycle assessment and environmental
cost accounting principles and provide technical assistance to agencies in
developing life cycle assessments and environmental cost accounting assess-
ments under this Part.
Sec. 303. Pollution Prevention to Address Compliance. Each agency shall
ensure that its environmental regulatory compliance funding policies promote
the use of pollution prevention to achieve and maintain environmental
compliance at the agency's facilities. Agencies shall adopt a policy to pref-
erentially use pollution prevention projects and activities to correct and
prevent noncompliance with environmental regulatory requirements. Agency
funding requests for facility compliance with Federal, State, and local envi-
ronmental regulatory requirements shall emphasize pollution prevention
through source reduction as the means of first choice to ensure compliance,
with reuse and recycling alternatives having second priority as a means
of compliance.
Sec. 304. Pollution Prevention Return-on-Investment Programs. Each agency
shall develop and implement a pollution prevention program at its facilities
that compares the life cycle costs of treatment and/or disposal of waste
and pollutant streams to the life cycle costs of alternatives that eliminate
or reduce toxic chemicals or pollutants at the source. Each agency shall
implement those projects that are life-cycle cost-effective, or otherwise offer
substantial environmental or economic benefits.
Sec. 305. Policies, Strategies, and Plans.
(a) Within 12 months of the date of this order, each agency shall ensure
that the goals and requirements of this order are incorporated into existing
agency environmental directives, policies, and documents affected by the
requirements and goals of this order. Where such directives and policies
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Federal Register/Vol. 65, No. 81/Wednesday, April 26, 2000/Presidential Documents 24597
do not already exist, each agency shall, within 12 months of the date
of this order, prepare and endorse a written agency environmental manage-
ment strategy to achieve the requirements and goals of this order. Agency
preparation of directives, policies, and documents shall reflect the nature,
scale, and environmental impacts of the agency's activities, products, or
services. Agencies are encouraged to include elements of relevant agency
policies or strategies developed under this part in agency planning documents
prepared under the Government Performance and Results Act of 1993, Public
Law 103-62.
(b) By March 31, 2002, each agency shall ensure that its facilities develop
a written plan that sets forth the facility's contribution to the goals and
requirements established in this order. The plan should reflect the size
and complexity of the facility. Where pollution prevention plans or other
formal environmental planning instruments have been prepared for agency
facilities, an agency may elect to update those plans to meet the requirements
and goals of this section.
(c) The Federal Acquisition Regulation (FAR) Council shall develop acqui-
sition policies and procedures for contractors to supply agencies with all
information necessary for compliance with this order. Once the appropriate
FAR clauses have been published, agencies shall use them in all applicable
contracts. In addition, to the extent that compliance with this order is
made more difficult due to lack of information from existing contractors,
or concessioners, each agency shall take practical steps to obtain the informa-
tion needed to comply with this order from such contractors or concessioners.
Sec. 306. Interagency Environmental Leadership Workgroup. Within 4 months
of the date of this order, EPA shall convene and chair an Interagency
Environmental Leadership Workgroup (the Workgroup) with senior-level rep-
resentatives from all executive agencies and other interested independent
Government agencies affected by this order. The Workgroup shall develop
policies and guidance required by this order and member agencies shall
facilitate implementation of the requirements of this order in their respective
agencies. Workgroup members shall coordinate with their Agency Environ-
mental Executive (AEE) designated under section 301(d) of Executive Order
13101 and may request the assistance of their AEE in resolving issues
that may arise among members in developing policies and guidance related
to this order. If the AEEs are unable to resolve the issues, they may request
the assistance of the Chair of the Council on Environmental Quality (CEQ).
Sec. 307. Annual Reports. Each agency shall submit an annual progress
report to the Administrator on implementation of this order. The reports
shall include a description of the progress that the agency has made in
complying with all aspects of this order, including, but not limited to,
progress in achieving the reduction goals in sections 502, 503, and 505
of this order. Each agency may prepare and submit the annual report in
electronic format. A copy of the report shall be submitted to the Federal
Environmental Executive (FEE) by EPA for use in the biennial Greening
the Government Report to the President prepared in accordance with Execu-
tive Order 13101. Within 9 months of the date of this order, EPA, in
coordination with the Workgroup established under section 306 of this order,
shall prepare guidance regarding the information and timing for the annual
report. The Workgroup shall coordinate with those agencies responsible
for Federal agency reporting guidance under the Greening the Government
Executive orders to streamline reporting requirements and reduce agency
and facility-level reporting burdens. The first annual report shall cover cal-
endar year 2000 activities.
PART 4—PROMOTING ENVIRONMENTAL MANAGEMENT AND
LEADERSHIP
Sec. 401. Agency and Facility Environmental Management Systems. To attain
the goals of section 201 of this order:
(a) Within 18 months of the date of this order, each agency shall conduct
an agency-level environmental management system self assessment based
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24598 Federal Register/Vol. 65, No. 81/Wednesday, April 26, 2000/Presidential Documents
on the Code of Environmental Management Principles for Federal Agencies
developed by the EPA (61 Fed. Reg. 54062) and/or another appropriate
environmental management system framework. Each assessment shall include
a review of agency environmental leadership goals, objectives, and targets.
Where appropriate, the assessments may be conducted at the service, bureau,
or other comparable level.
(b) Within 24 months of the date of this order, each agency shall implement
environmental management systems through pilot projects at selected agency
facilities based on the Code of Environmental Management Principles for
Federal Agencies and/or another appropriate environmental management
system framework. By December 31, 2005, each agency shall implement
an environmental management system at all appropriate agency facilities
based on facility size, complexity, and the environmental aspects of facility
operations. The facility environmental management system shall include
measurable environmental goals, objectives, and targets that are reviewed
and updated annually. Once established, environmental management system
performance measures shall be incorporated in agency facility audit protocols.
Sec. 402. Facility Compliance Audits. To attain the goals of section 202
of this order:
(a) Within 12 months of the date of this order, each agency that does
not have an established regulatory environmental compliance audit program
shall develop and implement a program to conduct facility environmental
compliance audits and begin auditing at its facilities within 6 months of
the development of that program.
(b) An agency with an established regulatory environmental compliance
audit program may elect to conduct environmental management system audits
in lieu of regulatory environmental compliance audits at selected facilities.
(c) Facility environmental audits shall be conducted periodically. Each
agency is encouraged to conduct audits not less than every 3 years from
the date of the initial or previous audit. The scope and frequency of audits
shall be based on facility size, complexity, and the environmental aspects
of facility operations. As appropriate, each agency shall include tenant,
contractor, and concessioner activities in facility audits.
(d) Each agency shall conduct internal reviews and audits and shall take
such other steps, as may be necessary, to monitor its facilities' compliance
with sections 501 and 504 of this order.
(e) Each agency shall consider findings from the assessments or audits
conducted under Part 4 in program planning under section 301 of this
order and in the preparation and revisions to facility plans prepared under
section 305 of this order.
(f) Upon request and to the extent practicable, the EPA shall provide
technical assistance in meeting the requirements of Part 4 by conducting
environmental management reviews at Federal facilities and developing poli-
cies and guidance for conducting environmental compliance audits and im-
plementing environmental management systems at Federal facilities.
Sec. 403. Environmental Leadership and Agency Awards Programs.
(a) Within 12 months of the date of this order, the Administrator shall
establish a Federal Government environmental leadership program to promote
and recognize outstanding environmental management performance in agen-
cies and facilities.
(b) Each agency shall develop an internal agency-wide awards program
to reward and highlight innovative programs and individuals showing out-
standing environmental leadership in implementing this order. In addition,
based upon criteria developed by the EPA in coordination with the
Workgroup established in section 306 of this order, Federal employees who
demonstrate outstanding leadership in implementation of this order may
be considered for recognition under the White House awards program set
forth in section 803 of Executive Order 13101 of September 14, 1998.
Sec. 404. Management Leadership and Performance Evaluations.
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Federal Register/Vol. 65, No. 81/Wednesday, April 26, 2000/Presidential Documents 24599
(a) To ensure awareness of and support for the environmental requirements
of this order, each agency shall include training on the provisions of the
Greening the Government Executive orders in standard senior level manage-
ment training as well as training for program managers, contracting personnel,
procurement and acquisition personnel, facility managers, contractors, con-
cessioners, and other personnel as appropriate. In coordination with the
Workgroup established under section 306 of this order, the EPA shall prepare
guidance on implementation of this section.
(b) To recognize and reinforce the responsibilities of facility and senior
headquarters program managers, regional environmental coordinators and
officers, their superiors, and, to the extent practicable and appropriate, others
vital to the implementation of this order, each agency shall include successful
implementation of pollution prevention, community awareness, and environ-
mental management into its position descriptions and performance evalua-
tions for those positions.
Sec. 405. Compliance Assistance.
(a) Upon request and to the extent practicable, the EPA shall provide
technical advice and assistance to agencies to foster full compliance with
environmental regulations and all aspects of this order.
(b) Within 12 months of the date of this order, the EPA shall develop
a compliance assistance center to provide technical assistance for Federal
facility compliance with environmental regulations and all aspects of this
order.
(c) To enhance landscaping options and awareness, the United States
Department of Agriculture (USDA) shall provide information on the suit-
ability, propagation, and the use of native plants for landscaping to all
agencies and the general public by USDA in conjunction with the center
under subsection (b) of this section. In implementing Part 6 of this order,
agencies are encouraged to develop model demonstration programs in coordi-
nation with the USDA.
Sec. 406. Compliance Assurance.
(a) In consultation with other agencies, the EPA may conduct such reviews
and inspections as may be necessary to monitor compliance with sections
501 and 504 of this order. Each agency is encouraged to cooperate fully
with the efforts of the EPA to ensure compliance with those sections.
(b) Whenever the Administrator notifies an agency that it is not in compli-
ance with section 501 or 504 of this order, the agency shall provide the
EPA a detailed plan for achieving compliance as promptly as practicable.
(c) The Administrator shall report annually to the President and the public
on agency compliance with the provisions of sections 501 and 504 of this
order.
Sec. 407. Improving Environmental Management. To ensure that government-
wide goals for pollution prevention are advanced, each agency is encouraged
to incorporate its environmental leadership goals into its Strategic and An-
nual Performance Plans required by the Government Performance and Results
Act of 1993, Public Law 103-62, starting with performance plans accom-
panying the FY 2002 budget.
PART 5—EMERGENCY PLANNING, COMMUNITY RIGHT-TO-KNOW, AND
POLLUTION PREVENTION
Sec. 501. Toxics Release Inventory/Pollution Prevention Act Reporting. To
attain the goals of section 203 of this order:
(a) Each agency shall comply with the provisions set forth in section
313 of EPCRA, section 6607 of PPA, all implementing regulations, and
future amendments to these authorities, in light of applicable EPA guidance.
(b) Each agency shall comply with these provisions without regard to
the Standard Industrial Classification (SIC) or North American Industrial
Classification System (NAICS) delineations. Except as described in subsection
(d) of this section, all other existing statutory or regulatory limitations or
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exemptions on the application of EPCRA section 313 to specific activities
at specific agency facilities apply to the reporting requirements set forth
in subsection (a) of this section.
(c) Each agency required to report under subsection (a) of this section
shall do so using electronic reporting as provided in EPA's EPCRA section
313 guidance.
(d) Within 12 months of the date of this order, the Administrator shall
review the impact on reporting of existing regulatory exemptions on the
application of EPCRA section 313 at Federal facilities. Where feasible, this
review shall include pilot studies at Federal facilities. If the review indicates
that application of existing exemptions to Federal Government reporting
under this section precludes public reporting of substantial amounts of
toxic chemicals under subsection 501(a), the EPA shall prepare guidance,
in coordination with the Workgroup established under section 306 of this
order, clarifying application of the exemptions at Federal facilities. In devel-
oping the guidance, the EPA should consider similar application of such
regulatory limitations and exemptions by the private sector. To the extent
feasible, the guidance developed by the EPA shall be consistent with the
reasonable application of such regulatory limitations and exemptions in
the private sector. The guidance shall ensure reporting consistent with the
goal of public access to information under section 313 of EPCRA and section
6607 of PPA. The guidance shall be submitted to the AEEs established
under section 301(d) of Executive Order 13101 for review and endorsement.
Each agency shall apply any guidance to reporting at its facilities as soon
as practicable but no later than for reporting for the next calendar year
following release of the guidance.
(e) The EPA shall coordinate with other interested Federal agencies to
carry out pilot projects to collect and disseminate information about the
release and other waste management of chemicals associated with the envi-
ronmental response and restoration at their facilities and sites. The pilot
projects will focus on releases and other waste management of chemicals
associated with environmental response and restoration at facilities and
sites where the activities generating wastes do not otherwise meet EPCRA
section 313 thresholds for manufacture, process, or other use. Each agency
is encouraged to identify applicable facilities and voluntarily report under
subsection (a) of this section the releases and other waste management
of toxic chemicals managed during environmental response and restoration,
regardless of whether the facility otherwise would report under subsection
(a). The releases and other waste management of chemicals associated with
environmental response and restoration voluntarily reported under this sub-
section will not be included in the accounting established under sections
503(a) and (c) of this order.
Sec. 502. Release Reduction: Toxic Chemicals. To attain the goals of section
204 of this order:
(a) Beginning with reporting for calendar year 2001 activities, each agency
reporting under section 501 of this order shall adopt a goal of reducing,
where cost effective, the agency's total releases of toxic chemicals to the
environment and off-site transfers of such chemicals for treatment and dis-
posal by at least 10 percent annually, or by 40 percent overall by December
31, 2006. Beginning with activities for calendar year 2001, the baseline
for measuring progress in meeting the reduction goal will be the aggregate
of all such releases and off-site transfers of such chemicals for treatment
and disposal as reported by all of the agency's facilities under section
501 of this order. The list of toxic chemicals applicable to this goal is
the EPCRA section 313 list as of December 1, 2000. If an agency achieves
the 40 percent reduction goal prior to December 31, 2006, that agency
shall establish a new baseline and reduction goal based on agency priorities.
(b) Where an agency is unable to pursue the reduction goal established
in subsection (a) for certain chemicals that are mission critical and/or needed
to protect human health and the environment or where agency off-site transfer
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Federal Register/Vol. 65, No. 81/Wednesday, April 26, 2000/Presidential Documents 24601
of toxic chemicals for treatment is directly associated with environmental
restoration activities, that agency may request a waiver from the EPA for
all or part of the requirement in subsection (a) of this section. As appropriate,
waiver requests must provide: (1) an explanation of the mission critical
use of the chemical; (2) an explanation of the nature of the need for the
chemical to protect human health; (3) a description of efforts to identify
a less harmful substitute chemical or alternative processes to reduce the
release and transfer of the chemical in question; and (4) a description of
the off-site transfers of toxic chemicals for treatment directly associated
with environmental restoration activities. The EPA shall respond to the
waiver request within 90 days and may grant such a waiver for no longer
than 2 years. An agency may resubmit a request for waiver at the end
of that period. The waiver under this section shall not alter requirements
to report under section 501 of this order.
(c) Where a specific component (e.g., bureau, service, or command) within
an agency achieves a 75 percent reduction in its 1999 reporting year publicly
reported total releases of toxic chemicals to the environment and off-site
transfers of such chemicals for treatment and disposal, based on the 1994
baseline established in Executive Order 12856, that agency may independ-
ently elect to establish a reduction goal for that component lower than
the 40 percent target established in subsection (a) of this section. The agency
shall formally notify the Workgroup established in section 306 of this order
of the elected reduction target.
Sec. 503. Use Reduction: Toxic Chemicals, Hazardous Substances, and Other
Pollutants. To attain the goals of section 205 of this order:
(a) Within 18 months of the date of this order, each agency with facilities
shall develop and support goals to reduce the use at such agencies' facilities
of the priority chemicals on the list under subsection (b) of this section
for identified applications and purposes, or alternative chemicals and pollut-
ants the agency identifies under subsection (c) of this section, by at least
50 percent by December 31, 2006.
(b) Within 9 months of the date of this order the Administrator, in coordina-
tion with the Workgroup established in section 306 of this order, shall
develop a list of not less than 15 priority chemicals used by the Federal
Government that may result in significant harm to human health or the
environment and that have known, readily available, less harmful substitutes
for identified applications and purposes. In addition to identifying the appli-
cations and purposes to which such reductions apply, the Administrator,
in coordination with the Workgroup shall identify a usage threshold below
which this section shall not apply. The chemicals will be selected from
listed EPCRA section 313 toxic chemicals and, where appropriate, other
regulated hazardous substances or pollutants. In developing the list, the
Administrator, in coordination with the Workgroup shall consider: (1) envi-
ronmental factors including toxicity, persistence, and bio-accumulation; (2)
availability of known, less environmentally harmful substitute chemicals
that can be used in place of the priority chemical for identified applications
and purposes; (3) availability of known, less environmentally harmful proc-
esses that can be used in place of the priority chemical for identified
applications and purposes; (4) relative costs of alternative chemicals or
processes; and (5) potential risk and environmental and human exposure
based upon applications and uses of the chemicals by Federal agencies
and facilities. In identifying alternatives, the Administrator should take into
consideration the guidance issued under section 503 of Executive Order
13101.
(c) If an agency, which has facilities required to report under EPCRA,
uses at its facilities less than five of the priority chemicals on the list
developed in subsection (b) of this section for the identified applications
and purposes, the agency shall develop, within 12 months of the date
of this order, a list of not less than five chemicals that may include priority
chemicals under subsection (b) of this section or other toxic chemicals,
hazardous substances, and/or other pollutants the agency uses or generates,
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24602 Federal Register/Vol. 65, No. 81/Wednesday, April 26, 2000/Presidential Documents
the release, transfer or waste management of which may result in significant
harm to human health or the environment.
(d) In lieu of requirements under subsection (a) of this section, an agency
may, upon concurrence with the Workgroup established under section 306
of this order, develop within 12 months of the date of this order, a list
of not less than five priority hazardous or radioactive waste types generated
by its facilities. Within 18 months of the date of this order, the agency
shall develop and support goals to reduce the agency's generation of these
wastes by at least 50 percent by December 31, 2006. To the maximum
extent possible, such reductions shall be achieved by implementing source
reduction practices.
(e) The baseline for measuring reductions for purposes of achieving the
50 percent reduction goal in subsections (a) and (d) of this section for
each agency is the first calendar year following the development of the
list of priority chemicals under subsection (b) of this section.
(f) Each agency shall undertake pilot projects at selected facilities to gather
and make publicly available materials accounting data related to the toxic
chemicals, hazardous substances, and/or other pollutants identified under
subsections (b), (c), or (d) of this section.
(g) Within 12 months of the date of this order, the Administrator shall
develop guidance on implementing this section in coordination with the
Workgroup. The EPA shall develop technical assistance materials to assist
agencies in meeting the 50 percent reduction goal of this section.
(h) Where an agency can demonstrate to the Workgroup that it has pre-
viously reduced the use of a priority chemical identified in subsection
503(b) by 50 percent, then the agency may elect to waive the 50 percent
reduction goal for that chemical.
Sec. 504. Emergency Planning and Reporting Responsibilities. Each agency
shall comply with the provisions set forth in sections 301 through 312
of the EPCRA, all implementing regulations, and any future amendments
to these authorities, in light of any applicable guidance as provided by
the EPA.
Sec. 505. Reductions in Ozone-Depleting Substances. To attain the goals
of section 206 of this order:
(a) Each agency shall ensure that its facilities: (1) maximize the use of
safe alternatives to ozone-depleting substances, as approved by the EPA's
Significant New Alternatives Policy (SNAP) program; (2) consistent with
subsection (b) of this section, evaluate the present and future uses of ozone-
depleting substances, including making assessments of existing and future
needs for such materials, and evaluate use of, and plans for recycling,
refrigerants, and halons; and (3) exercise leadership, develop exemplary
practices, and disseminate information on successful efforts in phasing out
ozone-depleting substances.
(b) Within 12 months of the date of this order, each agency shall develop
a plan to phase out the procurement of Class I ozone-depleting substances
for all nonexcepted uses by December 31, 2010. Plans should target cost
effective reduction of environmental risk by phasing out Class I ozone deplet-
ing substance applications as the equipment using those substances reaches
its expected service life. Exceptions to this requirement include all exceptions
found in current or future applicable law, treaty, regulation, or Executive
order.
(c) Each agency shall amend its personal property management policies
and procedures to preclude disposal of ozone depleting substances removed
or reclaimed from its facilities or equipment, including disposal as part
of a contract, trade, or donation, without prior coordination with the Depart-
ment of Defense (DoD). Where the recovered ozone-depleting substance is
a critical requirement for DoD missions, the agency shall transfer the materials
to the DoD. The DoD will bear the costs of such transfer.
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PART 6—LANDSCAPING MANAGEMENT PRACTICES
Sec. 601. Implementation.
(a) Within 12 months from the date of this order, each agency shall
incorporate the Guidance for Presidential Memorandum on Environmentally
and Economically Beneficial Landscape Practices on Federal Landscaped
Grounds (60 Fed. Reg. 40837) developed by the FEE into landscaping pro-
grams, policies, and practices.
(b) Within 12 months of the date of this order, the FEE shall form a
workgroup of appropriate Federal agency representatives to review and up-
date the guidance in subsection (a) of this section, as appropriate.
(c) Each agency providing funding for nonfederal projects involving land-
scaping projects shall furnish funding recipients with information on environ-
mentally and economically beneficial landscaping practices and work with
the recipients to support and encourage application of such practices on
Federally funded projects.
Sec. 602. Technical Assistance and Outreach. The EPA, the General Services
Administration (GSA), and the USD A shall provide technical assistance
in accordance with their respective authorities on environmentally and eco-
nomically beneficial landscaping practices to agencies and their facilities.
PART 7—ACQUISITION AND PROCUREMENT
Sec. 701. Limiting Procurement of Toxic Chemicals, Hazardous Substances,
and Other Pollutants.
(a) Within 12 months of the date of this order, each agency shall implement
training programs to ensure that agency procurement officials and acquisition
program managers are aware of the requirements of this order and its applica-
bility to those individuals.
(b) Within 24 months of the date of this order, each agency shall determine
the feasibility of implementing centralized procurement and distribution
(e.g., "pharmacy") programs at its facilities for tracking, distribution, and
management of toxic or hazardous materials and, where appropriate, imple-
ment such programs.
(c) Under established schedules for review of standardized documents,
DoD and GSA, and other agencies, as appropriate, shall review their standard-
ized documents and identify opportunities to eliminate or reduce their use
of chemicals included on the list of priority chemicals developed by the
EPA under subsection 503(b) of this order, and make revisions as appropriate.
(d) Each agency shall follow the policies and procedures for toxic chemical
release reporting in accordance with FAR section 23.9 effective as of the
date of this order and policies and procedures on Federal compliance with
right-to-know laws and pollution prevention requirements in accordance
with FAR section 23.10 effective as of the date of this order.
Sec. 702. Environmentally Benign Adhesives. Within 12 months after environ-
mentally benign pressure sensitive adhesives for paper products become
commercially available, each agency shall revise its specifications for paper
products using adhesives and direct the purchase of paper products using
those adhesives, whenever technically practicable and cost effective. Each
agency should consider products using the environmentally benign pressure
sensitive adhesives approved by the U.S. Postal Service (USPS) and listed
on the USPS Qualified Products List for pressure sensitive recyclable adhe-
sives.
Sec. 703. Ozone-Depleting Substances. Each agency shall follow the policies
and procedures for the acquisition of items that contain, use, or are manufac-
tured with ozone-depleting substances in accordance with FAR section 23.8
and other applicable FAR provisions.
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24604 Federal Register/Vol. 65, No. 81/Wednesday, April 26, 2000/Presidential Documents
Sec. 704. Environmentally and Economically Beneficial Landscaping Prac-
tices.
(a) Within 18 months of the date of this order, each agency shall have
in place acquisition and procurement practices, including provision of land-
scaping services that conform to the guidance referred to in section 601
of this order, for the use of environmentally and economically beneficial
landscaping practices. At a minimum, such practices shall be consistent
with the policies in the guidance referred to in section 601 of this order.
(b) In implementing landscaping policies, each agency shall purchase envi-
ronmentally preferable and recycled content products, including EPA-des-
ignated items such as compost and mulch, that contribute to environmentally
and economically beneficial practices.
PART 8—EXEMPTIONS
Sec. 801. National Security Exemptions. Subject to subsection 902(c) of
this order and except as otherwise required by applicable law, in the interest
of national security, the head of any agency may request from the President
an exemption from complying with the provisions of any or all provisions
of this order for particular agency facilities, provided that the procedures
set forth in section 120(j)(l) of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended (42 U.S.C. 9620(j)(l)),
are followed, with the following exceptions: (a) an exemption issued under
this section will be for a specified period of time that may exceed 1 year;
(b) notice of any exemption granted under this section for provisions not
otherwise required by law is only required to the Director of OMB, the
Chair of the CEQ, and the Director of the National Security Council; and
(c) an exemption under this section may be issued due to lack of appropria-
tions, provided that the head of the agency requesting the exemption shows
that necessary funds were requested by the agency in its budget submission
and agency plan under Executive Order 12088 of October 13, 1978, and
were not contained in the President's budget request or the Congress failed
to make available the requested appropriation. To the maximum extent
practicable, and without compromising national security, each agency shall
strive to comply with the purposes, goals, and implementation steps in
this order. Nothing in this order affects limitations on the dissemination
of classified information pursuant to law, regulation, or Executive order.
Sec. 802. Compliance. After January 1, 2002, OMB, in consultation with
the Chair of the Workgroup established by section 306 of this order, may
modify the compliance requirements for an agency under this order, if
the agency is unable to comply with the requirements of the order. An
agency requesting modification must show that it has made substantial good
faith efforts to comply with the order. The cost-effectiveness of implementa-
tion of the order can be a factor in OMB's decision to modify the requirements
for that agency's compliance with the order.
PART 9—GENERAL PROVISIONS
Sec. 901. Revocation. Executive Order 12843 of April 21, 1993, Executive
Order 12856 of August 3, 1993, the Executive Memorandum on Environ-
mentally Beneficial Landscaping of April 26, 1994, Executive Order 12969
of August 8, 1995, and section 1-4. "Pollution Control Plan" of Executive
Order 12088 of October 13, 1978, are revoked.
Sec. 902. Limitations.
(a) This order is intended only to improve the internal management of
the executive branch and is not intended to create any right, benefit, or
trust responsibility, substantive or procedural, enforceable at law by a party
against the United States, its agencies, its officers, or any other person.
(b) This order applies to Federal facilities in any State of the United
States, the District of Columbia, the Commonwealth of Puerto Rico, Guam,
American Samoa, the United States Virgin Islands, the Northern Mariana
Islands, and any other territory or possession over which the United States
has jurisdiction. Each agency with facilities outside of these areas, however,
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Federal Register/Vol. 65, No. 81/Wednesday, April 26, 2000/Presidential Documents 24605
is encouraged to make best efforts to comply with the goals of this order
for those facilities.
(c) Nothing in this order alters the obligations under EPCRA, PPA, and
CAA independent of this order for Government-owned, contractor-operated
facilities and Government corporations owning or operating facilities or sub-
jects such facilities to EPCRA , PPA, or CAA if they are otherwise excluded.
However, each agency shall include the releases and other waste management
of chemicals for all such facilities to meet the agency's reporting responsibil-
ities under section 501 of this order.
(d) Nothing in this order shall be construed to make the provisions of
CAA sections 304 and EPCRA sections 325 and 326 applicable to any
agency or facility, except to the extent that an agency or facility would
independently be subject to such provisions.
Sec. 903. Community Outreach. Each agency is encouraged to establish
a process for local community advice and outreach for its facilities relevant
to aspects of this and other related Greening the Government Executive
orders. All strategies and plans developed under this order shall be made
available to the public upon request.
PART 10—DEFINITIONS
For purposes of this order:
Sec. 1001. General. Terms that are not defined in this part but that are
defined in Executive Orders 13101 and 13123 have the meaning given in
those Executive orders. For the purposes of Part 5 of this order all definitions
in EPCRA and PPA and implementing regulations at 40 CFR Parts 370
and 372 apply.
Sec. 1002. "Administrator" means the Administrator of the EPA.
Sec. 1003. "Environmental cost accounting" means the modification of cost
attribution systems and financial analysis practices specifically to directly
track environmental costs that are traditionally hidden in overhead accounts
to the responsible products, processes, facilities or activities.
Sec. 1004. "Facility" means any building, installation, structure, land, and
other property owned or operated by, or constructed or manufactured and
leased to, the Federal Government, where the Federal Government is formally
accountable for compliance under environmental regulation (e.g., permits,
reports/records and/or planning requirements) with requirements pertaining
to discharge, emission, release, spill, or management of any waste, contami-
nant, hazardous chemical, or pollutant. This term includes a group of facili-
ties at a single location managed as an integrated operation, as well as
government owned contractor operated facilities.
Sec. 1005. "Environmentally benign pressure sensitive adhesives" means
adhesives for stamps, labels, and other paper products that can be easily
treated and removed during the paper recycling process.
Sec. 1006. "Ozone-depleting substance" means any substance designated
as a Class I or Class II substance by EPA in 40 CFR Part 82.
Sec. 1007. "Pollution prevention" means "source reduction," as defined
in the PPA, and other practices that reduce or eliminate the creation of
pollutants through: (a) increased efficiency in the use of raw materials,
energy, water, or other resources; or (b) protection of natural resources
by conservation.
Sec. 1008. "Greening the Government Executive orders" means this order
and the series of orders on greening the government including Executive
Order 13101 of September 14, 1998, Executive Order 13123 of June 3,
1999, Executive Order 13134 of August 12, 1999, and other future orders
as appropriate.
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24606 Federal Register/Vol. 65, No. 81/Wednesday, April 26, 2000/Presidential Documents
Sec. 1009. "Environmental aspects" means the elements of an organization's
activities, products, or services that can interact with the environment.
[FR Doc. 00-10550
Filed 4-25-00; 8:45 am]
Billing code 3195-01-P
THE WHITE HOUSE,
April 21, 2000.
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Citizens Suits. EPCRA section 326 allows citizens to
initiate civil actions against EPA, SERCs, and the owner or
operator of a facility for failure to meet the EPCRA
requirements. A SERC, LEPC, and State or local
government may institute actions against facility owner/
operators for failure to comply with EPCRA requirements.
In addition, States may sue EPA for failure to provide trade
secret information.
Where Can You Find EPCRA
Information?
MSDSs, hazardous chemical inventory forms, follow-up
emergency notices, and the emergency response plan are
available from the SERC and LEPC.
MSDSs on hazardous chemicals are maintained by a
number of universities and can be accessed through
www .hazard. com.
EPA also provides fact sheets and other information on
chemical properties through its website: www.epa.gov.
EPA has compiled a list of all chemicals covered by name
under these regulations into a single list and published them
as The Title III List of Lists available at www.epa.gov/
swercepp/ds-epds.htm#title3.
Profiles of extremely hazardous substances are available at
www.epa.gov/ceppo/ep_chda.htm#ehs
Each year, EPA publishes a report summarizing the TRI
information that was submitted to EPA and States during
the previous year. In addition, TRI data are available
through EPA's Envirofacts database at www.epa.gov/
enviro. TRI data are also available at www.epa.gov/tri,
www.rtk.net, and www.scorecard.org.
All of these sites can be searched by facility, city, county,
and state and provide access to basic TRI emissions data.
The RTK-Net site, maintained by the public advocacy
group OMB Watch, provides copies of the full TRI form
for each facility. The Scorecard site, maintained by the
Environmental Defense public advocacy group, ranks
facilities, States, and counties on a number of parameters
(e.g., total quantities of carcinogens released) as well as
maps that show the locations of facilities in a county or city.
Initial emergency release notifications made to the National
Response Center or EPA are available on line at
www.epa.gov/ernsacct/pdf/index.html.
A list of LEPCs and SERCs is available at http://
www.RTK.NET: 80/lepc/.
Many of these sites can also be accessed through
www.epa.gov/ceppo/.
Are There Other Laws That Provide
Similar Information?
The Oil Pollution Act (OPA) of 1990 includes national
planning and preparedness provisions for oil spills that are
similar to EPCRA provisions for extremely hazardous
substances. Plans are developed at the local, State and
Federal levels. The OPA plans offer an opportunity for
LEPCs to coordinate their plans with area and facility oil
spill plans covering the same geographical area.
The 1990 Clean Air Act Amendments require the EPA and
OSHA to issue regulations for chemical accident
prevention. Facilities that have certain chemical above
specified threshold quantities are required to develop a risk
management program to identify and evaluate hazards and
manage those hazards safely. Facilities subject to EPA's
risk management program rules must submit a risk
management plan (RMP) summarizing its program. Most
RMP information is available through RMP*Info, which
can be accessed through www.epa.gov/enviro.
For More Information
Contact the EPCRA Hotline at:
(800)424-9346 or(703)412-9810
TDD (800)553-7672
Monday -Friday, 9 AM to 6 PM, EST
Visitthe CEPPO Home Page at:
WWW.EPA.GOV/CEPPO/
For EPA EPCRA contacts, check the CEPPO home page.
For TRI program officials and EPA TRI regional contacts,
checkwww.epa.gov/tri/statecon.htm.
Chemical Emergency Preparedness and Prevention Office
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SEPTEMBER 14, 2004 VA DIRECTIVE 0057
VA ENVIRONMENTAL MANAGEMENT SYSTEM AND
GOVERNING ENVIRONMENTAL POLICY
1. PURPOSE AND SCOPE
a. The Department of Veterans Affairs' (VA) mission is to deliver quality health care to our
Nation's veterans, provide benefits and services to veterans and their families, and honor
veterans with final resting places and lasting memorials that commemorate their service to our
Nation. In accomplishing this mission, VA is committed to preventing pollution, reducing
waste, and conserving natural and cultural resources. The purpose of this directive is to
establish VA policy to ensure that all necessary actions are taken to integrate environmental
accountability into day-to-day decision-making and long-term planning processes across VA
activities, functions, and services.
b. This directive also establishes policy and assigns responsibilities for developing and
implementing an environmental management system (EMS) at all appropriate VA facilities by
December 31, 2005, pursuant to Executive Order (EO) 13148, Greening the Government
Through Leadership in Environmental Management. An EMS provides a systematic
framework to identify and address the environmental aspects and impacts of an organization's
work, ensure compliance with applicable environmental requirements, and determine
opportunities for continual improvement.
2. POLICY. In conducting its mission to serve our Nation's veterans, it is VA's environmental
policy to:
a. Encourage VA employees at all levels to be good stewards of the environment by
complying with all applicable environmental requirements; preventing pollution; reducing
waste; conserving energy, water, and other natural and cultural resources; and continually
reviewing and improving VA environmental programs.
b. Ensure top management commitment and accountability through the incorporation of
position description elements and performance standards/measures related to pollution
prevention and environmental management for appropriate senior level managers and other
employees who have responsibilities related to the management of environmental programs.
c. Have top managers provide necessary support, including funds and other resources, to
ensure compliance by VA facilities with Federal, state, and local environmental requirements,
including development and implementation of an EMS.
d. Utilize sustainable practices to eliminate, minimize, or mitigate adverse environmental
impacts.
e. Evaluate and monitor the operation of VA facilities and incorporate policies and
procedures necessary to reduce environmental vulnerabilities and ensure environmental
compliance.
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VA DIRECTIVE 0057 SEPTEMBER 14, 2004
f. Integrate pollution prevention, waste reduction, natural and cultural resource
conservation, affirmative procurement/green purchasing, life cycle costing, and environmental
compliance into planning, purchasing, and operating decisions, wherever practicable.
g. Implement source reduction as the pollution prevention method of choice, or alternative
methods of reuse, recycling, treatment of wastes, or proper disposal.
h. Use natural resources efficiently and maintain and protect plant and wildlife habitat,
consistent with VA's mission.
i. Recognize that the development and construction of VA facilities must consider the
unique conditions of the environment of which the facility is a part.
j. Train all appropriate VA staff, as needed, to satisfactorily carry out the environmental
responsibilities of their positions.
k. Solicit input regarding environmental matters affecting the operation of VA facilities, as
appropriate, from stakeholders including, but not limited to, staff, veterans, and the community.
I. Develop and implement an EMS at all appropriate VA facilities by December 31, 2005.
(1) The environmental responsibilities of VA Administrations and staff offices differ in both
scope and complexity. As such, Administrations and staff offices shall develop an EMS best
suited to its needs and based on the International Organization for Standardization (ISO)
14001 or equivalent standard.
(2) For assistance, the Administrations and staff offices may use the Green Environmental
Management System (GEMS) Guidebook developed by the Veterans Health Administration,
Office of the Deputy Under Secretary for Health for Operations and Management (1 ON). The
GEMS Guidebook presents a nine-step process based on the ISO 14001 Standard.
3. RESPONSIBILITIES
a. The Assistant Secretary for Management (004) is the VA Environmental Executive
and will be responsible for environmental policy and oversight to coordinate implementation of
the requirements of this directive at the Department level.
b. The Office of Acquisition and Materiel Management (OA&MM), Office of the
Associate Deputy Assistant Secretary for Program Management and Operations (049M),
will be responsible for providing program leadership, guidance, and coordination at the
Department level to ensure that the requirements of this directive are appropriately
implemented.
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SEPTEMBER 14, 2004 VA DIRECTIVE 0057
c. VA Administrations and Staff Offices will be responsible for the development,
implementation, and management of an EMS and other environmental programs. Each VA
Administration and staff office shall:
(1) Develop guidance and policy, as needed, to implement and manage environmental
programs, including the requirements of this directive.
(a) Environmental policy is to be developed that specifically addresses the requirements
contained in paragraph 2. Policy in this directive.
(b) Internally developed guidance and policy shall be consistent with applicable Federal,
state, and local environmental requirements.
(2) Define "appropriate" facilities in accordance with EO 13148 and direct these facilities to
develop and implement an EMS. The designation of "appropriate" facilities is to be based on
facility size, complexity, and the environmental aspects of an individual facility's operations.
Appropriate facilities would generally include those that are either subject to registration or
permitting by the U.S. Environmental Protection Agency (EPA) or state/local environmental
regulators or otherwise could have a significant impact on the environment.
(3) Staff offices that operate VA facilities in VA-owned or -leased space are responsible
for determining which of their facilities are "appropriate" in accordance with the criteria stated in
paragraph 3 (c) (2) (i.e., size, complexity, and environmental aspects) and for directing these
facilities to develop and implement an EMS. Such an EMS shall address functions under the
control of the staff office and be coordinated to the extent practicable with the owner of the
space in which VA is a tenant.
(4) Develop a facility self-declaration protocol by December 31, 2004, that provides
credible verification of the status of an EMS in accordance with guidance provided by the EPA,
the Council on Environmental Quality, or other national standard recognized by EPA.
(5) Ensure that the requirements of this directive are implemented at the facilities for
which they are responsible.
4. REPORTING. Each VA Administration and staff office shall report on the status of
implementation of an EMS, including providing a list of "appropriate" facilities. Reports are due
annually to OA&MM (049M) by January 31, or alternative date provided to meet EO 13148
reporting requirements.
5. REFERENCES
a. Executive Order 13148, Greening the Government Through Leadership in
Environmental Management (April 21, 2000).
b. Green Enviromental Management System (GEMS) Guidebook (March 2004).
http://vaww.ceosh.med.va.qov
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Department of Veterans Affairs VHA DIRECTIVE 2001-036
Veterans Health Administration
Washington, DC 20420 June 8, 2001
POLLUTION PREVENTION (P2) PROGRAM
1. PURPOSE: This Veterans Health Administration (VHA) Directive assigns responsibility
and describes procedures for the implementation of pollution prevention (P2) programs
throughout VHA.
2. BACKGROUND
a. VHA is committed to environmental leadership in creating programs of environmental
excellence and will effectively support the national P2 policy through education and training,
acquisition and procurement, facility management practices, environmental management and
leadership, and VHA encourages innovative P2 practices and technologies.
b. The Federal Pollution Prevention Act formally establishes P2 as a national objective and
defines P2 as source reduction and other practices that reduce or eliminate the creation of
pollutants. This act establishes a hierarchy of environmental protection consisting of prevention
or source reduction, recycling, treatment and disposal into the environment. The most desirable
method of pollution abatement is prevention or source reduction. Disposal or other releases into
the environment should be done only as a last resort and then in an environmentally safe manner.
c. The Resource Conservation and Recovery Act (RCRA) covers the generation, treatment,
storage, disposal and transportation of both hazardous and non-hazardous waste and emphasizes
source reduction as the highest priority. RCRA requires the "cradle-to-grave" management of
hazardous waste (HW), encourages recycling and reuse, and further requires HW generators and
treatment, storage, and disposal facility owners to certify that the generator has a program in
place to "reduce the volume or quantity and toxicity" of waste.
d. Title III of the Superfund Amendments and Reauthorization Act (SARA) is also known as
The Emergency Planning and Community Right-To-Know Act (EPCRA). This Act is comprised
of four distinct parts:
(1) Emergency planning,
(2) Emergency notification,
(3) Community right-to-know, and
(4) Toxic chemical release reporting.
NOTE: The intent of the community right-to-know provision is to provide protection for
emergency responders, the local community and the environment from toxic and hazardous
materials and their emissions.
THIS VHA DIRECTIVE EXPIRES JUNE 30, 2006
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VHA DIRECTIVE 2001-036
June 8, 2001
e. Executive Order (EO) 13101, Greening the Government Through Waste Prevention,
Recycling, and Federal Acquisition, is a policy document for resource conservation and pollution
prevention. EO 13101 directs each Federal agency to set measurable goals for recycling and
solid waste reduction and requires specific means of affirmative procurement of recycled and
reusable "environmentally preferable" material. This EO stresses the hierarchy of environmental
protection: source reduction, recycling, treatment and disposal.
f. EO 13148, Greening the Government Through Leadership in Environmental Management,
establishes performance standards in environmental management, environmental compliance and
the public's right-to-know. A goal of the EO is to achieve significant reductions in toxic
chemicals, hazardous substances and other pollutants utilizing source reduction as the single
most important means of pollution prevention. These reductions may be accomplished by
proven substitutes and established facility management practices. Other key agency
requirements include:
(1) Facility environmental audits,
(2) Specific reduction goals,
(3) Planning and accountability,
(4) Environmental management and leadership,
(5) Additional EPCRA reporting requirements, and
(6) Acquisition and procurement.
g. VHA Directive 98-011, Management of Hazardous Chemicals, provides policy and
procedures to ensure that hazardous chemicals are used, stored, handled and disposed of in
accordance with accepted environmental standards. The Directive further requires employee
training, record keeping, and minimization of hazardous chemicals and/or waste at VHA health
care facilities.
h. VHA Directive 99-011, Emergency Planning and Community Right-To-Know (EPCRA)
Program, provides information and policy for implementing EPCRA programs in VHA health
care facilities. Key provisions of this Directive include participation with the local emergency
planning committees and reporting quantities of hazardous chemicals and wastes.
i. VHA Directive 99-037, Waste Minimization and Compliance Report (RCN 10-00-904),
provides the format for reporting data on waste categories, volume, environmental compliance,
recycling and waste minimization initiatives.
j. Under Secretary for Health Memorandum, Resource Conservation and Recovery Act,
Section 6002, Environmental Goals, establishes specific environmental goals for VHA in waste
prevention, recycling and acquisition of recovered materials in VHA for target years 2000, 2005,
and 2010.
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VHA DIRECTIVE 2001-036
June 8, 2001
3. POLICY: It is the policy of VHA to fully comply with the Pollution Prevention Act,
Resource Conservation and Recovery Act, Emergency Planning and Community Right-To-
Know Act, EO 13101, EO 13148 and other applicable state and local environmental regulations,
while continuing to provide high quality health care to our Nation's veterans.
NOTE: Additional policy and guidance on performance and position description requirements
for senior management, environmental compliance audits and (Chloroflurocarbon) CFC
reductions as required by EO 13148 will be provided separately.
4. ACTION
a. Veterans Integrated Service Network (VISN) Directors must ensure that each health care
facility:
(1) Develops a facility specific P2 plan to be reviewed annually and to include, as a
minimum; a statement of management commitment to P2, a listing of measurable goals for
hazardous waste reduction, procurement of recycled products and recycling and budgetary
requirements for implementation.
(2) Reduces toxic and hazardous chemical releases and off site transfer by 10 percent
annually between calendar years 2001 and 2006.
(3) Implements P2 into all phases of the acquisition and procurement processes, as well as the
management operations of the facility by:
(a) Purchasing environmentally preferable products when possible. Environmentally
preferable products include, but are not limited to, products that can be reprocessed and revised,
products that have recycled content; can be recycled after use; are less toxic or hazardous and
can be substituted for existing more toxic or hazardous products; are energy efficient or
otherwise protect the environment.
(b) Developing facility guidance, policies, and operating procedures to implement pollution
prevention into all aspects of facility operations, but with emphasis on those elements that
involve toxic or hazardous substances.
(4) Implements source reduction measures including, but not limited to, the substitution of
materials that are less hazardous and/or toxic to the maximum extent feasible.
(5) Promotes pollution prevention through employee training, outreach and awareness
programs.
(6) Includes environmental costs in life-cycle and other cost estimating done in conjunction
with the acquisition of goods and services.
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VHA DIRECTIVE 2001-036
June 8, 2001
b. The Chief Facilities Management Officer (18) is responsible for:
(1) Ensuring that P2 data reporting requirements are incorporated into report
RCN 10-99-904, as needed.
(2) Incorporating P2 and applicable requirements of EO 13148 into the Office of Facilities
Management (18) guidance, practices, procedures, standards and specifications, e.g.,
environmentally and economically beneficial landscaping, environmentally preferable products
and life-cycle costing.
(3) Conducting an agency-level environmental management system review that emphasizes
pollution prevention as it relates to the Code of Environmental Management Principles for
Federal Agencies developed by the Environmental Protection Agency (61 Federal Register
54062), and/or another appropriate environmental management system framework.
(4) Developing and administering a VHA-wide P2 awards program for innovative programs
and outstanding environmental leadership.
(5) Encouraging, reviewing, and supporting the development of pilot projects for P2 and
waste reduction.
(6) Determining if there are national trends requiring redress.
(7) Providing for periodic review and follow up with the Assistant Deputy Under Secretary
for Health (ION).
(8) Developing recommendations for correction to the Under Secretary for Health.
5. REFERENCES
a. Pollution Prevention Act of 1990, Public Law (Pub. L.) 101-453.
b. Emergency Planning and Community Right-To-Know Act of 1986, Pub. L. 99-499, The
Superfund Amendments and Re-authorization Act of 1986, Sections 302-304 and 311-313.
c. Resource Conservation and Recovery Act of 1976, Pub. L. 94-580.
d. EO 13101, Greening the Government Through Waste Prevention, Recycling, and Federal
Acquisition, dated September 4, 1998.
e. EO 13148, Greening the Government through Leadership in Environmental Management,
dated April 21,2000.
6. FOLLOW-UP RESPONSIBILITY: Director, Environmental Programs Service (181C), is
responsible for the content of this Directive.
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VHA DIRECTIVE 2001-036
June 8, 2001
7. RESCISSION: This VHA Directive expires June 30, 2006.
Thomas L. Garthwaite, M.D.
Under Secretary for Health
DISTRIBUTION: CO: E-mailed 6/12/01
FLD: VISN, MA, DO, OC, OCRO, and 200 - E-mailed 6/12/01
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United States
Environmental Protection
Agency
Enforcement and
Compliance Assurance
EPA315-B-97-001
March 1997
(2261 A)
»EPA
Implementation Guide
For The Code of
Environmental Management
Principles for Federal Agencies
(CEMP)
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This document was prepared by the
Federal Facilities Enforcement Office
(2261-A) in the Office of Enforcement
and Compliance Assurance. Consulting
assistance and document design/layout
services were provided under IAG
number DW89936515.
For additional copies of this document,
please contact:
Priscilla Harrington
U.S. EPA (2261-A)
1200 Pennsylvania Avenue, N.W.
Washington, B.C. 20460
Tel: (202)564-2461
Fax: (202) 501-0069
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IMPLEMENTATION GUIDE FOR THE CODE OF ENVIRONMENTAL
MANAGEMENT PRINCIPLES FOR FEDERAL AGENCIES (CEMP)
CONTENTS
1. INTRODUCTION 1
What is the Code of Environmental Management Principles (CEMP)? 1
What is an Environmental Management System (EMS)? 2
Is the CEMP an EMS Standard? 3
HowDoesthe CEMPTielnto Other EPA Programs? 5
What You Will Find in This Document 6
2. FEDERAL AGENCY RESPONSES TO THE CEMP 10
CEMP Development Process 10
Responses From Federal Agencies and Departments 10
3. MANAGEMENT COMMITMENT (PRINCIPLE 1) 15
1.1 OBTAIN MANAGEMENT SUPPORT 15
1.1.1 Policy Development 15
1.1.2 System Integration 16
1.2 ENVIRONMENTAL STEWARDSHIP AND SUSTAINABLE DEVELOPMENT.. 17
4. COMPLIANCE ASSURANCE AND POLLUTION PREVENTION (PRINCIPLE 2) ... 20
2.1 COMPLIANCE ASSURANCE 20
2.2 EMERGENCY PREPAREDNESS 22
2.3 POLLUTION PREVENTION AND RESOURCE CONSERVATION 23
5. ENABLING SYSTEMS (PRINCIPLE 3) 27
3.1 TRAINING 27
3.2 STRUCTURAL SUPPORTS 28
3.3 INFORMATION MANAGEMENT, COMMUNICATION, DOCUMENTATION .. 29
6. PERFORMANCE AND ACCOUNTABILITY (PRINCIPLE 4) 33
4.1 RESPONSIBILITY, A UTHORITYAND ACCOUNTABILITY 33
4.2 PERFORMANCE STANDARDS 34
7. MEASUREMENT AND IMPROVEMENT (PRINCIPLE 5) 35
5.7 EVALUATE PERFORMANCE 35
5.7.7 Gather and Analyze Data 35
5.1.2 Institute Benchmarking 37
5.2 CONTINUOUS IMPROVEMENT 38
8. CEMP SELF-ASSESSMENT MATRIX 40
How the CEMP Matrix Works 40
Moving From Level to Level 41
APPENDIX 1. AGENCY RESPONSES
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TABLES AND FIGURES
Table 1 Summary of Agency Responses to the CEMP 14
Figure 1 Environmental Processes in a Management System 2
Figure 2 Pollution Prevention Act Environmental Management Hierarchy 24
Figure 3 Federal Agency Environmental Compliance Management System 29
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CHAPTER 1: INTRODUCTION
What is the Code of Environmental Management Principles (CEMP)?
The Code of Environmental Management Principles for Federal Agencies (CEMP), developed by the
Environmental Protection Agency (EPA) in response Executive Order 12856, is a collection of five
broad principles and underlying performance objectives that provide a basis for Federal agencies to move
toward responsible environmental management. Adherence to the five principles will help ensure
environmental performance that is proactive, ^^^^^^^^^^^^^^^^^^^^^^^^^^^^
flexible, cost-effective, integrated, and
sustainable THE PRINCIPLES
CEMP focuses federal agencies on the
necessity of state-of-the-art environmental
management for reaching the highest levels of
environmental performance. State-of-the-art
should be defined as those environmental
management programs or systems that ensure
environmental performance be considered as
world-class or best-in-class by peers and
stakeholders. EPA has patterned the CEMP on
the common critical elements of a
comprehensive management system tailored to
the environmental activities of an organization
(an Environmental Management System).
Executive Order 12856, "Federal Compliance
with Right-to-Know Laws and Pollution
Prevention Requirements," which was signed
on August 3, 1993, requires EPA to "establish
a 'Federal Government Environmental
Challenge Program'," one component of which
is to "challenge Federal agencies...to agree to a
code of environmental principles to be
developed by EPA, in cooperation with other
agencies, that emphasizes pollution
prevention, sustainable development and state-
of-the-art environmental management
programs..." EPA has been working to
develop the CEMP through the Interagency
Pollution Prevention Task Force, which was
created by the Executive Order, early in
calendar year 1995. Sixteen Federal agencies
participated in the development of the CEMP.
1. MANAGEMENT COMMITMENT:
The agency makes a written top-management
commitment to improved environmental
performance by establishing policies which
emphasize pollution prevention and the need to
ensure compliance with environmental
requirements.
2. COMPLIANCE ASSURANCE AND
POLLUTION PREVENTION:
The agency implements proactive programs that
aggressively identify and address potential
compliance problem areas and utilize pollution
prevention approaches to correct deficiencies and
improve environmental performance.
3. ENABLING SYSTEMS:
The agency develops and implements the necessary
measures to enable personnel to perform their
functions consistent with regulatory requirements,
agency environmental policies, and its overall
mission.
4. PERFORMANCE AND
ACCOUNTABILITY:
The agency develops measures to address employee
environmental performance, and ensure full
accountability of environmental functions.
5. MEASUREMENT AND IMPROVEMENT:
The agency develops and implements a program to
assess progress toward meeting its environmental
goals and uses the results to improve environmental
performance.
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The CEMP is not a regulation, it is a voluntary component of a program established to encourage federal
agencies to enhance their environmental performance through the creative use of management tools. As
such, the goal is to move agencies "beyond compliance" and the traditional short-term focus on
regulatory requirements to a broader, more inclusive view of the interrelated nature of their
environmental activities.
Unfortunately, federal agencies often lack the resources to develop a complete environmental
management program, especially when their primary missions are not directly related to environmental
protection or management. They are often forced to take a "finger in the dike" approach that focuses on
compliance, addressing situations as they occur, instead of planning their activities to prevent such
situations. They may even be successful, until they run out of fingers. Thus, short-term success is no
indicator of the long-term stability of the system and may even lead to complacency. Agencies that are
able to better understand their "dike" (how it was built, why it was built the way it was, and how the
demands on it are changing over time) will be in a better position to identify weak points and predict the
next "high tide," managing their resources for prevention, not just response. Of course, regulatory
compliance is still required, but the CEMP, properly implemented, will provide agencies with a tool to
improve overall performance while maintaining compliance as a performance baseline.
What is an Environmental Management System (EMS)?
The International Organization for Standardization (ISO) defines environmental management systems as
"that part of the overall management system which includes organizational structure, planning activities,
responsibilities, practices, procedures, processes and resources for developing, implementing, achieving,
reviewing and maintaining the environmental policy." In other words, an EMS focuses on environmental
management practices, rather than the activities themselves, such as air monitoring or drum handling.
The EMS provides the structure by which the specific activities can be carried out efficiently and in a
manner consistent with key organizational goals, but does not specify levels of performance (e.g., the
EMS will ensure that proper procedures are in place and that operator training exists but won't specify
methods or frequency of sampling). The EMS allows an organization the flexibility to adapt the system
to its needs and priorities, rather than forcing a "one size fits all" mentality.
The EMS approach has its genesis in
the same movement that created the
"quality management" systems
traditionally applied to manufacturing,
such as Total Quality Management
(TQM). The Global Environmental
Management Initiative (GEMI)
patterned its Total Quality
Environmental Management (TQEM)
philosophy on TQM, employing many
of the same diagnostic tools for
environmental applications. The more
general EMS approach incorporates the
"plan-do-check-act" cycle and the
emphasis on continuous improvement
Environmental Processes in a
Management System
4) Measure } ( 3) Implement
Organization and Resources
Code of Environmental Management Principles
Figure 1
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found in TQM and other quality management schemes. [See Figure 1] A number of organizations and
countries (e.g., ISO, Britain, Canada) have developed standards to encourage implementation of the EMS
approach.
Is the CEMP an EMS Standard?
BASIC EMS ELEMENTS
The CEMP is a set of principles - not a standard - that will help an organization improve its
environmental performance and level of environmental protection. In developing the CEMP, EPA
examined a number of EMS standards to identify common
elements and areas that needed to be addressed. The CEMP
reflects its EMS origins in its structure and format; however, it
is not a standard. A technical standard for a product describes
characteristics related to its performance, such as size,
strength, durability, and materials of construction. Similarly, a
technical management standard describes the characteristics
desirable for a management approach to a particular subject
area, such as quality or the environment. Just as conforming to
a technical product standard allows a manufacturer to advertise
that its product meets agreed-upon specifications for
performance, an organization conforming to a technical
management specification standard (such as ISO 14001) can
claim that its management practices are aligned with consensus
"best practices." In addition to the possibility of improving
performance through improved management, one of the
primary motivations for adopting such standards is the
potential for commercial advantage resulting from independent certification of conformance to the
standard (and potential for disadvantage from
failure to conform).
1.
2.
3.
4.
5.
Environmental Policy
Planning
Implementation and Operation
Checking and Corrective Action
Management Review
Although these terms refer
specifically to the ISO 14001 EMS
Standard, they are common elements
of other EMS Standards and reflected
in the CEMP.
Rather than focus on strict evaluations of
conformance, EPA would like to emphasize the
aspects of improved management (leading to
improved performance) and continuous
improvement. In addition to a statement of
expectation for each broad principle, the CEMP
stresses the important indicators supporting each
principle (the "Performance Objectives"), so that
agencies can understand their intrinsic and
systemic value and better judge agency progress.
This Guide expands upon that informative
discussion. The CEMP also differs from most
EMS standards in its emphasis on regulatory
compliance and the fact that it is targeted toward
Federal agencies (essentially removing the appeal
of commercial advantage). For these reasons, EPA
believes that it would be inappropriate for it to
"endorse" a particular EMS standard at this time,
CEMP BACKGROUND SOURCES
1. ISO 14001 EMS Standard (draft)
2. NSF-110 EMS Standard (draft)
3. CMA Responsible Care Program
4. CSA-2750 EMS Standard (draft)
5. DOE Environmental Management
Assessment Protocols
6. U.S. Sentencing Commission Guidelines
7. Canadian Code of Environmental
Stewardship
8. EPA Environmental Leadership Program
(proposed)
9. GEMITQEM materials
10. Wever, "Utilizing a Self Assessment Matrix
for Implementing TQEM"
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although EPA has participated strongly in the ISO process and exchanges information with other
countries that have developed such standards.
On September 3, 1996, Steve Herman, the EPA Assistant Administrator for Enforcement and
Compliance Assurance, signed a letter transmitting the CEMP to the Federal agency executives who had
signed the Charter for the Interagency Pollution Prevention Task Force in September 1995, requesting
written commitment to the Principles contained in the CEMP. In this letter, EPA also asked each agency
to provide a written statement declaring their support for the CEMP principles at the agency level along
with a description of their plans for implementation of the CEMP at the facility level. The CEMP was
published in a Federal Register notice on October 16, 1996 (61 FR 54063). The information in this
document is provided as a guide to assist agencies in formulating their responses to EPA and their
approaches to implementation of the CEMP.
Although this document presents specific actions that could be taken in implementing the principles, they
are offered only as suggested steps that have proven useful to other organizations in implementing
similar programs. Agencies are encouraged to consider other steps that might be more appropriate for
their circumstances, or to adopt an EMS standard as the vehicle for implementing the CEMP. An agency
that implements an EMS (such as ISO 14001) will have addressed the major elements of the CEMP, so
long as its system includes an explicit compliance assurance component.
The term "agency" is used throughout the CEMP to represent the participation of individual federal
government bodies. Many Cabinet-level "agencies" have multiple levels of organization and contain
independently operating bodies (known variously as bureaus, departments, administrations, services,
major commands, etc.) with distinct mission and function responsibilities. Therefore, while it is
expected that a "parent agency" would subscribe to the CEMP, each parent agency will have to
determine the most appropriate level(s) of explicit CEMP implementation for its situation. Regardless of
the level of implementation chosen for the organization, it is important that the parent agency or
department demonstrate a commitment to these principles.
Before an agency can fully implement the CEMP,
it should conduct an initial review or "gap
analysis" to evaluate its current program and
specific needs. Although the gap analysis is very
important, it can be counter-productive for an
agency to focus narrowly on what it is not doing.
It is also important to understand what it is
already doing, and evaluate ways to improve and
build on existing programs and activities. Some
agencies may find that they are already
performing many of the suggested activities.
This is good; there is no need to rebuild a
program from scratch. In fact, EPA believes that
many agencies do have programs that address the
principles of the CEMP, but those programs may
not be seen as connected parts of a system and
may be operated in isolation or by multiple
contractors. Looking outside the environmental
PLUGGING THE GAPS
A gap analysis is designed to answer the following
questions:
I
How well are the organization and its
environmental programs performing?
What standards of environmental performance
does the organization hope to achieve?
What are the gaps between objectives and
performance?
What existing programs and activities can serve
as the best foundation for improved
environmental performance?
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arena can provide inspiration. Agencies may be tempted to say "Yes, we do that, but it's not
environmental, it's part of our quality (or some other) system." If it already helps manage important
agency activities, it can probably help environmental management as well. The full impact of the
CEMP/EMS approach will be realized in tying these programs and activities together to improve
efficiency, which is also likely to improve performance and cost-effectiveness.
Building on existing programs becomes even more important when agencies are faced with diminishing
resources and being asked to "do more with less." Through careful analysis, agencies will probably find
ways to address the principles at little or no cost. For example, developing a policy statement on
environmental protection does not require large investments in personnel or equipment, yet it can carry
agency-wide visibility and impact. Ultimately, agencies that are able to invest in the implementation of
the principles are likely to realize a high return on that investment through an improved "risk profile" at
their facilities, resulting in a lowering of costs associated with regulatory compliance, health and safety,
incident response, and cleanup of contaminated sites. Non-monetary benefits, such as improved public
opinion and employee satisfaction, can also be achieved.
How Does the CEMP Tie Into Other EPA Programs?
EPA has several programs that are designed to encourage creative approaches to environmental
protection. Most notable among
these are Project XL and the
Environmental Leadership Program
(ELP), both of which encourage
Federal agency participation
(McClellan AFB in Sacramento and
Puget Sound Naval Shipyard in
Bremerton, Washington participated
in the pilot phase of the ELP). The
ELP has established the full-scale
implementation of an EMS as one of
its criteria for participation, and
evaluated the CEMP and ISO 14001
as background material in developing
this criterion. Project XL also has the
use of innovative regulatory
management programs as a required
element. One major difference
between the two programs is that the
ELP seeks to identify more efficient
operations within the existing
regulatory structure, while Project
XL will allow some relief from
regulatory requirements //the
ultimate performance exceeds that
achievable with full compliance.
WHY DOES THE CEMP EMPHASIZE COMPLIANCE?
A basic EMS describes the managerial framework within which
environmental activities are carried out, rather than the activities
themselves The philosophy behind the EMS approach is that the
way in which a site is managed (rather than a strict focus on
outcomes) does make a difference. Most existing environmental
regulations do not address this management implementation
aspect.
While EPA agrees with this approach, it does not wish to lose
sight of the fact that compliance with regulations is of paramount
importance, as well as a primary mission of the Agency.
Implementation of regulatory requirements has driven most of the
improved environmental performance over the past quarter-
century, and the regulatory structure continues to ensure the basic
level of protection for workers, the public, and the environment.
A properly implemented EMS can provide more consistent levels
of compliance and higher levels of environmental performance,
depending upon the objectives and targets selected.
Organizations should not take the view that a few regulatory
lapses are of secondary importance to implementing the EMS.
Indeed, low or inconsistent levels of compliance can be indicative
that the EMS is not working. EPA approves of EMS
implementation as a means to identify weaknesses in an
organization's approach to compliance and to examine its internal
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MANUAL ELEMENTS REQUIRED FORA
COMPLIANCE-FOCUSED ENVIRONMENTAL MANAGEMENT SYSTEM
IN A SETTLEMENT AGREEMENT
1. Management Policies and Procedures
a. Organization's Environmental Policy - Must clearly communicate management commitment to
environmental performance, including compliance with applicable federal, state, and local
environmental statutes and regulations, including permits (i.e., "environmental requirements").
b. Site-specific Environmental Policies and Standards
Body of general policies, rules, and procedures for environmental principles and practices.
Includes process for developing, approving, and communicating standard operating practices
for activities having potentially adverse environmental or regulatory compliance impacts.
! Clearly identifies organizational responsibilities for maintaining regulatory compliance,
including required reporting to regulatory agencies.
! Includes ongoing means of communicating environmental issues and information to all
organization personnel, on-site service providers, and contractors, and receiving and
addressing their concerns.
! Describes and establishes processes to ensure sustained interaction with regulatory agencies,
and within the organization (e.g., between the various divisions, contractors, and the
Environmental Control Department) regarding environmental issues and regulatory
compliance.
2. Organization, Personnel, and Oversight of EMS
a. Describes, organizationally, how the EMS is implemented and maintained.
b. Includes organization charts that identify units and individuals having environmental performance
and regulatory compliance responsibilities.
c. Identifies duties, responsibilities, and authorities of key environmental program personnel in
implementing and sustaining the EMS (e.g., could include position descriptions and performance
standards for all environmental department personnel, and excerpts from others having specific
environmental program and regulatory compliance responsibilities).
3. Accountability and Responsibility
a. Specifies accountability and responsibilities of organization's management, on-site service
providers, and contractors for environmental protection practices, compliance, required reporting
to regulatory agencies, and corrective actions implemented in their area(s) of responsibility. Also
specifies potential consequences of departure from specified operating procedures, including
responsibilities (personal and organizational) for civil/administrative penalties imposed as a result
of noncompliance.
In addition, EPA's National Enforcement Investigation Center (NEIC) has begun to require EMS
elements in consent decrees with several private companies. This approach is intended to ensure that
companies with prior instances of non-compliance address the root causes of those situations. [See
Related Boxes]
What You Will Find in This Document
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Chapter 2 summarizes federal agency responses to the CEMP, as received by EPA. Each of Chapters 3-7
is dedicated to one of the principles. The principle and its supporting Performance Objectives, which
provide more information on the tools and mechanisms by which the principle is fulfilled, are described
in detail and several possible actions that can help an agency meet the principle are provided. These
actions are provided as guidelines to assist agencies in understanding the scope of the principles, and as a
suggested basis for planning. Agencies are not required to pursue all of these actions, nor are they
limited to them. It should be understood that, as is implicit in the EMS approach, implementation of the
principles will not be as effective if they are administered as though they are discrete pieces of a larger
EMS MANUAL ELEMENTS (cont.)
4. Environmental Requirements
a. Describes process for identifying, understanding, and communicating environmental requirements to
affected organization personnel, on-site service providers, and contractors, and ensuring that facility
activities conform to those requirements. Specifies procedures for identifying and obtaining
information about changes and proposed changes in environmental requirements, and incorporating
those changes into the EMS.
5. Assessment, Prevention, and Control
a. Identifies an ongoing process for assessing operations, for the purposes of preventing and controlling
releases, environmental protection, and maintaining compliance with statutory and regulatory
requirements. This shall include monitoring and measurements, as appropriate, to ensure sustained
compliance. It shall also include identifying operations and waste streams where equipment
malfunctions and deterioration, operator errors, and discharges or emissions may be causing, or may
lead to, releases of hazardous waste or hazardous constituents to the environment, or a threat to human
health or the environment. Finally, process shall include performing root cause analysis of identified
problems to prevent recurring issues.
b. Describes process for identifying activities that could cause adverse environmental impacts and/or
regulatory noncompliance, and where documented standard operating practices need to be developed
[see element l.(b)].
c. Describes a system for conducting and documenting routine, objective, self-inspections by department
supervision and trained staff, especially at locations identified by the process described in (a) above.
d. Describes process for ensuring input of environmental concerns and requirements in planning; design;
and operation of ongoing; new; and/or changing buildings, processes, maintenance activities, and
products.
6. Environmental Incident and Noncompliance Investigations
a. Describes standard procedures and requirements for incident and noncompliance reporting,
investigation; and development, tracking, and effectiveness verification of corrective and preventive
actions. The procedures shall specify testing of such procedures, where practicable.
program. In fact, they are so tightly interconnected that the entire program can succeed only if the
elements are fully integrated. Although clear managerial responsibility must be assigned for each
component, the system as a whole depends ultimately on communication among the various program
elements.
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Similarly, activities described in the context of one of the principles are often carried throughout other
EMS MANUAL ELEMENTS (cont.)
7. Environmental Training, Awareness, and Competence
a. Identifies specific education and training required for organization personnel, as well as process
for documenting training provided.
b. Describes program to ensure that organization employees are aware of its environmental policies
and procedures, environmental requirements, and their roles and responsibilities within the
environmental management system.
c. Describes program for ensuring that personnel responsible for meeting and sustaining compliance
with environmental requirements are competent on the basis of appropriate education, training,
and/or experience.
8. Planning for Environmental Matters
a. Describes how environmental planning will be integrated into other plans developed by
organizational subunits, as appropriate (e.g., capital improvements, training, maintenance).
b. Requires establishing written goals, objectives, and action plans by at least each operating
organizational subunit, as appropriate, including those for contractor operations conducted at the
facility, and how specified actions will be tracked and progress reported.
9. Maintenance of Records and Documentation
a. Identifies the types of records developed in support of the EMS (including audits and reviews),
who maintains them and where, and protocols for responding to inquiries and requests for release
of information. Specifies the data management systems for any internal waste tracking,
environmental data, and hazardous waste determinations.
10. Pollution Prevention Program
a. Describes an internal program for reducing, recycling, reusing, and minimizing waste and
emissions, including procedures to encourage material substitutions. Also includes mechanisms
for identifying candidate materials to be addressed by program and tracking progress.
11. Continuing Program Evaluation
a. Describes program for periodic, at least annually, evaluation of the EMS, including incorporating
the results of the assessment into program improvements, revisions to the manual, and
communicating findings and action plans to affected employees, on-site service providers, and
contractors.
12. Public Involvement/Community Outreach
a. Describes a program for ongoing community education and involvement in the environmental
aspects of the organization's operations and general environmental awareness.
principles. For example, benchmarking should be done not only in connection with daily operations, but
also in terms of information management, pollution prevention initiatives, safety and emergency
response, training, and so on. Audits will target not only what is commonly thought of as
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"environmental compliance," but also safety, emergency response, and documentation procedures.
Training and information management are integral to the successful operation of any organization.
The last chapter in this document contains a "Self-Assessment Matrix," which describes stages that an
organization may go through in implementing the principles. The Matrix shows five levels for each of
the Performance Objectives that support the principles, with a brief description of a typical organization's
accomplishments at that level. Agencies can use the Matrix and the accompanying text in the chapter to
relate the suggested activities to the levels in the Matrix. There is no real significance to the numbering
of the levels. No scoring system is implied, although agencies are free to track their own progress in
such a manner, if they so desire. Agencies are also free to modify the Matrix to make it a more useful
tool.
EPA does not expect the CEMP to be implemented "overnight." EPA fully realizes that some agencies,
bureaus, and departments may require years to implement the CEMP. Awareness and understanding are
the necessary first steps. The CEMP, like EMS standards, includes ongoing review and a commitment to
continuous improvement, so in one sense implementation will never be "finished."
EPA's Federal Facilities Enforcement Office (FFEO) is available to provide technical assistance to
agencies implementing the CEMP. EPA is also collaborating with the Department of Energy in
preparing a primer on environmental management systems for federal facilities. The Primer addresses
specific aspects of environmental management (e.g., pollution prevention and audits) and discusses ways
to integrate and make them more powerful within the context of an EMS. FFEO is leading EPA's efforts
on the Primer.
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CHAPTER 2: FEDERAL AGENCY RESPONSES TO THE CEMP
CEMP Development Process
On August 3, 1993, President Clinton signed Executive Order No. 12856, which pledges the federal
government to implement pollution prevention measures, and publicly report and reduce the generation
of toxic and hazardous chemicals and associated emissions. Section 4-405 of Executive Order 12856
requires the Administrator of the Environmental Protection Agency (EPA), in cooperation with federal
agencies, to establish a Federal Government Environmental Challenge Program. As required under the
Executive Order, the Challenge program consists of three components to challenge Federal agencies to:
1) agree to a code of environmental principles emphasizing pollution prevention, sustainable
development, and "state of the art" environmental management programs; 2) submit applications to EPA
for individual Federal facilities for recognition as "Model Installations"; and 3) encourage individual
Federal employees to demonstrate outstanding leadership in pollution prevention.
On September 12, 1995, senior agency representatives signed the Charter for the Interagency Pollution
Prevention Task Force committing the federal government to achieve, among other items, environmental
excellence through various activities including: a) active agency and facility participation in the Federal
Government Environmental Challenge Program and, b) participation in the establishment of an agency
Code of Environmental Management Principles (CEMP). In June 1995, a subcommittee of federal
agency representatives was formed by the Task Force to work directly with EPA in the development of
the CEMP. Through this process, several drafts of the CEMP were forwarded to federal agencies by the
subcommittee for formal review and comment. The version of the CEMP published on October 16, 1996
(61 FR 54062) represents the final version as approved by the subcommittee and incorporates comments
from members of the Interagency Task Force.
As stated in Chapter 1, EPA formally transmitted the CEMP to the federal agency executives who had
signed the Charter for the Interagency Executive Order 12856 Pollution Prevention Task Force on
September 3, 1996. In the letter accompanying the CEMP, Steve Herman, the EPA Assistant
Administrator for Enforcement and Compliance Assurance, requested written agency commitment to the
Principles contained in the CEMP and a description of their plans for implementation of the CEMP at the
facility level. EPA sought endorsement of the CEMP Principles on an agency wide basis, with flexibility
as to how the Principles themselves are implemented at the facility level. For example, agencies could
choose to directly implement the CEMP Principles at the facility level or use another alternative
environmental management system (e.g., ISO 14001). This flexible approach was in recognition that of
the fact that individual federal facilities and installations may already have environmental management
systems in place or are considering adoption of the ISO 14001 Environmental Management Standard.
Responses From Federal Agencies and Departments
As previously stated, in September 1996 EPA requested federal agencies to provide a brief written
statement declaring the agency's support for the CEMP Principles along with a concise explanation of
how the agency plans to implement the CEMP at the facility level. Responses endorsing the CEMP on
an agency-wide basis have been received from the 16 agencies that participated in the development of
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the CEMP. A table summarizing the responses is provided in Table 1 and the copies of each agency
response are contained in Appendix 1.
Three of the responses were detailed in nature. The Postal Service, the Department of Defense (DoD),
and the Central Intelligence Agency (CIA) addressed each of the five CEMP principles as well as the
objectives of the principles, explained how the agency planned to implement the CEMP at the facility
level, and described how the agency's management system will meet the CEMP.
The Postal Service's head of Environmental Management Policy endorsed the CEMP, described its
management commitment, submitted a copy of its Policy for Environmental Protection which contains
seven guiding principles, and stated that the Postal Service is also evaluating the use of ISO 14001 as a
management system to meet the CEMP. The Postal Service described its compliance program, discussed
its Environmental Strategic Plan, and submitted its most recent annual status report which tracks the
status of the current 105 Tactical Action Plans intended to achieve compliance and leadership. The
Postal Service described its enabling systems and submitted a copy of its environmental target areas
(e.g., leadership targets and compliance targets) which provide focus and direction for developing and
implementing plans at the Area, District and Plant Levels. The Postal Service described its performance
and accountability program, and how it continuously monitors progress and updates the Tactical Actions
in its Environmental Strategic Plan to reflect many new ideas, target areas and programs. Since Postal
Service employees are accountable for environmental objectives through the Policy for Environmental
Protection, the Policy was integrated into personnel evaluations to reinforce personnel accountability.
The Postal Service also discussed its measurement and improvement strategy, and its utilization of a
concept known as Environment Information Services and Support to gather, analyze and distribute data
and information through the Postal Routed Network to Postal environmental professionals and personnel
throughout the U.S.
DoD endorsed the CEMP at the Deputy Under Secretary level, and provided the only response which
addressed all of the objectives of each CEMP principle. DoD discussed its management commitment,
and described its Environmental Security Directive which establishes environmental protection goals and
develops supporting strategies that fully complement accomplishment of DoD's overall mission. DoD
also stated that the Department is using ISO 14001 in the development of its current strategic plan and is
evaluating adoption of ISO 14001 as a management system for the entire Environmental Security
program. DoD described its compliance program in the context of its Environmental Security Directive
and supporting instructions, and described its requirement that each installation conduct a self audit for
environmental performance at least annually. DoD described its enabling systems in the context of the
Environmental Security Directive which establishes environmental goals, supporting strategies, budget
priorities and measures of merit that support overall organizational objectives. DoD also described its
extensive environmental training program which includes military recruit training, technical training
programs, professional (officers) military education programs as well as insertion of environmental
requirements into the education programs for non environmental professionals whose actions could
affect the environment. DoD described its performance and accountability program, and how the
Environmental Security Directive establishes goals for compliance, pollution prevention and
conservation, and requires periodic reporting on progress towards meeting these goals through measures
of merit. DoD personnel regulations require that major job components be identified in job descriptions,
and that evaluation criteria for the major job components be prepared in employee's annual work plans.
Thus, persons with environmental responsibilities are evaluated on the performance of those
responsibilities and outstanding performance by installations and individuals is recognized via an awards
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program. DoD also discussed its measurement and improvement strategy which includes
implementation of an automated data management system, annual assessments of progress towards
achieving the goals established by the Environmental Security Directive, and evaluation/benchmarking
of environmental operations in other government and non-government organization which have
environmental challenges similar to DoD and CEMP. DoD efforts to improve environmental
performance include establishment of hazardous materials pharmacies at installations and ships to
provide central control of purchasing, storing, distributing and disposing of hazardous materials,
resulting in reduced purchases, disposals, and potential for violations.
The CIA's chief of Environmental Safety endorsed the CEMP, and described its management
commitment in the context of establishment of a formal environmental program in FY 1992. The
program is designed to gain compliance with environmental regulations and initiate remediation of
potential cleanup sites, and has been funded on a multiyear basis and administered by the newly formed
Environmental Safety Group. Most recently, the CIA issued an Agency Notice establishing the CIA
Pollution Prevention Policy and Goals, with a target of fifty percent reduction in the use of toxic
chemicals and a reduction in the use of extremely hazardous substances. The CIA described its proactive
compliance program which consists of annual compliance inspections of all CIA sites, compliance audits
at some sites, and provision of expert consultation and assistance to field sites to address specific issues.
The CIA described its enabling personnel including funding for environmental compliance training
programs for specialists, site managers, and selected component personnel, and regular briefings of
senior managers on the progress of the program. The CIA has also established a Lotus Notes electronic
bulletin board database which provides means to disseminate regulatory updates to field personnel,
functions as an inquiry and response forum, and serves as a general discussion media for promoting
environmental issues and policies. The CIA described its performance and accountability program, and
how all major field sites are staffed with a full-time Environmental Safety Officer (ESO) who
implements the environmental program under the direction of the site manager. The ESOs are
responsible for coordinating the environmental program among the various tenants located at a site, and
have their performance evaluations prepared annually by the site manager and forwarded to the CIA
environmental program office for review, accountability. The CIA also discussed its measurement and
improvement strategy, including annual programmatic appraisals to assess the status of the CIA
environmental program, periodic review by the CIA IG to ensure programmatic compliance with
environmental laws and regulations, and prioritization of centrally funded resources to address
deficiencies identified by the reviews/appraisals. Annual environmental conferences are also held to
assemble field ESOs to review the status of site and CIA programs, and to discuss goals and
opportunities for improvement in areas such as pollution prevention, affirmative procurement, waste
reduction and recycling.
The remaining 13 responses endorsed the CEMP but were more general in nature. EPA is in the process
of following up with these agencies to obtain more specific information about how the agencies plan to
implement the CEMP at the facility level. The responses from the Department of Commerce (DoC),
Department of Energy (DoE), Department of Interior (Dol), Department of Justice (DoJ), Environmental
Protection Agency (EPA), and the National Aeronautics and Space Administration (NASA) addressed
the five CEMP principles in varying levels of detail. DoE, DoJ, EPA and NASA explained in general
terms how they plan to implement the CEMP at the facility level. DoC, DoE, DoJ and EPA generally
described how their agency's management system will meet the CEMP. DoE, Dol, and NASA indicated
that their agency's are evaluating the use of ISO 14001 as a management system to meet the CEMP. The
responses from the Department of Health and Human Services (HHS), Department of Transportation
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(DoTransp.), Department of Treasury (DoTreas.), General Services Administration (GSA), Department
of Agriculture (USDA), Veterans Administration (VA), and Tennessee Valley Authority (TVA)
addressed the CEMP principles and how the agency's plan to implement the CEMP at the facility level in
a very general way. GSA and TVA briefly describe how their agency's management system will meet
the CEMP, and DoTreas., indicated that it is evaluating the use of ISO 14001 as a management system to
meet the CEMP.
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Table 1.
Summary of Agency Responses to Code of Environmental Management Principles (CEMP)
Agency
CIA
USDA
DoC
DoD
DoE
Dol
DoJ
DoTransp.
DoTreas.
EPA
GSA
HHS
NASA
Postal Service
TVA
VA
CEMP
endorsed on
agency wide
basis
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Explains plan
to implement
CEMP at
facility level
Yes
Partial
Yes
Partial
Partial
Partial
Partial
Partial
Partial
Partial
Yes
Partial
Describes how
alternative
system (e.g.,
ISO 14001)
will meet
CEMP
Yes
Partial
Yes and
evaluating ISO
14001
Partial and
evaluating ISO
14001
Evaluating
ISO 14001
Partial
Evaluating
ISO 14001
Partial
Partial
Evaluating
ISO 14001
Yes and
evaluating ISO
14001
Partial
Addresses
each CEMP
principle
Yes
Partial
Yes
Partial
Partial
Partial
Partial
Partial
Partial
Partial
Yes
Addresses the
objectives of
each CEMP
principle
Partial
Yes
Partial
Partial
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CHAPTER 3: MANAGEMENT COMMITMENT (PRINCIPLE 1)
The agency makes a written top-management commitment to improved environmental
performance by establishing policies which emphasize pollution prevention and the need to ensure
compliance with environmental requirements.
The first Principle stresses the importance of upper-level management in setting the agenda for the
agency's commitment to environmental management. Although it is possible for organizations to adopt
ideas that originate at the grassroots level, it is more likely that such ideas will be dismissed unless they
have a champion with sufficient organizational clout to advance them. Agencies can advance the cause
of environmental management by setting policies, ensuring that the environmental system is integrated
throughout the agency, and setting a clear example of long-term commitment by articulating support for
strategies that enhance environmental stewardship and sustainable development.
PERFORMANCE OBJECTIVES:
1.1 OBTAIN MANAGEMENT SUPPORT
The agency ensures support for the environmental program by management at all levels and assigns
responsibility for carrying out the activities of the program.
Management sets the priorities, assigns key personnel, and allocates funding for agency activities. In
order to obtain management approval and support, the environmental management program must be
seen as vital to the functioning of the organization and as a positive benefit, whether it be in financial
terms or in measures such as regulatory compliance status, production efficiency, or worker
protection. If management commitment is seen as lacking, environmental concerns will not receive
the priority they deserve.
Organizations that consistently demonstrate management support for pollution prevention and
environmental compliance generally perform at the highest levels and will be looked upon as leaders
that can mentor other organizations wishing to upgrade their environmental performance.
1.1.1 Policy Development
The agency establishes an environmental
policy followed by an environmental
program that complements its overall
mission strategy.
Management must take the lead in
developing organizational goals and
instilling the attitude that all organization
members are responsible for
implementing and improving
environmental management measures, as
well as develop criteria for evaluating
POSTAL SERVICE POLICY
"The United States Postal Service is committed to
provide employees and customers with a safe and
healthy environment. Environmental protection is
the responsible thing to do and makes for sound
business practices.
"In performing its mission...the Postal Service will
conduct its activities in a manner protecting human
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POSTAL SERVICE GUIDING PRINCIPLES
how well overall goals are met. The environmental policy will be the statement that establishes
commitments, goals, priorities, and altitudes.
It incorporates the organization's mission
(purpose), vision (what it plans to become),
and core values (principles by which it
operates). The environmental policy also
addresses the requirements and concerns of
stakeholders and how the environmental
policy relates to other organizational policies.
1. Meet or exceed all applicable environmental laws
and regulations in a cost-effective manner;
2. Incorporate environmental considerations into
business planning processes;
3. Foster the sustainable use of natural resources by
promoting pollution prevention, reducing waste,
recycling, and reusing materials;
4. Expect every employee to take ownership and
responsibility for environmental objectives;
5. Work with customers to address mutual
environmental concerns;
6. Measure progress in protecting the environment;
7. Encourage suppliers, vendors, and contractors to
comply with similar environmental protection
policies.
Appropriate steps to address policy
development could include:
! Develop overall organizational goals and
priorities;
! Prepare Mission and Vision statements
emphasizing commitment;
! Communicate with stakeholders,
including regulatory agencies, to identify
needs, expectations, and concerns.
1.1.2 System Integration
The agency integrates the environmental management system throughout its operations,
including its funding and staffing requirements, and reaches out to other organizations.
Management should institutionalize the environmental program within organizational units at all
levels and should take steps to measure the organization's performance by incorporating specific
environmental performance criteria into managerial and employee performance evaluations, as
appropriate.
Organizations that fulfill this principle demonstrate consistent high-level management
commitment, integrate an environmental viewpoint into planning and decision-making activities,
and ensure the availability of adequate personnel and fiscal resources to meet organizational
goals. This involves incorporating environmental performance into decision-making processes
along with factors such as cost, efficiency, and productivity.
As one of the main determiners of success or failure, management cannot afford to be isolated
from the strategies and activities associated with an organization-wide environmental
management program. All levels of management must be responsive to the demands of the
program, encourage initiatives to expand its effectiveness, and take proactive steps to integrate
program requirements into existing activities across the organization. Management should also
seek a leadership role for the organization in order to serve as an example to others wishing to
emulate its success. Management backing should also provide organization members with an
indication of the organization's place in the global community.
Appropriate steps to address program integration could include:
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Identify environmental liabilities and risks;
Conduct an organizational review to assist in integrating the environmental program into all
planning, organizing, implementing, and measuring processes;
Assign specific management responsibilities;
Encourage teaming across all divisions within the agency to improve communication and
teamwork;
Include environmental performance in the evaluation criteria for organizational units,
managers, and employees, as appropriate;
Coordinate and review budget requirements to ensure adequate funding to achieve goals;
Review responsibilities to ensure adequate staffing at all levels;
Assume a leadership role through involvement in outreach activities, such as professional
organizations, conferences, information exchanges, local government, and public
information sessions;
Provide awareness training to all levels of management and workers.
1.2 ENVIRONMENTAL STEWARDSHIP AND SUSTAINABLE DEVELOPMENT
The agency strives to facilitate a culture of environmental stewardship and sustainable development.
"Environmental Stewardship" refers to the
concept that society should recognize the impacts
of its activities on environmental conditions and
should adopt practices that eliminate or reduce
negative environmental impacts. Every aspect of
an organization's operations, including strategic
planning, procurement, waste reduction, waste
management, water and energy usage, responses
to existing environmental problems, and land
management, must be conducted in such a way as
to limit or eliminate adverse impacts on the
environment. Government agencies, whose
national policies affect a range of complex
management decisions and who have been
entrusted with the management of the nation's
immense and diverse land and water resources,
must provide an example to others in
implementing programs of environmental
stewardship.
The President's Council on Sustainable
Development was established on June 29, 1993
by Executive Order 12852. The Council has
adopted the definition of sustainable development
as: "meeting the needs of the present without
compromising the ability of future generations to
meet their own needs." The concept was
ECOSYSTEM MANAGEMENT
Ecosystem management is a relatively recent
development that has been adopted by several
federal agencies. The concept of ecosystem
management is a response to the recognition of
the inadequacy of the traditional resource-
management approach, which focused on
individual resources, such as water, land,
forest, wildlife, etc. It has become clear in
recent years that these seemingly separate
components are in fact highly integrated and
interdependent. Therefore, the federal
government is attempting to tailor its
management responsibilities to entire
ecosystems, many of which range across
legislatively or administratively defined
boundaries. It is believed that encouraging
consideration of these complex and dynamic
systems as complete entities will provide a
more coherent framework for resource
management and protection, reduce
administrative conflict, and better address
declining ecological conditions. This approach
will require significant interaction and
coordination with state and local authorities
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developed to provide insight into the way in which natural resources and systems (rainforests,
atmospheric conditions, natural water bodies, etc.) are integrated within the environment and how
that relationship is affected by the use of the resources. It is hoped that this understanding will lead
to a new level of consciousness in which use of natural resources is limited to identifiable needs,
original conditions are restored as much as possible, and waste material is managed in an
environmentally friendly manner, all of which will help to ensure the presence of these resources for
future generations.
INTERAGENCY COOPERATION IN
ECOSYSTEM MANAGEMENT
Fourteen federal agencies came together to sign
the "Memorandum of Understanding to Foster
the Ecosystem Approach" (December 15, 1995).
The MOU defines the Ecosystem Approach as:
a method for sustaining or restoring
ecological systems;
goal driven;
based on a vision of desired future
conditions that integrates ecological,
economic, and social factors;
applied within a geographic framework
defined primarily by ecological boundaries.
The goal of the Ecosystem Approach is to
"restore and sustain the health, productivity, and
biological diversity of ecosystems and the overall
quality of life through a natural resource
management approach that is fully integrated
with social and economic goals."
The signatories agree that federal agencies
should
! provide leadership in and cooperate with
activities that foster the Ecosystem
Approach;
! ensure that they utilize their authorities in a
way that facilitates the Ecosystem Approach;
! administer their programs in a manner that is
sensitive to the needs and rights of
landowners, local communities, and the
public;
! work with landowners, local communities,
and the public to achieve common goals.
Responsible environmental management should be
one of the main pillars of the organization, not an
ancillary concern or afterthought. Personnel at all
levels need to be "on the same page" when it comes
to environmental issues. In order to generate this
level of awareness, personnel need to have some
understanding of environmental issues, how they
are related to the organization's activities, and the
consequences of inaction or negative action.
Where possible, the organization should attempt to
supplement information on specific regulatory,
compliance, or management concerns by providing
a global perspective in its presentation of
environmental issues that encompasses concepts
such as sustainable development and ecosystem
management. The organization's culture should be
extended to draw in the surrounding community, in
which personnel are likely to reside.
An organization's commitment to environmental
stewardship and sustainable development would be
demonstrated through implementation of several of
the CEMP Principles and their respective
Performance Objectives. For example, by
implementing pollution prevention and resource
conservation measures (see Principle 2,
Performance Objective 2.3), the agency can reduce
its negative environmental impacts resulting
directly from its facilities. In addition, by including
the concepts of environmental protection and
sustainability in its policies, the agency can help
develop the culture of environmental stewardship
and sustainable development not only within the
agency but also to those parts of society that are
affected by the agency's activities.
Appropriate steps in creating a culture of
environmental stewardship could include:
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Provide orientation describing the
program for all personnel;
Encourage each organizational group to
prepare an environmental action plan,
which will describe the steps the group
will implement to improve environmental
performance and what will be achieved;
Introduce the concepts of life-cycle
analysis and design for the environment
to the agency, focusing on groups with
responsibilities in potentially affected
areas (e.g., procurement or engineering);
Provide outside speakers describing
issues of environmental concern and how
they relate to the agency;
Provide in-house "brown bag" speakers
from various aspects of the agency describing their responsibilities;
Create newsletters and other promotional items describing the progress of the program and how
it benefits the agency;
Encourage organizational sponsorship of outside activities with environmental content, such as
"Clean up days" or school visits;
Promote "Open House" days for the local community;
Participate in local government hearings and other activities;
Implement a program that demonstrates commitment to sustainable development and renewable
resources by planting trees or other such activity;
Incorporate evaluations of environmental implications of proposed activities into decision-
making processes.
ECOSYSTEM CASE STUDIES
The Interagency Ecosystem Management Task
Force has conducted case studies in seven areas
facing extreme environmental stress:
Anacostia River watershed;
Coastal Louisiana;
Great Lakes basin;
Pacific Northwest forests;
Prince William Sound;
South Florida; and
Southern Appalachians.
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CHAPTER 4: COMPLIANCE ASSURANCE AND POLLUTION
PREVENTION (PRINCIPLE 2)
The agency implements proactive programs that aggressively identify and address potential
compliance problem areas and utilize pollution prevention approaches to correct deficiencies and
improve environmental performance.
The second Principle addresses what might be considered the core of environmental management.
Whatever an agency's approach to environmental management, it must always meet the obligation of
compliance with regulations. The CEMP is intended to help agencies more easily meet this obligation
and expand their vision "beyond compliance." Aggressive pollution prevention strategies will also be
central to maintaining compliance, improving environmental performance, reducing risks, and cutting
costs. Preparation for emergency situations can also help avoid breakdowns in compliance and pollution
control.
PERFORMANCE OBJECTIVES:
2.1 COMPLIANCE ASSURANCE
The agency institutes support
programs to ensure compliance
with environmental regulations
and encourages setting goals
beyond compliance.
Implementation of an
environmental management
program should be a clear signal
that non-compliance with
regulations and established
procedures is unacceptable and
injurious to the operation and
reputation of the organization.
Satisfaction of this performance
objective requires a clear and
distinct compliance management
system as a component of the
agency's overall environmental
management system.
All personnel, beginning with
management, must understand
that the objective of a
compliance program is not to set
up obstacles that prevent
COMPLIANCE ASSURANCE...
Environmental compliance can be a sensitive subject, and not
one that many organizations eagerly address. Environmental
regulations have been characterized by some as unnecessary,
burdensome, overly costly, stifling of creativity, and ineffective.
Federal facilities, which were not a primary focus of many of the
environmental statutes but have come under their jurisdiction,
may consider these descriptions particularly appropriate.
However, EPA and other regulatory agencies weigh the societal
benefits of regulation against the societal burden of compliance,
taking into account the best available scientific information.
Admittedly, it can be difficult to assign a dollar figure to
improved air or water quality, and many issues are not easily
resolved by science, such as the effects of dioxins on living
tissue.
The lack of an underlying regulatory structure can be seen in the
legacy of contamination at CERCL A sites and many Federal
facilities. Compliance with regulations must be a core value of
any organization. Federal agencies, which are endowed with the
public trust, should give no more thought to violating
environmental rules than they would to distributing sensitive
information or disregarding contracting, procurement, and other
financial requirements.
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meaningful work from being accomplished,
.AND "BEYOND COMPLIANCE"
Supporters of Environmental Management
Systems and other "quality" approaches to
environmental management often speak of the
need to go "beyond compliance." What does this
mean? Are there different levels of compliance,
rather than just "in" or "out of compliance?
What can be found "beyond compliance"?
"Beyond compliance" is recognition that much of
the activity that falls under environmental
programs is driven by regulations. Permits are
requested, forms are filled out, reports are filed,
to comply with regulation. But accepting
compliance as a core value doesn't preclude
looking for ways to make it easier, less costly,
and less pervasive.
Although an EMS is a management system, not a
compliance system, the benefit of an EMS is that
it forces a look at all activities that can have an
environmental impact and provides an
integrating structure for supporting activities that
are not strictly environmental in nature, such as
training and documentation. This "holistic"
approach provides a context in which the core of
compliance can incorporate the organization
mission and vision. It encourages participation
at all levels to improve and coordinate
management, rather than a "do this because it's
required" directive.
A 1993 survey of six major corporations found
that facilities spent more on compliance than on
pollution prevention, but would rather have the
ratio heavily weighted toward pollution
prevention (Source: Business Roundtable). A
"beyond compliance" approach can help to
reallocate resources to priority areas without
sacrificing compliance. "Beyond compliance"
also includes working with regulators to form
mutually beneficial partnerships, rather than
approaching them as adversaries.
but to guide the organization through complex and often
uncertain terrain to the successful completion of
tasks. Early incorporation of a compliance
perspective will prevent unpleasant and costly
surprises later in a project's schedule. The
environmental management program must also
encourage forward-thinking to go beyond simple
compliance, as the organization will be constantly
playing catch-up to meet stricter standards. For
example, the agency should stress the importance
of the environmental compliance performance of its
outside contractors and suppliers, perhaps by
encouraging (and eventually requiring) their
adherence to a specified set of environmental
management principles.
An agency that fully incorporates the tenets of this
principle demonstrates maintainable regulatory
compliance and addresses occasions of non-
compliance swiftly and efficiently. It also has
established a proactive approach to compliance
through tracking and early identification of
regulatory trends and initiatives and maintains
effective communications with both regulatory
authorities and internally to coordinate responses to
those initiatives. It also requires that contractors
demonstrate their commitment to responsible
environmental management and provides guidance
to meet specified standards.
Appropriate steps to ensure compliance could
include:
I
Develop an independent compliance group,
with clear assignment of responsibility and
appropriate authority;
Review organizational activities in the context
of Federal, state, and local regulations;
Assess compliance status to establish a baseline
(performing compliance audits can help with
this step);
Establish a compliance management system
that is integrated with the overall
environmental management system;
Track regulatory initiatives to identify future
compliance issues;
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! Hold information sessions to explain the purpose and function of the compliance group;
! Develop guidance for operations to maintain compliance;
! Inform and coordinate with regulatory authorities as necessary;
! Evaluate the environmental and safety performance of outside contractors;
! Develop a program that encourages employees to report knowledge of environmental violations,
departures from procedure, or criminal conduct, and that maintains employee confidentiality;
! Take immediate action to address conditions identified as giving rise to incidents resulting in
non-compliance;
! Plan, track, schedule, and report on corrective actions;
! Develop procedures to elevate compliance issues to upper management, when necessary.
Appropriate steps to move beyond compliance could include:
! Make pollution prevention the primary approach for addressing environmental issues;
! Implement an effective system to keep environmental recordkeeping up-to-date;
! Utilize quality management tools and procedures to identify potential problems and prevent
incidents resulting in non-compliance;
! Develop regular contacts with regulatory authorities to proactively identify and prepare for
future compliance issues;
! Ensure that information on applicable regulations and permit limitations is communicated and
understood;
! Set performance goals that improve upon compliance standards;
! Introduce risk assessment considerations into compliance situations, where appropriate.
2.2 EMERGENCY PREPAREDNESS
The agency develops and implements a program to address contingency planning and emergency
response situations.
Emergency preparedness is not only required by law, it is good business. Properly maintained
facilities and trained personnel will help to limit property damage, lost-time injuries, and process
down time. Personnel should understand the use of fire extinguishers and other such equipment and
know whom to call, where to go, what to do, and (most importantly) what not to do. Simulated spill-
response and other such exercises are invaluable in limiting damage due to "upset conditions." In
addressing the environmental consequences of spills and other incidents, procedures should
incorporate an understanding of concepts such as ecosystem management that can be applied to limit
damage.
The emergency response program will also be the most likely mechanism for integrating the
environmental program with the organization's operational health and safety procedures. Sound
worker safety practices will help to limit situations that could result in environmental damage as well
as worker injuries.
Commitment to this principle is demonstrated by the institution of formal emergency-response
procedures (including appropriate training) and the appropriate links between health and safety
programs (e.g., medical monitoring for federal employees performing hazardous site work).
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Appropriate steps in development of an emergency preparedness program could include:
Develop procedures to address accidents, fires, spills, meteorological, seismological, radiological
incidents, etc.;
Develop a disaster preparedness plan that details procedures to be followed at all of the agency's
facilities;
Identify hazards associated with the activities of the agency and its facilities (e.g., chemicals,
equipment, transportation);
Devise appropriate measures to address and mitigate identified hazards (risk management), and
coordinate these measures with generic procedures;
Implement a preventive maintenance program for all equipment;
Identify an Emergency Management Team (EMT), with clear managerial responsibility;
Provide appropriate training for the EMT and other personnel;
Conduct exercises on a regular basis;
Develop an in-house program that provides medical monitoring for "high-risk" employees and
emergency treatment services as appropriate;
Coordinate with local fire, law enforcement, and medical authorities;
Develop a communication plan that outlines the coordination with local fire, law enforcement,
and medical authorities;
Identify available resources during emergency situations including lines of authority (e.g.,
emergency procurement
authority) for responding
to and mitigating
emergency situations.
2.3 POLLUTION
PREVENTION AND
RESOURCE
CONSERVATION
The agency develops a
program to address pollution
prevention and resource
conservation issues.
An organization with a fully-
developed pollution prevention
program ultimately can save time
and money, and reduce its
liability. Use of
environmentally-friendly
materials is also friendly to the
organization's reputation and
reinforces the idea that the
organization is a responsible
POLLUTION PREVENTION TOOLS
As interest in pollution prevention grows, and organizations look to
move beyond the "low-hanging fruit," it becomes increasingly
important to find ways to evaluate the potential benefits of competing
approaches. Two such tools are Life Cycle Analysis (LCA) and Total
Cost Assessment (TCA).
Life Cycle Analysis generally focuses on the environmental aspects
of a specific product (although it could be applied to processes or
services) over its lifetime. LCA looks at each stage from raw
material through production, use, and disposal. Inputs to the analysis
include energy use, waste generation, emissions, and releases from
each stage.
Total Cost Assessment focuses on the economics of a given
situation, including costs related to environmental variables. For
example, TCA might compare the cost of retrofitting to address
increased emissions with the cost of additional waste treatment and
disposal for two alternatives.
A number of publications give further detail on LCA and TCA. A
starting point for Federal agencies could be Federal Facility
Pollution Prevention Project Analysis: A Primer for Applying Life
Cycle and Total Cost Assessment Concepts, EPA 300-B-95-008, July
1995.
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citizen. Reducing exposure to toxics through material substitution or process modifications and
improvements also benefits employee health and can improve morale. Although source reduction should
be the primary focus of pollution prevention, recycling and reuse programs should also be aggressively
pursued and promoted.
NATIONAL PERFORMANCE REVIEW
In 1993, the National Performance Review
examined the Federal role in environmental
protection and degradation. Specifically, the NPR
looked at ways to improve the Federal ability to:
I
promote sustainable economic development;
prevent environmental degradation;
reduce costs; and
maintain the long-term health of the nation's
ecological systems.
The NPR made four specific recommendations in
two broad areas (see related boxes).
In order to be fully effective, pollution
prevention programs must be integrated
throughout the organization's activities. All
personnel should be encouraged to identify
additional opportunities for pollution prevention
initiatives. Energy conservation efforts can often
be paired effectively with pollution prevention
concerns, as can parallel programs to identify
conservation opportunities for water and other
resources. The pollution prevention/resource
conservation program can be employed as a
strong indicator of the organization's
commitment to sustainable development.
Incorporation of concepts such as life-cycle
analysis and total cost assessment can help to
identify preservation or conservation
opportunities.
An organization committed to pollution prevention has a formal program describing procedures,
strategies, and goals. In connection with the formal program, the most advanced organizations have
implemented policy that encourages employees to actively identify and pursue pollution prevention and
resource conservation measures, and instituted procedures to incorporate such measures into the formal
program. Resource conservation practices would address the use by the agency of energy, water, and
transportation resources, among others. Greater efficiency in using natural resources will also help to cut
pollution (e.g., lowered emissions from power generation and vehicles, lessened need for wastewater
treatment) and related costs. Pollution
prevention policies and practices should
follow the environmental management
hierarchy prescribed in the Pollution
Prevention Act of 1990 [Figure 2]: 1) source
reduction; 2) recycling; 3) treatment; and 4)
disposal.
Section 3-301(b) of Executive Order 12856
requires the head of each federal agency to
make a commitment to utilizing pollution
prevention through source reduction, where
practicable, as "the primary means of
achieving and maintaining compliance with
all applicable federal, state and local
Pollution Prevention Act
Environmental Management Hierarchy
Figure 2
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environmental requirements." Making this critical link between pollution prevention and compliance
assurance is the key to achieving and maintaining a "beyond compliance" state. An integrated
environmental management system can help
agencies make this link.
It is equally important to understand the link
between pollution prevention and resource
conservation, and the cyclical nature of this
relationship. For example, agriculture has been
identified as a principal source of non-point
source water pollution, mainly through run-off
that increases sedimentation in waterways and
deposits large amounts of pesticides, nitrates,
phosphates, and other compounds. The soil's
productive capability is diminished and water
quality degraded, with the result that greater
amounts of pesticides and fertilizers are needed
to maintain crop yields, and water supplies may
eventually be unsuitable for irrigation (e.g.,
through increased salinity). However, more
strategic approaches to irrigation that reduce
run-off can both reduce water usage and preserve
productive soil.
NPR RECOMMENDATIONS
Improve Implementation of Environmental
Management
1. Improve Federal Decisionmaking Through
Environmental Cost Accounting - use of tools
such as Life Cycle Analysis and Total Cost
Assessment, discussed earlier, is increasing
among Federal agencies. A number of
software packages have also been developed to
address this issue.
2. Develop Cross-Agency Ecosystem Planning
and Management - the "MOU to Foster the
Ecosystem Approach," described under
Principle 1, demonstrates progress in this area.
water quality, while maintaining greater amounts of
Similarly, new techniques are being
employed to reduce the impacts of pesticide
usage and livestock management. Integrated
pest management approaches that utilize both
biological (breeding pest-resistant strains,
selective introduction of pest predators) and
strategic planting (crop rotation, timing of
planting, removing land from production for
a period) methods can decrease reliance on
chemical pesticides.
NPR RECOMMENDATIONS (cont.)
Improve Environmental Performance at Federal
Buildings and Facilities
Increase Energy and Water Efficiency - Executive
Order 12902 calls for Federal buildings to use 30%
less energy, become 20% more energy efficient,
increase use of renewable energy sources,
incorporate water conservation goals, and
undertake energy and water audits.
Increase Environmentally and Economically
Beneficial Landscaping - the President issued a
"Memorandum on Environmentally Beneficial
Landscaping" (April 26, 1996) directing Federal
agencies to use regionally native plants, minimize
adverse effects on native habitat, use integrated
pest management practices, and use water-efficient . , . ,
landscaping practices. Another aPProach 1S to encourage the growth
of natural vegetation along waterways to act
as a natural filter for run-off, to act as a
barrier that prevents livestock from directly
contaminating the water, and to help absorb greenhouse gases produced by livestock and through
Prevention of livestock waste material is not
a realistic goal, but it can be appropriately
managed to lessen environmental impacts.
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clearing of land. Resource conservation strategies should be consistent with the agency's approach to
environmental stewardship and sustainable development (see Principle 1).
A number of initiatives over the past several years have boosted federal agency participation in pollution
prevention and resource conservation activities. Many originate from agency missions, such as EPA's
33/50, Energy Star, and Green Lights programs, the Department of Energy's Federal Relighting
Initiative, and the New Technology Demonstration Program, which is sponsored by DOE and the
Department of Defense through the Strategic Environmental Research and Development Program
(SERDP). Others arise from statute or directive, such as Executive Order 12856, which requires federal
agencies to develop facility-wide pollution prevention plans and report releases and transfers of toxic
chemicals to the Toxic Release Inventory (TRI), and Executive Order 12902, which sets targets for
reducing energy use and increasing energy efficiency in federal buildings, encourages use of renewable
energy sources, and requires Federal agencies to evaluate opportunities for water conservation and
develop plans for comprehensive energy and water audits at their facilities.
Appropriate steps in developing a pollution prevention/resource conservation program could include:
! Implement a program to identify and evaluate pollution prevention opportunities that emphasizes
source reduction as the policy and practice of first choice;
! Implement a program to identify and evaluate energy conservation opportunities;
! Implement a program to identify and evaluate opportunities to conserve other resources, such as
water;
! Implement an affirmative procurement program to address use of recycled-content materials;
! Identify and implement opportunities to reduce the use of toxic materials;
! Perform life-cycle analyses to assess overall environmental impacts;
! Incorporate design for the environment principles into activities, as appropriate;
! Implement a system of product stewardship;
! Implement a "Repair or Replace" program to track the condition of capital equipment;
! Institute recycling programs for glass, plastic, aluminum, cardboard, paper, and other waste
streams;
! Encourage reuse of paper and other materials.
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CHAPTER 5: ENABLING SYSTEMS (PRINCIPLE 3)
The agency develops and implements the necessary measures to enable personnel to perform their
functions consistent with regulatory requirements, agency environmental policies, and its overall
mission.
The third Principle concerns the underlying or supporting functions for an environmental management
system. These functions are generic in the sense that they support any type of management system, but
are critical to the system's effectiveness and success. Functions falling under this Principle include
training, operating procedures, technical standards, goal-setting, communication, information
management, and documentation.
PERFORMANCE OBJECTIVES:
3.1 TRAINING
The agency ensures that personnel are fully trained to carry out the environmental responsibilities of
their positions.
Comprehensive training is crucial to the success of any enterprise. People need to know what they
are expected to do and how they are expected to do it. Organizations that attempt to save time or
money by limiting training often exceed those savings through non-compliance, rework, remediation
of contaminated sites, or lost-time injuries. Trained personnel are better able to understand the
processes for which they are responsible and are therefore more likely to offer suggestions to
improve those processes.
Training for those expected to oversee the environmental management program must receive equal
priority with training for those whose functions are central to the organization's primary mission.
However, training in environmental subjects should not be limited to those directly involved with the
program, but should be extended to all employees as appropriate. For example, an environmental
training program may take a three-phase approach: 1) awareness training to introduce all employees
to the environmental program; 2) mandatory training for personnel directly involved with the
program (e.g., RCRA 262, 264, 265 and/or OSF£A 40-hour training); and 3) skills training for
personnel operating equipment or for other specific tasks. Refresher training offered on a regular
basis is also an important component of any training program.
An organization will be operating at the highest level when it has an established training program
that provides instruction to all employees sufficient to perform the environmental aspects of their
jobs, tracks training status and requirements, and offers refresher training on a periodic basis.
Appropriate steps in development of a training program could include:
Develop a "Core Curriculum" that is required of all personnel;
Identify additional job-specific training requirements;
Determine availability of outside training vs. desirability of "in-house" training;
Establish an in-house training group to be responsible for tracking the program;
Train the trainers, if necessary;
Establish periodic refresher training (e.g., 8-hour vs. 40-hour OSF£A training);
Develop methods to obtain feedback from employees and assess the effectiveness of the training;
Investigate alternative training methods, such as computer-based or video conference training;
Encourage continuing education for employees, such as seminars, trade shows, and college
courses.
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3.2 STRUCTURAL SUPPORTS
The agency develops and implements procedures, standards, systems, programs, and objectives that
enhance environmental performance and support positive achievement of organizational
environmental and mission goals.
Clear procedures, standards, systems, programs, and short- and long-term objectives must be in place
for the organization to fulfill its vision of environmental responsibility. The commitment to
responsible environmental management should be prominent within the organization's Mission and
Vision statements. The interrelationship and
interdependence of environmental concerns
with all other activities needs to be spelled out
in such a way as to infuse the organization with
environmental consciousness. It must also be
clear how the organization's method of
operation will help to support the concept of
environmental stewardship.
A streamlined set of procedures, standards,
systems, programs, and goals that describe and
support the organization's commitment to
responsible environmental management and
further the organization's mission demonstrate
conformance with this principle.
Appropriate steps in developing clear
organizational documentation could include:
! Review organizational documentation for
clarity, conciseness, conflict, and
redundancy;
! Eliminate or revise procedures, standards,
systems, programs, and goals determined
to be barriers to organizational goals;
! Encourage constructive input from all
personnel;
! Pursue integration of the environmental
program throughout the agency;
! Conduct periodic review of procedures,
etc. to ensure currency.
3.3 INFORMATION MANAGEMENT, COMMUNICATION, DOCUMENTATION
The agency develops and implements systems that encourage efficient management of
environmentally-related information, communication, and documentation.
Information management, communication, and documentation are necessary elements of an effective
environmental management program. The need for advanced information management capabilities
has grown significantly to keep pace with the volume of available information to be sifted, analyzed,
and integrated. The ability to swiftly and efficiently digest data and respond to rapidly changing
conditions can be key to the continued success of an organization. For example, an integrated
information management system may be used to track process requirements, procedures,
measurements, compliance standards, and compliance status. The effects of process changes can be
followed and incidents resulting in non-compliance quickly rectified. Generation of reports is also
greatly simplified, reducing demand on time, personnel, and financial resources. Many private and
public organizations have taken advantage of the explosion in networking capabilities to make
WEAVING THE WEB INTERNALLY...
Many organizations are using the World Wide Web
(WWW) to disseminate environmental and other
information to the people who carry out their
missions. Most federal agencies have a presence
on the Web, many with very sophisticated links to
information of interest. EPA, for example, uses its
Enviro$en$e pages to describe EPA programs and
policies, provide points of contact, and point to
environmental information provided by other
agencies and the private sector. EPA's
Enviro$en$e is available on the Web at
www.epa.gov/envirosense.
Agencies use their Web pages to post bulletins,
notices on meetings, reports on internal task forces,
etc. Some post electronic versions of internal
directives, technical standards, and procedures
(e.g., audit protocols). In this way, personnel
across the agency can be sure that they have the
most current version of a document, and that it is
the same version used by other agency locations.
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information available through the Internet (particularly the World Wide Web), organization intranets
(internal networks that utilize Internet technologies), and other commercial group software packages.
NEPA
Superfund Sites
Federal Agency
Environmental Compliance
Management System
Site Summary
Compliance Summary
Site:
Contact: '
Phone:"
RCRA: 3 USTs tested
CWA: NPDES permits amended
TSCA: PCBs removed
Figure 3
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Figure 3 offers a conceptual depiction of the multiple sources of environmental
information that can be maintained, coordinated, and combined through sophisticated
information management using such technologies.
Information management capabilities include not only hardware and software concerns,
but also people who are able to understand the information, draw informed conclusions,
and make intelligent decisions and recommendations. Integrating information
management capabilities
throughout the organization will
help to ensure that no part of the
organization is left behind. A
drawback to rapid technological
advances, such as those
exemplified by the use of the
Internet, is that they tend to
create "tiers" within
organizations. At the top of the
organization are the traditional
decision-makers, who obtain the
bulk of their information
through briefings, status reports,
and assignments to staff that
have specific information-
gathering functions. These
people will generally continue
to receive information through
these specialized channels.
The next tier is often the
sectional or line managers, who
may be responsible for reports or briefings to top management, but are also responsible
for some level of daily operations. These people often find that rapid technological
advances can make their functions more difficult, at least initially. They find that the
people they are managing are using unfamiliar technologies in ways they don't
understand, while their "tried and true" methods of gathering and evaluating information
are being phased out or are suddenly seen as inadequate. Their survival may depend on
how quickly they can adapt to the new technology.
...AND WITH STAKEHOLDERS
Agencies also find the Web helpful in communicating with
stakeholders. As an example, DOE has made available large
amounts of information related to its investigations of Human
Radiation Experimentation (HREX). Electronic public-access
information areas can save agencies the resources that would be
necessary to generate and distribute thousands of pages of text
that must be continually updated. Special care must be taken,
however, to ensure that sensitive information is properly excised
before making it available.
Agencies can also fulfill much of their public assistance
responsibilities electronically. For example, both the DOE
Pollution Prevention Information Clearinghouse (EPIC) and
EPA's Enviro$en$e pages provide the public with information on
pollution prevention, energy efficiency, and other environmental
assistance information through case studies, reports, event
calendars, notices of newly available documents, etc. Under
EPA's Enviro$en$e, the Federal Facilities Environmental
Leadership Exchange (FFLEX) provides pollution prevention
strategies and other information of interest to the public sector.
Similarly, although not environmentally-related, the Internal
The third tier consists of personnel who are at the "cutting edge" of technological
advances, whether they are responsible for development and implementation or simply
use the technology in their daily activities. The people at this level will ultimately
determine how widely a technology is adopted by demonstrating its value in meeting the
needs of the organization. The lowest tier generally consists of personnel who do not
have access to the technology, such as people in remote field offices or very old
buildings. Their ability to function may be severely hampered. Agencies need to be
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aware of this "tiering" effect and take steps to address it in order to maintain smooth
operations to the extent possible.
Effective communication allows coordination among the various parts of the
organization, ensures that activities are more clearly focused, enhances consistency, and
limits duplication of effort. Complete documentation and recordkeeping improves
regulatory compliance efforts, clarifies responsibilities, and enhances tracking of
processes.
Organizations adopting this principle have developed a sophisticated information
gathering and dissemination system that supports tracking of performance through
measurement and reporting. They also have an effective internal and external
communication system that is used to keep the organization informed regarding issues of
environmental concern and to maintain open and regular communication with regulatory
authorities and the public. Those organizations operating at the highest level ensure that
employees have access to necessary information and implement measures to encourage
employees to voice concerns and suggestions.
Appropriate steps in developing information management, communication, and
documentation capabilities could include:
Information Management:
! Assign managerial responsibility for information management;
! Create an in-house group to identify equipment needs, new developments, and
trends in information management;
! Review current capabilities to determine whether they are sufficient to meet
expected needs;
! Streamline and integrate existing technology to ensure that all personnel have
compatible capabilities;
! Develop procedures for evaluating new information management projects;
! Assign a "shepherd" (project point of contact) for each new initiative;
! Develop procedures for collection, management, and dissemination of information
obtained through the environmental program (routine reports and audits);
! Establish a Resource Center that includes regulations, guidance documents, and
other publications relating to environmental management;
! Implement the use of electronic networks including on-line databases and libraries
(see Figure 3);
! Identify key environmental records and documents to be managed and inventoried;
! Develop procedures to assure validity of environmental data;
! Develop secure procedures for handling, manipulating, and maintaining
environmental data;
! Develop methods to employ environmental management system data in strategic
decision making.
Communication:
! Develop a clearly delineated organizational structure indicating desired lines of
communication;
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! Assign each organizational group a "shepherd" within the environmental program
to act as the group's point of contact on the environmental program;
! Develop efficient in-house communication through the use of voice mail,
electronic mail, and inter-office mail;
! Provide regular status updates on organizational activities through the use of
newsletters, electronic bulletin boards, etc.;
! Provide a "shepherd" (project point of contact) for each major initiative;
! Develop a formal system to allow personnel to anonymously communicate
(without fear of retribution) environmental concerns to upper levels of
management for resolution;
! Develop a communication network with other organizations (both public and
private), as appropriate;
! Develop a public outreach program that can encourage public participation, where
appropriate;
! Develop channels to encourage cooperation, commitment, and solicit employee
environmental concerns;
! Develop a communications network to report environmental performance to
stakeholders and that can address compliance and emergency response situations;
! Ensure that effective working relationships exist between environmental staff of
headquarters and field units as well as between staff and line personnel whose
responsibilities directly impact environmental performance.
Documentation:
Develop a centralized filing system;
Develop an appropriate distribution network for documents;
Develop procedures for completion of all reports;
Develop quality assurance and security procedures for documentation;
Maintain documentation on the properties of materials used by the organization,
such as Material Safety Data Sheets (MSDS).
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CHAPTER 6: PERFORMANCE AND ACCOUNTABILITY (PRINCIPLE 4)
The agency develops measures to address employee environmental performance, and ensure full
accountability of environmental functions.
The fourth Principle concerns the need to lay out the organizational structure and lines of responsibility
for the environmental system. Without a clear structure showing who's in charge and who's accountable
for getting things done, the system components won't mesh as well as they should and the benefits of the
system will be reduced. Putting expectations into individual performance standards is one way to ensure
that people are aware of their responsibilities.
PERFORMANCE OBJECTIVES:
4.1 RESPONSIBILITY, AUTHORITY AND ACCOUNTABILITY
The agency ensures that personnel are assigned the necessary authority, accountability, and
responsibilities to address environmental performance, and that employee input is solicited.
At all levels, those personnel designated as responsible for completing tasks must also receive the
requisite authority to carry out those tasks, whether it be in requisitioning supplies or identifying the
need for additional personnel. Similarly, employees must be held accountable for their
environmental performance. Employee acceptance of accountability is improved when input is
solicited. Encouraging employees to identify barriers to effective performance and to offer
suggestions for improvement provides a feeling of teamwork and a sense that they control their own
destiny, rather than having it imposed from above.
Appropriate steps in addressing responsibility issues could include:
! Assign specific individuals who are senior management or above at the agency the authority to
ensure compliance with established environmental standards and procedures;
! Issue clear statements defining
responsibilities for personnel and groups
REWARDS...
"Four of 17 [Civilian Federal Agencies] reported
the use of award programs to recognize employee
environmental achievements. Expanding the use of
these programs is needed, and may be a relatively
easy way for CFAs to begin to improve their
performance..."
EPA EMS Benchmark Report, December 1994
within the agency that are directly
involved in the environmental program
(these statements should tie into the
agency's mission and vision statements
that stress the importance of
environmentally responsible operation);
! Issue, as necessary, statements defining
the authority for carrying out assigned
responsibilities;
! Prepare a process for addressing
conflicting spheres of authority;
! Develop a policy detailing the agency's
approach to accountability;
! Develop a program to solicit employee
input and address concerns.
4.2 PERFORMANCE STANDARDS
The agency ensures that employee performance standards, efficiency ratings, or other accountability
measures, are clearly defined to include environmental issues as appropriate, and that exceptional
performance is recognized and rewarded.
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A major barrier to efficient operation is a lack of specificity regarding employee expectations.
Therefore, performance criteria relating to environmental practices should be specifically
incorporated into employee evaluations, and employees should be rewarded for satisfying or
exceeding those criteria. Performance incentives give people the feeling that their contributions are
important. Employees who feel valued pay more attention to their work and perform at a higher
level. As noted above, providing employees with avenues for constructive input, and the expectation
that they will provide such input, spreads an attitude of ownership. In addition, the agency's written
policies defining standards and procedures to be followed by its employees must be consistently
enforced through appropriate disciplinary
mechanisms.
....AND PITFALLS...
...to be avoided in developing performance
incentives or awards. Some management experts
believe that incentives simply cannot work in any
meaningful way. How can this be true? Some
objections are that incentives:
! do not motivate beyond short-term
compliance;
don't differ from punitive management;
can harm relationships;
don't address root causes;
impede management's ability to manage;
discourage creativity;
undermine intrinsic motivation.
Agencies developing incentive or awards programs
need to give careful thought to the outcomes they
want to encourage, not just behaviors.
Organizations that identify specific
environmental performance measures (where
appropriate), evaluate employee performance
against those measures, take appropriate
disciplinary action when agency procedures are
violated, and publicly recognize and reward
employees for excellent environmental
performance through a formal program
demonstrate conformance with this principle.
Appropriate steps in developing performance
evaluations could include:
I
Identify appropriate organizational
performance goals;
Develop standards upon which employee
evaluations will be based;
Publicize and solicit input from the agency;
Develop procedures for evaluating
performance;
Prepare a program to reward or recognize
honorees;
Prepare disciplinary mechanisms to be
utilized when agency policy and procedures
are not followed.
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CHAPTER 7: MEASUREMENT AND IMPROVEMENT (PRINCIPLE 5)
The agency develops and implements a program to assess progress toward meeting its
environmental goals and uses the results to improve environmental performance.
The fifth Principle addresses the "feedback" aspect that is critical to any system and the importance of
collecting internal and external information on system performance. When the agency can judge how
well the system is working, it can also identify steps to improve the system. The measurement-
improvement cycle is continuous for the life of the system.
PERFORMANCE OBJECTIVES:
5.1 EVALUATE PERFORMANCE
The agency develops a program to assess environmental performance and analyze information
resulting from those evaluations to identify areas in which performance is or is likely to become
substandard.
Measurement of performance is necessary to understand how well the organization is meeting its
stated goals. Businesses often measure their performance by such indicators as net profit, sales
volume, or production. Two approaches to performance measurement are discussed below.
5.1.1 Gather and Analyze Data
The agency institutes a systematic program to periodically obtain information on environmental
operations and evaluate environmental performance against legal requirements and stated
objectives, and develops procedures to process the resulting information.
Managers should be expected to provide much of the necessary information on performance
through routine activity reports that
include environmental issues.
MEASURING PERFORMANCE
When choosing performance indicators, think
about whether they:
Address key organizational goals;
Can show performance trends;
Provide directly usable information;
Are controlled by the group being measured;
Show the way to improve performance.
Performance of organizations and
individuals in comparison to accepted
standards can also be accomplished
through periodic environmental audits
or other assessment activities.
Assessments can be performed by
members of the organization or by an
outside group brought in for the specific
purpose of evaluating the organization.
In order to be fully effective,
measurable performance indicators
(activities to be performed or results to
be achieved) against which the
organization's performance can be
compared must be identified. However, assessments that concentrate solely on numerical
"accounting" issues will tell only part of the story and may miss vital information. Assessments
will need to evaluate the effectiveness of the overall management system, even if this aspect is
not directly quantifiable. Various audit protocols have been developed by Federal agencies and
private concerns. EPA is in the process of revising its Generic Protocols for Conducting
Environmental Audits at Federal Facilities, which incorporates information from other agencies.
The operation of a fully-functioning system of regular evaluation of environmental performance along
with standard procedures to analyze and use information gathered during evaluations signal an
organization's conformance with this principle.
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COMPLIANCE VS. CONFORMANCE
Agencies should be aware that their EMS, as well
as their performance, needs to be evaluated. While
they will continue to audit their environmental
activities for compliance with regulations, the EMS
must be audited for conformance with the system
as designed. That is, how well does the system
match with the agency's plan (e.g., in terms of
training, documentation, policy development)?
Whether an EMS Standard like ISO 14001, or an
EMS of the agency's own design, this is a crucial
step in maintaining and improving a fully-
functional EMS.
Appropriate steps to address performance
measurement could include:
I
Develop procedures to convey system measurements
Develop, collect data, and report on
measurable performance indicators for each
organizational activity;
Develop an internal environmental audit
program;
Identify an independent outside (third party)
environmental audit group;
Define the scope, type, and frequency of
assessments;
Develop quality assurance objectives,
including appropriate levels of review;
Develop procedures for management and use
of information obtained from routine reports
and during audits, including analysis of
results, reporting, trend analysis, and root-
cause analysis;
into the review and improvement process.
GOVERNMENT PERFORMANCE AND RESULTS ACT OF 1993 (GPRA)
GPRA requires Federal agencies to provide information on their goals and how well they achieve them.
Agencies will have to:
! develop strategic plans prior to fiscal year 1998 that describe goals and objectives, plans to meet them,
necessary resources, and key external factors;
! develop annual plans describing fiscal year performance goals beginning in FY 1999;
! prepare annual reports comparing performance to goals beginning in March 2000.
Agencies can use the GPRA planning framework to include environmental goals and identify how they
will be met and the resources that will be needed.
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5.1.2 Institute Benchmarking
The agency institutes a formal program to compare its environmental operations with other
organizations and management standards, where appropriate.
"Benchmarking" is a term often used for the comparison of one organization against others,
particularly those that are considered to be operating at the highest level. The purpose of
Benchmarking is
twofold: first, the
organization is
able to see how it
compares with
those whose
performance it
wishes to
emulate; second,
it allows the
organization to
benefit from the
experience of the
peak-performers,
whether it be in
process or
managerial
practices. The
higher-
performing
organization also
benefits by
passing along
innovations or
efficiencies,
which will
enhance its
reputation among
its peers. It may
also obtain more tangible benefits, such as innovative technological approaches. Benchmarking
also serves an overall good by fostering a spirit of cooperation, rather than competition and
secrecy. The Malcolm Baldrige National Quality Award, for example, requires its winners to
share their strategies with other
organizations seeking improvements.
FEDERAL AGENCY BENCHMARK REPORT
EPA surveyed 17 civilian federal agencies (CFA), 4 defense related agencies (DRA),
and 3 corporations (Chevron, Xerox, and 3M) to evaluate their approaches to six
Benchmark Elements:
Organizational Structure;
Management Commitment;
Implementation;
Information Collection/Management/Follow-up;
Internal and External Communication;
Personnel.
EPA selected a total of 31 Key Indicators as representative of the six Elements. While
50 percent or more of the DRAs responded positively to all Key Indicators, CFAs did
so for fewer than half the Indicators. Rarely did more than 10 of the 17 CFAs respond
positively to an Indicator. Corporate responses fell much closer to the DRAs.
Source: "Environmental Management System Benchmark Report: A Review of
Federal Agencies and Selected Private Corporations," EPA-300R-94-009, December
1994
Benchmarking offers an attractive path to
improvement of performance through
adoption of practices already proven to
be effective. However, reliance on such
comparisons can be more harmful than
beneficial in certain circumstances. Too
often, organizations fail to focus their
efforts appropriately and attempt to adopt
practices that simply do not fit. The
practice of Benchmarking, rather than the
improper approach to it, is then blamed
for the poor result and abandoned.
BENCHMARKING TIPS
1. Tie efforts to strategic objectives;
2. Keep teams of manageable size (e.g., 6 to 8);
3. Involve those most affected;
4. Avoid focusing on overly broad issues;
5. Set realistic timetables;
6. Pick benchmarking partners carefully;
7. Follow benchmarking protocol;
8. Focus the data collection process;
9. Focus on process, not on numbers;
10. Identify future recipient of information.
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During 1993-94, EPA surveyed 21federal agencies and three private corporations to determine
whether they display behavior indicative of "best in class" environmental management systems.
The elements used for the "best in class" benchmark were taken from a number of sources,
including management standards. Benchmarking against established management standards,
such as the ISO 14000 series or the Responsible Care program developed by the Chemical
Manufacturers Association (CMA), may be useful for those agencies with more mature
environmental programs, particularly if the agencies' activities are such that their counterparts in
the private sector would be difficult to find. However, it should be understood that the greater
benefit is likely to result from direct comparison to an organization that is a recognized
environmental leader in its field.
Appropriate steps to address benchmarking could include:
Evaluate the agency to identify areas in which benchmarking would be most beneficial;
Begin to develop and implement a program of comparison with other organizations;
Develop methods to apply results of inter-organizational comparisons and further encourage
comparison with other organizations and networking through professional organizations and
conferences;
! Explore the possibility of mentoring another public or private organization.
5.2 CONTINUOUS IMPROVEMENT
The agency implements an approach toward continuous environmental improvement that includes
preventive and corrective actions as well as searching out new opportunities for programmatic
improvements.
Continuous improvement is approached through the use of performance measurement to determine
which organizational aspects need to have more attention or resources focused upon them.
Environmental excellence should be viewed as a journey, not a destination. There are always
constructive steps to be taken. The
development of organizational goals should
incorporate the principle of continuous
MANAGEMENT REVIEW
An EMS needs periodic management review. This
is different from the conformance review discussed
earlier. Management needs to evaluate the EMS to
see if it needs to be changed to meet an
organization's evolving goals and needs. Of
course, the implemented EMS will have to be
evaluated to see if it conforms to the revised EMS
plan.
improvement. The institution of a program
to solicit and respond to employee
suggestions is an important step in
generating confidence in the organization's
commitment to improvement. Public and
private organizations that are generally
considered by their peers and the public to
be performing at the highest levels can
provide incentive and insight toward
implementation of improvement measures.
Continuous improvement may be
demonstrated through the implementation
of lessons learned and employee
involvement programs that provide the opportunity to learn from past performance and incorporate
constructive suggestions. In addition, the agency actively seeks comparison with and guidance from
other organizations considered to be performing at the highest level.
Appropriate steps to address continuous improvement could include:
! Develop procedures to address the root cause of current deficiencies and prevent future
deficiencies;
! Develop a "lessons learned" program to educate personnel;
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! Develop and implement a program of comparison with other organizations;
! Develop a program to apply results of inter-organizational comparisons and continue to conduct
comparisons and/or develop partnerships with other organizations, particularly those considered
"best in class";
! Encourage suggestions for improvement from all personnel;
! Conduct periodic review of operating procedures;
! Review contemporary management philosophies to identify viable approaches;
! Provide a mechanism to incorporate identified improvements into the next planning cycle;
! Periodically review and report on improvements.
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CHAPTER 8: CEMP SELF-ASSESSMENT MATRIX
The CEMP Self-Assessment Matrix is a tool to help agencies evaluate their progress in implementing the
CEMP and map their next steps. The Matrix was designed to support the gradual development of an
environmental program that addresses the CEMP principles, and to relate the suggested actions presented
in previous chapters to the stage in the program's evolution when they are most likely to be implemented.
The Matrix is also intended to support several points that are key to development of an environmental
management system, including:
! there is a logical (but not strictly structured) progression of activities in the growth of a program;
! advancing to the next "higher" level builds upon the foundation of more fundamental activities at
"lower" levels;
! integration of the system by addressing all of the principles, and maintaining that integration
throughout the life of the program, is fundamental to its success;
! even after reaching the "highest" level, continual review and improvement is necessary to
maintain that level of performance.
It will be helpful for agencies to keep in mind that they may already have a foundation of system
elements that they can build upon. The results of an agency's "gap analysis" can provide a starting point
for implementation of each principle.
How the CEMP Matrix Works
The CEMP Matrix is laid out to show the implementation of each principle over five levels of
development. There is nothing magical about the use of five levels. The number was chosen as an
intermediate point that communicates the idea of progression without overwhelming the user. Although
the levels are numbered, no "scoring" scheme is implied, although agencies are free to develop such
schemes if they believe it would benefit them. Similar approaches that are intended to be used as
scoresheets have been developed by other organizations. For example, the Council of Great Lakes
Industries (CGLI) has developed a matrix that is intended to take an organization through a "roadmap" to
implement Total Quality Environmental Management. The CGLI uses the seven Malcolm Baldrige
Award criteria as its categories, and ranks progress over ten levels. Like the Baldrige award itself, the
seven categories are weighted to indicate their relative importance.
The Global Environmental Management Initiative has developed two slightly different approaches to
environmental self-assessment. The first is based on the 16 principles found in the International
Chamber of Commerce (ICC) Business Charter for Sustainable Development, which are generally
applicable to any organization. Using this "Environmental Self-Assessment Program," organizations rate
their performance for 71 "elements" identified under the 16 principles on a scale of 1 through 4 (or Not
Applicable), with 1 corresponding to simple regulatory compliance. Each element is also assigned a
weighting factor, which represents its relative importance to the scoring organization (unlike the CGLI
matrix, where a category has the same weighting factor for all organizations).
The second GEMI approach is for organizations that want to measure their environmental management
systems against the ISO 14001 EMS Standard. The "ISO 14001 Self-Assessment Checklist" covers a
total of 31 questions under the five ISO 14001 EMS elements. By scoring each on a scale of 0 through 2,
an organization should get an idea of how well its EMS conforms to the ISO 14001 Standard. The
Checklist can be used to support a gap analysis or as an indicator that ISO conformance has been
achieved. This exercise would be especially useful for companies that may need to explore ISO
Code of Environmental Management Principles 40 Implementation Guide
-------
certification (and third-party certification) for business purposes, although Federal agencies may also
benefit from comparison to a recognized international standard. Agencies will also recognize that the
questions in the Checklist can help them implement the CEMP.
For the CEMP Matrix, each block gives an indication of what the agency will have accomplished under a
particular principle. Some of these are more concrete than others, while some may be more subjective
and will require interpretation by the agency. For example, Level 3 under "Policy Development" states
that the agency "develops draft policy and circulates it for review and comment," which is fairly
straightforward. Level 3 under "Environmental Stewardship" states that the agency "identifies
alternatives to high-impact activities," which will
require agencies to determine which activities are
high-impact and develop criteria for identifying
alternatives.
The Matrix is offered as a potentially useful tool
that gives one approach to implementing the
principles, not as a rigid "one size fits all"
blueprint. Agencies are encouraged to adapt the
Matrix to their own programs, and to make
whatever modifications they deem advisable.
ICC CHARTER
The International Chamber of Commerce Business
Charter for Sustainable Development Principles for
Environmental Management cover the following
areas:
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
Corporate Priority
Integrated Management
Process of Improvement
Employee Education
Prior Assessment
Products and Services
Customer Advice
Facilities and Operations
Research
Precautionary Approach
Contractors and Suppliers
Emergency Preparedness
Transfer of Technology
Contributing to the Common Effort
Openness to Concerns
Compliance and Reporting
Moving From Level to Level
Previous chapters have presented possible steps
that could be taken by agencies implementing the
CEMP. To enhance the usefulness of the Matrix,
the steps are repeated here and related to the
Matrix level (1 through 5) at which they might be
most appropriate. Again, the Matrix is intended
as a guide and therefore these actions are not
required, nor is it required that they be performed
in any particular order. Not all levels have
actions associated with them, and many of the
activities will be continuing or ongoing through
the upper levels of the Matrix, rather than
performed on a one time only basis. However, it
will be beneficial to agencies to understand that
some activities are very basic "first steps," while
others are likely to require significant
groundwork in terms of program maturity if they are to be properly conducted. Some agencies may find
that they are in a position to conduct some "higher-level" activities before other "lower-level" activities
can be completed, or can skip some activities altogether. The important thing is for agencies to
understand their own circumstances and tailor their activities appropriately.
Similarly, it is not necessary for agencies to complete the same level for all principles before moving to
the next level. In fact, this would be counterproductive. An agency may well find that it has reached
Level 4 for one principle before Level 1 is completed for another. It is, however, important that the
various parts of the program maintain communication with each other, as is illustrated by the number of
candidate actions that cover similar ground. For example, several of the principles can be partially
fulfilled by implementing a system to obtain employee feedback. Even though this activity cross-cuts
the principles, it does not necessarily appear at the same Matrix level for each.
Finally, the Matrix does not represent a mythical state of perfection that will be impossible for agencies
to attain. Rather, it should be thought of as a means by which agencies can gauge their progress in
implementing the CEMP and, more broadly, in improving their approaches to environmental
Code of Environmental Management Principles
41
Implementation Guide
-------
management by incorporating those elements considered "state of the art." Improvements in
management should be reflected by improvements in the efficiency, cost-effectiveness, and performance
of environmental programs.
Code of Environmental Management Principles 42 Implementation Guide
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 1: MANAGEMENT COMMITMENT
LEVEL
1.1 OBTAIN MANAGEMENT SUPPORT
Policy Development
System Integration
1.2
ENVIRONMENTAL
STEWARDSHIP
FINISH
fl
5
Agency communicates its policy
externally, to regulatory
authorities, other agencies, and
other stakeholders
Agency decisions consider
environmental criteria when
appropriate; program thoroughly
integrated
! Assume leadership through
outreach
All agency decisions include
appropriate environmental criteria
to minimize impact
! Consider environmental impacts
! Participate in hearings and other
activities
Agency develops final policy and
communicates it internally
Over 50% of agency decisions
consider environmental criteria;
program integrated through 75% of
agency
! Encourage teaming across
divisions
Agency develops procedures to
evaluate environmental impacts of
future activities
! Introduce LCA and design for
environment concepts
! Provide outside speakers
! Sponsor outside activities
! "Open House" for community
! Demonstrate commitment
Agency develops draft policy
and circulates it for review and
comment
Environmental criteria are
incorporated into employee
performance standards as
appropriate; program integrated
through 50% of agency; criteria for
environmental decision-making
developed
! Review responsibilities
Agency identifies alternatives to
high-impact activities
! Encourage environmental action
plans
! Provide "brown bag" speakers
! Create promotional items
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 2: COMPLIANCE ASSURANCE AND POLLUTION PREVENTION
LEVEL
2.1
COMPLIANCE
ASSURANCE
2.2
EMERGENCY
PREPAREDNESS
2.3
POLLUTION PREVENTION
AND
RESOURCE
CONSERVATION
FINISH
It
5
Full agency compliance is
sustainable; contractors are
included within the compliance
program
! Set "beyond compliance"
performance goals
! Evaluate contractor
performance
! Introduce risk assessment
All agency personnel are trained in
emergency response procedures; full-
scale exercieses are conducted at least
annually
Program maintained throughout the
agency; significant reductions in
waste generation achieved
It
4
Agency develops proactive and
cooperative relations with
regulators; non-compliance
situations reduced significantly
! Employee reporting
encouraged
! Regular contact with
regulators
! Procedures to elevate issues to
upper management
! Pollution prevention is
primary management
approach
Agency implements medical
monitoring for environmental
program personnel as appropriate
and inspects facilities periodically
! In-house medical monitoring,
where appropriate
Agency encourages reduced use of
resources and identifies indificuals
contributing to the success of the
program; process improvements
implemented
! Affirmative procurement
program
! Life-cycle analysis performed
! Design for environment
! Product stewardship
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 3: ENABLING SYSTEMS
LEVEL
3.1
TRAINING
3.2
STRUCTURAL SUPPORTS
3.3
INFORMATION
MANAGEMENT,
COMMUNICATION,
DOCUMENTATION
FINISH
It
5
100% of agency fully trained,
refresher training provided,
computer-based and distance
learning employed when
appropriate; training program
continually evaluated
! Obtain feedback on training
! Investigate alternative
training methods
Procedures are fully implemented
and reviewed periodically
! Conduct periodic review of
procedures to ensure currency
Agency maintains effective
communications, applies
environmental information to
decision-making, and maintains
thorough records
! Use EMS data in decision-making
75% of agency fully trained;
refresher training developed and
available, where appropriate;
continuing education
encouraged
! Establish refresher training
! Encourage continuing
education
Agency implements procedures and
begins training of all staff, as
appropriate
! Pursue integration of
environmental program
throughout agency
Agency develops procedures for use
of information, provides avenues for
employee input, and has a well-
maintained records center
Use electronic networks
Assure validity of envtl. data
Secure data-handling procedures
Employee reporting system
Encourage employee input
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 4: PERFORMANCE AND ACCOUNTABILITY
LEVEL
4.1
RESPONSIBILITY, AUTHORITY AND
ACCOUNTABILITY
4.2
EMPLOYEE PERFORMANCE
STANDARDS
FINISH
It
5
Assignment of environmental responsibilities is
reviewed periodically in light of performance
Agency develops a program to recognize and reward
personnel that carry out environmental
responsibilities exceptionally well; appropriate
disciplinary mechanisms also in place
! Prepare program to reward or recognize honorees
! Prepare disciplinary mechanisms to address non-
conformance with agency policy or procedures
It
4
Personnel are provided avenues to provide input
and employees are held accountable for
environmental performance
! Develop employee input/concerns program
Personnel are evaluated based on environmental
aspects of their performance standards
! Develop procedures for evaluating performance
It
3
All employees assigned environmental
responsibilities are given appropriate authority
and training
! Issue clear statements of environmental
responsibility
! Prepare process to address authority conflict
! Develop policy on accountability
Affected employees have environmental
responsibilities clearly stated in performance
standards
It
2
Managers assigned environmental responsibilities
are given training and authority to meet those
responsibilities
! Issue statements defining authority
Managers have environmental responsibilities clearly
stated in performance standards
! Develop employee evaluation standards
! Publicize standards and solicit input from agency
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 5: MEASUREMENT AND IMPROVEMENT
LEVEL
5.1 EVALUATE PERFORMANCE
Gather/Analyze Data
Institute Benchmarking
5.2
CONTINUOUS
IMPROVEMENT
FINISH
It
5
Data-gathering is a continuous
process; gaps in performance
are identified and analyses
conducted to identify their root
cause(s)
Agency maintains ongoing
"benchmarking cycles"; agency
becomes a target for benchmarking
by others
! Explore possibility of mentoring
other organizations
Agency shows significant
improvement in addressing
substandard performance situations
and aggressively seeks to compare its
performance to others
! Review other management
approaches for applicability
Periodic evaluations of
operations and data-gathering
procedures are conducted to
assess performance
! Include system measurement
in review and improvement
process
Agency identifies and implements
improvements based on evaluation of
other organization
! Develop methods to apply results
of benchmarking and pursue
further involvement
Agency fully implements periodic
reviews of systems and performance
and seeks out additional
opportunities for improvement
! Develop methods to apply results
of benchmarking and pursue
further involvement
! Conduct review of procedures
! Review and report improvements
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 5: MEASUREMENT AND IMPROVEMENT
Data-gathering and processing
procedures are implemented
throughout the agency
! Identify independent audit
group
! Develop procedures to
manage and use information
from audits
Agency evaluates performance of
target organization through sharing
of information (e.g., site visit) for
comparison with its own
Agency implements employee-
involvement measures, such as
newsletters and lessons learned, to
solicit input on improving
performance
! Develop lessons learned program
! Encourage employee suggestions
! Work to include improvements in
next planning cycle
Agency develops procedures for
gathering appropriate data and
communicates them to
management
! Define assessment parameters
! Develop QA objectives
Agency identifies other organizations
with similar activities and/or
exceptional performance and initiates
contact with them
! Develop program of comparison
to other organizations
Agency develops procedures to
address preventive and corrective
action situations and communicates
them to management
! Develop procedures to identify
root causes
! Develop program of comparison
to other organizations
START
Agency identifies performance
indicators, data needs, and
standards of comparison
! Develop and report on
performance indicators
! Develop internal audit
program
Agency evaluates its activities and
sets goals for environmental
performance
! Evaluate most useful
benchmarking areas
Agency evaluates performance to
identify areas needing improvement
Notes:
-------
It
START
Agency identifies personnel with responsibility for
environmental performance
! Assign authority to ensure environmental
compliance
Agency identifies personnel with responsibility for
environmental performance
! Identify organizational performance goals
Notes:
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 3: ENABLING SYSTEMS
50% of agency fully trained;
system to track fulfillment of
training requirements developed
and implemented
! Establish in-house group to
track training program
Agency disseminates procedures
throughout to raise awareness of
issues; implementing staff is trained
! Encourage input from personnel
Agency communicates with
regulators and stakeholders and
develops information gathering,
manipulation, and management
procedures
Evaluate new IM projects
Assign POC for new projects
Establish Resource Center
Provide regular status updates
Communicate with other orgs.
Develop public outreach
program
Communicate with stakeholders
Develop distribution network
QA and security procedures
Agency training group identifies
available outside training and
develops in-house training where
necessary; 20% of agency fully
trained
! Identify job-specific
requirements
! Evaluate outside vs. in-house
training
! Train the trainers as
necessary
Agency develops or revises
procedures to address activities
identified as having environmental
aspects
! Eliminate or revise procedures
found to be barriers
Agency develops internal
communications and information
management infrastructure, and
document control procedures
! Ensure compatibility
! Develop envtl. IM procedures
! Identify key records/documents
! Develop in-house communication
! Enable working relationships
! Report completion procedures
! Maintain MSDS, etc.
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 3: ENABLING SYSTEMS
START
Agency training group identifies
environmental training needs
and where training is available
! Develop "Core Curriculum"
Agency identifies and evaluates
existing procedures and activities
that have environmental aspects
! Review agency documentation
Agency identifies lines of
communication, information needs,
documentation procedures
Assign managerial responsibility
Create in-house IM group
Review current capabilities
Define lines of communication
Assign environmental POCs
Develop centralized filing system
Notes:
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 2: COMPLIANCE ASSURANCE AND POLLUTION PREVENTION
It
3
Agency fully implements
compliance program, develops a
program to track relevant
legislation and regulations, and
sees improved performance
! Track regulatory initiatives
! Address non-compliance
conditions
! Track corrective action
progress
! Environmental recordkeeping
system
! Identify problems and
prevent non-compliance
incidents
! Establish compliance
management system that is
integrated with EMS
Agency emergency response teams
are trained and periodic drills are
conducted
! Emergency Response Team
! Training for Emergency
Response Team and other
personnel
! Conduct regular exercises
! Identify emergency resources
Agency develops goals, implements
employee suggestion procedures, and
identifies alternatives to major
generators
1 Toxic materials reductions
! Water conservation program
! "Repair or Replace" program
It
2
Agency communicates with
regulatory authorities, develops
procedures to address compliance
situations, and distributes them
throughout the agency
! Introduce compliance group
! Develop compliance guidance
! Coordinate with regulators
! Communicate information on
regulations and permits
Agency develops procedures to
address emergency response,
distributes them throughout the
agency
Develop response procedures
Disaster preparedness plan
Hazard mitigation measures
Preventive maintenance program
Coordinate with authorities
Develop communication plan
Agency communicates pollution
prevention commitment to all
personnel and begins recycling
programs (paper, aluminum, glass)
! Energy conservation program
! Recycling program in place
! Encourage reuse of materials
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 2: COMPLIANCE ASSURANCE AND POLLUTION PREVENTION
It
START
Agency compliance group
evaluates agency's activities and
compliance history
! Develop compliance group
! Review agency activities
! Assess compliance baseline
Agency emergency response group
evaluates its activities and
vulnerability to natural disaster and
accidents
! Identify hazards from agency
activities and facilities
Agency evaluates its waste
generation profile and identifies
major points of generation
! Pollution prevention program that
emphasizes source reduction
Notes:
-------
CEMP SELF-ASSESSMENT MATRIX
PRINCIPLE 1: MANAGEMENT COMMITMENT
Agency evaluates environmental
concerns of key stakeholders
! Develop goals and priorities
! Communicate with
stakeholders
Environmental criteria are
incorporated into affected
managerial performance standards;
program integrated through 25% of
agency, starting with activities most
affected
! Conduct organizational review
! Assign management
responsibilities
! Include performance criteria
! Coordinate and review budget
Agency implements awareness
programs to inform employees and
stakeholders
! Provide orientation
Agency evaluates its mission in
environmental terms
! Prepare Mission/Vision
statements
START
Environmental program is
communicated throughout agency;
environmental groups established
and their missions defined and
communicated
! Identify liabilities and risks
! Provide awareness training
Agency evaluates environmental
impacts of its activities
Notes:
-------
Appendix 1: Agency Responses
Central Intelligence Agency (CIA)
Department of Agriculture (USDA)
Department of Commerce (DoC)
Department of Energy (DoE)
Department of Interior (Dol)
Department of Justice (Do J)
Department of Transportation (DoTransp.)
Department of Treasury (DoTreas.)
Environmental Protection Agency (EPA)
General Services Administration (GSA)
Health and Human Services (HHS)
National Aeronautics and Space Administration (NASA)
Postal Service
Tennessee Valley Authority (TVA)
US Department of Defense
Veterans Administration (VA)
-------
Central laUffigsnce Agency
" " "7 -
9 October 1996
Mr. Steven A. Herman
Assistant Administrator
Environmental Protection Agency
Washington, D,C. 20450
Bear Mr. Herman:
In response to your letter dated, 3 September 1996, the Central
Intelligence Agency (CIA) is pleased to demonstrate its participation with the
federal government Code of Environmental Management Principles (CEMP). The
following is a brief description of the comprehensive CIA program and the
implementation of the CEMP fundamental elements.
1, Hi|i§gcijant _6>iBttitaient; in FY92, the Executive Director,
in coordination with the Deputy Director for Administration (DDA),
established a formal environmental program to gain compliance with
environmental regulations and initiate remediation of potential
cleanup sites. Funding for the multi-year program was identified
by the Comptroller commencing with the FY94 budget,
Administration of the program was assigned to the newly fortaed
Environmental Safety Group {ESG) within the Office of Medical
Services, Directorate of Administration. BSG is responsible for
centralized program management which includes planning, funding,
staffing, and. program oversight. Individual Agency field sites
are-staffed with an Environmental Specialist on assignment from
ESG. These Environmental Safety Officers (ESOs) are responsible
for implementation of the program and remediation of identified
deficiencies. Concurrently, the Agency established an
environmental compliance regulation requiring all components and
personnel to comply with environmental laws and regulations,
executive orders, and internal Agency requirements. The DDA, who
serves as the Agency Environmental Executive, issued a policy
statement which makes individual Agency components accountable for
any fines or penalties issued by federal or state regulators. In
March 1995, the DDA also issued an Agency Notice establishing the
CIA Pollution Prevention Policy and Goals. These goals are a
fifty percent reduction in the use of toxic chemicals and a
reduction in the use of extremely hazardous substances.
2. Compliance Assurance and Pollution Prevention: The CIA
has established a proactive program at all Agency sites to assure
compliance with environmental laws and regulations. This consists
of annual compliance inspections of all Agency sites by ESG
-------
Mr. Steven A. Herman
environmental specialists. In addition, compliance audits have
been performed at some Agency sites by environmental consultants,
U.S. Array and U.S. Navy environmental audit teams, and other
governmental agencies such as the national Security Agency. SSG
specialists provide expert consultation and assistance to field
sites to address specific issues or to provide surge support
during periods of increased workload.
The CIA has also implemented a proactive pollution
prevention program. As previously stated, the goal of this
program is to achieve a fifty percent reduction in the use of
toxic chemicals and to reduea the use of extremely hazardous
substances. To date, the pollution prevention program reduced the
Agency's inventory of toxic chemicals by thirty-eight percent and
is well on the way to attaining the fifty percent five-year goal.
Source reduction is the primary strategy in this effort with
recycling as a secondary approach. Each site has submitted a
pollution prevention plan which describes the methods by which
they will meet the corporate pollution prevention goals. An
officer in ESG has been designated as the Pollution Prevention
Program Manager. This individual visits each of our field sites
annually to provide assistance and guidance to site managers on
the program. Progress on this effort is tracked annually to
ensure that the December 1999 target date will be met.
3 • Enabling Peraopn^l: ESG provides funding for
environmental compliance training for program specialists, site
managers, and selected component personnel. A number of ESG
specialists are pursuing advanced degrees in Environmental
Engineering, Environmental Management, and Environmental Science
to further their expertise in these fields. Senior managers are
briefed on the progress of the program on a regular basis. A
Lotus Notes based electronic bulletin board database provides a
means to disseminate regulatory updates to field personnel,
functions as an inquiry and response forum, and serves as a
general discussion media for promoting environmental issues and
policies.
*• Performance and Accountability= All major Agency field
sites are staffed with a full time ESO who implements the
environmental program under the direction of the site manager.
The ESO is responsible for coordinating the environmental program
among the various tenants located at the site. Performance
evaluations for the ESO are prepared annually by the site manager
and forwarded to the Agency environmental program office for
review. The site manager and the chief of the environmental
program office are mutually accountable for the performance of the
-------
Mr. Steven A, Herman
ESO and the site program. However, as previously stated, the site
manager or offending component is held accountable for any fines
or penalties assessed against the site from an inspection by state
or federal regulators ,
5. Measurement and Improvement: Programmatic appraisals
are conducted annually by ESG to assess the status of the figency
environmental program. In addition, the Agency Inspector General
conducts periodic reviews of the program to ensure programmatic
compliance with environmental laws and regulations. Any
deficiencies that are identified fay these inspections are targeted
Eo*«orrectio3. Deficiencies requiring an outlay of resources are
centrally funded by ESG on a basis of priority. Annual
environmental conferences are held to assemble the field ESOs to
review the status of site programs as well as the Agency program.
Progress on pollution prevention, affirmative procurement, waste
reduction, and recycling goals are reviewed and discussed.
Additional pollution prevention opportunities are identified and
targeted,
Should you require any additional information on the CIA's
implementation of the CEMP, please contact Mr. Randy Hyde, Pollution
Prevention Program Manager on (703)482-6081.
Sincerely,
Lawrence j. MeGinty
Chief, Environmental Safety Group
-------
UNITED STATES DEPARTMENT OF COMMERCE
Office of die Secretary
Washington, D.C. 20230
Mr. Steven A. Herman
Assistant Administrator
Office of Enforcement and
Compliance Assurance
Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Herman:
In response to your letter dated September j, j.sy5, rhe U.S.
Department of Commerce is pleased to express its support for the
Code of Environmental Management Principles (CEMP) for Federal
Agencies. The Department is committed to improving its
environmental performance by developing and enhancing policies
and programs for pollution prevention and compliance with the
best environmental practices.
The Department has in place an effective policy and statement of
responsibilities for environmental compliance and has developed a
network of key environmental managers at the operating unit
level. These officials and their staff ensure that facilities
that store hazardous materials continue to make progress in
developing and implementing effective pollution prevention plans.
We look forward to continuing our work with the Environmental
Protection Agency (EPA) and the Interagency Pollution Prevention
Task Force (IPPTF) in our efforts to ensure that the CSMP is
fully realized in the Department of Commerce and throughout the
Federal government.
Sincerely,
Jeffrey Hunker
Deputy Assistant Secretary
-------
Department of Energy
Washington, DC 20S5
Hr. Steven A. Htnsan
Assistant 4tarinfstrat0r
Office of EnforcaBBit and CaopiiaTice Assurancs
U.S. Ehviyeiaenta.1 Protection Agency
401 H Street, S.lf.
Washington, D.C- 20460
fear Hr, Haman;
Tfcmk yoa for your letter of Septe-afcer 3, 1SS5, requesting U»
DeparfHsnt's support for the Codfe of Envi rorajental Hanagsient
Principles (CBIP). Protecting trai restoring the environment is a
central aissioR for the Stejrarunent of Eneir^ (DOE). Ihe five
lis of this Drie are consistent wtifc our caotimilM effons to
the quality, cast -effectiveness, and jutBgratioR 5f mr
operatiD«s- He therefore endorse the GEHP or, an
IipTementins the CEKP across ME will require a range of strategies
EJE op«ratE£ HIIBKF«IS faci titles that vsry widely in teras of
Mission, size, and snviroiwanta I omditiwi. For this reason no
single soliitioir can be affect! *E in insilaaefrting the !£K?
Dej«rti«!ot.»ide. We plan to incorporate. principles of the CEMP into
tht inplanfeititiou of an Migrated Safety Wanagtswtt Systeis it DOE
facilities. This approach to int^minf tht prrtectian of workErs
the public, sod tht eflyironBient has teen developed in response to t
recamewlation by ttie Qeftnse Saclear Facilities Safety ^rd and is
in the first phast ef ijsplaKntation. Hi «ie near tera, ve plan to
provide gaidsncte to oar sites for preparation of their ueditsl
pollution prevention plans; WB will attac± the CEMP and aicoarioB its
ttse in all site wvinMinental BSBtgeaent olannlni. The elements of
the CEMP are also feein§ incorporated into eoapreheisiirB plsns which
the Department is currently diveToptni to guide land irtd facility use
decisions. These decisions will be based on the principles of
ecosysiea nanagement and sustainable
Iifiplefflentiiar the C£MP via the Integrated Safety Hanageaent S
coaprehensive plans, and pollution prevention plans fs also
coesiste&t with use of the ISO 14601 Standard, frvimimxteJ
HmaseKfrt. Systea Specfffcttfeu. Several sites are ctrrHitly nsing
o? adopting envlroRsratal aanaieaant systoas consistent irttfl the IS)
Standaro;. This approach is 0sir,s voluntarily iiplaERted at stveral
sites, is crater consideration at others, an<3 was included as a
-------
performance incentive In the recent iatrfort contract. We look
forward to netting tht challenge of imleaantina the Code af
Environroenta} Kanageosnv Principles is an iaprtant requiremait of
Executive onier 1Z85S.
'Richard 0. Gtlimand
Assistant Surgeon teeral, USPHS
Principal Oaputy Assistant Secretary
for Environsentjl Management
Environmertil Executive
-------
United States Department of the Interior
OFFICE OF THE SECRETARY
Washington, D.C. 20240
Mr. Jin, Edward SIP 3 G
Director
FPEO Planning, Prevention and Compliance
?Q?"« E^irofent^ Protection Agency
401 M Street, S.W. {2261A}
Washington^ D.C. 20460
Dear Mr,
££5 f ^^ 3' 1996' «*
PEP hss established M Inm^S J"f?a°S and offi=«»-
, ss established M nm -
manager for the Fish and inAiS' ? * Glezentanner, a refuge
Closing the Circle Lard £ S^f!?™?' WaS a reciP^t of the
pollution preventLractivities at thrrr0m"ental.pr°tection and
Refuge in Lstwell fexas Aransas National Wildlife
-------
Again, DOI supports the intent of the CEMP and would appreciate
EPA's efforts to facilitate implementation of CEMP government-
wide, particularly at the field level, if you have any
questions, please contact Jim Ortiz, of »y office, at
(202) 208-7553.
Sincirely,
'Willie
Director
Office of Environmental Policy
and Compliance
-------
U.S. Department of Justice
SS30
3 996
Mr. Steven A. Herman
Assistant Administrator for Enforcement
Compliance Assurance
Environmental Protection Agency
Room 3204, Ariel Rios Federal Building
1200 Pennsylvania Avenue, NW
Washington, DC 20044
Dear Mr. Herman:
Lois J. Schiffer, Assistant Attorney General, Environment and
Natural Resources Division, referred your recent letter to her
concerning the cade of Environmental Management Principles (CEHP)
to ay office for action. As the Assistant Attorney General for
Administration, responsibility for the Department's internal
environmental management program falls under my general
responsibilities.
We, of course, endorse the concepts and objectives embodied in
the CBG> for Federal agencies. As your letter recognizes, some
of our components have already implemented internal systems and
approaches to address their environmental responsibilities.
Therefore, we appreciate the flexibility identified in your
letter and intend to encourage our components to move toward the
iitipleaentation of the CEKP principles in a manner which is most
appropriate for their needs.
Almost two years ago, I made a commitment to strengthen the
Department's environmental program by assigning additional staff
and resources. I also gave the program greater visibility by
elevating it organizationally to report directly to a Deputy
Assistant Attorney General for Administration. The newly
designated Department of Jostiee {DOJ) Environmental Executive
regularly_ participates in my executive staff meetings which
provide him the opportunity to bring environmental program
concerns to my immediate attention.
During the past year, we sponsored several briefings on
environmental and energy conservation topics for Departmental
program managers and administrative staff. These included
briefings by representatives from the Environmental Protection
-------
Mr. Steven A. Hensan
P?SrLCEP*i °n toe Ofm Lights Pr°9"»
£ES«£i0SJSSt- .25. ?»?^-!
supported the efforts of several of our* h«! h*Vf succ*ssfuUy
.
coaprehensive enviroiMantal JeSe^" *ls° instltuttd a
institution^ Thf cStr^t^roS^lof^/^6^1 Cor««i°nal
water using solar energy L the «newabl! !n ati°? d°Besti= tot
long-range energy savings pdtentS mtgy SDUrce and *>"
-f1^ ~ss o
environmental challenge DrS»! n ^ °Ur SJ3PP°rt of the
"seal year, the DepStaS^Ui co^"5 ^ refflaind« of this
leadership, direction Sdsupoort ?f tf6 lts efforts to P«v
Our thrust will be ^ fstabf?^ its COBP°^nts' programs.
"-- "
-------
Mr. Steven A. Heraan 3
anticipated enviroaaental projects. Once this information is
reported, the Department will have a basis tq provide oversight
and assistance for the environmental projects underway or planned
throughout the Department.
In addition, we have recently drafted our first proposed
Departmental policy guidance doeuaent an pollution prevention,
control and energy conservation. ItoeR issued, it will serve as
basic prograa guidance for all Departmental components and
incorporate the essential elements of the CSKP. Ae we mentioned
iiarHer, our bureaus with significant environmental issues have
already iaplesianted sone type of environmental management system
to trade compliance, accountability, and progress at their
facilities. In pronulgating our guidance, we will share
information with all of our components about the environmental
management systsm standards described in the enclosure to your
letter and urge thea to evaluate them and consider adopting one
if it appears to be beneficial.
If you have any questions regarding our response, your staff nay
contact Warren Oser, Department of Justice Environmental
Executive, on 202-514-0458,
Sincerely,
Sts
Assistant 'Attorney Gsfnferal
for Administration
•cc: Lois J, Schiffer
-------
e
US.Department of ASStstan Secretary joo Seven* Si S w
Thanspodotton '»Administration WM^on. o.c. ZQSSO
October 3D, 1336
Mr, Steven A. Hennas
Assistant Administrator
Federal facilities Enforcernem Office
Office of Enforcement and Compliance Assurance
United State Environmental Protection Agency
Washington, D.C. 20460
Dear Mr Herman:
Thank you for your letter regarding the Code of Environmental Management Principles for
Federal Agencies (CEMP). The Department of Transportation is committed to quality
environmental program management and agrees with the spirit and intent of the CEMP,
We already have initiatives which address many of the CEMP principles and we are making
significant efforts toward the goal of improving our existing environmental management
systems. As we progress, the principles will be a valuable internal benchmarking tool. We
intend to support these principles to the maximum extent feasible given our existing resoarces
and current budget constraints.
If you have any questions regarding this comment please call Christiai Barrett of my stiff on
202-366-0038.
Sincerely,
Melissa J. Spillenkothen
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DEPARTMENT OF THE TREASURY
WASHINGTON, D.C.
December 10,1996
Mr, Steven A. Herman
Assistant Administrator for
Enforcement and Compliance Assurance
Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
i) ear Mr. Herman:
Ttank you for your ter regarding the Co* ofEmrome
-
^
We have taken a r^bcr of imtiativcs, over the last few years, toward improving the
covironmeat managemm program here at Treisuiy, AU
CEMP provides.^valuable pta for futoe wivfe. We arc also examining the potential for
IdpiSmSTltfltlQH 01 tuC ISO 14Q01 FnVitAnmsmfaf Ctan4**>.4 ~* -., i" •!• « v«*
« *-«i'**uuuiciiial ^UUiyETy at OLff i^liltlft
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£ 4% \ UNITED STATES ENVIBONMEN
" WASHINGTON,
km/ A ^M OFFICE C
HDV 8 ••• ADMiNISTR*
AND RE SOU*
MAN AGE M:
MEMORANDUM
SUBJECT: Commitment to the Code of Environmental Management Principles
FROM: s^. AJvin M. Pesachowitz /M&Usfl/l 0'&~
-rtf"* Acting Assistant Administrator fj
TO: Steven A. Herman, Assistant Administrator
Office of Enforcement and Compliance
This memorandum responds to your request concerning trie Agency's plans to implemc
the Code of Environmental Management Principles for Federal Agencies, announced in the
October 16, 1996 Federal Register. As EPA's Designated Official for Safety, Health and
Environmental Management, I can assure you that EPA is committed to adopting the Code aa
incorporating its principles throughout the Agency. I have coordinated this response with
James S. Mathews, Office of Sold Waste and Emergency Response (5101), who serves as the
Agency's Environmental Executive, and will coordinate the implementation of these principles
•with him.
By implementing these principles throughout EPA, the Agency's internal environments
management practices will be significantly improved. We have documented, through our
extensive audits and program reviews, that the level of compliance is directly related to the qu;
of environmental management systems and visible management commitment.
Although we have integrated several of these environmental management principles int
the Agency's Safety, Health and Environmental Management (SHEM) Program, we think we
do better. We have updated many of our program documents and issued memorandums from
Deputy Administrator and myself to enhance the understanding of these responsibilities by sen
managers. We want to ensure the Agency's business is conducted in a manner that protects th
environment and its employees from harm. We have developed Pollution Prevention Plans for
each of EPA's facilities and are trying to integrate waste reduction into the work ethic and cul
of EPA employees. We are using technology-based job tools to improve program delivery, to
help our environmental officials, and to reduce program operating costs. We measure the
Agency's environmental performance through internal technical audits and program reviews.
-------
If your staff h«s the time, we would appreciate your Office's review of both the quality
ana tfte scope of our program, and would appreciate yaw ideas for usetaing ciiftomer
I have asked Juliua C, Jtaeno, Director, Safety, Hearth and Environmental
Division, to meet with Craig Hook, and di.«i« how we might "bench mark" the Ajncr
«nd incorporate mote aspects of the environmental management principles into our SHEM
Program.
cc: John C, Charaberlin
Julius C. Jimeno
James H. Mathews
-------
Deputy Administrator
General Services Administration
Washington, DC 20405
December 2, 1996
Mr. Steven A. Herman
Assistant Administrator
Office of Enforcement and Compliance Assurance
Environmental Protection Agency
Washington, DC 20460
Dear Mr. Herman:
Thank you for your letter of September 3, 1996, requesting a brief statement
declaring the General Services Administration's (GSA's) support for the Code of
Environmental Principles (CEMP). You also requested a concise explanation of
how GSA plans to implement the CEMP at the facility level,
GSA fully endorses the principles of the CEMP. Our agency currently has an
environmental management plan and will use it to implement the CEMP at the
facility level. GSA's current environmental management plan includes:
1) designation of a Senior Executive to serve as GSA's Environmental
Executive empowered to cut across organizational lines, facilitate the
development of agency-wide goals, and report directly to the Deputy
Administrator on environmental matters;
2) formation of an agency-wide Environmental Program Council (EPC)
composed of representatives from all GSA service and staff offices to
assist GSA Environmental Executive in the development of agency-wide
goals and review the status and achievement levels for all GSA
environmental programs;
3) the GSA Pollution Prevention Strategy of August 1994. The strategy
lays out GSA's pollution prevention goals, identifies the pollution
prevention activities in which GSA currently engages, and lists GSA's
pollution prevention innovative technologies that exceed the requirements
of E.O. 12856;
4) development of sample guidelines for a facility pollution prevention
plan that provides detailed information on how a facility can help reduce
the use and storage of toxic chemicals 50 percent by 1999;
Federal Recycling Program jg__ Jp, Printed on Recycled P
-------
-2-
5) designation of environmental and recycling program coordinators a!
GSA regional office level to implement and monitor their respective
programs at all GSA regional offices, field offices, and all other GSA-
owned and -operated Federal buildings; and
6) preparation of quarterly and annual reports on the status and
accomplishments of all existing GSA environmental programs.
My staff and I look forward to working with you to make the Federal Government
a leader in pollution prevention. The CEMP is certainly a positive step toward
meeting this important goal. ^w«u
Sincerely,
Thurman M. Davis, Sr.
Deputy Administrator
FwteraU Recycling Program W—7H Printed on Recycled paper
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^%v
DEPARTMENT OF HEALTH & HUMAN SEA VICES
SEP 2? I9S5
Steven A. Herman
Assistant Administrator
Protection Agency
and
Office of lh» S*<
Washington, O.C
Washington, D,C. 2046O
Dear Mr. Herman:
The Department of Health and Human Services
to
Protection
H^i^tt^ ^-S.StaSitt:tiS?^,:?*r£f??~^l. *-°te|tIon
facilit
please contact Dick
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National Aeronautics and
Space Administration
Headquarters
Washington, DC 20546-0001
SEP 3 0 1995
Mr. Steven A, Herman
Assistant Administrator
Office of Enforcement and Compliance Assurance
U. S. Environmental Protection Agency
Washington, DC 20460
Dear Mr. Herman:
The National Aeronautics and Space Administration (NASA) has already embraced the
principles put forth in the Code of Environmental Management Principles (CEMP) and fully
endorses them on an Agencywide basis. The NASA Strategic Plan recognizes our
responsibility to preserve the environment as one of the four strategic outcome activities
contributing significantly to the achievement of the Nation's science and technology goals and
priorities.
Additionally, the NASA Environmental Excellence for the Twenty-First Century stares:
"Environmental Excellence is not a program, nor can it be achieved through a policy
statement. Environmental excellence is a way of life and must be ingrained as parr
of ota- culture" , and, "Our Agencywide impact on the global environment must be
able to withstand the scrutiny of the international community. No one person can do
this alone, but working together, the entire NASA community-civil service contractor
ali fee-can make the vision a reality."
Dne of the avenues NASA is investigating to fuUy implement CEMP principles at the facility
evel is the ISO 14001 process. Currently, we are forming a working group that wiU analyze
SO 14001 requirements and make recommendations on implementing the standard. Several
jrgamzations have been identified that can provide the necessary training and education to
acilitate this process. A number of NASA Centers have already begun incorporating ISO
4001 standards into their policy documents.
-------
Please be assured that NASA fully endorses the CEMP principles and has already incorporafc
them into our environmental policy and goals. Our focus now is to fully implement those
principles throughout the Agency, If you have any questions regarding this effort, please
contact Ms. Olga Dominguez at 202-358-0230.
Sincerely,
:^-—-w /
Benita A. Cooper (
Associate Administrator for
Management Systems and Facilities
cc:
IE/Ms. Dominguez
ARCV223-1/MS. OlKges
DFRC/D-^4809B/Mr, Ambrose
GSFC/205.0/Mr. McNeil
JPL/3Ql-420/Mr, Buril
JSCflJl2/Mr. ffickens
KSC/DE-EMO/Mr. Wright
LaRC7429/Mr. Lee
LeRC/3065/Mr. McCallum
MSFCyAEOl/Ms, McCaleb
MAF/SA39/Mr. Celino
SSCA3AOO/Mr. Magee
WSTF/RA/Mr. Amidei
WFF/2Q5/Mr» Potterton
-------
M
KOTJSMGE
September 30,1918
Mr. Steven A Herman
Assistant Administrator
Office of Enforcement and Compliance Assurance
U. S. Environmental Proton Agency
Washington, DC 20460
Dear Mr. Herman;
Your September 3 letter to Mr, Gerald McKiernan was forwarded to my office for response, le
Postal Service supports the Code of Environmental Management Principles (CEMP). Attach
our strategy for the implementation of tie CEMP. We are continuing our investigation and
evaluation of IS0 14001 for its implication and applteaWltty to our organization. Thank p for
keeping us informed on the progress of your environmental vente.
Please contact Paul FennewaW at (202) 268-6239 or m at (202) 26 M1 88 if you have any
Sincerely,
'
Elravo
Manager
Environmental Management Policy
Attachment
cc; Mr, Dowling
Mr, McKJeman
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UNITED STATES
POSTAL SERVICE
Strategy for Implementation of
Code of Environmental Management Principles (CEMP)
for Federal Agencies
'• Management Commitnierjt: The agency makes a written top management
commitment to improved environmental performance by establishing policies
which emphasize pollution prevention and the need to ensure compliance
with environmental requirements.
The United States Postal Service (USPS) has a Policy for Environmental
Protection which is signed by the Postmaster General. The policy commits
the Postal Service to provide employees and customers with a safe and
healthy environment and promotes seven "Guiding Principles" that promote
Environmental Protection as a responsible thing to do, and as a sound
business practice.
(See Attachment I - Policy for Environmental Protection)
The USPS environmental function was placed in the operations and facilities
portion of the organization and the environmental responsibility was placed
on line management with environmental personnel providing technical
guidance and assistance to the field in implementing environmental policies
and procedures.
»• Compliance Assurance and Pollution Prevention: The agency
implements proactive programs that aggressively identify and address
potential compliance problem areas and utilize pollution prevention
approaches to correct deficiencies and improve environmental performance.
An Environmental Strategic Plan was developed for the period 1993 - 2OOO.
The plan's strategies and actions were aligned with the Policy for
Environmental Protection and its Guiding Principles. The plan initially
contained 117 tactical actions towards the goals of achieving compliance and
leadership. The tactical action plan is flexible with the ability to integrate
additional tasks and target areas as needed.
(See Attachment II - Annual Status Report Memo, October 16, 1995)
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'"• fsnabHpg Systems: The agency develops and implements the necessary
measures to enable personnel to perform their functions consistent with
regulatory requirements, agency environmental policies and its overall
mission.
The Postal Service also provides Environmental Target Areas to its Area and
District personnel to provide focus and direction for developing and
implementing plans at the Area, District and Plant levels. Two major
categories of environmental target areas have been identified:
1) Leadership targets which are intended to establish the USPS as a
leading organization in environmental initiatives, and
2) Compliance targets which are intended to reduce liability and ensure
USPS compliance with federal, state and local laws and regulations.
(S&e Attachment III - Environmental Target Areas)
lv> Perfprmance and Accountability: The agency develops measures to
address employee environmental performance and ensure full accountability
of environmental functions.
In keeping with its guiding principle
"We will incorporate environmental considerations into our business plannina
processes"
the Postal Service continuously monitors progress and updates the Tact/cat
Actions in its Environmental Strategic Plan to reflect many new ideas, target
areas and programs.
Since Postal Service employees are accountable for environmental
objectives through the Policy for Environmental Protection, it was integrated
into personnel evaluations to reinforce personnel accountability.
*• MsasMte-ment and Improvement" The agency develops and implements a
program to assess progress toward meeting its environmental goals and
uses the results to improve environmental performance,
The Postal Service implementation strategy for Measurerr?^
Improvement is based on the following Guiding Principle:
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"We will measure our progress in protecting the environment."
and is defined in the USPS Environmental Strategic Plan 1993-2000:
TRACK PROGRESS
• Define performance criteria for key target areas of environmental concern.
• Establish and maintain a national information system to monitor
environmental performance and compliance.
• Establish procedures for allocating resources to and monitoring the costs
of national environmental initiatives.
The USPS utilizes a concept known as Environmental Information Services
and Support (EISS) to gather, analyze and distribute data and information
through the Postal Routed Network (PRN) to Postal environmental
professionals and personnel throughout the United States. EISS currently
consists of a bulletin board system (an environmental and safety information
source module on the Customer Service Bulletin Board System (CSBBS)).
The USPS is developing an electronic Environmental Management
Information System (EMIS} that will b& linked to the Environmental
Management Policy worldwide web homepage. The homepage will give easy
access to stored information, currently not available on CSBBS, through
EMIS. EMIS will be capable of storing and disseminating /a/gre amounts of
environmental information focused on key target areas of environmental
concern and essential to daily Postal Service operations.
Through EMIS, resources may be allocated and costs of national
environmental initiatives may be monitored more effectively through shared
information resources.
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STATES
POSTAL SERVICE
UNITED STATES POSTAL SERVICE
POLICY FOR
ENVIRONMENTAL PROTECTION
POLICY
The United States Postal Service is committed to provide
employees and customers with a safe and healthy environment
Environmental protection is the responsible thing to do, and
makes for sound business practices.
GUIDING PRINCIPLES
m We will meet or exceed all applicable environmental laws and
regulations in a cost effective manner.
* We will incorporate environmental considerations into our
business planning processes,
• We will foster the sustainable use of natural resources by
promoting pollution prevention, reducing waste, recycling and
reusing materials. a'
* We will expect every employee to take ownership and
responsibility for our environmental objectives.
" We will work with customers to address mutual
environmental concerns.
• We will measure our progress in protecting the environment.
• We will encourage suppliers, vendors, and contractors to
comply with similar environmental proto^n policies.
Marvin Runyon
Postmaster General
September 1995
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UNtTED STATE*
POSTAL SEKVICE
October 16, 1995
MEMORANDUM FOR LEADERSHIP TEAM
SUBJECT: Annual Status Report
Attached is a copy of the Annual Status Report of the Postal Service's Environmental
Strategic Plan.
During this past year, we have made substantial progress in the development of our
environmental program, to addition, we have also been recognized nationally, through
various environmental awards, as a leader in environmental excellence. We are
continuing to make superb progress in achieving our goal in making environmental
excellence am integral part of the way we do business.
We are pleased to provide you with this Annual Status Report of our environmental
efforts. If you have any questions, contributions, or suggestions, please feel free to
contact me.
Charles E. Bi
Manager
Environmental*Management Policy
cc: Area Environmental Compliance Coordinators
District Environmental Coordinators
475 L'BMMT Pi*» SW
Wmatmatcn DC 2O26O
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UNITED STATES POSTAL SERVICE
ENVIRONMENTAL STRATEGIC PLAN
STATUS REPORT
SEPTEMBER 30, 1995
Two years ago we developed a comprehensive Environmental Strategy Plan for the
1993-2000 period. The plan's strategies and actions were aligned with the Environmental
Guiding Principles issued by the Postmaster General in April of 1993 and reissued in
September 1995 (enclosed). To support this commitment to a strong and active
environmental program, the Postal Service identified 10 target areas — categorized as
either leadership or compliance targets ~ to provide focus and direction for developing
and implementing plans at the Area, District and plant/facility level. Those original 10
environmental target areas has now been expanded to include Energy and Water
Conservation (enclosed).
The plan initially contained 117 tactical actions put forth with a view towards achieving
two principle goals:
• Compliance with federal, state, and local laws and regulations by postal facilities at
all levels.
• Leadership objectives that establish us as a leading organization in environmental
issues.
Integrating the consideration of the environment into our everyday business decision-
making process continues to evolve as shown in this status report. The results of this
comprehensive program have exceeded our expectations and served as a catalyst for
many new ideas and programs. As stated earlier, the energy conservation Function has
been integrated within Environmental Management Policy and will be expanded to
include water conservation. We expect a number of new tactical action items developed
over the coming months related to this new target area. What began as 117 separate
tactical actions and increased to 135, has now been pared down to 105. To date, 67
tactical actions have been completed, in which 46 have been, embedded into continuing
programs, with 38 tactical actions ongoing and are continuing to progress (Chart I). This
progress indicates that the managers are buying into the Environmental Strategic Plan.
Enclosed are listed some of our most significant environmental achievements during the
past two years. Although we have made significant progress carrying out our Strategic
Environmental Plan, we still have some important challenges ahead of us. Listed below
are some of the challenges we face in the coining yean
« Set goals, develop strategies, and establish programs for the Energy and Water
Conservation target area.
* Expand the application of the NEPA process to operational activities and improve the
integration of environmental consideration into our business planning process.
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» Establish DECs in every district and ensure they are adequately trained to assume
their responsibilities.
» Update, test, and field the Progress in Environmental Protection - Management
Information System (PEP-MIS) and the Customer Service and Sales Bulletin Board
System (CSBBS).
• Expand our environmental awareness programs and continue reaching out to our
employees, and suppliers, venders, and contractors,
• Intensify our efforts in pollution prevention, recycling, and waste reduction.
The progress we have made is attributed to the diligent work of the Work Groups and
their corporate sponsors (Chart 2). They were charged with developing the programs th
answered the "how to" to comply with the tactical actions. They, in turn, provided
headquarters. Environmental Management Policy, with updates on their progress.
Chart 3 represents the current distribution by lead office, of the ongoing tactical actions
that are at various stages of completion. This Annual Status Report comprises the detail
of the work groups to date.
The attached tabular summary is organized as follows:
Column I Tactical Action Plan
Of the 135 tactical actions plans, 30 have been combined with like action
(deleted).
The current tactical action plans are numbered 1 to 105.
Column n Contacts
The following is the key for the listings in the contacts column:
* The first item is the Lead Office
« The second item is the Point of Contact
* The third item is the telephone number of the Point of Contact
* The fourth item is the Corporate Sponsor
Column TO, Concepts
The concept is the work groups "how to" to develop a solution to the
Tactical Action Plans.
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Column IV Status
This is the status of the tactical action as of September 30, 1995,
Column V Next Step
This column identifies any future efforts necessary to complete the tactical
action.
Chart l Environmental Stratgfrir-
Status of the 135 Tactical Action Plans as of September 30, 1995.
Environmental Strata^ Plan
105 Taaical A"ions by L-d Office - of
Charts Environmental Strategic Plan
as
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ENVIRONMENTAL TARGET AREAS
Leadership Targets
Compliance Targets
Underground Storage
Tanks
- Establish monitoring procedures
& reduce number of USTS
Clean Air Act Amendment
- Reduce emissions
- Develop plan to use alternate fuels
Hazardous Chemicals
- ID hazardous substances & use
environmentally safe alternatives
Paint Spray Operations
- Reduce total number
Main Transport Equipment
- Reduce wastestreams & increase
lifecycle of materials
Recycling & Pollution
Prevention
- Conduct P2 assessments, develop
recycling programs & reduce waste
Regulatory Outreach
- Work with regulators & local
officials
Sensitivity to State & Local
Regulations
- Be active with associations & local
government activities
Awareness Training
(culture change)
- Train at all levels & increase
environmental awareness
Quality Assurance Reviews
- Conduct QAJRs & implement
corrective actions
Energy & Water
Conservation
- Set goals, develop strategies &
establish programs
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June 21, 1996
ENVIRONMENTAL TARGET AREAS
LEADERSHIP
1. Underground Storage Tanks
Reduce number of underground storage tanks
Complete surveys and upgrade remaining tanks
Establish monitoring and inspection procedures
STaws9 and inSPeCti°n re^'rements *-• -»* abound tanks required by
2. Clean Air Act Amendments
Increasingly stringent amendments of the CAA will impose compliance requirements for
reducing emmston sources and using alternate fuel vehicles. requirements for
Identify applicable laws, regulations
9 ' ™^™«« storage »nk,. P™ spray
• Develop plans to use alternate fuels
• Increase the utilization of alternate fuel vehicles
• Obtain air credits and rebates, wherever possible
3. Hazardous Chemicals
• Identify hazardous substances
•" SfaJS"^0181;?1' f°r Substitutin9 environmentally safe alternatives
Work to reduce the generator status to conditionally exempt, wherever possible
4. Paint Spray Operations
• Minimize liability and reduce costs by reducing total number of paint sorav ooerations
• Convert rerunning operations to most efficient technologies ind^C»Hfan vKe L L
Pressure Systems (HVLP) and tow volatile organic paints "CIU°mg M'9n Volume L°^
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Recycling/Pollution Prevention (P*)
Activities In support of recycling and pollution prevention generate revenue, save money and
reduce liability. Increasing our activities in these endeavors increases customer and employee
satisfaction and identifies the Postal Service as a good neighbor and leader in environmental
issues. Moreover, these initiatives support sustainable development for future generations.
Complete P* plans at all plants. VMFs. and large AOs
Establish procedures for wastestream assessment at all facilities
Select methods for recycling, eg,, Southwest Area model
Reduce/eliminate disposal contracts
Generate revenue from recycling activities
6. Mail Transport Equipment
Much of the waste generated at a plant is cardboard, plastic, shrink-wrap, and pallets used in
handling mail.
» Establish strategies to reduce wastestream and Increase life cycle of materials, including
use of long-life pallets, reusable trays
* Establish recycling programs of MTE items
« Work with MTE centers on recycling
COMPLIANCE TARGET AREAS
1. Quality Assurance Reviews
A review system is essential to (1) identify and ensure compliance with environmental
regulations In all facilities and (2) to identify and monitor implementation of corrective measures
and improvements.
Implement immediate corrective actions
Implement pollution prevention initiatives
Change applicable work practices
Initiate review and evaluation process in all "high-risk' facilities on a regular basis
Establish a follow-up program
Ensure VMFs and Plants conduct a self-review (brief checklist) annually (e.g., VMF model
review, section six)
Regulatory Outreach
Effective compliance with applicable laws and regulations requires consistent interaction with
regulators who monitor public and private organizations. Developing good working
relationships with regulators ensures awareness of regulatory changes and increases timely
compliance.
* Participate in award programs sponsored by regulatory agencies
* AECCs and DECCs should work with appropriate regulators to help affect federal, state
and local laws which are beneficial to the environment and the Postal Service
* Participate in Regulatory Task Forces and industry groups
* Attend conferences and workshops sponsored by regulatory agencies
* Encourage facility managers to contact appropriate local environmental officials
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3. Sensitivity to State and Local Regulations
To enhance the Postal Service's position as a good neighbor and leader in environmental
initiatives, community outreach and environmental practices need to match local laws and
regulations. Postmasters, managers, environmental professionals and other employees need
to more actively participate in state and local activities.
• Managers and environmental professionals should participate in associations and local
government activities
- Encourage employees at all levels to participate in appropriate environmental activities
e.g., local government recycling programs, local Earth Day events
• Provide Postmasters Training and state specific Postmasters Guides
4. Awareness Training (Culture Change)
Successful implementation of environmental initiatives first requires an organization-wide
awareness and understanding of roles and responsibilities to increase compliance with
applicable laws and regulations.
• Provide multi-media training at all levels on environmental issues and initiatives
• Develop communications initiatives to increase employee awareness
• Brief union and management association leaders to stimulate environmental awareness
• Provide local training and/or have key environmental stakeholders attend environmental
training at the Technical Training Center
5. Energy Savings Program
Energy savings techniques and technologies will be implemented to meet the Energy Policy
Act (1992) requirement of a 20% reduction in energy use by the year 2000 In addition
strategies will be implemented to achieve water conservation.
Designate Energy Coordinators
Implement high ROl projects
Focus on lighting opportunities with new technology
Use shared energy savings as appropriate
Implement demonstration projects
Evaluate renewable energy opportunities
Review energy rates to obtain best values
Promote environmental awareness
Conduct training on energy
Target high energy rate utilities/areas
P^"trWith °ther federal agencies when aggregating (GSA, DOE, DOD) and negotiating
with utility companies » »
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USPS ENVIRONMENTAL PROGRAM
SIGNIFICANT ACHIEVEMENTS
District Environmental Coordinators
* In the final stages of establishing DECs in each District.
Expanding Alternate Fuel Program
* More than 4,185 vehicles converted to compressed natural gas with plans to
increase to 6,500 by the end of 1995.
• Testing ethanol-fueled and electric powered vehicles,
* Leading an international effort on studying alternative fuels with the Universs
Postal Union.
Recycling and Pollution Prevention
* Developed a National Strategy.
* VMFs are reducing the number of chemical line items which has resulted in ct
avoidance related to hazardous materials management and cost savings throuj
waste reduction of less frequently usert chemicals.
* Significantly expanded our recycling effort both in what we purchase and whs
we discard, especially in UBBM,
* Using recyclable material in many of our Mail Transport Equipment.
* More than 400,000 tons of wastepaper, cardboard, plastics, cans, and other
material were recycled last year. These activities generated about $6A million
revenues this year.
« The Postal Service is a national leader in the use of re-refined oil. More than
100,000 postal vehicles currently use re-refined oil.
Underground Storage Tanks
* Rembved over 500 nationwide since 1992.
* Issued a new MI establishing guidance that will minimize the installation of
additional tanks.
Paint Sprav Operations
* Sixty-nine painting operations have been deactivated, with the remainder eithe
discontinuing, consolidating, or upgrading their painting operations.
-------
Significant Achievements (continued)
Reduction of Hazardous
* J*sued a new policy goal to virtually eliminate 17 targeted chemicals bv 1998
• We are on target to achieve a 50% reduction by the end of this year
• Developing a ncw MI on integrated Pest Management.
Environmental Awarenesy and Training
• Sixteen environmental courses are now offered at the TTC
• Environmental content is being embedded into 45 other courses.
envi™«»*"**I 'raining in 1995.
Hn , *W*™ness k P*"-* «f ^w employee orientation.
ecasth '
events such as Earth Day to increase environmental awareness.
Quality Assurance
- Completed the development of a QAR manual and ML
• Conducted over 105 QARs in which 60 were conducted this year.
National Recognition faf i?^.-o
,rshi
for environmental leadership and
-------
QCT 3 11SS5
Mr, Steven A. Herman, Assistant Administrator
Office of Enforcement and Compliance Assurance
Environmental Protection Agency
4O1 M Street, SW
Washington, DC 20460
Dear Mr. Herman:
T^ii F^^^|,tld^to>2Jnlh/t0 P3rticipate in me '"Agency Pollution Prevention
Program and the Code of Environmental Managtinient Prlro^T^EMP)*1'*119*
SfirSr dSr,^Ped and commcnced implementation of a state-of-the-art
develoomsnf of the. ico ijinn-t e? • '-"»•-* w^a assigned concurrently with the
w^vKiupiiterii or ine ioLj i4uoi Environmental Standard and th*» r*Pn/iD -j
aligned to the extent practicable with both. <-fcMP and has been
System and
>-3012.
Sincerely,
William H. Kennoy, P.E
LRB;SC
cc: Craven Crowell, ET12A-K
Johnny H. Hayes, ET 12A-K
Alan CarmJchaeJ, ET 12A-K
Kathryn J. Jackson, WT 11A-K
Jon M. ^onev. WT 8C-K
Ronald J. Wlttiams, CTR 2C-M
Norman A. Zigrossi. ET 12A-K
CTS Number, 08O444
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OFFICE OF THE UNDER SECRETARY OF DEFENSE
300O DEFENSE PENTAGON
WASHINGTON DC 20301-3OOO
ACQUISITION AND
TECHNOLOGY
Mr. Steven Herman
Assistant Administrator 05 WQW 1£!QC
Office of Enforcement and Compliance Assurance
Environmental Protection Agency
Mail Code 2261A
401M Street SW
Washington, DC 20460
Dear Mr. Herman;
I endorse the draft Code of Environmental Management Principles (CEMP) on an agency
level as described in your letter dated September 3,1996.
The Department of Defense is folly committed to protecting the environment and
building excellence into the management of its programs. The Department is using ISO 14001 in
the development of its current strategic plan and is evaluating the adoption of ISO 14001 as an
Environmental Management System for the entire Environmental Security program, Ow goal is
continuous improvement of our environmental performance through a cost-effective
implementation strategy. The enclosed implementation plan describes how the CEMP is
incorporated into the Department's existing environmental management system,
I would be happy to brief you on the Department's Environmental Security program. If
you have any questions, please do not hesitate to contact me at (703) 695-6639 or Mr, Peter
Walsh at (703) 604-1529.
Very teaty yours,
Sherri Goodman
Deputy Under Secretary of Defense
(Environmental Security)
Enclosure
-------
IMPLEMENTATION OF THE CODE OF ENVIRONMENTAL
MANAGEMENT PRINCIPLES
Principle 1: Management Commitment
Performance Objectives:
1.1 Obtain Management Support
1.1.1 Policy Development
The Department of Defense (DoD) Environmental Security Directive and supporting
instructions signed by the Under Secretary of Defense (Acquisition and Technology) establish
environmental protection goals and developed supporting strategies that fully complement
accomplishment of the Department's overall mission. The instructions also establish budget
priorities and measures for evaluating how well established goals are being met (see attachment
2)
1.1.2 System Integration
The DoD Acquisition Directive, recently published, directs that environmental performance
must be considered in the acquisition process along with other factors such as mission
performance and cost. In addition, the DoD Planning instruction requires the completion of an
environmental analysis in accordance with the National Environmental Policy Act to aid decision
making.
The Department annually provides budget development guidance direction to the
Services through both the Program Objective Memorandum (POM) Preparation Instruction and
Defense Planning Guidance. These documents specifically identify environmental performance
goals or accomplishments. Thereafter, the Deputy Under Secretary of Defense (Environmental
Security) reviews the Services' budget submissions to ensure they meet guidance,
1.2 Environmental Stewardship and Sustainable Development
The Department's policies, as described in the Environmental Security Directive and
supporting instructions, and annual budget planning guidance, promotes environmental
stewardship and sustainable development.
The DoD policies conserve natural and cultural resources, and promote biological
diversity and total ecosystem land management. The DoD instructions require completion of
inventories of special resources such as wetlands, endangered species habitat, archaeological
sites and historic properties. They further require preparation of integrated plans for their proper
management. The Department's land management practices at training ranges balance the
military training needs with the ability of the land to sustain and recover, thereby protecting
valuable resources and ensuring future realistic training opportunities.
The DoD instructions also promote the conservation of resources through the
establishment of goals and reporting requirements for the reducing solid waste, hazardous waste,
and toxic substances released from an installations each year. The Department's instructions also
require a recycling program at every installation and establish goals and reporting requirements
for increasing the total volume of material recycled each year. The Department's instructions
-------
S^
-zsstttzs
DoD personnel reflations require that supervisors identify major job components m
J*^
on. The installation's environmental performance is one of many considerations that
would contribute to the commander's performance appraisal ^'deranons that
Hie Department believes this is the appropriate interpretation of the phrase
organizational umts should take steps to measure the organization's performance by
Principle 2: Compliance Assurance and Pollution Prevention
Performance Objectives
2.1 Compliance Assurance
™e DoD's directive and supporting instructions require compliance with federal state
«d local ovnww.il laws Arauai budget guidance requires the full funding of acSo
st y m comphance and to get mto compliance if currently out, and a prudem invLen ia tee
actjonsnecessarytomeetstaBdardswhoseeflfectivedateisin the tare. TheDepaTenT
ms^ons ako require that each installation conduct a self audit for environment performance
east annually, and that the Services report progress on specific compliance and poLion
1 in the Department's Annual Environmental
- it's instructions establish Regional Environmental
) work closely with federal, state and local environmental replators m identifying
miKi»v f
-------
response plans. The checklist developed to aid the mandatory environmental self audit includes
this requirement.
2.3 Pollution Prevention and Resource Conservation
The DoD Pollution Prevention instruction establishes pollution prevention goals and
strategies. It requires all installations accomplish an opportunity assessment and develop a
pollution prevention plan, Further, the instruction requires installations to give preference to
pollution prevention projects over "end of pipe" treatment and disposal to meet compliance
requirements. The Department's annual budget guidance reinforces this preference for pollution
prevention solutions. The instruction also establish goals for reductions in solid waste and
hazardous waste released from an installation and requires periodic reporting by the Services on
their progress towards achieving these goals.
Priadple3: Enabling Systems
Performance Objectives
3.1 Training
The Department is developing an extensive training program so that all persons can meet
the environmental responsibilities of their jobs. The Department provides an environmental
awareness program during military recruit training. The Services have evaluated the
environmental requirements of military enlisted personnel jobs, such as jet engine maintenance
and fire fighting, and are currently in process of embedding appropriate environmental
instruction into the technical training programs.. The Department is also in process of inserting
discussion of national and international environmental in professional (officers) military
education programs. The Services are developing an integrated professional continuing
education and training program for both civilians and officers. This program provides the legally
mandated training for those persons handling hazardous materials. It also provides education for
environmental professionals so they can meet the changing challenges of their jobs. The
Department is also inserting environmental instruction into the education programs for non
environmental professionals whose actions could affect the environment. For example, the
Department is currently revising the curricula at the Defense Acquisition University so that
persons managing acquisitions in the future would better understand environmental requirements
and the environmental cost implications of their decisions. The Services and the Department
conduct Environmental Leadership Courses to prepare installation commanders and senior
officials to understand and meet the environmental responsibilities of their jobs.
3.2 Structural Supports
The Department's Environmental Security Directive and supporting instructions
establish environmental goals, supporting strategies, budget priorities, and measures of merit
that support overall organizational objectives. The Department reports progress towards
achieving the goals in its annually environmental quality and restoration reports to Congress.
3.3 Information Management, Communication, Documentation
The Department is currently developing a Defense Environmental Security Corporate
Information Management (DESCIM) system to provide for more effective and efficient
-------
management of the environmental program. The system, to be used by all Services, standardizes
data entries and information display. The system is being developed to meet management needs
at all organizational levels - installation, major command and headquarters.
Principle 4 Performance and Accountability
Performance Objectives
4.1 Responsibility, Authority and Accountability
The Department is in process of implementing a program to educate or tram personnel to
meet the environmental responsibilities of their jobs. The Department's Environmental Security
directives and supporting instructions establish goals for compliance, pollution prevention and
conservation and require periodic reporting on progress towards meeting those goals through
measures of merit. 5 B
DoDpasonne] regulations require that supervisors identify major job components in
emptoyees job descriptions and prepare evaluation criteria for those major job components in
employees annual work plans. Supervisors therefore evaluate persons with environmental
responsibilities on the performance of those responsibilities, as appropriate. Similarly military
personnel with environmental responsibilities would be evaluated on their performance of those
responsibilities. Installation commanders are evaluated on the total performance of the
rnstallatioa The installation's environmental performance is one of many considerations that
would contribute to the commander's performance appraisal.
4.2 Performance Standards
The Department's instructions establish environmental compliance performance
measures. The instructions further require the Services report to the Deputy Under Secretary of
Defense (Environmental Security) semi-anaually on their environmental compliance
performance using these established measures.
The Department's instructions establish an awards program to recognize outstanding
performances by installations and by individuals. The Services select winners in each of 17
categories from nominations from their respective installations. These Sendee winners in turn,
compete for recognition as best in the DoD.
Principle 5; Measurement and Improvement
Performance Objectives
5.1 Evaluate Performance
5.1.1 Gather and Analyze Data
The Department is in process of implementing a automated data management system to
collect data to support management needs at installation, major command and headquarters
levels, n
The Department's Environmental Security directive and supporting instructions establish
goals and require the Services to provide assessments, at least annually, to the Deputy Under
Secretary of Defense (Environmental Security) on progress towards achieving those goals
5.1.2 Institute Benchmarking
-------
Hie Department is cwrently equating environmental operations in other government
and non-government organizations which have similar environmental challenges. Hie effort is
scheduled for completion by January 1997.
5.2 Continuous Improvement
The Department is promoting numerous initiatives to improve environmental
performance. For example, the Department is establishing hazardous materials pharmacies at
most installations and on ships. Pharmacies provide central control of purchasing storing
distributing and disposing of these materials. Implementation of pharmacies results in reduced
purchases, disposals, and potential for violations. Another example is the "ENWEST"
initiative, jointly sponsored by EPA and the Department. Under this initiative, a regulator may
grant relief from requirements that provide little additional health protection or environmental
improvement In return for such relief, the installation commander, in coordination with the
regulator, commits the money originally programmed to satisfy the "waived" requirements to
fund high payback pollution prevention projects. A third example is the single process
initiative. Under this initiative, program managers for different weapon systems supported by a
single process agree to a single test and validation process for an environmentally sound
alternative to that process. If the test and validation process is successful, changes affecting all
weapons are made simultaneously, thereby improving the environment and reducing costs
-------
DEPARTMENT OF VETERANS AFFAIRS
DEPUTY ASSISTANT SECRETARY FOR ACQUISITION AND MATERIEL MANAGEMENT
WASHINGTON DC 20420
DEC 24 1995
Mr. Steven A. Herman
Assistant Administrator
U.S. Environmental Protection Agency
Office of Enforcement and Compliance Assurance
4O1 M Street, SW
Washington, DC 2046O
Dear Mr. Herman;
We are responding to your letter regarding the Code of Environmente
Management Principles (CEMP). The Department of Veterans Affairs (V.
is committed to maintaining the highest level of environmental
compliance at its facilities and in enhancing the management of
environmental programs Department-wide.
We have reviewed the five principles that comprise the CEMP and
believe they provide a sound basis in which to enhance the managemen
of environmental programs at VA. We intend to develop a VA CEMP th.a
addresses these principles. My staff is working with other organizations
within VA to affect the foregoing programs. The initial draft will be
available by February 1, 1997.
If you have any questions, contact Mr. John Staudt, Chief,
Environmental Engineering Division (10NB), at (2O2) 273-5863.
Sincerely,
Gary J. Krump
Environmental Executive
-------
U.S. Army Environmental
Management System
Implementers Guide
Version 1.0
May 2003
-------
ACKNOWLEDGMENTS
This document was developed for the U.S. Army by the Logistics Man-
agement Institute (LMI). In preparing this guide, the authors relied on nu-
merous public documents and information sources for background
information, implementation ideas, examples, and other critical references.
The following sources were invaluable in developing this guide:
• International Organization for Standardization, Environmental man-
agement systems—Specification with guidance for use, ISO
14001:1996.
• International Organization for Standardization, Environmental man-
agement systems—General guidelines on principles, systems and
supporting techniques, first edition, ISO 14004:1996(E).
• Concurrent Technologies Corporation, Environmental Management
System Guidance Manual: Implementing ISO 14001.
• Concurrent Technologies Corporation, Environmental Management
Toolkit—An Environmental Management System Implementation
Tool, October 2002.
• National Science Foundation International Strategic Registrations
(NSF-ISR), Ltd., Environmental Management Systems—An Imple-
mentation Guide for Small and Medium-Sized Organizations, sec-
ond edition, January 2001.
• The Public Entity Environmental Management System Resource
(PEER) Center, How to Implement an EMS [on-line document], un-
dated [cited February 2003]. Available from http://www.peercen-
ter.net/howtoimplement/.
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Contents
Chapter 1 Introduction 1-1
PURPOSE OF THIS GUIDE 1-1
WHAT Is AN EMS? 1-1
Mission Focus 1-1
ISO 14001 1-1
IMPLEMENTATION REQUIREMENTS 1-2
ARMY POLICY 1-3
General 1-3
Metrics and Reporting Requirements 1-4
RESOURCING IMPLEMENTATION 1-5
IMPLEMENTATION ROADMAP 1-6
ROLES AND RESPONSIBILITIES 1-8
CONTINUAL IMPROVEMENT 1-8
FREQUENTLY ASKED QUESTIONS 1-8
Chapter 2 Step-by-Step Guidance 2-1
INTRODUCTION 2-1
Step 1. Designate the EMSMR 2-2
Step 2. Coordinate with senior leaders and select the CFT 2-2
Step 3. Orient and train the CFT in EMS implementation 2-4
Step 4. Conduct a self-assessment (by 30 March 2004) 2-6
StepS. Meet with the EQCC 2-7
Step 6. Prepare an EMS implementation plan 2-8
Step 7. Obtain CDR approval of the EMS implementation plan
(by 30 September 2004) 2-9
Step 8. Hold an EMS implementation kickoff meeting 2-9
Step 9. Identify mission focus 2-11
Step 10. Revise and sign installation environmental policy
statement (by 30 September 2003) 2-15
-------
Step 11. Plan and conduct EMS awareness training (by 30
March 2005) 2-18
Step 12. Initiate EMS documentation 2-22
Step 13. Develop EMS document control procedures 2-25
Step 14. Establish communications procedures 2-28
Step 15. Compile legal and other requirements 2-31
Step 16. Identify all mission and installation activities, products,
and services 2-36
Step 17. Identify the environmental aspects of your installation's
activities, products, and services that can be controlled or
influenced 2-40
Step 18. Identify the environmental impacts of each aspect 2-44
Step 19. Identify significant environmental aspects 2-47
Step 20. Develop or revise installation environmental
management programs 2-57
Step 21. Establish environmental objectives and targets 2-59
Step 22. Describe structure and responsibilities 2-67
Step 23. Develop SOPs and work practices for activities
associated with significant aspects 2-68
Step 24. Identify and fulfill environmental competency-based
training requirements for all installation personnel
(garrison and tenants) 2-69
Step 25. Establish monitoring and measurement procedures 2-73
Step 26. Establish procedures for maintaining EMS records 2-76
Step 27. Develop and review emergency preparedness and
response documents and procedures 2-79
Step 28. Establish procedures for nonconformance and
preventive and corrective actions 2-83
Step 29. Conduct periodic EMS audits 2-87
Step 30. Conduct periodic EMS management reviews 2-90
References
Appendix A. Acronyms
VI
-------
Contents
FIGURES
Figure 1-1. ISO 14001 Model with Mission Focus 1-2
Figure 1-2. Suggested EMS Implementation Sequence for Army Installations 1-7
Figure 2-1. EMSMR and Cross Functional Team Implement the EMS 2-11
Figure 2-2. EMS Document Hierarchy 2-22
Figure 2-3. Fuel Storage and Dispensing Operations 2-43
Figure 2-4. EMS Document Hierarchy 2-77
Figure 2-5. Linkages Among EMS Audits, Corrective Action, and
Management Reviews 2-89
TABLES
Table 2-1. Federal Laws and Regulations 2-34
Table 2-2. Mission or Functional Areas and Their Processes 2-37
Table 2-3. Environmental Aspects of Vehicle Maintenance Activities 2-42
Table 2-4. Environmental Aspects and Impacts of Vehicle Maintenance
Activities 2-45
Table 2-5. Sample Rating Factors for Frequency or Likelihood of
Environmental Impact 2-49
Table 2-6. Sample Rating Factors for Severity of Environmental Impacts or
Consequences 2-50
Table 2-7. Sample Rating Factors for Severity of Mission Impacts 2-50
Table 2-8. Sample Rating Factors for Regulatory Status 2-51
Table 2-9. Sample Rating Factors for Community Concern 2-51
Table 2-10. Information Sources 2-62
Table 2-11. Preliminary Environmental Objectives 2-62
Table 2-12. Regulatory Requirements and Objectives 2-63
Table 2-13. Installation Communications 2-64
Table 2-14. Target Objectives 2-64
Table 2-15. Performance Measures for Final Objectives 2-66
VII
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Chapter 1
Introduction
PURPOSE OF THIS GUIDE
This guide provides Army personnel an easy-to-use, step-by-step tool for
implementing the Army's environmental management system (EMS). It
provides the information needed to establish and implement an installation
EMS, while allowing the flexibility to address differing installation missions
and operational readiness requirements.
WHAT Is AN EMS?
An EMS is the part of an organization's overall management system that
integrates environmental concerns and issues in the organization's man-
agement processes. An EMS addresses organizational structure, plan-
ning activities, responsibilities, practices, procedures, processes, and re-
sources for developing, implementing, achieving, reviewing, and maintain-
ing environmental policy. An EMS enables an organization of any size or
type to control the impact of its activities, products, or services on the
natural environment, allowing it to not only achieve and maintain compli-
ance with current environmental requirements, but to recognize and
proactively manage future issues that might impact mission sustainability.
Implementing an EMS generally will not require installations to create an
entirely new system. Many of the required elements of an EMS are
already in place as part of existing programs.
Mission Focus
Each installation's EMS must focus on supporting and sustaining the in-
stallation's mission. This guide shows how to identify and incorporate
mission priorities in EMS implementation. The resulting management sys-
tem will help organizations identify, manage, and mitigate the environ-
mental impacts associated with mission-related activities.
ISO 14001
The Army leadership has decided to use the ISO 14001 standard devel-
oped by the International Organization for Standardization as a model for
developing and implementing an EMS at each installation. The ISO
14001 standard provides EMS specifications that apply to a wide variety of
1-1
-------
organizations. Click here to view the ISO 14001 standard. This imple-
mentation guide is specifically designed to enable Army installations to
develop a mission-focused EMS that conforms with the ISO 14001 stan-
dard.
Figure 1-1 shows the ISO 14001 model, which employs a continual cycle
of policy, planning, implementation and operation, checking and corrective
actions, and management review. The ultimate goal is to continually im-
prove environmental performance as the cycle is repeated.
Figure 1-1. ISO 14001 Model with Mission Focus
Environmental
Policy
Management
Review
Implementation
& Operation
IMPLEMENTATION REQUIREMENTS
Executive Order (EO) 13148, "Greening the Government Through Leader-
ship in Environmental Management," directs all federal agencies as fol-
lows:
• By 31 December 2005, each agency shall implement an [EMS] at
all appropriate agency facilities based on facility size, complexity,
and the environmental aspects of facility operations.
• The facility [EMS] shall include measurable environmental goals,
objectives, and targets that are reviewed and updated annually.
1-2
-------
Introduction
• Once established, [EMS] performance measures shall be incorpo-
rated in agency facility audit protocols.1
ARMY POLICY
General
The Deputy Assistant Secretary of the Army (Environment, Safety and
Occupational Health) signed an action memorandum on EMS, which di-
rects installations to meet the following requirements:
• Implementation shall be initiated NLT [no later than] FY04, with an
environmental management system in place NLT 31 December
2005.
• Adopt the internationally recognized management system standard,
ISO 14001, as a goal.
• Full conformance with the ISO 14001 standard shall be completed
NLT FY09.2
The action memorandum also states the following:
• Third party registration to the standard is not required. However,
installation commanders may pursue registration when it provides
clear and documented mission benefits.
• Implementation of the standard will be incremental. It will be con-
sistent with available funds and the requirements of Executive Or-
der 13148, "Greening the Government Through Leadership in Envi-
ronmental Management."
The Army's EMS policy directs a phased approach to satisfying EO 13148
and EMS implementation:
• First, comply with EO 13148 by meeting the Army/Department of
Defense (DoD) implementation metrics by 31 December 2005 (see
below).
1 Executive Order 13148, "Greening the Government Through Leadership in Envi-
ronmental Management," April 21, 2000.
2 Memorandum for Assistant Chief of Staff for Installation Management, from Ray-
mond J. Fatz, Deputy Assistant Secretary of the Army (Environment, Safety and Occupa-
tional Health), OASA(I&E), Subject, Army Environmental Management System, July 13,
2001. Available from http://aec.army.mil/usaec/support/ems-requirements080601.pdf.
1-3
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• Then, use continual improvement to build the remaining parts of a
mission-focused, ISO 14001-conformant EMS by December 2009.
Developing and implementing an EMS is required at all appropriate Army
installations, including those located in the Continental United States
(CONUS) and Outside Continental United States (OCONUS), as well as
all Army Reserve and National Guard installations. Click here for a defini-
tion and listing of appropriate organizations and installations. Installations
OCONUS will integrate EMS elements into existing management practices
and procedures, in consonance with Final Governing Standards and ap-
plicable host nation requirements. As indicated previously, no boilerplate
EMS applies to all Army installations. Although the ISO 14001 standard
can be applied to many different types of organizations, differences in or-
ganization and mission dictate that EMSs must be tailored to individual
installations. Installation staffs must individually determine the best way to
design or adapt their own management procedures to conform with the
ISO 14001 standard.
Click here for the latest EMS guidance specific to Army National Guard
(ARNG), OCONUS, and government-owned, contractor-operated (GOCO)
installations and other special categories of organizations.
Metrics and Reporting Requirements
Beginning first quarter FY04, installations must submit data semiannually
to the Environmental Quality Report (EQR) on EMS implementation
status. The Army will track EMS implementation in the Strategic Readi-
ness System (SRS). Click here for the latest guidance on reporting re-
quirements. The following Army EMS implementation metrics3 meet the
requirements of EO 13148 and should be completed by the listed dates:
• Develop an ISO 14001-conformant environmental policy state-
ment, consistent with the Army EMS action memorandum, signed
by the commander, NLT 30 September 2003.
• Complete an installation-wide EMS self-assessment with appropri-
ate documentation, signed by the commander, NLT 30 March 2004.
3 Memorandum for Deputy Assistant Secretary of the Army (Environment, Safety and
Occupational Health) from John Paul Woodley, Jr., Assistant Deputy Undersecretary of
Defense (Environment), Subject, Environmental Management System (EMS) Implemen-
tation Criteria and Metrics, 30 Jan 2003.
1-4
-------
Introduction
• Complete a written EMS implementation plan with defined dates,
identified resources, and organizational responsibilities for imple-
menting a mission-advancing, ISO 14001-conformant EMS, signed
by the commander, NLT 30 September 2004.
The meaning of the term commander, as used in this guide, varies by organization:
• For active-Army and Army Reserve organizations, it means the garrison com-
mander.
• For ARNG organizations, it refers to the adjutant general or garrison com-
manders at major training sites.
• For civil works organizations, it refers to the district chief of operations.
Environmental aspect is an element of an organization's activities, products, or ser-
vices that can interact with the environment. Chapter 2 discusses environmental as-
pects in detail.
• Compile a prioritized list of environmental aspects NLT 30 March
2005.
• Provide awareness-level briefings on the Army's EMS to all appro-
priate installation personnel NLT 30 March 2005.
• Complete at least one management review in accordance with the
installation's documented policy for recurring internal EMS man-
agement reviews NLT 31 December 2005.
These metrics are minimum requirements. Installations should complete
them before the scheduled dates if resources allow. Some organizations
have reported that moving faster maintains interest and makes implemen-
tation easier.
Scheduling management reviews. Instructions regarding the EMS management review
do not appear until Step 30 of this guide. However, we recommend periodic (annual or
semiannual) management reviews during the implementation process as well. These
reviews will help you meet the Army EMS implementation metrics above and maintain
senior leader oversight of EMS implementation.
RESOURCING IMPLEMENTATION
Army leadership has programmed funds for installation-wide EMS imple-
mentation, including ranges and training areas. Implementation funding
will be available starting in FY04 and will continue through FY06. Click
here for the latest EMS funding guidance. Typical installation resource
requirements for implementing an EMS include the cost of people, time,
and contractors. As the Army gains experience in implementing EMSs,
1-5
-------
implementation costs will likely decrease. Although initial costs of devel-
oping and implementing an EMS can be significant, the program will lead
to efficiencies in the long term. Click here to view case studies of EMS
costs and cost savings.
Updated tools, training materials, example documentation, and guidance
are available to help Army installations implement an EMS. For informa-
tion related to EMS tools and guidance, see the Defense Environmental
Network Information Exchange (DENIX) Army EMS website
https://www.denix.osd.mil/denix/DOD/Library/EMS/ems.html.
IMPLEMENTATION ROADMAP
This guide identifies 30 EMS implementation steps that lead to a mission-
focused, ISO 14001-conformant EMS. Chapter 2 provides step-by step
instructions. Figure 1-2 is a suggested implementation sequence chart,
which provides installations a visual overview of the 30 steps. The steps
are arranged in a logical order that progressively builds the essential parts
of an ISO-conformant EMS.
The sequence in Figure 1-2 differs slightly from ones you may see in other
EMS guidance documents:
• It contains additional requirements specifically designed for Army
installations.
• Certain requirements or elements have been moved forward in the
implementation sequence to help installations get an early start in
meeting dates associated with Army implementation metrics.
• Requirements associated with communications and documentation
procedures have been moved forward in the sequence to help in-
stallations manage the implementation process.
• The implementation sequence is not rigid and can be adapted to
accommodate an installation's specific situation. In Figure 1-2, yel-
low boxes highlight the requirements associated with Army and
DoD implementation metrics, which must be completed by 31 De-
cember 2005.
1-6
-------
Figure 1-2. Suggested EMS Implementation Sequence for Army Installations
LMI
The elements shown in the blocks below provide a logical sequence for planning and
implementing an EMS, starting at the left side of the page and following the arrows. You
may also choose to revise this sequence to accommodate specific situations at
your installation. We recommend you carefully read the entire guide before
choosing an alternative sequence.
31 December 2005 Milestone:
At a minimum, the Army metric elements (in yellow)
must be completed and an annual management review
performed before 31 December 2005 in order to satisfy
Army Policy and EO 13148 requirements.
Start Here
Commander (CDR) and
EMS Management Representative(EMSMR)
Initiate EMS Planning (Steps 1-8):
EMSMR and Cross Functional
Team (CFT) Implement the EMS:
CDR Selects EMSMR
CDR/EMSMR Coordinate with EQCC and
Select Cross Functional Team (CFT)
CFT Receives EMS Training
CFT Conducts Self-Assessment
CDR/EMSMR Brief the EQCC
CFT Prepares EMS Implementation Plan
CDR Approves EMS Implementation Plan
CDR/EMSMR Hold EMS Kickoff Meeting
Mission
Step 10
Environmental
Policy, ISO 14001
Sec 4.2
Step 11
Awareness
Training ISO 14001
Sec 4.4.2
H
Step 12
Documentation
ISO 14001
Sec 4.4.4
>n ^^ D
Step 13
ocument Contr
ISO 14001
Sec 4.4.5
t
NOTE: The EMSMR leads the CFT.
After all EMS elements are
implemented, the system shifts to a
"continual improvement" mode,
where all EMS elements are
periodically reviewed and revised to
improve mission focus and
environmental performance.
Step 20: Environmental Management
Programs, ISO 14001, Sec 4.3.4
Step 21: Objectives & Targets
ISO 14001. Sec 4.3.3
Step 22: Structure & Responsibility
ISO 14001, Sec 4.4.1
Step 23: Operational Control
ISO 14001, Sec 4.4.6
Step 24: Competence Training,
ISO 14001, Sec 4.4.2
Step 25: Monitoring and Measurement
ISO 14001, Sec 4.5.1
Step 26: Records, ISO 14001, Sec 4.5.3
Step 15
Legal and Other
Requirements
ISO 14001
Sec 4.3.2
Step 14
Communicatio
ISO 14001
Sec 4.4.3
I
I
Step 27
Emergency
Preparedness and
Response
ISO 14001
Step 28
on-Conformance and
Corrective and Preventive
Actions, ISO 14001
Sec 4.5.2
;
ive
Step 30
Management Review
ISO 14001, Sec 4.6
Step 29
EMS Audits
ISO 14001, Sec 4.5.4
30 September 2009 Milestone:
Installations must complete all the elements
above and have a fully functioning EMS
(ISO 14001 compliant).
1-7
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ROLES AND RESPONSIBILITIES
Chapter 2 recommends specific roles and responsibilities for overseeing
and completing the elements shown in Figure 1-2. Senior leaders have a
particularly important role in supporting EMS implementation. The com-
mander has overall responsibility for the implementation but delegates au-
thority for executing the process to a designated EMS management repre-
sentative. The installation environmental quality control committee
(EQCC), or similar senior leader advisory group, provides installation-wide
oversight and support to the EMS implementation effort.4 Establishing an
active EQCC facilitates the senior leader oversight and buy-in vital to EMS
implementation. All on-site contractors are required to operate in confor-
mance with and support the EMS. Click here for detailed guidance
regarding contractors and non-DoD entities located on the installation.
CONTINUAL IMPROVEMENT
An EMS must be continually updated to address changes in missions, en-
vironmental aspects and impacts, legal requirements, roles and responsi-
bilities, and training requirements. Audits and periodic reviews of the EMS
procedures and documentation identify areas for improvement. Once im-
plementation is completed, EMS responsibilities continue, but mostly at
the operational or functional process level. If the EMS has been properly
designed and implemented, most day-to-day EMS activities become part
of how the installation conducts its business, as opposed to a special,
separate program. Chapter 2 describes key EMS and continuous im-
provement activities.
FREQUENTLY ASKED QUESTIONS
Click here to view frequently asked questions and responses regarding
EMS implementation.
4 We use the abbreviation EQCC throughout this report to refer to an actual EQCC or
any similar senior leader advisory group.
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Chapter 2
Step-by-Step Guidance
INTRODUCTION
The remainder of this guide leads the user through required actions for
EMS implementation by defining terminology, describing recommended
actions, identifying those involved, and giving detailed instructions, exam-
ple documentation, and links to tools and other materials that will help im-
plement the EMS. The sequence of steps shown in this guide is not
unalterable. You can rearrange the sequence to fit your situation.
COMMANDER AND EMS
MANAGEMENT REPRE
SENTATIVE INITIATE EMS
PLANNING (STEPS 1-8)
CDR selects EMSMR
CDR/EMSMR coordinate with EQCC and selects CFT
CFT receives EMS training
CFT conducts self-assessment
CDR and EMSMR meet with EQCC
CFT prepares EMS implementation plan
CDR approves EMS implementation plan
CDR/EMSMR hold EMS kickoff meeting
EMS implementation at the installation begins with the commander (CDR).
The CDR must ensure that several key actions are completed before EMS
implementation can actually start:
• Designate the EMS management representative (EMSMR).
• Coordinate with senior leaders and select the cross-functional team
(CFT).
• Conduct a self-assessment.
• Meet with the EQCC.
• Prepare an implementation plan.
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Step 1. Designate the EMSMR.
The CDR designates the EMSMR, who is responsible for managing and
overseeing the EMS implementation effort. In some cases, the CDR may
designate him or herself as the EMSMR to ensure the appropriate level of
visibility and support for EMS. If so, the CDR should also designate an ac-
tion officer or assistant to attend to the day-to-day details of implementing
the EMS. In other cases, the CDR might designate a key staff member as
the EMSMR. The EMSMR (or designated action officer) should possess
• the necessary authority,
• a good understanding of installation organizations, and
• the project management and facilitation skills needed to succeed in
this role.
The EMSMR coordinates the implementation, manages day-to-day opera-
tions, and leads and manages the CFT. Specific responsibilities include
• planning and managing EMS implementation,
• delegating tasks and establishing deadlines,
• collecting and evaluating work, and
• arranging training, guidance, and assistance.1
The CDR should consider background, experience, availability, and other
appropriate factors when designating the EMSMR. Consider individuals
outside the environmental office when choosing the EMSMR. The EMS
needs installation-wide support to be effective, and designating a non-
environmental person to implement the system conveys the message that
EMS involves much more than environment. In many cases, members of
the CDR's special staff are prime choices for the EMSMR position.
Step 2. Coordinate with senior leaders and select the CFT.
EMS implementation requires support from across the installation. The
CFT coordinates this support and is responsible for implementing the EMS
installation wide. This step has two objectives: coordinating with senior
leaders on the installation to get their buy-in and (in some cases) obtaining
a CFT member from their organizations. Under the leadership of the
1 The Public Entity Environmental Management System Resource (PEER) Center,
How to Implement an EMS [on-line document], undated [cited February 2003]. Available
from http://www.Deercenter.net/howtoimplement/.
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Step-by-Step Guidance
EMSMR, CFT members become the EMS experts and proponents in each
functional area. Typical responsibilities of the CFT include
• gathering, organizing, and disseminating information;
• delegating EMS tasks and general responsibilities;
• collecting and evaluating work;
• developing EMS procedures;
• advising, coordinating, and facilitating EMS implementation;
• representing all functional areas of the installation regardless of ac-
tual CFT representation; and
• managing the reactions to the changes resulting from EMS imple-
mentation.2
Each CFT member should have clear responsibilities for representing and
coordinating with specific organizations on the installation. For example, a
CFT member from a military unit might serve as the CFT representative
for all the military units on the installation.
Do the following to make the CFT succeed:
• Look to the leaders. You need motivated, organized individuals: let supervi-
sors identify the appropriate candidates.
• Provide training.
• Clearly communicate member roles and responsibilities.
• Secure time commitments from management.
(The PEER Center, How to Implement an EMS)
CFT members should include a representative from the environmental of-
fice as well as representatives concerned with key installation activities
such as operations and training, logistics, acquisition, and ranges. The
CDR and EMSMR should seek volunteers or ask other senior leaders on
the installation to recommend employees to serve on the CFT.
2 PEER Center, How to Implement an EMS [on-line document], undated [cited Feb-
ruary 2003]. Available from http://www.peercenter.net/howtoimplement/.
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The CFT should consist of no more than eight people. The CDR and
EMSMR should ask the following questions when selecting the team
members:
• Are they motivated, interested, and able?
• Are they experts in their own functional areas?
• Are they good communicators?
• Can they give credence to the EMS program?3
• Do coworkers trust and respect them?
• Are they responsible for environmental issues?4
• Do they represent functional areas that are directly concerned with
or potentially affected by environmental issues?5
• Are they aware of the installation's most critical environmental is-
sues?
• Are key functions represented?6
The CDR and EMSMR should ask the commanders or supervisors of
various tenants, activities, and units to approve potential team members,
after which the CDR announces the team.
Step 3. Orient and train the CFT in EMS implementation.
After the EMSMR and CFT members are selected, the EMSMR should
hold a CFT orientation meeting before CFT training begins. At this meet-
ing, the EMSMR should do the following:
• Provide members with copies of the EMS implementation guidance
and other pertinent information.
• Establish an initial CFT EMS training schedule and set additional
research assignments, if needed.
3 PEER Center, How to Implement an EMS [on-line document], undated [cited Feb-
ruary 2003]. Available from http://www.peercenter.net/howtoimplement/.
4 PEER Center, How to Implement an EMS [on-line document], undated [cited Feb-
ruary 2003]. Available from http://www.peercenter.net/howtoimplement/.
5 PEER Center, How to Implement an EMS [on-line document], undated [cited Feb-
ruary 2003]. Available from http://www.peercenter.net/howtoimplement/.
6 PEER Center, How to Implement an EMS [on-line document], undated [cited Feb-
ruary 2003]. Available from http://www.peercenter.net/howtoimplement/.
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Step-by-Step Guidance
• Establish a schedule for periodic CFT meetings (weekly breakfast,
monthly, etc.). The periodic CFT meetings need not be formal, just
a venue for reviewing the current implementation status, discussing
new initiatives, checking status of research assignments, etc.
• Appoint a member of the CFT as the EMS document coordinator.
This person will be responsible for ensuring the proper documents
are created, stored, and maintained in accordance with procedures
established later in the implementation process. This can be a big
job, and it will continue to require effort beyond initial EMS imple-
mentation. The document coordinator should have a strong infor-
mation technology (IT) background because the EMS documenta-
tion is best managed electronically. This person should have
access to the necessary files (with appropriate security clearances)
and the capability to store and modify documents, as well as dis-
tribute information as needed. Choose someone well organized:
this job is key to initial EMS implementation and continuous opera-
tion.
• Choose a member of the CFT as meeting recorder (possibly the
same person as the EMS document coordinator). This person is
responsible for properly documenting each meeting (including the
initial one) through written minutes. The recorder also files and
maintains the meeting records in accordance with the procedures
the EMS document coordinator establishes.
Is EMS management software necessary?
Numerous commercial off-the-shelf (COTS) software packages are available to help
you implement and manage your EMS. In May 2003, the Army completed an evalua-
tion of 19 of these systems, using a variety of evaluation criteria. These systems can
be very useful, providing you choose a system appropriate for your needs. Don't buy
the first one you see. Click here to view the EMS software evaluation, and do your
homework!
All team members need in-depth EMS training and a clear understanding
of their roles and responsibilities to plan and lead the implementation ef-
fort. Specific training objectives should include the following:
• EO requirements
• Army policy
• ISO 14001 requirements
• EMS fundamentals (what it is, how it works, who is responsible
etc.).
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Training is available from many sources. The CFT can be trained by con-
tractors on- or off-site, at private institutions or training centers, or through
Army training sites. The training can be done in-house via distance learn-
ing or train-the-trainer sources. Click here to find information on training
resources.
Step 4. Conduct a self-assessment (by 30 March 2004).
Army EMS Implementation Metric
Self Assessment: An installation-wide EMS self-assessment consistent with Army
EMS policy has been conducted, documented, and briefed to the CDR.
The CFT is responsible for performing a self-assessment to analyze the
installation's current conformance with the ISO 14001 standard. This sys-
temic-level self-assessment should examine installation policies, proc-
esses, and procedures relevant to EMS requirements. The self-
assessment itself is not a required ISO 14001 element, but it is one of the
Army's EMS implementation metrics. It should require only a few days to
complete, and the assessment team (headed by the EMSMR) should be
no more than six people.
CFT members should have a basic understanding of ISO 14001 before
conducting the self-assessment. Completing initial EMS training, plus
some additional self-study, should suffice. Use the following links to ac-
cess tools to assist with the assessment. These assessment tools help
you determine what your installation has and what it needs to have for an
Army-approved EMS. (Click here to view a self-assessment worksheet.
Click here to view a gap analysis checklist. Click here to view a gap
analysis scoring worksheet.) Since the self-assessment is one of the
Army's EMS implementation metrics you should maintain internal records
of the results. However, ISO 14001 does not require self-assessment re-
cords for conformance.
The self-assessment team should report the results to the CDR. These
results ultimately help the EMSMR and CFT develop an implementation
plan and identify the resources needed to implement the EMS.
Because most Army installations have well-established environmental programs,
some basic components of the EMS are likely already in place.
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Step-by-Step Guidance
Step 5. Meet with the EQCC.7
After the self-assessment is completed, the CDR should meet with the
EQCC and discuss the following:
• EMS implementation efforts
> Provide a brief EMS introduction and overview.
> Explain that the garrison is implementing an EMS per Army pol-
icy and EO 13148.
> Explain that the garrison will involve them in future tasks, such
as implementation planning and management reviews.
> Obtain buy-in and set the stage for future meetings.
• Results from the self-assessment
> Explain the purpose of the self-assessment.
> Provide the installation's EMS status—the requirements already
met and those pending.
> Ask for assistance in highlighting areas that may require signifi-
cant resources (including non-environmental ones) and identify-
ing funding sources.
• Reviewing and revising the environmental policy statement
> Explain that the environmental policy is an Army metric for im-
plementing the EMS and must be completed by 30 September
2003.
> Explain that your staff will revise the installation's environmental
policy to reflect EMS implementation efforts and that they will be
included in the staffing process.
> Obtain input.
If your installation does not have the required EQCC or it has not been
meeting regularly, you must form one (as required by Army Regulation
(AR) 200-1) and set a regular meeting schedule. The EQCC is the ideal
senior leader group to participate in EMS implementation because it in-
cludes mission commanders and other senior representatives from all the
major organizations and tenants on the installation.
7 We use the abbreviation EQCC throughout this report to refer to an actual EQCC or
any similar senior leader advisory group.
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Step 6. Prepare an EMS implementation plan.
Using the results of the self-assessment and guidance from the meeting
with the EQCC, the EMSMR should begin working with the CFT to de-
velop an EMS implementation plan and associated budget:
• The implementation plan is critical because it is the roadmap for
EMS implementation across the installation. Completing the plan
and obtaining command approval is also an Army EMS implemen-
tation metric.
• Use the self-assessment results and this guidance to determine
what parts of the EMS your installation needs and how to complete
them.
• The EMS implementation plan should detail the key actions needed
to complete the elements required in an ISO 14001-conforming
system, who completes those elements, the resources needed,
who provides the resources, and when the work is completed.8
• The plan must clearly cite the desired goals for EMS implementa-
tion (for example, whether certification is desired) and clearly define
roles and responsibilities for plan execution. Make sure it includes
key milestones.
• Use automated project planning tools as needed to help plan and
manage the EMS implementation process over time.
Some organizations may elect to establish timekeeping codes to track
hours spent implementing the EMS. These data can be useful in tracking
total EMS implementation costs and in continuing project management
efforts.
Click here to view an example implementation plan.
8 NSF International Strategic Registrations (NSF-ISR), Ltd., Environmental Manage-
ment Systems—An Implementation Guide for Small and Medium-Sized Organizations,
2001, p. 13.
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Step-by-Step Guidance
Step 7. Obtain CDR approval of the EMS implementation plan (by 30
September 2004).
Army EMS Implementation Metric
Implementation Plan. A written plan with defined dates, identified resources,
timelines, and organizational responsibilities for implementing an installation-wide
EMS consistent with Army EMS policy has been signed by the CDR.
When completed, the implementation plan and budget must be staffed
through all senior leaders in the garrison and non-garrison organizations,
and then reviewed and signed by the CDR. By concurring with the imple-
mentation plan, mission commanders and directors commit to providing
the necessary resources (funding and manpower) for EMS implementa-
tion. Be certain to identify specific funding sources in the plan budget.
Resources include human resources and specialized skills, technology, and funding.
After the plan is approved, file it in an accessible location (see documenta-
tion requirements) and give it and the budget to the installation manage-
ment regional office (IMRO). Use the approved plan as the primary
project management tool to identify potential roadblocks and to ensure
task accomplishment. Periodically review implementation progress with
regard to milestones and analyze the budget. ISO 14001 does not require
documentation or records regarding the implementation plan. However,
since the plan is required by the Army implementation metrics, we rec-
ommend controlling the implementation plan under the document control
system (Step 13) and tracking implementation progress with appropriate
records (Step 26).
Step 8. Hold an EMS implementation kickoff meeting.
An installation-wide EMS implementation kickoff meeting is a good way to
formally announce the EMS effort. Explain why the installation is imple-
menting an EMS and the benefits that will result from EMS implementa-
tion. Present the self-assessment results as the foundation for EMS
implementation efforts across the installation and discuss the installation
and Army goals for EMS implementation. A wide variety of people should
attend this kickoff meeting, including the following:
• CDR
• EMSMR
• CFT
• EQCC
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• Installation master planning representative
• Installation environmental staff
• Representatives from all installation functional areas
• IMRO representative, if available
• Unions
• Contracting officer or contracting officer's representative
• Community advisory boards
• Interested parties from the community.
The CDR should sponsor and announce the kickoff meeting. The EMSMR
prepares the agenda and supports the CDR as required. At the kickoff
meeting, the CDR should introduce the installation's EMS efforts, explain
why the initiative is important, and briefly overview how the implementa-
tion is going to occur.
Click here to view draft talking points for the CDR's briefing.
Ensure that members of the environmental management office attend the
kickoff meeting since they provide environmental technical support regard-
ing specific environmental issues. Include representatives from all func-
tional areas on the installation to inform them how they are expected to
contribute to the implementation effort. Good representation from tenants,
activities, and units at the installation is essential. Emphasize that EMS
implementation requires support from across the installation. Tenants, ac-
tivities, and units are all involved in implementation efforts. Finally, invite
an IMRO representative. The IMRO is the next higher headquarters
above the garrison in the Installation Management Agency (IMA) organiza-
tional structure. An IMRO representative may be willing to attend the
kickoff and make some remarks regarding the IMA and the regional per-
spective on the EMS implementation initiative.
EMSMR AND CFT IMPLEMENT THE EMS
At this point, most of the preparatory work is complete and you are ready
to begin the critical phase of EMS implementation. Except for "Mission
Focus," all elements in Figure 2-1 directly relate to the requirements of
ISO 14001. Those highlighted in yellow include requirements contained in
the Army and DoD implementation metrics.
2-10
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Step-by-Step Guidance
Figure 2-1. EMSMR and Cross Functional Team Implement the EMS
Step 10
Environmental
Policy. ISO 14001
Sec 4.2
Step 11
Awareness Training
ISO 14001
Sec 4.4.2
Documentation
ISO 14001
Sec 4.4.4
Document Control
ISO 14001
Sec 4.4.5
Step. 20: Environmental Management
Programs, ISO 14001. Sec 4.3.4
SteD21: Objectives & Targets
ISO 14001. Sec 4.3.3
Step 22: Structure & Responsibility
ISO 14001. Sec 4.4.1
Step 23: Operational Control
ISO 14001. Sec 4.4.6
Steg 24: Competence Training,
ISO 14001. Sec 4.4.2
Step 25: Monitoring and Measurement
ISO 14001, Sec 4.5.1
Step 26: Records. ISO 14001. Sec 4.5.3
S
^ En'
I
^
^^"
Steps 16-19
Environmental
Aspects
ISO 14001
Sec 4.3.1
Step 15
Legal and Other
Reguirements
ISO 14001
Sec 4.3.2
Step 14
Communication
ISO 14001
Sec 4.4.3
Emergency
Preparedness and
Step 28
Nonconformance and
Corrective and Preventive
Actions. ISO 14001
Sec 4.5.2
Response
ISO 14001
Sec 4.4.7
Step 30
Management Review
ISO 14001. Sec 4.6
Step 29
EMS Audits
ISO 14001. Sec 4.5.4
Remember, you can rearrange the sequence of these steps as ap-
propriate for your situation. To accelerate implementation and frontload
the implementation metric requirements, you can postpone Steps 12,13,
and 14 until after the aspects and impacts analysis is completed. You can
also perform many of these steps concurrently, if resources permit.
The concept of continual improvement is critical to the EMS. The entire
EMS is periodically reviewed and revised to improve performance and ad-
dress changes in mission or installation operations.
Step 9. Identify mission focus.
Objective
Identify and document installation-level mission priorities.
In order to create a mission-enhancing EMS, the CFT members must in-
terview senior leaders from the major organizations on the installation to
help determine installation-level mission priorities. The interview process
should accomplish the following objectives:
• Identify and prioritize actions that installation units and organiza-
tions must currently perform to maintain readiness or to accomplish
the organization's day-to-day missions.
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• Identify and prioritize anticipated (future) mission requirements (3 to
5 years in the future).
• Identify future large-scale issues that might affect the installation
mission (10 or more years in the future).
• Identify environmental roadblocks or impediments that affect mis-
sion capabilities.
Why Is Mission Focus Important?
An essential step in designing an EMS is understanding the mission priori-
ties of the units and organizations on the installation. The warfighting,
training, and sustaining missions are the top priorities of any installation:
these missions are why the installation exists. The challenge is to identify,
manage, and mitigate the environmental impacts of mission-related activi-
ties. By proactively managing these impacts, you can continue to train
and perform critical activities now and in the future. Clearly identifying fu-
ture missions and large-scale issues early allows greater time and flexibil-
ity for identifying impacts and finding solutions. A well-designed EMS
supports realistic, effective, and sustainable training and operations, and
helps the installation prepare for new mission requirements.
Every installation has a unique set of mission priorities based on the dif-
ferent organizations residing, operating, and training on the installation.
The following paragraphs provide recommendations for planning and
completing mission focus interviews.
1. Develop an inventory of all units and organizations to be inter-
viewed. This will help you make sure that no organization is left
out, set completion milestones, and schedule interviews.
> Get copies of organizational charts and learn the chain of com-
mand, so you understand the hierarchy of the military organiza-
tions.
> As you develop the inventory, you must consider all units, or-
ganizations, and tenants on the installation, including Table of
Organization and Equipment (TOE), Table of Distribution and
Allowances (TDA), active, Reserve, and ARNG.
> If your installation has multiple units with the same organization
and mission (three infantry battalions, for example), limit the in-
terview to one of those units.
> Identify unit environmental compliance officers (ECOs) in mili-
tary units and their respective level of training per AR 200-1.
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Step-by-Step Guidance
> In preparation for selecting the leaders to be interviewed, review
recent notices of violation (NOVs), environmental enforcement
actions, and Environmental Program Assessment System
(ERAS) or Environmental Compliance Assessment System
(EGAS) findings. Be certain to interview the leaders of organi-
zations where environmental problems or issues have been
identified.
2. Notify leaders and ECOs to be interviewed.
> Explain the purpose of the interview.
> Provide read-ahead materials and request completion and re-
turn of the unit information sheet along with a copy of the unit
mission-essential task list (METL), if available.
> When scheduling interviews, begin with the garrison com-
mander, senior mission commanders, and directors of non-TOE
activities on the installation. Include senior leaders of any non-
Army organizations that are tenants on the post.
> The read-ahead materials should include an EMS information
brochure, unit information sheet and instructions, and the inter-
view format and instructions. Click here to view an example unit
information sheet.
3. Select the interviewers and prepare for the interviews. Be cer-
tain to match the interviewer's experience and knowledge with the
organization being interviewed. Persons interviewing commanders
of military units should have a good understanding of Army units
and operations and should spend time reviewing the unit informa-
tion sheet before conducting the interviews.
4. Conduct the Interviews.
> Begin each interview by explaining the purpose of the interview
and how the results will be used to develop a mission-
enhancing EMS. Use a written format sheet to guide the dis-
cussion and record information. Click here to view a recom-
mended interview format. Click here to view the instructions for
using the interview template.
> Major interview objectives
• Identify current missions and mission priorities. What are
the unit's most important missions and mission-related
activities? One technique for determining priorities is to
perform a hypothetical resource allocation. If the leader had
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100 "resource units" to fund mission priorities, how would
they be distributed?
• Identify and prioritize anticipated future missions (3 to 5
years out). What new missions or weapons systems will be
assigned to the unit in the near future? Where do these fall
in the priority scheme?
• Identify future large-scale issues that might affect the
installation and its missions (10 or more years out). Ask the
leader to discuss any situations that might significantly limit
future mission capabilities. Examples include regional
issues, such as water shortages and power grid or
infrastructure limitations, and military issues, such as
increased training space requirements for new longer-range
weapons systems.
• Discuss environmental "roadblocks" or issues that negatively
affect the mission. These should be issues that are difficult
to work around or that cause significant impairments to the
mission or training. Examples include endangered species
habitats, noise restrictions, and air emission restrictions
(dust, smoke, etc.).
5. Determine the installation's top mission priorities. After com-
pleting all the interviews, combine the results and total the resource
units for each mission listed on the interview sheets. The activities
with the highest (composite) resource allocations are the installa-
tion's top mission activities. When the roll-up (installation-level)
mission priorities are determined, the CFT (with assistance from the
environmental office) reviews and verifies the results, which will be
used in the aspects and impacts analysis, described in Steps 16
through 19. As you determine the significance of environmental
aspects and impacts, be certain to consider the aspects and im-
pacts associated with the top priority missions identified in this step.
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Step-by-Step Guidance
Step 10. Revise and sign installation environmental policy
statement (by 30 September 2003).
Environmental Policy,
ISO 14001, Section 4.2
Army EMS Implementation Metric
Policy. An installation-wide environmental policy has been signed by the CDR and
made available to installation personnel and the public.
Objective
Complete an installation environmental policy statement that conforms to
ISO 14001 requirements.
Importance of the Environmental Policy
The environmental policy is the installation's statement of the overall direc-
tion and principles of action regarding its environmental responsibility. "It
sets the goal as to the level of environmental responsibility and perform-
ance required of the organization, against which all subsequent actions
will be judged."9
ISO 14001 defines an environmental policy as a statement by the organization of its
intentions and principles in relation to its overall environmental performance, which is
a framework for action and for setting its environmental objectives and targets.
Your installation probably already has an installation environmental policy.
Use this opportunity to review the policy and make sure it fulfills the re-
quirements described below. The EMSMR will need to work with the CDR
and CFT to review and revise, or create, a suitable environmental policy
statement.
Policy Content
In order to conform with ISO 14001 and be relevant to an Army installa-
tion, the policy must include the following key features:
• It must be appropriate for the nature, scale, and environmental im-
pacts of the installation's activities, products, or services. This is
one of the reasons why we examined mission focus in Step 9. The
policy must have some reference to the installation's mission.
9 International Organization for Standardization, Environmental management sys-
tems—General guidelines on principles, systems and supporting techniques, ISO 14004,
1996, Section 4.1.4, p.6.
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• It must include a commitment to continual improvement and pre-
vention of pollution. Nothing elaborate is required—just a brief
statement that commits the installation to these two concepts.
ISO 14001 defines continual improvement as the process of enhancing the EMS to
achieve improvements in overall environmental performance in line with the organiza-
tion's environmental policy.
ISO 14001 defines prevention of pollution as the use of processes, practices, materi-
als, or products that avoid, reduce, or control pollution, which may include recycling,
treatment, process changes, control mechanisms, efficient use of resources, and ma-
terial substitution.
• The policy must make a commitment to comply with relevant envi-
ronmental legislation and regulations and with other requirements
to which the installation subscribes. If the installation has already
made this commitment, it can be stated in one sentence in the pol-
icy.
• It must provide the framework for setting and reviewing environ-
mental objectives and targets. Again, no elaborate explanation is
required. You might state that you will be setting objectives and
targets in the same sentence as continual improvement.
• The policy must be documented, implemented, maintained, and
communicated to all employees. The policy must be managed and
controlled in accordance with your document control procedures
(Step 13). It must be signed by the CDR and reissued following
changes of command (some installations make the initial signing
ceremony a media event or press release). It must also be com-
municated to and understood by everyone in the organization.
Some installations have used wallet cards to assist in this effort.
• And finally, the policy must be available to the public, at least as re-
quested. Your installation may choose to publish the policy in a
newspaper or on your website.10
10 International Organization for Standardization, Environmental management sys-
tems—Specification with guidance for use, ISO 14001, 1996, Section 4.2, p. 2.
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Step-by-Step Guidance
Optional Content
Your environmental policy may include other goals for which your installa-
tion strives, for example,
• minimize any significant adverse environmental impacts of new
missions or processes through the use of the integrated environ-
mental management procedures and planning;
• incorporate sustainability and life-cycle thinking in planning deci-
sions;
• select products that minimize environmental impacts in production,
use, and disposal;
• reduce waste and the consumption of resources (materials, fuel,
and energy) and commit to recovery and recycling, as opposed to
disposal, where feasible;
• improve environmental education and training of the workforce;
• share environmental experience;
• promote involvement of and communication with interested parties;
• work with local communities toward sustainable development; and
• encourage the use of EMS by suppliers and contractors.11
Anything you include in the policy is subject to audit. If you commit to
something, you must follow through and be able to prove it.
Staffing and Finalizing
In most cases, the EMSMR is responsible for drafting a new or revised
environmental policy. After completing the draft, staff the policy according
to your installation's staffing guidance. Staffing is essential for obtaining
constructive input and commitment from those who will implement the pol-
icy. The garrison commander will want to ensure that key subordinates
and the installation's major tenant commanders understand and support
the environmental policy.
Click here to view an example of an ISO 14001-conformant, installation-
level environmental policy from Fort Lewis. Click here to view Toby-
hanna's policy statement.
11 ISO 14004, Section 4.1.4, p. 7.
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Step 11. Plan and conduct EMS awareness training
(by 30 March 2005).
Training, Awareness and
Competence, ISO 14001,
Section 4.4.2
Objective
Army EMS Implementation Metric
Training. Installation personnel defined as appropriate by the CDR have received
awareness-level EMS training that is consistent with Army EMS policy and docu-
mented.
Plan and complete EMS awareness training to meet ISO 14001 require-
ments.
Importance
This is not the same as the competency-based environmental training, covered in
Step 24, which ISO 14001, Section 4.4.2, also requires.
ISO 14001 addresses awareness and competency training in the same
section, but does not clearly distinguish between the two. The Army has
decided to address awareness training early in the implementation proc-
ess to prepare and educate all installation personnel on the basic con-
cept of the EMS and how it might generally affect them. Competency-
based training addresses job-specific issues and occurs later in the im-
plementation process, after key elements of the EMS are already in place.
One of the great benefits of implementing an EMS is that it educates and
empowers employees so everyone (not just the environmental office) can
find ways to improve environmental performance. The purpose of EMS
awareness training is to create a basic awareness and understanding of
EMS principles. Installations must complete all EMS awareness training
requirements by 31 December 2005.
The purpose of this general environmental awareness training is to
• gain commitment to the environmental policy;
• gain commitment to achieving organization objectives and targets;
and
instill a sense of individual responsibility.
12
12
ISO 14004, Section 4.3.2.4, p. 16.
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Step-by-Step Guidance
The EMSMR should work with the CFT to plan and conduct EMS aware-
ness training annually for all installation personnel. The CFT is re-
sponsible for identifying training needs; establishing and maintaining
procedures for conducting training; and keeping records of the training
that has been completed.
The first time you conduct awareness training, your EMS will probably not
be complete and all the elements and requirements of your EMS will not
be in place. Therefore, you may not be able to address all the require-
ments of Section 4.4.2 in the initial training sessions. Simply tell the at-
tendees that some parts of the EMS are still being developed and they will
receive additional guidance during refresher awareness training. As new
EMS elements are implemented, they must be incorporated into subse-
quent presentations of the awareness training to fully comply with the ISO
14001 requirement (by 2009).
For EMS awareness training content, consider using some of the same
training sources that you used in previous steps (see Step 3 for the CFT
training).
Required Elements
Awareness training is intended to be general in nature. Remember that
individuals whose work has a direct impact on the environment will later
receive specialized competency-based training. The required elements of
EMS awareness training include
• discussion of the installation's environmental policy and the impor-
tance of conformance with the policy and its associated proce-
dures;
• what an EMS is, why the installation needs one, and how the EMS
procedures and requirements help protect the environment;
• examples of relationships between typical work or mission activities
and significant environmental impacts;
• what individuals can (and are expected to) do to protect the envi-
ronment;
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• roles and responsibilities in achieving conformance with the envi-
ronmental policy and procedures and the EMS requirements, in-
cluding emergency preparedness and response; and
• the potential consequences of departure from operating proce-
dures.13
Optional Elements
Optional elements of the EMS awareness training include
• the Army's environmental policy;
• possible actions to minimize or eliminate environmental impacts
and how each employee can contribute;
• the importance of compliance with standard operating procedures
(SOPs) and regulatory requirements;
• the overall improvement of the installation's environmental per-
formance; and
• involvement of the local community and other interested parties.14
Key Actions
Take the following steps to implement EMS awareness training:
1. Meet with the training managers at your installation. Discuss
the requirements for EMS awareness training, the resources avail-
able, and what needs to be done. In most cases, they will assist
you in scheduling and arranging the training sessions and notifying
attendees. You may choose to incorporate EMS awareness train-
ing into regularly scheduled training events, such as unit training
days. You may also have access to computer-based training re-
sources or closed circuit television systems. Always remember that
EMS must be fully integrated into the installation's business proc-
esses and should therefore be a standard part of the installation's
training requirements.
13 ISO 14001, Section 4.4.2, p. 3.
14 Concurrent Technologies Corporation for U. S. Army, Environmental Management
System Guidance Manual: Implementing ISO 14001, p. 33.
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Step-by-Step Guidance
2. Schedule and initiate awareness training.
> Start EMS awareness training as soon as the environmental
policy has been updated and signed. You may have to sched-
ule multiple training sessions to accommodate all the employ-
ees who require the training.
Examples
At one large facility, all EMS awareness training is provided via CBT. The training ma-
terials have been placed on the facility's main computer server. Employees log on and
go through the training materials, which typically requires about 1 hour. The comput-
erized training program tracks who has taken the training and each person's test
scores, thus providing the necessary training records.
Environmental awareness classes provided by one global company use multiple-
choice tests to give the instructor an idea of the staff's level of understanding and help
the employees become more knowledgeable. This company also observed that as
employees learn more about the organization and what it does to protect the envi-
ronment, their sense of ownership grows.
> The awareness training does not have to be conducted in a
classroom. Consider alternatives, such as computer-based
training (CBT), resources listed on the Defense Environmental
Network and Information Exchange (DENIX), training work-
shops, and videos.
> Maintain records of EMS training. These records can be cen-
trally managed at the installation's training office or elsewhere.
They must be kept current and readily available for review or
audit, and their location must be specified in the EMS Records
procedures (see Step 26).
3. Ensure the continuing adequacy of EMS training. Offer training
frequently to reach new employees, transfers between depart-
ments, new contractors, and military units using the training areas.
Most installations provide a monthly or quarterly "newcomers orien-
tation" for new employees and military transfers. This is one venue
for providing EMS awareness training to the target audience. At
range areas, some installations add an EMS briefing to the required
safety brief.
4. Update and maintain training materials. Establishing standard-
ized training materials, and periodically reviewing and updating
them, will help keep the training relevant as situations, missions,
and organizations change. It will also help keep the training consis-
tent, even if different instructors or presentation media are used. It
also provides a good overview of training content for auditors or
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other interested parties. Procedures for maintaining, reviewing,
and updating the training materials should be included in your EMS
document control procedures (see Step 13).
Click here to access awareness training materials and training sources.
Step 12. Initiate EMS documentation.
Objective
IS Documentation,
ISO 14001. Section 4.4.4
u
Importance
Design a standardized framework your installation will use to develop and
organize the various types of documentation required by ISO 14001.
Complete, well-organized documentation is essential for describing, man-
aging, evaluating, and improving the EMS. EMS documentation provides a
written description of your installation's EMS and directions for how things
should be done. Developing EMS documentation is an ongoing process.
Some of the required documentation already exists on your installation—
you just need find it, review it, and ensure that it is kept current. Other
parts of the documentation required by ISO 14001 will take time to de-
velop. The following subsections describe the types of EMS documenta-
tion required. You can now start to develop and organize it.
Documentation Hierarchy
Think of EMS documentation as a tiered system, as shown in Figure 2-2.
Figure 2-2. EMS Document Hierarchy
A
V
More Detail
Procedures
Operational Controls
EMS Records
EMS Documentation
^v provides policy and
' direction
EMS Records describe results
Four types of EMS documentation typically constitute the hierarchy. (Re-
cords are not considered part of documentation.) As you move down the
pyramid, the amount of information, degree of specificity, and number of
pages generally increase.
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Step-by-Step Guidance
Environmental Policy
EMS Manual
The first level of documentation is the environmental policy—a statement
of the installation's mission, intentions, and principles related to its envi-
ronmental performance. (You completed the environmental policy in
Step 10.)
The EMS manual is the central document that describes core elements of
the EMS and how they fit together. The ISO 14001 specification does not
specifically require a manual, but a manual provides a simple and effective
solution for achieving conformance with ISO 14001 EMS documentation
requirements. The manual provides a roadmap of the installation's EMS,
briefly addresses each of the elements within the EMS, and clearly out-
lines the processes the installation uses to run the EMS (think of it as an
EMS concept of operations). You should now develop an outline for your
EMS manual, which lists its basic content:
• Environmental policy
• An outline of the installation environmental management programs
• The location of EMS roles, responsibilities, and authorities
• The location of current EMS objectives and targets
• The location of other documentation, such as emergency response
plans, training plans, and sops (consider using a flowchart)
• The location of document control and records procedures
• The location of monitoring, measuring, and corrective action proce-
dures
• The location of information on regulatory and other requirements.
As you continue implementation of your EMS, you will develop the infor-
mation and procedures described above. Think about organizing the
manual along the lines of the EMS elements shown in Figure 2-1, which
address the requirements in ISO 14001. This will help you check your
conformance with the ISO 14001 standard.
15
15 Concurrent Technologies Corporation for U. S. Army, Environmental Management
System Guidance Manual: Implementing ISO 14001, p. 40; and ISO 14004, Section
4.3.3.2, p. 19.
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The EMS manual is not a comprehensive physical collection of all the de-
tailed procedures developed throughout the EMS implementation. Try to
keep the EMS manual short, no more than one page per EMS element,
and as simple as possible.16 You do not need to describe every detail of
your EMS in the manual: refer to other documents or procedures so that
you can revise individual procedures without revising the entire EMS
manual. The EMS manual can be a useful tool for explaining the installa-
tion's EMS to new employees, auditors, or other interested parties, if de-
sired. Review and update the manual according to your document control
procedure (Step 13) to account for any changes to your EMS. Click here
for examples of EMS manuals developed by other Army installations.
In addition to the EMS manual, the installation needs more detailed docu-
mentation of its EMS.17 As you continue with the implementation process,
you will create procedures for certain elements of the EMS. These proce-
dures are part of the EMS, and your manual should include directions to
locate the EMS procedures. As you create area- or activity-specific in-
structions (SOPs) on certain operations or activities, you may also choose
to include their locations in the EMS manual.
You will not be able to complete the manual until you finish EMS imple-
mentation, but starting it now helps you organize and document ongoing
efforts.
EMS Procedures
The third level of documentation is EMS procedures, which describe how
to operate and maintain the EMS and define the authority, responsibility,
and accountability for implementation and follow-through. Developing and
maintaining EMS procedures is mainly the responsibility of the CFT. This
guide will prompt you to develop the required EMS procedures as you
continue implementation. When you reach the end of this implementation
guide, most of your EMS procedures should be completed. As you oper-
ate and refine your EMS, you will probably see a need to revise some of
the procedures or add new ones to address emerging issues.
Operational Controls (SOPs)
The fourth level is the collection of EMS operational controls or SOPs.
Your installation already has SOPs for most major processes or activities.
Supervisors and leaders are responsible for the SOPs in their functional
areas. As you implement the EMS, the goal is to ensure the SOPs direct
16 NSF-ISR, Environmental Management Systems—An Implementation Guide for
Small and Medium-Sized Organizations, p. 47.
17 NSF-ISR, Environmental Management 5
Small and Medium-Sized Organizations, p. 47.
17 NSF-ISR, Environmental Management Systems—An Implementation Guide for
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Step-by-Step Guidance
employees to perform their jobs in ways consistent with the installation's
environmental policy and the goals and objectives of the EMS. The SOPs
should incorporate significant environmental aspects (Step 19), objectives
and targets (Step 21) and monitoring and measurement procedures (Step
25) into the daily activities or job practices of installation personnel.
CFT members and environmental personnel should work with unit leaders
and civilian supervisors to produce SOPs that support the EMS. These
SOPs give specific, detailed instructions that describe the methods for at-
taining environmental goals and hence complying with environmental pol-
icy.
Although most SOPs are already in place, reviewing and revising them
can be a lengthy process. We recommend you develop a prioritized
schedule that starts with environmentally significant processes or activities
on your installation and maintain steady progress toward revising the
SOPs. Step 23 provides detailed guidance for developing and revising
SOPs.
EMS Records
EMS records are not considered part of EMS documentation. Documen-
tation describes policies, procedures, and other directive information,
while records provide a written history of EMS performance and actions
completed (such as training). We detail the EMS records and related ISO
14001 requirements in Step 26. Click here to view a summary of ISO
14001 and Army requirements for EMS documentation and records.
Step 13. Develop EMS document control procedures. Document control,
ISO 14001, Sec 4.4
Objective
Importance
Develop written procedures to ensure proper management of EMS docu-
mentation and conform to the ISO14001 standard.
In order to effectively implement and operate the EMS, installation per-
sonnel must have access to the information they need to do their jobs
properly. They need correct and current procedures, instructions, and
other reference documents. "Without a mechanism to manage these EMS
documents, the organization cannot be sure that people are working with
the right tools."18 To ensure everyone works with the proper documents,
you need a procedure to describe how the documents are controlled.
18 NSF-ISR, Environmental Management Systems—An Implementation Guide for
Small and Medium-Sized Organizations, p. 50.
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Requirements
ISO 14001 requires only that organizations "establish and maintain"
document control procedures. We recommend these procedures be writ-
ten and maintained as part of the EMS documentation. Your document
control procedure should ensure that documents
• can be easily located and accessed (employees must know where
to find them);
• are kept current (the latest version or revision);
• are kept as paper or electronic copies (but paper copies must be
kept up to date, controlled, and effectively managed in a central lo-
cation);
Because keeping documentation up to date and maintaining it at a central location is
difficult, you may (and are encouraged to) use electronic systems to manage your
EMS documentation. The feasibility of using an electronic format depends on your
installation's computer network and the degree of employee access to the system. If
your installation is already using an electronic document management system, you
should try to use it, if possible. If you plan to purchase a new document control sys-
tem for the EMS, be sure that it meets your needs and is compatible with other sys-
tems already in use.
• are periodically reviewed, revised as needed, and approved by ap-
propriate personnel (check to make sure documents are still valid);
• are available at all locations where operations essential to the
effective functioning of the EMS are performed (make sure the peo-
ple who need the documents have access);
• that are obsolete are promptly removed from all points of issue and
points of use, or otherwise kept from unintended use (prevent peo-
ple from using the wrong document); and
• are suitably identified if obsolete and retained for legal reasons or
knowledge preservation.
Try to keep your system as simple as possible, including only documents
that need to be controlled. You can quickly overwhelm the system by in-
cluding unnecessary documents. Ensure that everyone knows how to use
the system and understands their individual responsibilities for maintaining
the system.
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Step-by-Step Guidance
Click here to view a document control worksheet that summarizes key
questions regarding the document control process. By answering the
questions on the worksheet, you can build a framework for your EMS
document control procedures.
Among others, the following EMS documents should be managed under
the document control system:
• Environmental policy
• Aspects and impacts analysis data and results
• Environmental management program documents
• Objectives and targets
• Roles, responsibilities, and authorities
• EMS manual
• EMS procedures
• Process- or activity-level procedures
• Related plans (such as emergency response plans).19
Click here to view a document index spreadsheet for listing and tracking
the status of controlled EMS documents.
Click here to view examples of systems used successfully at other Army
installations.
19 NSF-ISR, Environmental Management Systems—An Implementation Guide for
Small and Medium-Sized Organizations, p. 51.
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Document Control System Hints
• Keep the document control procedure simple. Consider other document con-
trol procedures on the installation when developing yours.
• Limit document distribution—make only the copies you need.
• Consider using the LAN or Intranet as a paperless system. Consider com-
mercial document control software packages, but make sure the system
meets your needs.
• Prepare a document control index that shows all your EMS documents, their
location, their revision history, and the date of the next review. Include a ref-
erence to the index in the EMS manual, but do not include the index in the
manual, because the index will require frequent revisions. If you use a paper-
based system, prepare a distribution list that shows who has copies of the
documents and their location.
• When revising documents, highlight the changes (using highlight, bold, under-
line, different colors, etc.) or use a change sheet to show the changes.
(NSF-ISR, Ltd., Environmental Management Systems—An Implementation Guide for
Small and Medium-Sized Organizations, 2001)
Step 14. Establish communications procedures.
Objective
Communication ISO
14001, Section 4.4.3
Importance
Develop procedures for internal and external communication of EMS in-
formation, as required by the ISO14001 standard.
ISO 14001 requires only that the organization establish and maintain pro-
cedures for communication and does not require documentation. How-
ever, we recommend that you document (write down) communication
procedures if you want personnel to universally understand and consis-
tently follow the procedures.
Good communication, within the installation and to external interested par-
ties, is essential for developing and implementing the EMS. "Effective en-
vironmental management requires effective communications, both
internally and externally."20 The installation must establish and maintain
two different types of communications procedures:
• Internal communications between the various levels and functions
on the installation, and
20
NSF-ISR, Environmental Management Systems—An Implementation Guide for
Small and Medium-Sized Organizations, p. 43.
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Step-by-Step Guidance
External communications.
Most installations already have basic communications procedures in
place. If that is the case at your installation, you need only revise the pro-
cedures to address EMS information.
Internal Communications
Internal communications include verbal communication (staff meetings,
brown bag lunches, training, etc.), e-mail, intranet, memoranda, newslet-
ters, posters, and bulletin boards. When developing the procedures, take
advantage of existing communications channels and consider how differ-
ent target audiences on the installation access or distribute information.
Some employees may not have consistent access to a computer for e-
mail and intranet-based information, so multiple types of communication
may have to be used. The following information needs to be communi-
cated internally:
• Information on day-to-day EMS operations, including the environ-
mental policy and how it will be publicly available
• General EMS education and awareness information, including the
process for receiving and responding to the concerns of employees
and other interested parties
• Environmental regulatory reporting requirements
• How to achieve objectives and targets
• Environmental incidents
• Environmental aspects
• Personnel responsible for various parts of the EMS
• How the EMS will be monitored
• EMS audit results and results, including the process for making all
personnel aware of those results (communicated through the
EQCC)
• The management review cycle.
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External Communications
You need an effective procedure for dealing with external communica-
tions. The installation must establish procedures describing how it distrib-
utes information to the public and how it receives, documents, and
responds to relevant communication from different types of external inter-
ested parties. The procedure should clearly identify the information to be
made available to the public. ISO 14001 requires only that the environ-
mental policy be made available, but some installations also include the
following:
• Environmental aspects and impacts
• Installation environmental objectives and targets
• Meeting minutes
• Permits
• Compliance information, such as fines and NOVs.
Consult the public affairs office (PAO), legal office, security, operations,
and other involved staff elements before deciding what information to re-
lease.
In addition to listing the publicly available information, document how you
make it available and how frequently your installation updates it.
The PAO likely coordinates external communications and is probably the
best external point of contact (POC). If no external POC exists, establish
one and require the POC to coordinate and maintain records of external
communications. ISO 14001 requires documenting or keeping records of
communications with external parties. The procedure for recording exter-
nal communications can be as simple as stapling an inquiry to the re-
sponse and then filing them together.21
The installation leadership determines whether the installation initiates and
establishes external communication of the installation's significant aspects
(see Step 19). Army installations are not required to publicly communicate
this information. We recommend you decide in advance what information
will be shared with the public and record your decision. If you choose, you
can share EMS information by various means:
• Reports and newsletters
• Press releases in newspapers, in magazines, or on television
21 NSF-ISR, Environmental Management Systems—An Implementation Guide for
Small and Medium-Sized Organizations, p. 44.
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Step-by-Step Guidance
• Websites
• Public meetings.
Although it is not an ISO 14001 requirement, we recommend you docu-
ment the internal and external communications procedures, including
• who manages inquiries and the flow of information,
• who is responsible for preparing and approving responses, and
• types of information to be communicated.
Written communications procedures should be maintained in accordance
with the installation's document control procedures.
Effective internal and external environmental communication and reporting
has the following characteristics:
• It is two-way.
• Information is understandable and adequately explained.
• Information is verifiable.
• It presents an accurate picture of the organization's performance.
• Information is presented in a consistent form (for example, similar
units of measure to allow comparison of two periods).22
Click here to view an example of an internal communications procedure
document. Click here to view an example of an external communications
procedure document.
Step 15. Compile legal and other requirements. Le9a| and other Requirements,
r r a ^ IS014001, Section 4.3.2
Objective
Develop a written procedure to compile and keep current all legal and
other requirements pertaining to installation environmental issues.
ISO 14001 requires only that the organization establish and maintain pro-
cedures pertaining to legal and other requirements and does not require
documentation. However, we recommendthat you document the proce-
dure to ensure it is periodically reviewed and revised as needed.
22 ISO 14004, Section 4.3.3.1, p. 18.
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Importance
Legal and other requirements are part of the baseline for your EMS. As
your installation performs its mission activities, everyone must be aware of
the environmental regulations and other requirements that they must
meet.
In addition, the revised environmental policy (developed in Step 10) re-
quires a commitment to legal and other requirements. To fulfill this com-
mitment, your organization needs to know the legal requirements that
apply to your operations, activities, or services and how they affect what
you do."
23
Your installation probably already has a process for identifying legal and
other requirements that pertain to environmental issues. In this step, you
review the process to ensure that it captures all the applicable laws and
regulations.
Your installation does not have to commit to additional voluntary require-
ments not mandated by law or Army policies. However, if your installation
has previously volunteered or subscribed to other requirements, you must
follow through on that commitment. This commitment also holds if you
plan to participate in such activities in the future.24
Legal requirements include all federal, state, and local legislative and regulatory envi-
ronmental requirements that apply to your operations, including all Army policies and
regulations. They also include administrative requirements, such as permits, authori-
zations, licenses, records, reporting, and environmental plans.
Other requirements include voluntary obligations to which the organization commits,
including the following:
• Industry standards of practice, such as American National Standards Institute
(ANSI) and ASTM standards
• Agreements with public authorities, such as consent decrees and U.S. Envi-
ronmental Protection Agency (EPA) programs
• Internal installation requirements, such as ISO 9000
• Environmental management principles.
(U.S. Army Guidance Manual, p. 16.)
23 PEER Center, How to Implement an EMS [on-line document], undated [cited Feb-
ruary 2003]. Available from http://www.peercenter.net/howtoimplement/.
24 Concurrent Technologies Corporation for U. S. Army, Environmental Management
System Guidance Manual: Implementing ISO 14001, p. 16.
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Step-by-Step Guidance
As you review your current process for identifying legal and regulatory re-
quirements, make sure it meets the following criteria:
• Identifies relevant requirements, including state and local.
• Identifies proposed requirements and changes to existing ones.
• Describes a process for reviewing and analyzing requirements to
determine potential impacts on installation activities, including who
reviews and how results are recorded and communicated.
• Is properly documented and sufficiently detailed.
• Is stored and maintained in accordance with your EMS document
control procedure.
25
Table 2-1 lists laws and regulations that govern common activities at Army
installations. The environmental management office should be able to
provide a list of applicable environmental regulations. The following
sources can also help identify legal requirements:
• AR 200-1, 200-2
• DENIX
• IMRO
• U.S. Army Environmental Center (USAEC) regional environmental
offices (REOs)
• Federal, state, and local governmental agencies
• Industrial trade associations, societies, and other related groups
• Commercial databases
• Professional services, including environmental consultants and law
firms
• ECAS/EPAS
• Publications that pertain to self-compliance audits or environmental
checklists.26
25 ISO14004, Section 4.2.3, p. 9.
26 Concurrent Technologies Corporation for U. S. Army, Environmental Management
System Guidance Manual: Implementing ISO 14001, p. 17.
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Table 2-1. Federal Laws and Regulations
Federal laws and regulations
Clean Air Act (CAA), 40 CFR Parts 50-99
Clean Water Act (CWA), 40 CFR parts 100-
145, 220-232, 410-471
Resource Conservation and Recovery Act
(RCRA), 40 CFR Parts 240-299
Spill Prevention, Control, and Countermea-
sures (SPCC), 40 CFR Parts 112-114
Toxic Substances Control Act (TSCA),
40 CFR Parts 700-799
Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA,
also known as Superfund),
40 CFR Parts 300-311
Emergency Planning and Community Right-
To-Know Act (EPCRA, also known as SARA
Title III), 40 CFR Parts 350-374
Hazardous Materials Transportation Act
(HMTA), 49 CFR Parts 100-180
Safe Drinking Water Act (SDWA), 40 CFR
Parts 141 -149
AR200-4
Federal Insecticide, Fungicide, and Rodenti-
cide Act (FIFRA), 40 CFR parts 150-171
Endangered Species Act (ESA), 16 USC
1531 etseq.
Sikes Act, 16 USC 670a-670f
AR200-3
Noise Control Act (NCA)
EO 1 31 48 "Greening the Government
Through Environmental Management" and
Pollution Prevention Act
Common activities
Air emissions, including ozone depleting chemicals
(ODCs) from operations, stack or fugitive emissions,
equipment, and stored chemicals or fuel
Water discharges, including storm water, wastewater,
and sewage
Chemical or hazardous material or waste, or energy
resources (such as coal and petroleum fuels) storage
Hazardous waste generation, storage, handling, trans-
port, or disposal
Solid waste related activities, including sanitary land-
fills and recycling and waste minimization programs
Underground storage tanks
Storage, handling, or transport of oil of any kind, in-
cluding petroleum, fuel oil, sludge, oil refuse, and oil
mixed with wastes, other than dredge spoils
Manufacture, process, distribution, use, or disposal of
TSCA-regulated chemicals
Releases of hazardous substances needing to be re-
ported under CERCLA
Contaminated site cleanup
Toxic chemical or extremely hazardous substance use
(according to EPA's list)
Toxic chemical or extremely hazardous substance (ac-
cording to EPA's list) transport, processes, use, or
storage.
Drinking water systems, underground injection, well-
head protection or cross-connection control, and back-
flow prevention
Cultural resources management
Pest management
Threatened and endangered species, critical habitat,
or associated initiatives
Natural resources management
Natural resources management
Noise mitigation, monitoring, and management
Pollution prevention activities versus compliance-
based solutions, priority chemical use reduction, pollu-
tion prevention plans
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Step-by-Step Guidance
COMPLETE ASPECTS AND IMPACTS
ANALYSIS AND DEVELOP PRIORITIZED
ISO 14001, Section 4.3.1
ASPECT LIST (STEPS 16-19)
(BY 30 MARCH 2005)
Environmental Aspects
Army EMS Implementation Metric
Prioritized List of Aspects. A list of environmental aspects consistent with ISO
14001 and Army EMS policy has been developed, documented, and briefed to the
CDR.
Steps 16 through 19 collectively identify the significant environmental as-
pects resulting from your installation's activities, products, and services:
• Step 16. Identify all mission and installation activities, products, and
services.
• Step 17. Identify the environmental aspects of your installation's ac-
tivities, products, and services.
• Step 18. Identify the environmental impacts of each aspect.
• Step 19. Identify significant environmental aspects.
The identification of significant environmental aspects is critical in develop-
ing your EMS because they provide the basis for establishing environ-
mental management programs, developing objectives and targets,
identifying training requirements, determining requirements for operational
controls and work procedures (such as SOPs), performing general risk
assessments, and completing periodic management reviews.
These steps have proven the most difficult for organizations to implement
because the methods used can vary widely in detail and complexity and
can quickly snowball if you don't tailor your approach to capture the most
significant aspects before you exhaust available time and resources. The
recommended procedures that follow will help you achieve maximum ef-
fectiveness with minimum complexity. ISO 14001 requires only that or-
ganizations establish and maintain procedures to identify environmental
aspects, but we recommend that you develop written documentation for
these procedures to help ensure consistency and understanding.
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Step 16. Identify all mission and installation activities, products, and
services.
Objective
Identify all major installation activities (tactical and nontactical), products,
and services for consideration in the aspects and impacts analysis.
Importance
Activities, products, and services provide the basis for identifying environ-
mental aspects and impacts.
This step will particularly challenge the CFT because of the sheer num-
bers of organizations on an installation and the variety of missions and
functions they undertake. Executing assigned missions and functions
usually involves undertaking a number of different activities; procuring, us-
ing, and developing specific products; and providing services daily in sup-
port of the operational readiness mission and routine base operations
functions.
Mission or Functional Areas and Associated Processes
To identify your installation activities, products, and services, follow the
simple hierarchy depicted below.
Mission or
functional area
Associated
processes
Activities, products,
and services
Before defining activities, products, and services, you need to understand
the various mission and functional areas and associated processes that
both tactical and nontactical organizations undertake across the installa-
tion. Table 2-2 shows typical mission and functional areas and associated
processes at the installation level.
Activities, Products, and Services
Within each mission or functional area, a number of major processes are
likely. For example, within the transportation equipment functional area, a
typical installation process is to conduct vehicle maintenance operations.
At the next level, conducting vehicle maintenance operations might involve
a number of specific activities, products, and services.
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Step-by-Step Guidance
Table 2-2. Mission or Functional Areas and Their Processes
Mission or
functional area
Description of associated processes
Weapons system
acquisition
Major systems acquisition phases of concept and technology development,
system development and demonstration, production and deployment, opera-
tions and support, and demilitarization and disposal
Example: Demilitarization and disposal of excess or waste munitions
Logistics support
Acquisition, storage, distribution, and recovery of all classes of supply; main-
tenance of materials and equipment; transportation of personnel and mate-
riel; provision of support services such as food, commissaries, laundries, and
property disposal; and facilities (real property) operation and maintenance,
including utilities, minor construction, and general engineering support
Example: Ammunition supply operations
Training
Click here for specific
guidance on identifying
processes, activities,
aspects, and impacts
associated with tactical
training.
Providing and conducting individual, functional, and organizational (tactical
and nontactical) training
Example: Conducting basic training
Infrastructure
development and
maintenance
Processes required to operate the total system of facilities; buildings; struc-
tures; horizontal transportation facilities (roads, railroads, bridges, dams, and
airfields); utility, transport, and communication systems; ranges and other
training areas; ports; airfields; and associated lands and equipment
Example: Road maintenance
Industrial operations
Manufacture of commodities, equipment, and weapons systems
Example: Manufacturing small arms ammunition
Base operations
Processes required to support the missions and functions of assigned and
tenant units and activities at the installation level
Example: Providing and maintaining troop housing
Health and medical
support
Providing general health care and medical and dental support to personnel
and operating and maintaining Army hospitals, medical centers, dental and
veterinary clinics, medical treatment facilities, and supporting laboratories
Example: Providing outpatient medical services
Transportation
equipment
Operation of tactical and nontactical vehicles, fixed and rotary wing aircraft,
rail systems, watercraft, and supporting maintenance operations
Example: Perform vehicle maintenance
Mobilization and
deployment
Assembly and organization of material and personnel resources in response
to war or other emergencies, and the physical movement of those resources
to the theater of operations
Example: Railhead operations
Research,
development, testing,
and evaluation
(RDT&E)
Testing and evaluation of materiel, equipment, and weapons systems at
Army proving grounds, laboratories, and related facilities
Example: Development of new flameless ration heater
Note: The list is not all inclusive and varies from one installation to another.
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Scoping
Activities related to vehicle maintenance include changing oil, lubricating
chassis, replacing brake linings, and rebuilding engines. Products that
might be used or provided include oil, solvents, grease, and repair parts.27
Provided services could include vehicle washing and operator mainte-
nance training.
Another example is the base operations functional area. Typical installa-
tion processes include operating a water or wastewater treatment plant,
power generation facility, or sanitary landfill. Activities include primary and
secondary treatment of wastewater, operating boilers to power generators,
or covering solid waste with earth fill. Products include potable water,
while products used include water, fossil fuels, and various chemicals.
Provided services include electric power, potable water distribution, solid
waste disposal, and recycling.
As illustrated by these examples, "activity" generally refers to a major ele-
ment of a process undertaken to achieve the mission, a desired objective,
or end state. "Product" refers to any commodity or item used, consumed,
or created (for example, ammunition manufactured at an industrial facility)
during a process. "Service" refers to useful labor or efforts that do not
necessarily produce a tangible commodity, but otherwise provide value to
a customer.
A fine line distinguishes an activity, product, or service. What one views
as an activity, another may see as a product or service. Do not allow this
to become problematic. Identifying all key elements of the major installa-
tion processes for subsequent use in aspects and impacts analysis is the
key.
Clearly, the total number of processes, activities, products, and services
on the typical installation can be very large. At least one Army installation
reports having identified over 600 activities across all mission and func-
tional areas. The number may have been exaggerated because the com-
pilers went into too much detail or listed elements of work as activities.
(The steps involved in changing vehicle fluids aren't activities.) Also, keep
in mind that you should identify major processes and related activities,
products, and services only.
More realistic is 100 to 200 activities, but even that relatively small number
engenders much work completing the aspects and impacts analysis and
subsequent EMS implementation steps. For this reason, installations may
27 Products can also be defined as tangible results of a process that turns inputs
(such as raw materials) into outputs (such as a weapons system).
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Step-by-Step Guidance
decide to limit the scope of initial EMS implementation to one or two mis-
sion or functional areas, and then gradually expand the EMS to the other
areas. Fort Lewis, WA, took this approach by starting EMS implementa-
tion in the directorate of public works (DPW). Now that the complete sys-
tem is in place at the DPW, Fort Lewis is working to bring in other
organizations and functions across the installation.
Regardless of your approach, you must ensure that all installation organizations, ac-
tivities, and tenants are covered under the broad umbrella of the installation EMS by
31 December 2005.
Getting Started
To do a thorough job of identifying all installation activities, products, and
services, you should start by compiling as much information as possible,
beginning at the process level and working down. Identify every organiza-
tion (tactical and nontactical) that resides within the installation fence line,
including sub-installations. (You accomplished this in Step 9 when you
identified mission focus.)
Once you have identified every organization, you should learn as much as
possible about their assigned missions, functions, and inherent processes.
(Again, you should have already done a much of this in Step 9.) For tacti-
cal units, for example, you should already have copies of the unit mission
statements and appropriate METLs or Army Readiness Training Evalua-
tion Programs (ARTEPs). The METLs and ARTEPs in particular provide a
wealth of information about the primary processes and activities involved
in mission execution and maintaining operational readiness. You should
be able to obtain similar mission and function information from nontactical
support organizations, in hard copy or by interviewing key personnel. On
industrial installations, contractual documents for GOCO facilities can pro-
vide valuable information for this effort. National Environmental Policy Act
(NEPA) documents and other historical assessment records can also as-
sist in defining processes and associated impacts and aspects.
Identify all missions, functions, processes, and activities subject to environmental
regulations or permits. Members of the environmental staff can assist.
If your installation has implemented activity-based costing (ABC), docu-
mentation developed during ABC implementation can provide most of the
information you need for the entire installation in a single package. In ad-
dition, this guide includes a matrix of typical DoD installation major proc-
esses and activities. To view the matrix, click here. Reviewing the major
processes and activities that Fort Lewis identified in its analysis can also
help. To view a PowerPoint presentation of Fort Lewis's results, click
here.
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You can assign responsibility for specific mission or functional areas to
CFT members. When feasible, CFT experts in functions (such as logis-
tics, operations, and training) should be assigned responsibility for compil-
ing information on those functional areas. Unfortunately, since the
number of functional areas usually exceeds the number of CFT members,
some members must compile information on areas with which they are
less familiar. They have to do the best they can by gathering as much in-
formation as possible with the time and resources available. Regardless
of the approach and sources used, the goal is to compile a comprehensive
listing of all major activities, products, and services by mission or func-
tional area and process.
Compiling Information and Keeping Records
The CFT members should compile activities, products, and services for
their assigned mission or functional areas using a simple Excel spread-
sheet to capture information. This will enable the CFT to readily compile,
revise, and manipulate information to perform various analyses or future
revisions. To view a sample Excel form (with a few entries) for collecting
this information, click here.
Step 17. Identify the environmental aspects of your installation's activities,
products, and services that can be controlled or influenced.
Objective
Examine your list of major activities, products, and services and identify
the associated environmental aspects that can reasonably be controlled or
managed.
Definitions and Examples
Once you have listed the installation's major activities, products, and ser-
vices, you must identify the environmental aspects associated with them.
ISO 14001 defines environmental aspects as "elements of an organiza-
tion's activities, products, and services which can interact with the envi-
ronment." An environmental aspect signifies the potential for an
environmental impact, whether good or bad.
Environmental aspects are the cause component of a cause-and-effect
relationship (with the resulting environmental impact being the effect,
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Step-by-Step Guidance
which is discussed in the next step). Generally, the environmental as-
pects of Army installation activities, products, and services fall into one or
more of the following categories:
• Air emissions (fugitive or stationary), such as paniculate matter,
open burn/open detonation (OB/OD), smokes and obscurants, ve-
hicle exhaust, dust, combustion gases, smoke from prescribed
burning, dust, and noise.
• Hazardous waste generation, such as various types of industrial
and hazardous wastes, contaminated containers, and solvents.
• Nonhazardous waste generation, such as solid waste.
• Uncontrolled releases to air, water, or ground, such as lead and
migrating munition constituents from ranges.
• Spills to water or ground, such as fuel or petroleum, oil, or lubricant
(POL) spills, hydraulic fluid leaks, storage tank leaks.
• Discharges (point and nonpoint) to ground or surface waters, in-
cluding sewage, sediment, and other wastes.
• Energy consumption or conservation, including electricity, petro-
leum-based, and alternative fuels.
• Natural resource and raw material consumption or conservation, in-
cluding water, timber, minerals, and soil.
• Ecological resource degradation or conservation, such as wetland
protection or destruction and endangered species.
• Natural resource degradation or conservation, including ground dis-
turbance, hydrological alteration, and vegetation alteration.
• Cultural resource degradation or conservation, including historic
properties, archeological sites, and more traditional cultural re-
sources.
• Generation of heat or radiation.
You are only required to identify the aspects (and related impacts) that
you can control or influence.
For example, consider the environmental aspects of vehicle maintenance
activities, products, and services presented and discussed in Step 16.
Table 2-3 summarizes them.
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Table 2-3. Environmental Aspects of Vehicle Maintenance Activities
Activity, product,
or service
Environmental aspects
Change fluids
Spills (oil or antifreeze)
Discharge to ground or surface water (storm water discharge)
Nonhazardous waste generation (used oil, oily rags, etc.)
Resource use (petroleum, antifreeze)
Resource conservation (if oil or antifreeze is recycled)
Lubricate chassis
Nonhazardous waste generation (greasy rags)
Spills (grease)
Discharge to ground or surface water (storm water discharge)
Replace brake linings
Air emissions (brake dust)
Solid waste generation (old linings)
Resource conservation (if linings are recycled)
Clean and degrease
parts
Air emissions (volatile organic compounds [VOCs] from solvent)
Spills (solvent)
Hazardous waste generation (spent solvent)
Resource conservation (if spent solvent is recycled)
Wash vehicles
Discharge to ground or surface water (storm water discharge)
Resource use (water, electricity)
Resource conservation (if wastewater is recycled and reused on
site)
Strategies for Identifying Environmental Aspects
Now that you understand environmental aspects in general terms, what is
the best way to go about identifying them? Once again, you primarily rely
on the CFT members who are identifying the activities, products, and ser-
vices information. In instances where they are in fact mission or functional
area experts, they should be able to readily identify the environmental as-
pects for the various activities, products, and services. If they are not ex-
perts themselves, then they will have to consult other installation experts
and have them describe how their activities, products, and services may
interact with the environment. In addition, other information sources are
available to gain insight into environmental aspects. These include the
following:
• Previous aspects and impacts evaluations
• Process flow charts and hazard analyses
• Air emissions inventories
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Step-by-Step Guidance
• National Environmental Policy Act (NEPA) studies (environmental
assessments or environmental impact statements)
• Product economic analyses
• Design for the environment (DFE) documentation
• Facility pollution prevention and waste minimization audits
• EGAS reports and corrective action plans
• Environmental site assessments
• Risk assessments
• Environmental cost accounting records
• Project safety and hazard reviews.
Process Flow Charts
It may be helpful to prepare simple process flow charts that capture inputs
and outputs for the various activities, products, and services. For exam-
ple, Figure 2-3 shows another logistics function, fuel storage and dispens-
ing operations, which includes fuel receipt, storage, and shipping and
dispensing activities.
Figure 2-3. Fuel Storage and Dispensing Operations
GASOLINE DIESEL
FUEL
ENERGY
(pumps, lights)
RECEIVING
1
UNLOADING
SPILLS (storm)
1
STORAGE
\
TANK
LEAKS
' 1
SHIPPING/
DISPENSING
' i 1
voc
EMISSION SPILLS VOC
(breathing) (storm) EMISSION
(displacement
r
VOC
EMISSIONS
(displacement)
PIPING
LEAKS
2-43
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By laying the process out in this way, you can easily conceptualize the re-
source inputs to each activity and the manner in which each activity inter-
acts with the environment. Whether or not you use this approach is purely
a matter of preference.
Tips and Tools
Regardless of your approach, as you identify specific aspects, you should
try to capture as much related quantitative information as possible. For
example, if an activity generates waste solvent, estimate the total amount
(for example, 100 gallons per month). Other information that should be
captured includes specific legal and other requirements that may apply,
permits in force, special record-keeping requirements, pollution controls or
equipment in use, best management practices that are currently em-
ployed, regulatory monitoring requirements, etc. This information will help
you identify environmental impacts and determine their significance.
As you identify environmental aspects, you must include admission and
functional areas. A key mission area you must evaluate is the training that
supports METL and ARTEP skills. Click here to view a tool specifically
designed to identify the activities and associated aspects for training and
range operations. Click here to view a matrix that outline typical canton-
ment area activities and associated aspects.
To view an example of an environmental aspects worksheet completed for
one of the previously presented vehicle maintenance activities, click here.
Step 18. Identify the environmental impacts of each aspect.
Objective
For each activity, product, or service identified in Step 16, determine what
environmental impacts might reasonably be produced by the associated
aspects.
Definitions and examples
Once you have identified the environmental aspects of the installation's
major activities, products, and services, you must next identify the envi-
ronmental impacts associated with them. ISO 14001 defines an environ-
mental impact as "any change to the environment, whether adverse or
beneficial, wholly or partially resulting from an organization's activities,
products, or services."
For example, Table 2-4 summarizes some of the environmental aspects
and impacts of the vehicle maintenance activities, products, and services
discussed in Steps 16 and 17.
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Step-by-Step Guidance
Table 2-4. Environmental Aspects and Impacts of Vehicle Maintenance Activities
Activity, product,
or service
Environmental aspect
Environmental impact
1. Change fluids
Oil or antifreeze spills
Storm water discharge
Nonhazardous waste generation (used
oil, oily rags, etc.)
Resource use (petroleum, antifreeze)
Resource conservation (if oil or anti-
freeze is recycled)
Contaminated water or soil
Contaminated surface water
Solid waste disposal
Depleted petroleum reserves and
virgin antifreeze supplies
Petroleum reserves last longer; less
virgin antifreeze needed
2. Lubricate chassis
Nonhazardous waste generation
(greasy rags)
Grease spills
Storm water discharge
Solid waste disposal
Contaminated water or ground
Contaminated storm water
3. Replace brake lin-
ings
Air emissions (brake dust)
Solid waste generation (old linings)
Resource conservation (if linings are
recycled)
Reduced air quality
Solid waste disposal
Reduced resource use (virgin metals
and other components)
4. Clean/degrease
parts
Air emissions (VOCs from solvent)
Solvent spills
Hazardous waste generation (spent
solvent)
Resource conservation (if spent sol-
vent is recycled)
Reduced air quality
Contaminated water or ground
Hazardous waste disposal
Reduced disposal requirements
5. Wash vehicles
Wastewater discharge
Resource use (water, electricity)
Resource conservation (if wastewater
is recycled and reused on site)
Wastewater treatment
Depleted water, electricity
Increased potable water availability
As illustrated by this example, environmental impacts are the effect com-
ponent of a cause-and-effect relationship. Generally, the environmental
impacts of Army installation activities, products, and services fall into one
or more of the following categories:
• Air, water, and ground pollution and associated reductions in envi-
ronmental quality (such as ozone depletion)
• Energy consumption (or conservation as a positive impact)
• Natural resource depletion or conservation
• Cultural resource damage or destruction
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• Damage to the natural environment (such as ground disturbance,
erosion, and tree and vegetation loss)
• Hazardous, biohazardous, and medical waste disposal
• Solid waste disposal (or recycling and reuse as a positive impact)
• Sewage disposal
• Nuisances to local communities.
Strategies for Identifying Environmental Impacts
Now that you have a general picture of environmental impacts, what is the
best way to identify them? As with previous steps, the expertise you need
primarily resides with the CFT members. Representatives from the envi-
ronmental functional area probably know the most about environmental
issues, applicable regulatory requirements, resource (air, water, soil) sen-
sitivities to harmful emissions or discharges, local community concerns,
etc.
One approach is to have the environmental staff members facilitate a
structured CFT brainstorming session to analyze each aspect for potential
impacts, including a team review of the activities involved and process in-
puts and outputs. Although some team members are not environmental
professionals, with a little probative questioning and group discussion,
those who know the activity itself should be able to lend insight into how it
affects the environment. Have a staff member take detailed minutes of
the discussion, review decisions, and action items.
The CFT should work through the process by mission and functional area,
capturing the results as they are developed. For example, begin by look-
ing at the logistics support mission and functional area, evaluating each
activity, product, and service and its identified environmental aspects. Af-
ter you identify and document all associated environmental impacts, move
on to the next mission and functional area (for example, training).
As in previous steps, compile your results on a spreadsheet. To view an
example environmental aspects and impacts worksheet with a few data
entries for the vehicle maintenance process, click here. This form in-
cludes columns on the far right used to evaluate the significance of envi-
ronmental impacts and related aspects. You should ignore those columns
until you get to the next step.
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Step-by-Step Guidance
Step 19. Identify significant environmental aspects
Objective
Establish, use, and maintain a procedure to examine and prioritize the en-
vironmental impacts and aspects identified earlier and determine which
are significant.
Although the ISO 14001 standard does not require documentation of the
procedure, we recommend that you maintain written documentation to en-
sure consistency in execution.
Definition
A significant environmental aspect is an aspect that has or can have sig-
nificant environmental impact. As stated earlier, your significant environ-
mental aspects form the basis for establishing your environmental
management programs (EMPs) (Step 20) and objectives and targets (Step
21).
Determining Significance
Once you have identified all environmental aspects and associated im-
pacts for your activities, products, and services, you must then determine
which environmental aspects are significant. ISO 14001 does not specify
how an organization should determine which impacts are significant be-
cause the relative significance of an impact can vary widely from one or-
ganization to another, depending on environmental and business
concerns and other site-specific considerations. However, the ISO 14004
companion document to ISO 14001 does list several environmental and
business related factors that an organization can consider in evaluating
the significance of an environmental impact, including the following:
• Environmental considerations
> Scale of the impact
> Severity of the impact or potential impact
> Probability of occurrence
> Duration of the impact
> Frequency of the impact or potential impact
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> Location of the facility (for example, in an environmentally sensi-
tive area)
> Scope of the impact (local, regional, or global).
• Business considerations
> Potential regulatory and legal exposure
> Difficulty of changing the impact
> Cost of mitigating the impact
> Effect of change on other activities and processes
> Concerns of interested parties
> Effect on the organization's public image
> Return on investment of the cost to mitigate the impact.
Army installations must also consider the affect on mission accomplish-
ment of any restrictions imposed because of the impact (for example, op-
erational noise levels may restrict your ability to fire weapons, conduct
demolition training, or employ aircraft).
Identifying Rating Factors and Numerical Ratings
A commonly used approach to determining the significance of environ-
mental impacts employs a simple numerical rating system. You identify a
number of rating factors (considerations), define numerical ratings, and
use an algorithm incorporating those factors and ratings to calculate a sig-
nificance score for each impact. You then can sort and rank impacts by a
relative significance score and make a combination of objective and sub-
jective judgments to determine the significant impacts.
The greater the number of rating factors used, the more difficult it is to de-
velop an easy-to-use, structured process for impact evaluation. As a start-
ing point, try limiting the number to five. Good choices are the following:
• Environmental impact frequency or likelihood
• Environmental impact severity
• Mission impact severity (if the impact results in mission constraints,
or if the organization cannot perform, produce, or provide the activ-
ity, product, or service at all)
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Step-by-Step Guidance
• Regulatory status
• Community concerns.
After selecting the rating factors you will use, define the numerical ratings
that will apply. For the five rating factors shown above, Tables 2-5
through 2-9 provide some suggested numerical ratings. You may modify
these as you see fit on the basis of your own unique situation or experi-
ence.
Frequency or Likelihood
The probability that an impact might occur, or how often it actually occurs
will affect the significance of the impact.
Table 2-5. Sample Rating Factors for Frequency or Likelihood of
Environmental Impact
Frequency or likelihood (F) scale
5 = Continuous—ongoing or daily.
4 = Frequent—more than once per month.
3 = Infrequent—more than once per year, less than once per month.
2 = Rare—impact may occur once every year or two.
1 = Never—never occurred or highly unlikely.
Environmental Impact Severity
Table 2-6 provides a suggested format for scoring the potential severity of
environmental impacts, assuming they occur. When evaluating environ-
mental impact severity, it may help to consider the following:
• Proximity of the impact to people or environmentally sensitive areas
• Toxicity of substances involved
• Quantities of substances involved
• Effects from startup and shutdown conditions
• Duration of exposure or effects
• Size of the area affected
• Potential for migration of the hazard.
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Table 2-6. Sample Rating Factors for Severity of Environmental Impacts
or Consequences
Environmental impact severity (E) scale
5 = Severe—immediate threat likely to result in widespread damage to human health or
the environment; requires great effort to remediate or correct.
4 = Serious—no immediate health threat, but significantly damages the environment; dif-
ficult but possible to remediate.
3 = Moderate—somewhat harmful, but correctable.
2 = Mild—small potential for harm to environment, correctable.
1 = Insignificant—trivial consequences, easily correctable or not impact.
Mission Impact Severity
In Table 2-7, the severity of mission impacts can be influenced by the fol-
lowing:
• Priority or importance of the impacted missions (see Step 9)
• Restriction of specific activities (digging, using smoke, etc.)
• Duration restrictions (such as limiting boiler operations to 12 hours
per day)
• Permanent versus temporary closure or restrictions of training ar-
eas or industrial processes
• Availability of alternative training sites or training techniques.
Table 2-7. Sample Rating Factors for Severity of Mission Impacts
Mission impact severity (M) scale
5 = Loss of ability to accomplish critical mission or near mission failure.
4 = Severely degraded mission capability or serious mission restrictions.
3 = Moderate mission restrictions.
2 = Minor mission impacts or restrictions.
1 = Insignificant mission impacts or restrictions; alternative courses of action are avail-
able.
0 = No mission impacts or restrictions.
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Step-by-Step Guidance
Regulatory Impact
Impacts subject to federal or state regulations are automatically signifi-
cant. Situations involving a high risk of noncompliance demand increased
priority.
Table 2-8. Sample Rating Factors for Regulatory Status
Regulatory impact (R) scale
5 = Regulated—noncompliance condition; actual or possible enforcement action or NOV.
4 = Regulated—generally in compliance, but not completely controlled or managed;
some risk of noncompliance in future, or under scrutiny by regulators.
3 = Regulated—in compliance, well controlled or managed; little regulator interest.
2 = Likely to be regulated in future by federal, state, or host nation agency.
1 = Best management practice (BMP) applies.
0 = No requirements apply.
Community Concerns
When determining community concern ratings in Table 2-9, consider the
following actions or situations:
• Lawsuits
• Obstruction efforts
• Negative or positive press coverage
• Number and scope of citizen complaints
• Community-generated political or regulator interest
• Level of positive interaction with the local community.
Table 2-9. Sample Rating Factors for Community Concern
Community concern (C) scale
4 = Public outcry or lawsuits.
3 = Serious community concern, political or activist inquiries, intense negative media.
2 = Moderate community concern, some media coverage.
1 = Community is not currently concerned, but could become so.
0 = Community is ambivalent or unconcerned.
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Calculating Impact Significance Score
Calculate the impact significance score (SS), in the following example, as
SS = frequency x (environmental impact severity + mission impact sever-
ity) + regulatory status + community concern.
With the rating factors shown, the maximum possible SSfor any given im-
pact is [5 x (5 + 5) + 5 + 4], or 59.
Examples
1. Assume you have five large boilers in operation on the installation that
heat water for subsequent distribution and use across all facilities. They
are oil-fired and regulated under a single Title V operating permit. The
boilers are designed for continuous operation and release air emissions in
amounts within the operating parameters prescribed in the permit. How-
ever, because you are located in a non-attainment area for sulfur and ni-
trogen oxides, these sources are under considerable regulator scrutiny,
and operation of the boilers has been restricted to 12 hours per day. This
in turn has required the installation to cut back on the operation of indoor
ranges and other indoor training facilities, resulting in some degradation of
operational readiness. No major issues about boiler operation exist within
the surrounding community.
Given this scenario, you might arrive at the following results:
• Activity, product, or service: boiler operation
• Environmental aspect: air emissions
• Environmental impact: degraded air quality
• Impact SS determination
> frequency of impact: 5 (happens daily for 12 hours per day)
> environmental impact severity: 2 (small potential for harm to the
environment, correctable)
> mission impact severity: 2 (moderate mission restrictions)
> regulatory status: 4 (in compliance, but strong regulator interest)
> community concern: 0 (public is not concerned).
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Step-by-Step Guidance
Applying these ratings to the equation yields the following:
SS = frequency x (environmental impact severity + mission impact sever-
ity) + regulatory status + community concern.
SS = 5 x (2 + 2) + 4 + 0 = 24.
2. Assume you are generating substantial quantities of spent solvents
across the installation during daily vehicle maintenance parts cleaning ac-
tivities and that the related environmental aspect you are evaluating is
spills. The spent solvents are not being recycled; consequently, they must
be temporarily stored on site until your supporting contractor picks them
up and transports them off-site for local disposal in accordance with
RCRA. You have been storing and disposing of spent solvents in this
manner for many years, having had only two minor spills (less than 10 gal-
lons) within the past year. In those instances, the spills were quickly con-
tained and cleaned up with only minor soil contamination, and no
disruption of maintenance operations occurred. However, a larger spill
could cause significant contamination of a nearby stream, seriously affect-
ing the local trout fishing industry. For this reason, local regulators are
closely watching this activity and have increased the frequency of unan-
nounced inspections. The local community has had minor concerns over
the past few years regarding the storage and transport of hazardous mate-
rials and wastes and the potential for spills, but restricting parts cleaning
activities or general solvent use has not been necessary.
Given this scenario, you might arrive at the following results:
• Activity, product, or service: parts cleaning or degreasing
• Environmental aspect: virgin or waste solvent spills
• Environmental impact: contaminated soil or water
• Impact SS determination
> Frequency of Impact: 3 (more than once a year, less than once
a month)
> Severity of Environmental Impact: 3 (harmful but not immedi-
ately fatal to humans or the environment, difficult but possible to
remediate)
> Severity of Mission Impact: 0 (no restrictions)
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> Regulatory Status: 4 (in compliance, but under scrutiny by regu-
lators)
> Community Concern: 2 (moderate community concern)
Applying these ratings to the equation yields the following:
SS = frequency x (environmental impact severity + mission impact sever-
ity) + regulatory status + community concern.
SS=3x (3 + 0) + 4 + 2 = 15.
3. In this final scenario, consider the routine daily vehicle washing activi-
ties at the various vehicle maintenance facilities. All facilities use modern
wash racks that collect wastewater and process it through an oil/water
separator before discharge to the local municipal wastewater treatment
plant. Dirt, oil, grease, and other harmful wastes are collected from the
oil/water separators and disposed of in accordance with applicable regula-
tions. The total quantity of these wastes is generally very small from
month to month. No incidents involving harmful discharges from these fa-
cilities to the publicly owned treatment works (POTW) have occurred in
the past 5 years. Regulators do not have a special interest in vehicle
washing facilities at this time, and no major issues or concerns about ve-
hicle washing exist in the surrounding community. No restrictions exist on
vehicle washing. Restrictions would have little to no mission impact any-
way because vehicle washing is not a mission-critical activity.
Given this scenario, you might arrive at the following results:
• Activity, product, or service: vehicle washing
• Environmental aspect: water use, wastewater generation
• Environmental impact: water resource depletion, degraded water
quality
• Impact significance score determination
> Frequency of impact: 5 (occurs daily)
> Severity of environmental impact: 1 (insignificant)
> Severity of mission impact: 0 (no restrictions)
> Regulatory status: 3 (in compliance, well controlled)
> Community concern: 0 (community is not concerned)
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Step-by-Step Guidance
Applying these ratings to the equation yields the following result:
SS = frequency x (environmental impact severity + mission impact sever-
ity) + regulatory status + community concern.
SS = 5 x (1 + 0) + 3 + 0 = 8.
As in all previous steps, you should record the results of significance scor-
ing. To view the example aspects and impacts worksheet presented ear-
lier with a few sample entries, click here (the spreadsheet calculates the
significance score automatically on the basis of the values you input). Ig-
nore the far right column on the worksheet until you get to the end of this
step.
Determining Significant Impacts
Once you determine the significance score for each impact, you must then
decide which impacts are in fact significant.
The only required criterion for determining significance is regulatory
impact. If an impact is regulated by state or federal laws, the impact
(and the associated aspect) is considered significant.
In addition to determining significance by regulatory status, you should
rank all impacts by significance score and sort them from high to low. This
ranking helps identify impacts and aspects that are not regulated but still
significant, and helps establish priority among the significant regulated im-
pacts and aspects. Outside of the regulatory status requirement, you
have considerable flexibility in determining what impacts and as-
pects are significant. You could draw a numerical cut line (such as SS =
12) where all impacts having a significance score at or above the cut line
would be significant. Using this approach, both the first and second sce-
narios (boiler operation and solvent spills) would result in significant im-
pact designations (degraded air quality and soil or water contamination).
Tracking this back to the associated environmental aspects would then
result in air emissions and spills becoming significant aspects.
Another possible approach would be to look at the individual ratings that
you applied to each rating factor. For example, you might decide that any
actual or potential impact receiving one or more ratings as follows would
be considered significant regardless of its overall significance score:
• Environmental impact severity rating of 3 or higher
• Mission impact rating of 3 or higher
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• Regulatory status rating of 3 or higher (anything regulated is signifi-
cant)
• Community concern impact rating of 3 or 4.
Applying this approach would make the scenario 1 and 2 impacts signifi-
cant. The scoring system is a useful tool in this process, but you are
not obligated to use the numerical scores as your sole criteria for de-
termining significance. Use good judgment, and tailor the system to
your needs.
Cumulative Impacts and Significance
Also try to identify and address any impacts that may have a cumulative
effect. This is especially important when a large number of different activi-
ties, products, or services produce a common impact. Individually, the
significance scores for these impacts may be low, but in some cases, the
cumulative impact may be significant.
Determining Significant Aspects
As stated earlier, significant aspects are simply those that you determine
to have significant impacts. All you have to do at this point is to apply your
chosen approach to each impact and then document the results in the far
right column of the aspects and impacts worksheet by indicating yes or no
(click here).
Looking across the entire installation at all mission and functional areas,
activities, products, and services, you undoubtedly can identify a large
number of environmental aspects and impacts. However, many environ-
mental aspects and impacts repeat themselves. Once you compile a list-
ing of unique aspects and impacts, you will find that the total number is
much more manageable. In fact, after all is said and done, the significant
environmental aspects of the typical Army installation probably boil down
to some combination of the aspects listed in Step 17.
Review and Update of Significant Aspects
The installation must have a process to systematically identify changes in
activities, products and services that might drive changes to the installa-
tion's significant aspects. Review all functional areas and processes at
least annually to identify any changes. Be sure to ask functional area ex-
perts to identify any new processes or activities, products or functions that
have not been subjected to an aspect and impact analysis.
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Step 20. Develop or revise installation environmental
management programs.
Step-by-Step Guidance
Environmental Management
Programs, ISO 14001, Sec-
tion 4.3.4
Objective
Definition
Determine which environmental management programs (EMPs) are
needed and establish the framework for those programs.
The ISO 14001 definition of "program" differs from the Army's definition. In
ISO 14001, the term "environmental management programs" refers to ef-
forts smaller than Army program-level efforts. An EMP is a plan for ad-
dressing and managing significant aspects and associated objectives and
targets. In this guide, we use the ISO terminology and meaning for EMPs.
The Army recommends aligning EMPs with significant aspects, which
meets the ISO 14001 requirement for establishing and maintaining EMPs
to manage each objective and target.
Required Content
The EMP is a convenient way to organize activities and information within
your EMS. You are likely to have several EMPs—one for each significant
aspect identified in Step 19. Each EMP should include the following:
• Objectives and targets. How can we improve specific elements of
environmental performance, and how can success be docu-
mented?
• Regulatory and other requirements (if applicable). What envi-
ronmental regulations, guidelines, or other agreements apply to the
significant aspect?
• Responsibilities. What actions are required to manage the signifi-
cant aspect or achieve objectives and targets, and who is responsi-
ble? How is the EMP kept up to date? When appropriate,
personnel (or positions) should be designated at each relevant
function and level.
• Operational controls. What operational controls or SOPs are
relevant in controlling the significant aspect? Where can these be
found?
• Training. What training is required by ISO 14001, by environ-
mental or other regulations, or to improve performance and reach
specified targets?
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• Resources. What human, technological, or financial allocations
are needed? Include specific funding amounts and sources (refer
to the hotlink in Chapter 1 for current, detailed information about
funding sources).
• Action Plans, Milestones, and Timelines. How will the target be
achieved? Are there milestones and timelines to mark your pro-
gress? When are periodic reviews scheduled?
• Measuring and monitoring. What must be measured or checked
to ensure EMP effectiveness, progress toward objectives and tar-
gets, or effective monitoring of significant aspects? How can you
be sure the measurements are accurate?
• EMS performance records. What progress are we making toward
achieving objectives and targets? Are required actions being per-
formed?
In addition to EMPs for each significant aspect, you might also consider
developing EMPs for emergency preparedness and response procedures
or other issues not covered under significant aspects.
Coordination and Oversight
Updating
The EMSMR should coordinate and oversee the EMPs. In many cases,
Army installations are engaged in strategic planning efforts and have im-
plemented systems to track installation-level goals and objectives. If this
is the case on your installation, make sure that the EMS objectives and
EMPs are included in the strategic planning effort and the EMSMR is in-
volved.
Creating good EMPs is a challenge and may take several iterations to per-
fect. As you develop and use your EMPs, you will acquire new insights on
your significant aspects and associated processes and probably see the
need to make changes. This is why EMSs are built around the concept of
continual improvement. You need to modify your EMPs and related plan-
ning documents when
• activities, products, services, and related objectives and targets
change;
• objectives and targets are added;
• relevant legal requirements are introduced or changed;
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Step-by-Step Guidance
• substantial progress in achieving your objectives and targets has
been made (or has not been made); and
• services, process, or facilities change or other issues arise.
Documentation and Records
Although the ISO 14001 standard only requires you to establish and main-
tain the EMPs, we recommend you develop and maintain documentation
pertaining to your EMPs in accordance with your installation's EMS docu-
ment control procedures. Records of EMP status and progress should
also be maintained, including summary sheets, meeting minutes, status
reports, in-process review (IPR) input, and other progress indicators.
Keep it simple. You may find it useful to establish a standard form that
summarizes the basic information for each EMP and its current completion
status. Click here to view sample forms for summarizing EMPs.
In Step 19, you identified your significant environmental aspects. In Step 20, you de-
termined your requirements for environmental management programs (from signifi-
cant aspects) and developed a framework for EMP content. Next, Steps 21-26
provide guidance for developing the essential contents of your EMPs.
Objectives and Targets,
ISO 14001, Section 4.3.3
Step 21. Establish environmental objectives and targets.
Objective
The objective of this step is to develop, maintain, and document objectives
and targets for the EMPs established in Step 20.
As stated in the introduction to the environmental aspects and impacts de-
velopment steps, your significant aspects provide the basis for establish-
ing objectives and targets, identifying training requirements, determining
requirements for operational controls and work procedures (such as
SOPs), performing general risk assessments, and completing periodic
management reviews. In this step, you focus on establishing environ-
mental objectives and targets.
Definition
ISO 14001 defines an environmental objective as "an overall environ-
mental goal, arising from the environmental policy, that an organization
sets itself to achieve, and which is quantified where practicable." In other
words, environmental objectives are goals the installation sets for itself,
usually over the long term, at each relevant functional and organizational
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level. For example, an installation that identifies hazardous waste genera-
tion as one of its significant aspects might establish a quantifiable (meas-
urable) reduction in hazardous waste generation as one of its long-term
objectives.
Similarly, ISO 14001 defines an environmental target as "a detailed per-
formance requirement, quantified where practicable, applicable to the or-
ganization or parts thereof, that arises from the environmental objectives
and that needs to be set and met in order to achieve those objectives."
Like objectives, environmental targets should be specific and measurable,
but they should also directly link to a specific time frame for accomplish-
ment. Continuing with the example above, an installation might require a
subordinate organization or organizations to reduce hazardous waste
generation by a specific amount (such as 10 percent or 2,000 pounds) by
a specific time (such as by 1 January 2004, or the end of FY04).
Generally, you want to establish at least one environmental target for each
environmental objective. In addition, your objectives and targets must
support mission accomplishment, be consistent with installation environ-
mental policy, and include a commitment to pollution prevention.
Determining Objectives
When determining environmental objectives, the installation should con-
sider the following:
• Mission priorities (Step 9)
• Applicable legal and other requirements (Step 15)
• Identified significant environmental aspects and impacts, including
known obstacles to effective mission accomplishment
• Installation sustainability (25-year) goals, if applicable
• Ability to control the activities, products, or services involved
• Ability to track, monitor, and measure results
• Overall cost to track, monitor, and measure results
• Technological options that are or will be available (such as green
bullets, alternative fuels, and hybrid electric vehicles)
• Financial, operational, and functional requirements
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Step-by-Step Guidance
• Views of interested parties
• Linkage to the environmental policy statement.
As a principal consideration, your objectives and targets (at the floor level)
should facilitate mission accomplishment and help ensure continuous
compliance with all applicable legal and other requirements. As a ceiling,
however, installations can seek to go beyond compliance to ensure long-
term sustainability and establish objectives and targets that help them
achieve that end.
Establishing Objectives and Targets
To establish objectives and targets, you must first determine the level or
levels to which they apply (for example, the entire installation, certain units
or organizations, or individual functional areas) and who is responsible for
establishing them. A typical installation-level scenario is to have the CFT
that completed the aspects and impacts analysis recommend objectives
and targets, which the CDR or a designated representative (such as the
EMSMR) then reviews and approves. Another scenario has the CFT de-
veloping environmental objectives for the installation, and designated sub-
ordinate leaders (such as appropriate civilian functional managers and
tactical unit commanders) establishing environmental targets to ensure the
objectives are accomplished. Many alternative scenarios are possible, so
each installation should decide how to proceed at this point.
No "standard" environmental objectives and targets pertain to every instal-
lation. Your objectives and targets should reflect what your installation
does, how well it is performing, and what you want to achieve. Your ob-
jectives and targets must be readily understandable, measurable, and,
above all, realistic (achievable). Generally, you should undertake the fol-
lowing activities as you develop objectives and targets:
1. Involve the CFT. Quality input from the CFT expedites your instal-
lation's efforts to set realistic objectives and targets. Just as the
team provided knowledge and insight during aspects and impacts
analysis, it can quickly identify realistic and readily measurable ob-
jectives and targets consistent with command policy and guidance,
mission-related legal requirements, available resources, and envi-
ronmental aspects and impacts.
2. Gather information from available sources. A great deal of in-
formation should be readily available to the CFT from a number of
sources. Table 2-10 shows some sources. In addition, you can
take a physical walkthrough of facilities (such as heating plants,
motor pools, weapons system production facilities, firing ranges,
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and maneuver training areas) to identify other potential information
sources.
Table 2-10. Information Sources
Information source
Identified environmental aspects
Process maps
Waste and emission data
Site maps
ECAS/EPAS audit reports
Environmental Quality Report (EQR), Instal-
lation Status Report (ISR), Environmental
Program Requirements (EPR), Defense
Site Environmental Restoration Tracking
System (DSERTS), etc.
Possible benefit
Identify and target significant impacts
Identify process steps with environmental aspects
Determine current wastes and sources
Identify environmentally sensitive areas
Identify areas needing improvement
Evaluate environmental performance history
3. Identify preliminary environmental objectives. From the as-
pects and impacts of Steps 16-19, mission support requirements,
and your assessment of other available information, compile a list
of preliminary environmental objectives. It may be helpful to group
them by category as illustrated (Table 2-11). You can prioritize
your objectives, starting with those that relate directly to your sig-
nificant environmental aspects and mission critical tasks, and then
adding others that are less significant but still have mission or envi-
ronmental impact potential.
Table 2-11. Preliminary Environmental Objectives
Energy
use
Increase
alternative
fuel vehicle
use
Decrease
facility en-
ergy use
Raw
materials
Increase
vehicle bat-
tery recy-
cling
Increase
use of recy-
cled paper
Air
impacts
Reduce
VOC emis-
sions
Reduce
visible emis-
sions from
power plant
Water
impacts
Reduce
fuel spills
Eliminate
effluent
from vehi-
cle washing
facilities
Land
impacts
Reduce haz-
ardous waste
disposal from
vehicle main-
tenance fa-
cilities
Reduce land-
filling of solid
waste
Mission
impacts
Reduce op-
erational
noise levels
Address
endangered
species en-
croachment
in training
areas
Other
(specify)
Improve
employee
awareness
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Step-by-Step Guidance
A key question at this point is how many environmental objectives
you should have. Historical EMS implementation project case stud-
ies suggest starting with a limited number of objectives, and then
expanding the list over time. In other words, keep your objectives
simple initially, gain some early successes, and then build on them.
As a realistic starting point, consider limiting your initial list of major
objectives to 12 to 15, fewer if possible.
4. Identify new or proposed regulatory requirements. Identify new
or proposed requirements that affect (or could potentially affect) the
installation's operations or activities. Also, identify potential objec-
tives related to each requirement, as illustrated in Table 2-12.
Table 2-12. Regulatory Requirements and Objectives
New or proposed regulation
or other requirement
Possible objectives
New CAA national ambient air quality standard
(NAAQS) ozone standard
New CAA NAAQS PM2.5 standard
Reduce petroleum fuel consumption in administrative
vehicle fleet.
Reduce emissions of chlorofluorocarbons (CFCs)
from vehicle air conditioning units.
Reduce off-road vehicle travel.
Reduce particulate emissions from coal-and oil-fired
boilers.
5. Identify, review, and evaluate installation communications with
interested parties. Consider the need for additional environmental
objectives related to views of installation neighbors, community
groups, or other interested parties. By definition, an interested
party is "an individual or group concerned with or affected by the
environmental performance of the organization." You can hold an
open house or establish an installation focus group that includes lo-
cal community representatives. Table 2-13 provides an example of
how a local concern might translate into an installation environ-
mental objective:
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Table 2-13. Installation Communications
Communication with
interested party
Response
Possible objectives
Telephone discussion with Jim
Evans, president of Old Bridge
Estates subdivision HOA
(3/15/03, 703-590-5002). Con-
cerned with installation power
plant operation and visible emis-
sions potentially harming local
residents.
Discussed installation policy
regarding power plant opera-
tions and operating permit re-
quirements for controlling and
monitoring emissions. Advised
that we would establish objec-
tives to reduce emissions and
volunteered to attend next HOA
meeting.
Reduce visible emissions from
power plant.
Improve community outreach by
establishing a community advi-
sory panel.
6. Identify appropriate targets for achieving each objective. Envi-
ronmental targets are detailed performance requirements, quanti-
fied where practicable, that arise from the environmental objectives
and that the installation must meet in order to achieve the objec-
tives. Table 2-14 provides a few examples.
Table 2-14. Target Objectives
Objective
Reduce solid waste disposal
Reduce hazardous waste (HW) disposal
Reduce visible emissions from power plant
Reduce energy consumption
Improve employee environmental awareness
Target
Divert 40% of solid waste from landfilling
Reduce HW disposal by 20% from FY02
Reduce visible emissions 60% by 1QFY03
Reduce electricity use by 10% from FY02
Conduct awareness training for all employees by
the end of FY03
For each environmental objective, you should identify at least one
target (some objectives may have more than one). In addition to
being measurable, they should have a specific time frame for com-
pletion. Targets should be achievable, but difficult. The idea is to
motivate the organization to improve environmental performance.
7. Evaluate preliminary objectives and targets. Carefully evaluate
your preliminary objectives and targets to determine whether they
are reasonable, technologically feasible, measurable, consistent
with the environmental policy, and affordable. From your evalua-
tion, compile a final list of objectives and targets (if you identify an
objective but cannot determine an effective way to measure it, put it
on hold for further analysis).
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Step-by-Step Guidance
8. Establish performance measures for final objectives and tar-
gets. As stated earlier, you should quantify your environmental ob-
jectives and targets when practicable. The units commonly used to
quantify objectives and targets are environmental performance in-
dicators (EPIs). An EPI is "an expression that is used to provide in-
formation about environmental performance or the condition of the
environment." Examples of EPIs include the following:
> Quantity of raw material or energy used (total or per unit of pro-
duction)
> Quantity of specific pollutant emissions (for example, nitrogen
oxides (NOX), sulfur oxides (SOX), wastewater)
> Quantity of waste generated or disposed (total or per unit of
production)
> Efficiency of material and energy use
> Number of environmental incidents and accidents
> Number of enforcement actions received
> Number and amount of environmental fines or penalties as-
sessed and paid
> Percentage of waste recycled or reused
> Percentage of recycled material used in packaging
> Number of vehicle miles per unit of production or training
> Investment in environmental protection
> Land area set aside for wildlife habitat.
Continuing with previous illustrations, Table 2-15 shows a few examples.
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Table 2-15. Performance Measures for Final Objectives
Objective
Reduce solid waste dis-
posal
Reduce VOC emissions
Reduce energy con-
sumption
Eliminate enforcement
actions (ENFs)
Improve employee envi-
ronmental awareness
Target
Recycle 50% of solid waste in FY03
Divert 40% of solid waste in FY03
Reduce use of high-VOC paints by
25% in FY03
Reduce use of electricity by 10% in
FY03
No more than two ENFs per FY
Conduct monthly awareness courses
Train all employees by end of FY03
Performance indicator
Tons or % of solid waste recycled
Tons or % of solid waste diverted
Gallons or % reduction in high-
VOC paint used
kWh or % reduction in use
Number of ENFs received
Monthly training is conducted
Number or % of employees who
receive environmental training
When developing your EPIs, be careful to choose those that reflect
the most accurate picture of what is happening on the ground. For
example, suppose that an industrial facility produces 500 main bat-
tle tanks each month and decides to set an objective to reduce
hazardous waste disposal by a certain quantity (tons or percent-
age) by a certain point in time compared with a specific baseline.
progress toward achieving the desired goal.
The facility then makes several process changes and decides to
use less hazardous substances during production to achieve its ob-
jective. If, however, the facility has to substantially increase pro-
duction (to say 750 units) to meet an emergency mission related
requirement, actual hazardous waste disposal might increase in
spite of the process changes. In this case, it probably would have
been better to choose an EPI that measured the tons or percentage
reduction per unit of production to more accurately measure actual
After developing your final list, you should formally document all
your objectives, targets, and EPIs. To view a sample objectives
and targets worksheet that you can use for this purpose, click here.
9. Identify responsible parties and ensure inclusion in appropri-
ate EM Ps. For each objective and associated targets, designate
CFT members (or other technically competent individuals) to be re-
sponsible for achieving them. Normally, this will be managed as
part of an environmental management program that prescribes
who, what, when, where, why, and how the specific objectives will
be achieved (see Step 20 for detailed guidance for preparing envi-
ronmental management programs).
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Step-by-Step Guidance
10. Document your procedure for developing environmental ob-
jectives and targets. In addition to keeping records of your objec-
tives and targets, you should formally document the specific
procedure you used to develop them. You should then use the
same procedure to complete periodic updates and revise the pro-
cedure as needed to ensure continual improvement. To view an
example procedure that Fort Lewis uses for developing objectives
and targets, click here.
Step 22. Describe structure and responsibilities.
Structure and Responsibility,
ISO 14001, Section 4.4.1
Objective
Confirm and document the organization and structure of EMPs that consti-
tute the installation EMS and the associated individual and organizational
Army installations already have the organization, staffing, programs, and resources to
conform to the ISO requirements for structure and responsibility. This step develops
or provides documentation that describes the existing organization and how it imple-
ments and operates the EMPs and the EMS.
responsibilities for implementing and operating the EMS.
Appointing a Management Representative
ISO 14001 requires top management to appoint a specific management
representative who, regardless of other responsibilities, has the responsi-
bility and authority for
• ensuring that EMS requirements are established, implemented, and
maintained in accordance with the ISO 14001 standard, and
• reporting on the performance of the EMS to top management for
review and as a basis for improvement of the EMS.
We recommended selecting the EMSMR in Step 1.
Organizational Chart
You probably already have one, and it is a very convenient tool for docu-
menting and explaining your organizational structure and responsibilities.
Include a current organizational chart with your EMS documentation for
roles and responsibilities. Click here to view an example organization al
chart.
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EMS Organizational Responsibilities Table
A table or matrix is a simple and effective way to summarize EMS respon-
sibilities. The table should list the EMSMR, CFT members, and individu-
als responsible for the EMPs. You can then refer the reader to the
individual EMPs for further information. ISO 14001 does not require a ta-
ble or form, but it is probably the simplest way to summarize and docu-
ment EMS-related responsibilities. Include a reference or direction to the
responsibilities table in your EMS manual. Click here to view an example
EMS responsibilities list.
Review and Update
Your document control procedure (Step 13) should describe how informa-
tion on structure and responsibilities is periodically reviewed and updated.
Step 23. Develop SOPs and work practices for activities
associated with significant aspects.
Operational Control, ISO
14001, Section 4.4.6
Objective
Systematically develop, revise, and document the SOPs associated with
all activities, products, and services that have environmental impacts and
associated aspects to describe the appropriate actions for managing those
impacts and aspects.
Installations should already have SOPs or work practice instructions
(called operational controls in the ISO 14001 standard) for most complex
operations or mission activities, including those with associated significant
environmental aspects. This step ensures that SOPs are in place and that
they contain instructions that enable personnel to comply with the envi-
ronmental policy and achieve environmental objectives and targets. This
information should also be consistent with information presented in com-
petency-based training (Step 24).
Where to Start
Begin this step by reviewing your prioritized list of significant aspects and
impacts. Start with the operations or mission activities at the top of that
list (most significant impacts), and identify any SOPs that address those
activities. Make sure the SOPs adequately address all the skills and pro-
cedures needed to perform the activity in an environmentally acceptable
manner. If part of the process is not documented, the area supervisor
needs to create a new SOP or modify the existing one.
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Step-by-Step Guidance
What to Include
Remember that one of the central ideas of the EMS concept is to integrate
sound environmental management practices in day-to-day operations.
Here, you can affect how employees perform their routine daily tasks. For
example, if the goal is to recycle certain used materials, make recycling a
part of the relevant SOPs. The result should be SOPs that get the job
done and mitigate environmental impacts.
Scheduling Work
You may find it useful to develop a schedule for reviewing and revising
SOPs from your prioritized list of significant aspects. Some installations
have found it effective to coordinate the execution of Steps 23 and 24 so
that SOPs are reviewed and updated immediately before or after compe-
tency-based training is conducted.
After all significant impacts and associated aspects are addressed in
SOPs, you should continue by routinely reviewing all SOPs for environ-
mental considerations as they are revised or updated. You can do so by
modifying your installation's staffing procedures to include appropriate en-
vironmental review and approval.
Operational controls and SOPs and work practice instructions should
• be easy to understand and use,
• list personnel who should receive or have access to them, and
• identify the training needed for the appropriate personnel.28
Your document control procedure (Step 13) should include requirements
and responsibilities for developing, maintaining, and reviewing operational
controls, SOPs, and work practices.
Training, Awareness
and Competency, ISO
14001, Section 4.4.2
Step 24. Identify and fulfill environmental competency-based
training requirements for all installation personnel (garrison
and tenants).
Objective
Establish and maintain a system or process to ensure job-specific compe-
tency for all employees whose work activities can cause real or potential
significant environmental impacts.
28 Concurrent Technologies Corporation for U. S. Army, Environmental Management
System Guidance Manual: Implementing ISO 14001, p. 45.
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Who Must Be Trained
We addressed the awareness portion of this requirement in Step 11. Step 24 deals
with the competency-based training. While all installation personnel are required to
complete EMS awareness training, competency-based environmental training is re-
quired only for those whose work activities can significantly impact the environment.
The first step in meeting this requirement is identifying employees who
need competency-based environmental training. Most installations al-
ready have a training office and a centralized system for managing indi-
vidual training requirements. Try to work within your existing system.
Your installation training coordinator can help complete this requirement.
After looking at the existing training management process, review the list
of significant environmental aspects and impacts (Step19). Employees
performing work or mission activities associated with these significant im-
pacts need competency-based training. When reviewing significant im-
pacts, look at the entire work process to identify all employees who need
the training. It may also help to look at the various regulatory require-
ments that mandate special environmental training and include personnel
working in those areas (Step 15). Be sure to include contract and tempo-
rary workers when assessing training needs.
What Must Be Trained
Competency-based training requirements must be relevant to specific
work activities or job descriptions. The level of training required may also
vary according the level of responsibility assigned to various grade levels
or military ranks. At a minimum, the competency-based training must in-
clude the following:
• The significant environmental impacts, actual or potential, of their
work activities and the environmental benefits of improved personal
performance
• Specific objectives and targets related to their work activities
• The potential consequences of departure from specified operating
procedures (Step 23)
• Environmental training required by applicable regulatory require-
ments
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Step-by-Step Guidance
• Training necessary to obtain or retain required licenses or registra-
tions
• Environmental benefits of improved personal performance.29
Organizing Competency-Based Training
Since competency-based training is more specialized than the awareness
training, addressing competency-based requirements process by process,
or mission by mission is useful. Begin by examining the activities that
contribute to your most significant aspect. Look at the processes, identify
the employees and job descriptions involved, and determine what they
need to know to perform their missions or jobs in an environmentally re-
sponsible manner. Get input from experienced employees or supervisors
as you determine training needs. They are the real experts in their par-
ticular areas and can quickly tell you what will work and what will not.
It may take a while to address all significant impacts and processes, so
develop a schedule and stick to it.
Options for Providing the Training
Competency-based training does not always have to take place in a class-
room. On-the-job training, brownbag sessions, and computer-based train-
ing are good alternatives.
Training Records
You must keep records of the training performed in order to conform to the
ISO 14001 standard. Training records must include the following:
• Individuals and job descriptions requiring training
• Information or skills taught (lesson outline or plan)
• Requirements for completion (written test, hands-on exercise, etc.)
• Schedule or timetable
• Attendance records (include a sign-in sheet)
• Results of evaluation (pass or fail, go/no go).
29 Concurrent Technologies Corporation for U. S. Army, Environmental Management
System Guidance Manual: Implementing ISO 14001, p. 35.
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ISO 14001 does not require documentation of training procedures, but we
recommend you develop training documentation that includes
• the process the installation uses to determine training needs,
• the location of the training plans and who is responsible for them,
and
• how training is prioritized on the installation.
The Army is one of the most experienced training organizations in the world.
If you follow the training procedures the Army uses to teach soldier skills, you will
meet the ISO requirements. Make maximum use of available assets, including the
training management systems and expert training personnel on your installation.
Your training program is an ongoing function on the installation. You must
continually assess and update installation-specific training needs. Keep
procedures and records in accordance with your installation's document
control and record-keeping procedures.
Obtaining Training Materials
Because of the specialized nature of competency-based training, you may
have to obtain information from a variety of sources or develop lessons "in
house" to meet your needs. However, all Army installations share many
similar functions, and good training materials will become readily available
as more installations implement their EMS. Before developing training
materials in house, check the sources that follow to see whether existing
materials can meet your needs:
• Training posted on DENIX
• Other installations with similar missions
• Training workshops
• Training videos
• Internal trainers
• Experts
• Consultants
• Community colleges
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Step-by-Step Guidance
• Vendors and suppliers
• Technical, trade, and business associations
• Self-study or study groups
• Training consortia (major command or IMA region meetings).
Click here for additional resources regarding competency-based training.
Step 25. Establish monitoring and measurement Monitoring and Measurement,
procedures. ' ISOMOOL section «.i
Objective
Establish and maintain documented procedures as required by ISO
14001, Sec 4.5.1, to
• regularly monitor and measure the key characteristics of your op-
erations and activities that can significantly impact the environment;
Key characteristics are the environmental performance indicators established for each
target set in Step 21.
Performance indicators should be simple and understandable, objective, measurable,
verifiable, reproducible, and relevant to your installation's objectives and targets.
They should also be practical, cost-effective, and technologically feasible. The identi-
fication of environmental performance indicators should be an ongoing process (ISO
14004, p. 21). Your performance indicators must provide top management with the
information it needs to make decisions about the EMS (NSF-ISR, p. 62).
• track environmental performance (including progress toward meet-
ing objectives and targets and conformance with SOPs);
• calibrate and maintain monitoring equipment and maintain records
of the calibration process; and
• periodically evaluate compliance with relevant environmental laws
and legislation.
What Should Be Measured?
Two major sets of activities or processes should be measured and moni-
tored:
• Processes associated with significant aspects all require some sort
of monitoring or measurement. Sophisticated techniques and
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automated systems are usually not required, but if a process is as-
sociated with a significant aspect, someone should be checking
performance.
• The group of processes related to objectives and targets requires
monitoring. These are actually a subset of the first group, and are
probably a higher priority since you specifically identified these ar-
eas for improvement. You can begin by reviewing your installa-
tion's list of objectives and targets and the associated and the
associated performance measures (Step 21).
You must eventually define required measuring and monitoring for all sig-
nificant aspects, but the first priority should relate to the objectives and tar-
gets.
Examine the performance measures (key characteristics) developed in
Step 21. Do you already have an accurate and reliable way to monitor
and measure these variables? At this point, check with the environmental
management staff and with the supervisors in charge of these processes
to determine what is already being measured and monitored. Some of the
monitoring you need is probably already being done.
For each of the key characteristics you need to monitor, think about the
following:
• Is the required monitoring already being done?
• If so, is the method
> providing accurate data? (Performed using valid, documented
procedures and calibrated equipment?)
> reliable? (Performed successfully on a regular schedule, with
data recorded and maintained according to documented proce-
dures?)
> performed at an appropriate frequency? (You need multiple data
points to track variables and interpret performance over a time
period. Recommended frequency depends on the variable be-
ing measured and the changes you need to demonstrate.)
If your current monitoring procedures do not satisfy these requirements,
you should examine the procedures and equipment to determine needed
improvements. Likewise, if you need to implement new monitoring pro-
grams, be sure that the procedures meet these requirements and provide
the data you need to effectively evaluate performance.
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Step-by-Step Guidance
"Monitoring and measuring can be a resource-intensive effort."30 Be cer-
tain to have clearly defined requirements for data collection and to avoid
collecting data for "data's sake."31
Ensure your installation has a clear, well-communicated schedule for rou-
tine monitoring and measurement and equipment calibration. In your
schedule, include time for proper data management and quality control
procedures.
Record, Analyze, and Understand Data
Monitoring programs are useless if you cannot correlate the measured
data with performance. To do so, you must accurately record the data you
are collecting and maintain it in format that illustrates any changes in per-
formance. Involve the supervisors and employees who work in the proc-
ess being measured; ensure they understand the data being collected and
how it relates to both the performance measures and the objectives and
targets.
Often, your performance measures will accurately document performance
but will not tell why the process is working better or worse. Understanding
the variables or factors that affect performance is critical to analyzing your
data and assessing your progress toward objectives and targets. A root
cause analysis, such as those performed as part of ERAS audits, can be
valuable. Also, supervisors and line employees can often provide quick
analyses of process performance and the factors affecting it. They can
help you identify what to change to obtain the results you want and can
often explain how underlying or uncontrolled variables are influencing per-
formance.
Tracking Performance
The ISO 14001 standard requires you to track performance of your signifi-
cant processes using performance measure data and evaluate your pro-
gress toward objectives and targets. This periodic evaluation ensures that
you are consistently moving toward the established objectives. If the proc-
ess is not meeting the established objectives and targets, you must de-
termine why and make changes to improve performance. For some
processes, you can establish operating parameters that apply to your per-
formance measures. Performance data that fall outside of your estab-
lished operating parameters indicate subpar performance and should
30 NSF-ISR, Environmental Management Systems—An Implementation Guide for
Small and Medium-Sized Organizations, p. 60.
31 NSF-ISR, Environmental Management 5
Small and Medium-Sized Organizations, p. 60.
31 NSF-ISR, Environmental Management Systems—An Implementation Guide for
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trigger evaluation of and adjustments to the process. Maintain perform-
ance records in accordance with your EMS records procedure.
Also, remember to look at SOPs and make sure they accurately describe
appropriate ways to perform duties and operate the process. After verify-
ing that the SOP is correct, ensure that employees are following it.
Calibration Requirements
Some measurements involve equipment such as scales, meters, and
other measurement devices. Proper and accurate functioning of these
items is critical to your success. Review the manufacturer's recommenda-
tions and document a calibration and testing procedure. Maintain the pro-
cedures, required calibration and testing schedules, and calibration and
testing records in accordance with your document control and records
maintenance procedures.
Evaluate Compliance with Environmental Laws and Regulations
In addition to meeting your objectives and targets, you need to periodically
check your regulatory compliance status. From Step 15, you know the
regulations and laws that apply to your installation and its activities. To
meet the ISO 14001 requirement, you must document the procedures you
use to periodically check compliance. Army installations have been doing
this for many years, and you probably already have these procedures in
place (such as ECAS/EPAS, internal and external assessments, and ISR
II). In most cases, your main task will be to check the documentation and
records for these processes and maintain the information in accordance
with your established procedures. Typical processes for ensuring compli-
ance include periodic inspections, as well daily, weekly, or monthly moni-
toring of critical process (wastewater treatment monitoring to satisfy the
national pollutant discharge elimination system (NPDES) permits, for ex-
ample). Also, internal and external audits performed as part of the EPAS
program can provide periodic snapshots of regulatory compliance. Be
sure to check installation compliance action plans (ICAPs) to verify that
existing compliance problems are being properly addressed.
Click here for example measuring and monitoring procedures.
Step 26. Establish procedures for maintaining EMS records. *enc°rdf' '5° A c,
r r & 14001, Section 4.5.3
Objective
Develop and implement procedures for managing records that document
EMS operation and performance.
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Step-by-Step Guidance
Definition
ISO 14001 requires organizations (such as installations and other appro-
priate facilities) to "establish and maintain procedures for the identification,
maintenance and disposition of environmental records. These records
shall include training records and the results of audits and reviews."32
The records are the information that must be maintained to document the
performance of the EMS and to demonstrate conformance with the ISO
14001 standard (Figure 2-4). Keeping complete and well organized envi-
ronmental records is critical, not only because of the ISO requirement, but
also because the records help you track environmental performance and
improve the EMS.
Figure 2-4. EMS Document Hierarchy
'Polic
A
V
Manual
Procedures
Operational Controls
More Detail
EMS Records
EMS Documentation
V. provides policy and
f direction
EMS Records describe results
You can organize your records in a variety of ways, such as according to
EMPs. Some types of records, like audit reports, include information cov-
ering multiple EMPs and might be stored in their own specific files. Using
an electronic database with search capabilities greatly increases the flexi-
bility of your record-keeping system and will resolve most file location is-
sues.
32
ISO 14001, Section 4.5.3, p.5.
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Hints for Records
• Begin by identifying the records required. Look at your procedures and SOPs
to determine the evidence needed to demonstrate conformance. Also,
consider records that must be generated due to various legal requirements.
• Focus on records that add value.
• If you generated forms in order to implement the EMS, the forms, once filled
out, become records. Keep forms simple and understandable.
• Establish a records retention policy and stick to it. Include records retention
requirements specified in applicable environmental regulations.
• When formulating your records management process, consider the people
who need access to the records and the circumstances.
• Consider using an electronic EMS records management system.
• Think about which records need additional security or restricted access.
Consider a remote backup of critical records at another location.
Records must be
• legible;
• identifiable and traceable to the activity, product, or service in-
volved;
• stored and maintained to be readily retrievable and protected
against damage, deterioration, or loss; and
• kept in accordance with established and recorded retention times.
Make sure your records policy answers the following questions:
• What records are kept?
• Who keeps them?
• Where are they kept?
• How are they kept?
• How long are they kept?
• How are they accessed?
• How are they disposed of?
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Step-by-Step Guidance
In addition to training records and audit results, records may also include
the following:
• Legislative and regulatory requirements
• Compliance records
• Job descriptions
• Permits, licenses, and other approvals
• Environmental aspects and their associated impacts
• Environmental training records
• Equipment inspection, calibration, and maintenance activity and re-
cords
• Sampling and monitoring data
• Information on emergency preparedness and response
• Details of nonconformance, incidents, complaints, external commu-
nications, and follow-up action
• Supplier and contractor information33
• Results of EMS audits and management reviews.
"The effective management of these records is essential to the successful
implementation of the EMS."34
Click here for examples of EMS record maintenance procedures used
successfully at other Army installations.
Step 27. Develop and review emergency preparedness
and response documents and procedures.
Emergency Preparedness
and Response, ISO 14001,
Section 4.4.7
Objective
Establish and maintain procedures as required by ISO 14001 to:
• Identify potential for accidents and emergency situations.
• Respond to accidents and emergency situations.
33 Concurrent Technologies Corporation for U. S. Army, Environmental Management
System Guidance Manual: Implementing ISO 14001, p. 50.
34 ISO 14004, Section 4.4.4, p. 22.
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Prevent and mitigate the environmental impacts that may be asso-
ciated with accidents and emergencies.
Review and revise emergency preparedness and response proce-
dures where necessary, especially after the occurrence of an acci-
dent or emergency.
Conduct drills and tests of emergency preparedness and response
procedures
Potential environmental accidents and emergency situations include
• accidental emissions to the atmosphere,
• accidental discharges to water and land,
• specific environment and ecosystem effects from accidental releases, and
• fire.
(ISO 14004 and Concurrent Technologies Corporation for U. S. Army, Environmental
Management System Guidance Manual: Implementing ISO 14001)
You should also consider emergency situations resulting from terrorist or
other intentional acts that might impact the environment when developing
and reviewing emergency preparedness and response documents and
procedures.
On most Army installations, the required plans and procedures are already
in place as required documentation per Army policy, so reviewing and
documenting the location and maintenance of the plans constitutes most
of your work.
Key Team Members
Emergency preparedness and response normally involve multiple organi-
zations on and off the installation. All participants must work together to
develop detailed plans and execute quick, coordinated responses. The
CDR is ultimately responsible for these operations but, in most cases, re-
lies on the staff to coordinate and execute the technical aspects of the re-
sponse. On medium and large installations, key individuals in this process
are the heads of the fire and emergency services organizations. They are
most likely to manage the execution of any response. Other key organiza-
tions include the following:
• Medical services (casualty management)
• Military police or public safety (traffic control)
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Step-by-Step Guidance
• Public works (infrastructure and utility systems)
• Preventive medicine and environmental health (human health risk
issues)
• Safety
• Environmental management
• Public affairs
• Off-post responders (local hospitals, fire departments, and hazard-
ous materials (HAZMAT) units)
• Counter-terrorism officials (if applicable).
Determine Emergency Plans and Procedures
First, determine the plans and procedures required by laws and regula-
tions. Depending upon the nature of their missions and operations, Army
installations are often required by law to maintain the following:
• Risk management plan (a CAA Section 112r requirement for instal-
lations that stock certain chemicals above threshold quantities)
• Spill contingency plan (SCP) and spill prevention, control, and
countermeasures plan (SPCCP) to address potential oil spills
• RCRA contingency plan
• Facility response plan (FRP)
• Chemical accident/incident response and assistance (CAIRA) plan.
In addition, your state may require specific plans covering certain contin-
gencies. Check your state's requirements during this process.
To complete your list of required response plans, look at other areas or
operations on your installation that have the potential for environmental
accidents or releases not covered by laws and regulations. One way is to
look at the hazardous or regulated materials used on the installation. In
most cases, they will be addressed under the laws and regulations dis-
cussed earlier and will be included in an existing plan. If not, you should
make sure they are included.
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Review and Update Your Response Plans
Your document control procedures (Step 13) must include requirements
and responsibilities for reviewing and updating emergency response plans
at least annually. Key team members should participate in the review, and
the results should be recorded as part of the review process. The major
purpose of the review is to identify changes on the installation that affect
plan execution. Be sure to review attachments to the plans, such as con-
tact names and phone numbers, maps, facility floor plans, and material
safety data sheets (MSDSs). These details often change and can seri-
ously compromise the plan. As you review the plans, ensure that they
meet the ISO 14001 requirements listed at the beginning of this step.
Posting and Distributing Plans
Make sure that employees can easily access plans and that they under-
stand what they are expected to do in case of an emergency. Maintaining
the plans on your intranet helps document control issues, but you may
also want to post hard copies of the plans in affected organizations and
work areas to ensure easy access. Observe document control procedures
and remove outdated versions of the plans from the involved organiza-
tions and work areas. Include off-post responder organizations.
Training and Exercises
Competency-based training (Step 24) must cover the emergency prepar-
edness or response plans. When feasible, you should conduct no-notice
drills or exercises to test the ability of employees and responders to react
quickly and correctly in case of emergencies. When you conduct an exer-
cise (or after an actual emergency), hold an after-action review (AAR),
keep records of the results, and revise the affected plans as required.
Documentation
Maintain the following documentation in accordance with your EMS docu-
ment control procedures:
• A procedure for identifying the potential for environmental accidents
and emergencies (risk assessment)
• All installation environmental accident and emergency response
plans and procedures
• Documentation on how the installation works to prevent such inci-
dents and the associated environmental impacts (provide the loca-
tion of procedures for fire, safety, HAZMAT storage, and hazardous
waste accumulation point inspections)
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Step-by-Step Guidance
• Mitigation procedures for impacts associated with accident and
emergencies (covered in your response plans)
• Emergency preparedness and response document review and test-
ing processes.
Click here for example procedures covering emergency preparedness and
response.
Step 28. Establish procedures for nonconformance
and preventive and corrective actions
Nonconformance,
corrective and pre-
ventive action, ISO
14001, Sec. 4.5.2
Objective
Definition
At this point, you have taken great strides in establishing and implement-
ing the EMS, but your EMS is not perfect. To deal with imperfections—
some of which may have been identified from measuring, monitoring, au-
dits, and other reviews—and to adapt to changes on the installation, you
must develop procedures for dealing with nonconformance.
Develop and implement procedures that meet the ISO 14001 require-
ments for
• defining responsibility and authority for handling and investigating
nonconformance,
• taking action to mitigate any resulting impacts,
• initiating and completing preventive and corrective actions, and
• implementing changes to EMS procedures as a result of preventive
or corrective actions.
Nonconformance refers to situations or actions that do not meet or comply
with the requirements established in the your installation's EMS or the ISO
14001 standard. Nonconformance can also mean that implementation is
not consistent with the EMS description.35
35
NSF-ISR, Environmental Management Systems—An Implementation Guide for
Small and Medium-Sized Organizations, p. 65.
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Typical causes of nonconformance include
• poor communication,
• faulty or missing procedures,
• equipment malfunction (or lack of maintenance),
• lack of training,
• lack of understanding requirements,
• failure to enforce rules, and
• corrective actions that fail to address root causes of problems.
(NSF p. 66)
Means of identifying potential or real nonconformance include
• findings, conclusions, and recommendations reached as a result of
measuring and monitoring;
• audits and other reviews;
• accidents;
• employee comments; and
• changes in installation activities or structure.
Responsibilities and Authorities
Your nonconformance procedures must establish the nonconformance re-
sponsibilities and authorities for the various organizations and individuals
involved in the EMS. Organize this information with a table or separate
paragraphs covering each position or organization, as seen in Army regu-
lations. Click here for some examples. Whatever the format, everyone on
the installation, from the CDR and supervisors to individual employees,
must understand what they can and must do to address nonconforming
situations.
Processes
Your procedures must include instructions for completing several standard
actions designed to identify and respond to nonconformances:
• Identifying and Reporting. Guidance for individuals who identify a
potential nonconformance, including to whom one reports and how
to document the report.
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Step-by-Step Guidance
• Investigation and Analysis. Guidance for determining who has
the authority and responsibility to investigate nonconformance, the
steps to be included in the process, documentation of the results,
and who receives the results of the investigation.
• Mitigation of Impacts. For nonconformance that impacts the envi-
ronment, guidance on who is responsible for mitigation and who
approves and provides oversight on the mitigation activities.
• Corrective and Preventive Actions. Guidance for preventing the
nonconformance from occurring again, including the individuals or
groups responsible for formulating the preventive actions and en-
suring that the preventive actions are implemented and incorpo-
rated in existing EMS documentation.
General Principles
In any nonconformance situation, the parties responsible for addressing
the nonconformance must perform several key activities to correctly as-
sess and respond to the problem. Ensure that your nonconformance pro-
cedures include the following:
• Determine the root cause.
• Develop the appropriate corrective or preventive action.
• Document the corrective or preventive action. (The amount of plan-
ning and documentation varies with the severity of the problem and
its potential environmental impacts. Try to keep things simple:36)
• Implement the corrective or preventive action.
• Record the documentation and implementation of the corrective or
preventive action.
• Communicate the corrective or preventive action.
• Track and verify the effectiveness of corrective or preventive ac-
tions.
By analyzing system deficiencies, attempting to determine the root cause,
or identifying why the problems are actually occurring, you may be able to
detect patterns or trends. "Identifying trends allows you to anticipate and
prevent future problems. Preventing problems is generally cheaper than
36 NSF-ISR, Environmental Management Systems—An Implementation Guide for
Small and Medium-Sized Organizations, p. 66.
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fixing them after they occur (or after they reoccur)."37 When a problem is
documented, the installation commits to quickly resolving it. Be certain the
corrective and preventive action process developed includes responsibili-
ties and completion schedules. If the action is going to be lengthy or re-
source intensive, review progress regularly.
The corrective action should
• resolve the immediate problem,
• consider whether the same or similar problems exist elsewhere, and
• prevent the problem from recurring.
The corrective action process should also define the responsibilities and schedules
associated with these three steps.
(NSF p. 66)
Furthermore, you must ensure that any corrective or preventive action
taken to eliminate the causes of actual and potential nonconformances
must be appropriate to the magnitude of problems and commensurate
with the environmental impact encountered.38 Changes in the EMS
documented procedures that result from any corrective or preventive ac-
tion must be implemented and recorded. In addition, the installation must
ensure that these corrective and preventive actions have been imple-
mented and that systematic follow-up ensures their effectiveness.
If your installation has an ISO 9001 management system in place, use the
ISO 9001 corrective and preventive action process as a model for this
EMS corrective and preventive action procedure.40 Consider incorporating
parts of the corrective action process with the management review proc-
ess. For example, use the management review meetings to review non-
conformities, discuss causes and trends, and identify corrective actions
and assign responsibilities.41
ISO 14001 requires only that organizations establish and maintain proce-
dures for nonconformance and corrective and preventive action. We rec-
ommend that you document these procedures to ensure consistency and
understanding across the installation.
37 NSF-ISR, Environmental Management Systems—An Implementation Guide for
Small and Medium-Sized Organizations, p. 65.
38 ISO 14001, Section 4.5.2, p. 5.
39 ISO 14004, Section 4.4.3, p. 22.
40 NSF-ISR, Environmental Management Systems—An Implementation Guide for
Small and Medium-Sized Organizations, p. 65.
41 NSF-ISR, Environmental Management f
Small and Medium-Sized Organizations, p. 65.
41 NSF-ISR, Environmental Management Systems—An Implementation Guide for
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Step-by-Step Guidance
Environmental Management Sys-
Step 29. Conduct periodic EMS audits.
r r tern Audits, IS014001, Sec 4.5.4
Objective
Establish and maintain programs and procedures for periodic EMS audits
to do the following:
• Determine whether the EMS operates in accordance with docu-
mented procedures and the ISO 14001 standard.
• Determine whether the EMS has been properly implemented and
maintained.
• Provide audit results information to management.
• Base the audit coverage on environmental importance and previous
audit results.
• Include the scope, frequency, methods, responsibilities, and re-
quirements for conducting audits, measures to ensure auditor com-
petence, and reporting results.
Definition
ISO 14001 defines EMS audits as "systematic and documented verifica-
tion process of objectively obtaining and evaluating evidence to determine
whether an organization's environmental management system conforms
to the environmental management system audit criteria set by the organi-
zation, and or communication of the results of this process to manage-
ment."
Who Can Conduct Audits?
EMS audits can be performed by installation personnel or by external par-
ties selected by the installation. The ERAS program, which we detail be-
low, provides internal audit protocols and external audit support for Army
installations. If your installation is ISO 9001-conformant, consider using
your internal quality auditors as your internal EMS auditors.42 Regardless
whom you choose to perform audits, they must be properly trained. Train-
ing can come from a variety of sources, including on the job, on-line or
correspondence courses, or classroom auditor training. Finally, your EMS
42 NSF-ISR, Environmental Management Systems—An Implementation Guide for
Small and Medium-Sized Organizations, p. 72.
2-87
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auditors must be able to audit objectively and impartially.43 To help en-
sure objectivity, select auditors from outside the activity or chain of com-
mand of the activity being audited. When selecting external EMS auditors,
installations should consider using ISO 14012 "Guidelines for Environ-
mental Auditing—Qualification Criteria for Environmental Auditors" as their
selection criteria. Some installations recommend pairing an auditor from
an external organization (for objectivity) with an auditor within the activity
(for process and procedural knowledge.)
Frequency and Scope
The nature of the installation's environmental aspects and potential im-
pacts, as well as the previous audit's results, should guide the frequency
of the audits. Each organization has considerable flexibility as to how and
when it conducts internal audits. Do not wait until the EMS is fully imple-
mented and documented before conducting the first audit. Audits can oc-
cur simultaneously with implementation.44
You are not required to audit the entire EMS at one time. You may break
the EMS into discrete elements to allow for more frequent audits. In
general, each part of the entire EMS should be audited at least annually,
more often if warranted. Audit coverage should be prioritized using two
criteria: environmental significance and prior audit results. You should
audit areas with significant environmental impacts early and often. Like-
wise, operations or processes with a history of nonconformance (discov-
ered by audit results, regulatory violations, or other reporting) must also be
a high audit priority.
Objectives of EMS Audits
"Your EMS audits should focus on objective evidence of conformance.
During an audit, auditors should resist the temptation to evaluate, for ex-
ample, why a procedure was not followed-that step comes later."46 The
EMS "audit is a check on how well your system meets your own estab-
lished EMS requirements. An EMS audit is not an assessment of how
well employees do their jobs."47 Audits, if done properly, can provide
benefits beyond meeting the ISO requirement. They can identify and help
43
44
ISO 14004, Section 4.4.5, p. 22.
Concurrent Technologies Corporation for U. S. Army, Environmental Management
System Guidance Manual: Implementing ISO 14001, p. 51.
45 NSF-ISR, Environmental Management 5
Small and Medium-Sized Organizations, p. 71.
46 NSF-ISR, Environmental Management 5
Small and Medium-Sized Organizations, p. 72.
47 NSF-ISR, Environmental Management 5
Small and Medium-Sized Organizations, p. 73.
45 NSF-ISR, Environmental Management Systems—An Implementation Guide for
46 NSF-ISR, Environmental Management Systems—An Implementation Guide for
47 NSF-ISR, Environmental Management Systems—An Implementation Guide for
2-88
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Step-by-Step Guidance
correct nonconformities before any significant environmental impacts re-
sult. Audits can help you fine-tune your EMS to optimize environmental
(and mission) performance.
Figure 2-5. Linkages Among EMS Audits, Corrective Action, and
Management Reviews 48
Results
EMS Established
w Periodic EMS Audits
i
— ,
(
r
Management Reviews
Corrective Action Process
Records of audit results must be maintained and communicated to con-
form with the requirements of ISO14001. Audit results are one form of
EMS performance information that must always be communicated to
management. Recording audit results allows monitoring of corrective ac-
tions. Because audit results are EMS records, consider creating and us-
ing a template for documenting audit results. Although not a formal
requirement, it may ease compliance with your EMS's records and docu-
mentation requirements. Furthermore, installations should "ensure that
identified system gaps or deficiencies are corrected in a timely fashion and
that corrective actions are documented."50
You need a documented audit procedure that addresses
• audit scope (including the activities and areas considered in audits),
• audit protocols,
• audit criteria,
• audit frequency,
• auditor training and competence requirements,
• responsibilities and requirements for managing and conducting audits, and
• responsibilities and requirements for documenting, reporting, and communi-
cating results.
Source: ISO 14001
48
NSF-ISR, Environmental Management Systems—An Implementation Guide for
Small and Medium-Sized Organizations, p. 73.
49 Concurrent Technologies Corporation for U. S. Army, Environmental Management
System Guidance Manual: Implementing ISO 14001, p. 51.
50 NSF-ISR, Environmental Management Systems—An Implementation Guide for
Small and Medium-Sized Organizations, p. 72.
2-89
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ERAS
For the past several years, EGAS has provided comprehensive environ-
mental compliance audits for installations. EGAS is now transforming into
the ERAS, with a new focus on EMS and management issues. Many de-
tails of the ERAS program are still being developed, but it will provide ex-
ternal audit assistance for at least some elements of your EMS. Due to
resource constraints, annual ERAS audits at all installations are unlikely,
but audit protocols and other audit tools from ERAS will be made available
to installations as the tools are developed and fielded. The ERAS team
leader schedules periodic ERAS external assessments with input from
Army leadership, the IMA, and installation staffs. These ERAS audit tools
can help you establish your internal EMS audit procedures. ERAS will still
provide compliance auditing support to help meet the compliance auditing
requirements of EO 13148.
Click here for ERAS audit procedures, checklists, and example audit re-
sults.
Self-Declaration Procedures
Army EMS policy requires appropriate facilities to achieve full confor-
mance with the ISO 14001 standard by 31 December 2009. Third party
registration to the standard is not required, but facilities must follow Army
procedures for self-declaration of conformance in order to meet the FY09
requirement. The self-declaration procedures require confirmation of con-
formance by either an internal or external ERAS audit before facilities can
self-declare, or publicly assert that they conform to the ISO 14001 stan-
dard. Click here to view the Army self-declaration procedure.
Step 30. Conduct periodic EMS management reviews.
Management Review,
ISO 14001, Section 4.6
Objective
Establish procedures for top management to periodically review the per-
formance of the EMS.
As part of a continual improvement process, the ISO 14001 standard re-
quires an organization's top management (EQCC or similar group) to re-
view the EMS, at intervals that it determines, to ensure that the EMS is
working (suitable, adequate, and effective, given the installation's
needs).51
51 NSF-ISR, Environmental Management Systems—An Implementation Guide for
Small and Medium-Sized Organizations, p. 75.
2-90
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Step-by-Step Guidance
Management Reviews, Quality Management, and IPRs
The management review as described by the ISO standard is basically the
same as the IPR commonly used in the Army. Consider holding man-
agement reviews at least once a year. Depending on the nature of your
objectives and targets, hold IPRs semiannually or quarterly to track pro-
gress and make adjustments in a timely manner. You can combine man-
agement review meetings with other meetings, such as strategic planning
or quality review meetings, or have a standalone EMS management re-
view meeting."52 Management reviews are one key to continual improve-
ment and for ensuring that the EMS will continue to meet your
organization's needs over time."53
Management Review Questions to Ponder
• Did we achieve our objectives and targets? If not, why not? Should we modify
our objectives?
• Is our environmental policy still relevant to what we do?
• Are roles and responsibilities still clear, do they make sense, and are they
communicated effectively?
• Are we applying resources appropriately?
• Are our procedures clear and adequate? Do we need other controls? Should
we eliminate some of them?
• Are we fixing problems when we find them?
• Are we monitoring our EMS (such as via system audits)? What do the results
of those audits tell us?
• What effects have changes in materials, products, or services had on our
EMS and its effectiveness?
• Do changes in laws or regulations require us to change some of our ap-
proaches?
• What other changes are coming in the near term? What impacts (if any) will
these have on our EMS?
• What stakeholder concerns have been raised since our last review? How are
concerns being addressed?
• Is there a better way? What can we do to improve?
(NSF-ISR, Environmental Management Systems—An Implementation Guide for Small and Me-
dium-Sized Organizations, p. 76)
52
NSF-ISR, Environmental Management Systems—An Implementation Guide for
Small and Medium-Sized Organizations, p. 75.
53 NSF-ISR, Environmental Management Systems—An Implementation Guide for
Small and Medium-Sized Organizations, p. 75.
2-91
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Management Review Objectives
The management review should serve several functions:
• Providing general information about the EMS and current environ-
mental issues to top management (continuing awareness)
• Discussing the relevancy of the installation's environmental policy,
objectives, and targets in light of changing situations and making
appropriate revisions
• Discussing EMS audit results and approving related plans and re-
sources required to improve the EMS
• Reviewing progress toward objectives and targets, approving new
or revised objectives and targets.
Who Participates
Two kinds of people should be involved in the management review proc-
ess:
• Those who know and are responsible for specific aspects of the
EMS and related environmental issues. This group extends be-
yond the environmental management office and should include in-
dividuals responsible for EMPs, as well as individuals in the various
functional areas where significant impacts occur.
• Those who can make decisions about the organization and its re-
sources (top management).54 On an Army installation, these in-
clude the EQCC, chaired by the CDR.
Scope
The review should be comprehensive, though not all elements of an EMS
need to be reviewed at once and the review process may take place over
time. The review of the policy, objectives, and procedures should be car-
ried out by the level of management that defined them. Reviews should
include
• minutes from previous management reviews,
• results from audits,
• the extent to which objectives and targets have been met,
54 NSF-ISR, Environmental Management Systems—An Implementation Guide for
Small and Medium-Sized Organizations, p. 75.
2-92
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Step-by-Step Guidance
• the continuing suitability of the EMS in relation to changing condi-
tions and information,
• concerns among relevant interested parties (internal suggestions
and external communications),55
• other environmental performance measures, and
• reports of emergencies, spills, or other incidents or nonconform-
ities.
Evaluate the need to change the environmental policy, objectives, targets,
and other elements of the EMS due to the following factors:
• Changing mission
• Addition of new facilities
• Changing legislation
• Changing expectations and requirements of interested parties
• Changes in the products or activities of the installation
• Advances in science and technology
• Lessons learned from environmental incidents
• Reporting and communication.56
Management reviews should assess both positive and negative findings
and not only focus on the negative. Ensure the review focuses on the in-
stallation's environmental performance and evaluates the EMS's effec-
tiveness.
Documentation and Followup
Record the minutes of the management review and document resulting
observations, conclusions, and recommendations to prepare for neces-
sary actions. In addition, "if any corrective action must be taken, top man-
agement should follow up to ensure that the action was effectively
implemented."57 Consider maintaining a "due-out" list that documents re-
quired actions, responsible parties, and scheduled dates. Use this list to
55 ISO 14001, Section A.6, p. 10.
56 ISO 14004, Section 4.5.2, p. 23.
57 Concurrent Technologies Corporation for U. S. Army, Environmental Management
System Guidance Manual: Implementing ISO 14001, p. 53.
2-93
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track required actions to completion. Maintain all management review
documentation in accordance with your document control procedures.
Continual Improvement
"The purpose and final outcome of the management review should be
continual improvement of the EMS."58 The continual improvement proc-
ess should
• identify areas of opportunity for improvement of the EMS that lead
to improved environmental performance,
• determine the cause or causes of nonconformance or deficiencies,
• develop and implement plans of corrective and preventive action to
address root causes,
• verify the effectiveness of the corrective and preventive actions,
• document changes in procedures resulting from process improve-
ment, and
• make comparisons with objectives and targets".59
Management reviews offer an opportunity to keep the EMS efficient and
cost-effective. If your installation developed procedures or processes that
are no longer needed, eliminate them.60" As your organization's EMS in-
creases in its effectiveness and efficiency, your environmental perform-
ance will likewise increase."61
CONCLUSION
Congratulations! The basic elements of your EMS are now in place, and
you can focus on continual improvement. As you continue to operate and
examine the EMS and its procedures, you will undoubtedly find ways to
streamline the EMS to increase both effectiveness and ease of use. You
will also see that the environmental focus of the installation will shift from a
defensive, reactive posture to one that is proactive and based on sound
58 Concurrent Technologies Corporation for U. S. Army, Environmental Management
System Guidance Manual: Implementing ISO 14001, p. 53.
59 ISO 14004, Section 4.5.3, p. 24.
60 NSF-ISR, Environmental Management Systems—An Implementation Guide for
Small and Medium-Sized Organizations, p. 75.
61 Concurrent Technologies Corporation fo
System Guidance Manual: Implementing ISO 14001, p. 53.
61 Concurrent Technologies Corporation for U. S. Army, Environmental Management
2-94
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Step-by-Step Guidance
planning and informed decision-making. In order to keep the EMS rele-
vant and effective, you must ensure that the mission remains the central
focus of the management system and the EMS works to enhance readi-
ness and develop sustainable processes and activities.
2-95
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References
We used the following references to compile this guide.
POLICIES AND MEMORANDA
Executive Order 13148, "Greening the Government Through Leadership in
Environmental Management," 21 April 2000
Memorandum for Assistant Chief of Staff for Installation Management,
from Raymond J. Fatz, Deputy Assistant Secretary of the Army (Envi-
ronment, Safety and Occupational Health), OASA(I&E), Subject, Army
Environmental Management System, 13 July 2001. Available from
http://aec.army.mil/usaec/support/ems-requirements080601.pdf.
Memorandum for Deputy Assistant Secretary of the Army (Environment,
Safety and Occupational Health) from John Paul Woodley, Jr., Assis-
tant Deputy Undersecretary of Defense (Environment), Subject, Envi-
ronmental Management System (EMS) Implementation Criteria and
Metrics, 30 Jan 2003.
DOCUMENTS
ISO 14001:1996, Environmental management systems—Specification
with guidance for use.
ISO 14004:1996(E), Environmental Management Systems—General
Guidelines on principles, systems and supporting techniques, first edi-
tion.
Concurrent Technologies Corporation for U. S. Army, Environmental
Management System Guidance Manual: Implementing ISO 14001.
National Science Foundation International Strategic Registrations (NSF-
ISR), Ltd., Environmental Management Systems: An Implementation
Guide for Small and Medium-Sized Organizations. Second Edition.
2001.
Ref-1
-------
WEBSITES
DENIX EMS Subject Area
https://www.denix.osd.mil/denix/DOD/Library/EMS/ems.html
PEER) Center, How to Implement an EMS [on-line document], undated
[cited February 2003]. Available from:
http://www.peercenter.net/howtoimplement/.
CDs
Concurrent Technologies Corporation, Environmental Management Tool-
kit—An Environmental Management System Implementation Tool, Octo-
ber 2002.
Ref-2
-------
Appendix A
Acronyms
AAR
ABC
ANSI
AR
ARNG
ARTEP
BMP
CAA
CAIRA
CBT
CDR
CERCLA
CFCs
CFR
CFT
CONUS
COTS
CWA
DENIX
DFE
DoD
DPW
DSERTS
EGAS
ECOs
EMP
EMS
after-action review
activity-based costing
American National Standards Institute
Army Regulation
Army National Guard
Army Readiness Training Evaluation Programs
best management practice
Clean Air Act
Chemical accident/incident response and assistance
computer-based training
commander
Comprehensive Environmental Response, Compensation
and Liability Act
chlorofluorocarbon
Code of Federal Regulations
cross-functional team
Continental United States
commercial off-the-shelf
Clean Water Act
Defense Environmental Network Information Exchange
Design for the environment
Department of Defense
directorate of public works
Defense Site Environmental Restoration Tracking System
Environmental Compliance Assessment System
environmental compliance officers
environmental management programs
environmental management system
A-1
-------
EMSMR
ENFs
EO
EPA
ERAS
EPCRA
EPI
EPR
EQCC
EQR
ESA
FIFRA
FRP
FY
GOCO
HAZMAT
HMTA
HOA
HW
ICAPs
IMA
IMRO
IPR
ISR
IT
METL
MSDSs
NAAQS
NCA
NEPA
NLT
NOV
environmental management system management repre-
sentative
enforcement actions
Executive Order
U.S. Environmental Protection Agency
Environmental Program Assessment System
Emergency Planning and Community Right-To-Know Act
environmental performance indicators
Environmental Program Requirements
environmental quality control committee
Environmental Quality Report
Endangered Species Act
Federal Insecticide, Fungicide, and Rodenticide Act
Facility response plan
fiscal year
government-owned, contractor-operated
hazardous material
Hazardous Materials Transportation Act
homeowners association
hazardous waste
installation compliance action plans
Installation Management Agency
installation management regional office
in-process review
Installation Status Report
information technology
mission-essential task list
material safety data sheets
national ambient air quality standards
Noise Control Act
National Environmental Policy Act
no later than
notices of violation
A-2
-------
Acronyms
NOx
NPDES
OB/OD
OCONUS
ODCs
PAO
PM2.5
POC
POL
POTW
RCRA
RDT&E
REOs
SCP
SDWA
SOP
SOx
SPCC
SPCCP
SRS
SS
IDA
TOE
TSCA
USAEC
use
VOC
nitrogen oxides
national pollutant discharge elimination system
open burn/open detonation
Outside Continental United States
ozone depleting chemicals
public affairs office
particulate matter with diameter less than or equal to 2.5
microns
point of contact
petroleum, oil, or lubricant
publicly owned treatment works
Resource Conservation and Recovery Act
Research, development, testing, and evaluation
regional environmental offices
Spill contingency plan
Safe Drinking Water Act
standard operating procedure
sulfur oxides
Spill Prevention, Control, and Countermeasures
Spill Prevention, Control, and Countermeasures Plan
Strategic Readiness System
significance score
Table of Distribution and Allowances
Table of Organization and Equipment
Toxic Substances Control Act
U.S. Army Environmental Center
United States Code
volatile organic compounds
A-3
-------
Dtl'AHTME.,ST OF VETERANS AITAlHS
nti>>'T\ ASSIST.vvr SKiiinv\HY FOR ACQUISITION \\u
M A.N.\GLMENT
« ASHIXGION. DC 2
-------
T.
II 049-02-11
July 5, 2Q02
4. E.O. 13148, Part 7 - Acquisition and Procurement, specifically, provides guidance to
procurement officials and acquisition program managers. EO 13148 Part 7 includes the
followi no'.
Section 701: Limiting Procurement of Toxic Chemicals, Hazardous
Substances and other pollutants.
(b) Each agency shall determine the feasibility of implementing
centralized procurement and distribution (e.g., "pharmacy") programs at its
facilities for tracking, distribution, and management of toxic or hazardous
materials and, where appropriate, implement such programs.
(c) Under established schedules for review of standardized documents,
DOD and GSAr and other agencies, as appropriate, shall review their
standardized documents and identify opportunities to eliminate or reduce
their use of chemicals included on the list of priority chemicals developed
by the EPA.
(d) Each agency shall follow the policies and procedures for toxic
chemical release reporting in accordance with FAR section 23,9 and
policies and procedures on Federal compliance with right-to-know laws
and pollution prevention requirements in accordance with FAR section
23.10.
Section 702. Environmentally Benign Adhesives Each agency shall
revise its specifications for paper products using adhesives and direct the
purchase of paper products using those adhesives, whenever technically
practicable and cost effective. Each agency should consider products
using the environmentally benign pressure sensitive adhesives approved
by the U.S. Postal Service (USPS) and on the USPS Qualified
Products List for pressure sensitive recyclable adhesives.
Section 703. Ozone-Depleting Substances. Each agency shall follow
the policies and procedures for the acquisition of items that contain, use,
or are manufactured with ozone-depleting substances m accordance with
FAR section 23.8 and other applicable FAR provisions.
-------
1L 0494)2-11
lulv 5, 2002
Section 704, Environmentally and Economically Beneficial Landscaping
Practices,
(a) Each agency shall have in acquisition and procurement
practices, including provision of landscaping services that conform to the
"Guidance for Presidential Memorandum on Environmentally and
Economically Beneficial Landscape Practices on Federal Landscaped
Grounds", for the use of environmentally and economically beneficial
landscaping practices.
(b) In implementing landscaping policies, each agency shall purchase
environmentally preferable and recycled content products, including EPA-
designaled items such as compost and mulch, that contributes to
environmentally and economically beneficial practices,
5, Training programs will be implemented to ensure that agency procurement officials
and acquisition program managers are aware of the requirements of this order and its
applicability to those individuate. The training program dates will be announced at a
later date,
6. Direct any questions regarding this information letter to Patricia Ellis, Acquisition
Policy Division (049A5A), at (202) 273-6058,
/s/David S. Derr
Associate Deputy Assistant Secretary
for Acquisitions
Distribution; RPC 7029
-------
-------
Wednesday
October 16, 1996
Part VIM
Environmental
Protection Agency
Code of Environmental Management
Principles; Notice
54061
-------
54062
Federal Register / Vol. 61, No. 201 / Wednesday, October 16, 1996 / Notices
ENVIRONMENTAL PROTECTION
AGENCY
[FRL-5636-4]
Code of Environmental Management
Principles
AGENCY: Environmental Protection
Agency.
ACTION: Announcement of EPA's
Issuance of the Code of Environmental
Management Principles for Federal
Agencies.
SUMMARY: This notice serves as a public
announcement of the issuance of the
Code of Environmental Management
Principles or the CEMP developed by
EPA in consultation with other Federal
Agencies as mandated by Executive
Order 12856 ("Federal Compliance With
Right-to-Know Laws and Pollution
Prevention Requirements") signed by
President Bill Clinton on August 3,
1993. On September 3, 1996, EPA
transmitted the CEMP to Federal agency
executives who signed the Charter for
the Interagency Executive Order 12856
Pollution Prevention Task Force in
September 1995, requesting written
commitment to the principles contained
in the CEMP. EPA also is asking Federal
agency executives to provide a written
statement declaring their agency's
support for the CEMP principles along
with a description of the agency's plans
for implementation of the CEMP at the
facility level.
DATES: EPA has asked for written
responses from Federal agency
executives by October 1, 1996.
Extensions to requesting agencies
have been granted to October 18, 1996.
EPA plans to issue a summary of agency
responses in January 1997.
FOR FURTHER INFORMATION CONTACT:
James Edward, Acting Associate
Director, Federal Facilities Enforcement
Office, Office of Enforcement and
Compliance Assurance, United States
Environmental Protection Agency, 401
M Street, SW., Washington DC 20460,
telephone 202-564-2462 or Andrew
Cherry, U.S. Environmental Protection
Agency, 401 M Street, SW., Washington,
DC. 20460, phone (202) 564-5011, fax
(202) 501-0069
SUPPLEMENTARY INFORMATION:
I. Explanation of the CEMP
A. Background
EPA believes that leadership
opportunities in environmental
management should be fully realized for
the Federal agencies and departments
throughout the U.S. Government.
American citizens and other stakeholder
groups have increasingly sought a more
responsible standard of care toward the
environment from various sectors of
industry and other private
organizations. In response, more and
more companies and trade associations
have begun initiatives that call for
identifying their environmental impacts,
measuring their successes in meeting
environmental objectives, sanctioning
shortcomings, recognizing
accomplishments, and making
continuous improvement. Recently the
growing popularity of national and
international consensus based
environmental management standards
among industry demonstrates this trend.
However, the public has also demanded
that the Federal Government and its
agencies and departments, also
demonstrate a commitment to a
common environmental ethic. EPA
believes that if the Federal Government
is willing to make a public commitment
to voluntarily adopt an appropriate code
of environmental ethics or conduct,
which is at least equivalent to the
commitment demonstrated by
environmental leaders in the private
sector, and hold itself accountable for
implementing these principles, then
significant progress can be made toward
improving public trust and confidence
toward Federal facility environmental
performance.
On August 3, 1993, President Clinton
signed Executive Order No. 12856,
which pledges the Federal Government
to implement pollution prevention
measures, and publicly report and
reduce the generation of toxic and
hazardous chemicals and associated
emissions. Section 4-405 of Executive
Order 12856 requires the Administrator
of the Environmental Protection Agency
(EPA), in cooperation with Federal
agencies, to establish a Federal
Government Environmental Challenge
Program. Similar to the "Environmental
Leadership" program proposed in 1993
by EPA's Office of Enforcement, the
program is designed to recognize and
reward outstanding environmental
management performance in Federal
agencies and facilities. As required
under the Executive Order, the program
shall consist of three components to
challenge Federal agencies to: (1) Agree
to a code of environmental principles
emphasizing pollution prevention,
sustainable development, and "state of
the art" environmental management
programs; (2) submit applications to
EPA for individual Federal facilities for
recognition as "Model Installations";
and (3) encourage individual Federal
employees to demonstrate outstanding
leadership in pollution prevention. The
program is geared toward recognizing
those departments, agencies, and
Federal installations where mission
accomplishment and environmental
leadership become synonymous and to
highlight these accomplishments as
models for both Federal and private
organizations.
On September 12, 1995, senior agency
representatives signed the Charter for
the Interagency Pollution Prevention
Task Force committing the Federal
Government to achieve, among other
items, environmental excellence
through various activities including: (a)
Active agency and facility participation
in the Federal Government
Environmental Challenge Program and,
(b) participation in the establishment of
an agency Code of Environmental
Management Principles.
EPA has been working to develop the
CEMP through the Interagency Pollution
Prevention Task Force, which was
created by the Executive Order, since
January 1995. In June 1995, a
subcommittee of Federal agency
representatives was formed by the Task
Force to work directly with EPA in the
development of the CEMP. Through this
process, several drafts of the CEMP were
forwarded to Federal agencies by the
subcommittee for formal review and
comment. This version of the CEMP
represents the final version as approved
by the subcommittee and incorporates
comments from members of the
Interagency Task Force.
On September 3, 1996, Steve Herman,
the EPA Assistant Administrator for
Enforcement and Compliance
Assurance, signed a letter transmitting
the CEMP to the Federal agency
executives who had signed the Charter
for the Interagency Executive Order
12856 Pollution Prevention Task Force
in September 1995, requesting written
commitment to the Principles contained
in the CEMP. In this letter, EPA also
asked each agency to provide a written
statement declaring their support for the
CEMP principles at the agency level
along with a description of their plans
for implementation of the CEMP at the
facility level.
EPA is seeking endorsement of the
CEMP Principles on an agency wide
basis, with flexibility as to how the
Principles themselves are implemented
at the facility level. For example,
agencies can choose to directly
implement the CEMP Principles at the
facility level or use another alternative
environmental management system
(e.g., ISO 14001). This flexible approach
is in recognition that of the fact that
individual Federal facilities and
installations may already have
environmental management systems in
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Federal Register / Vol. 61, No. 201 / Wednesday, October 16, 1996 / Notices
54063
place or are considering adoption of the
ISO 14001 Environmental Management
Standard.
It is also important to point out that
the term "agency" is used throughout
the CEMP to represent the participation
of individual Federal Government
entities. It should be recognized that
many Cabinet-level "agencies" have
multiple levels of organization and
contain independently operating bodies
(known variously as bureaus,
departments, administrations, services,
major commands, etc.) with distinct
mission and function responsibilities.
Therefore, while it is expected that a
"parent agency" would subscribe to the
CEMP, each parent agency will have to
determine the most appropriate level(s)
of explicit CEMP implementation for its
organization. Regardless of the level of
implementation chosen for the
organization, it is important that the
parent agency or department
demonstrate a commitment to these
principles.
With respect to the other two
components of the Federal Government
Environmental Challenge Program, EPA
will merge the E.O. 12856 Model
Installation Program with EPA—s
Environmental Leadership Program
(ELP), which is also open to private
facilities, when the ELP becomes a full-
scale program in 1997. One of the
prerequisites for Federal facility
participation in the ELP will be agency
endorsement of the CEMP principles. In
addition, EPA will also the individual
employee recognition component of the
Challenge Program with the Executive
Order 12873 Closing the Circle Awards
Program beginning in 1996.
B. Overview of the CEMP
Five broad environmental
management principles have been
developed to address all areas of
environmental responsibility of Federal
agencies. More discussion of the intent
and focus of each principle and
supporting elements may be found in
the next section, "Implementation of
The Code of Environmental
Management Principles." The five
Principles are as follows:
1. Management Commitment
The agency makes a written top-
management commitment to improved
environmental performance by
establishing policies which emphasize
pollution prevention and the need to
ensure compliance with environmental
requirements.
2. Compliance Assurance and Pollution
Prevention
The agency implements proactive
programs that aggressively identify and
address potential compliance problem
areas and utilize pollution prevention
approaches to correct deficiencies and
improve environmental performance.
3. Enabling Systems
The agency develops and implements
the necessary measures to enable
personnel to perform their functions
consistent with regulatory requirements,
agency environmental policies and its
overall mission.
4. Performance and Accountability
The agency develops measures to
address employee environmental
performance, and ensure full
accountability of environmental
functions.
5. Measurement and Improvement
The agency develops and implements
a program to assess progress toward
meeting its environmental goals and
uses the results to improve
environmental performance.
II. Implementation of the Code of
Environmental Management Principles
Each of the five principles, which
provide the overall purpose of the step
in the management cycle, is supported
by Performance Objectives, which
provide more information on the tools
and mechanisms by which the
principles are fulfilled. The principles
and supporting Performance Objectives
are intended to serve as guideposts for
organizations intending to implement
environmental management programs or
improve existing programs. It is
expected that each of these principles
and objectives would be incorporated
into the management program of every
organization. The degree to which each
is emphasized will depend in large part
on the specific functions of the
implementing organization. An initial
review? of the existing program will help
the organization to determine where it
stands and how best to proceed.
Principle 1: Management Commitment
The agency makes a written top-
management commitment to improved
environmental performance by
establishing policies which emphasize
pollution prevention and the need to
ensure compliance with environmental
requirements.
Performance Objectives
1.1 Obtain Management Support. The
agency ensures support for the
environmental program by management
at all levels and assigns responsibility
for carrying out the activities of the
program.
Management sets the priorities,
assigns key personnel, and allocates
funding for agency activities. In order to
obtain management approval and
support, the environmental management
program must be seen as vital to the
functioning of the organization and as a
positive benefit, whether it be in
financial terms or in measures such as
regulatory compliance status,
production efficiency, or worker
protection. If management commitment
is seen as lacking, environmental
concerns will not receive the priority
they deserve.
Organizations that consistently
demonstrate management support for
pollution prevention and environmental
compliance generally perform at the
highest levels and will be looked upon
as leaders that can mentor other
organizations wishing to upgrade their
environmental performance.
1.1.1 Policy Development. The agency
establishes an environmental policy
followed by an environmental program
that complements its overall mission
strategy.
Management must take the lead in
developing organizational goals and
instilling the attitude that all
organization members are responsible
for implementing and improving
environmental management measures,
as well as develop criteria for evaluating
how well overall goals are met. The
environmental policy will be the
statement that establishes commitments,
goals, priorities, and attitudes. It
incorporates the organization's mission
(purpose), vision (what it plans to
become), and core values (principles by
which it operates). The environmental
policy also addresses the requirements
and concerns of stakeholders and how
the environmental policy relates to
other organizational policies.
1.1.2 System Integration. The agency
integrates the environmental
management system throughout its
operations, including its funding and
staffing requirements, and reaches out to
other organizations.
Management should institutionalize
the environmental program within
organizational units at all levels and
should take steps to measure the
organization's performance by
incorporating specific environmental
performance criteria into managerial
and employee performance evaluations.
Organizations that fulfill this
principle demonstrate consistent high-
level management commitment,
integrate an environmental viewpoint
into planning and decision-making
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Federal Register / Vol. 61, No. 201 / Wednesday, October 16, 1996 / Notices
activities, and ensure the availability of
adequate personnel and fiscal resources
to meet organizational goals. This
involves incorporating environmental
performance into decision-making
processes along with factors such as
cost, efficiency, and productivity.
1.2 Environmental Stewardship and
Sustainable Development. The agency
strives to facilitate a culture of
environmental stewardship and
sustainable development.
"Environmental Stewardship" refers
to the concept that society should
recognize the impacts of its activities on
environmental conditions and should
adopt practices that eliminate or reduce
negative environmental impacts. The
President's Council on Sustainable
Development was established on June
29, 1993 by Executive Order 12852. The
Council has adopted the definition of
sustainable development as; "meeting
the needs of the present without
compromising the ability of future
generations to meet their own needs".
An organization's commitment to
environmental stewardship and
sustainable development would be
demonstrated through implementation
of several of the CEMP Principles and
their respective Performance Objectives.
For example, by implementing pollution
prevention and resource conservation
measures (see Principle 2, Performance
Objective 2.3), the agency can reduce its
negative environmental impacts
resulting directly from its facilities. In
addition, by including the concepts of
environmental protection and
sustainability in its policies, the agency
can help develop the culture of
environmental stewardship and
sustainable development not only
within the agency but also to those parts
of society which are affected by the
agency's activities.
Principle 2: Compliance Assurance and
Pollution Prevention.
The agency implements proactive
programs that aggressively identify and
address potential compliance problem
areas and utilize pollution prevention
approaches to correct deficiencies and
improve environmental performance.
Performance Objectives
2.1 Compliance Assurance. The
agency institutes support programs to
ensure compliance with environmental
regulations and encourages setting goals
beyond compliance.
Implementation of an environmental
management program should be a clear
signal that non-compliance with
regulations and established procedures
is unacceptable and injurious to the
operation and reputation of the
organization. Satisfaction of this
performance objective requires a clear
and distinct compliance management
program as a component of the agency's
overall environmental management
system.
An agency that fully incorporates the
tenets of this principle demonstrates
maintainable regulatory compliance and
addresses the risk of non-compliance
swiftly and efficiently. It also has
established a proactive approach to
compliance through tracking and early
identification of regulatory trends and
initiatives and maintains effective
communications with both regulatory
authorities and internally to coordinate
responses to those initiatives. It also
requires that contractors demonstrate
their commitment to responsible
environmental management and
provides guidance to meet specified
standards.
2.2 Emergency Preparedness. The
agency develops and implements a
program to address contingency
planning and emergency response
situations.
Emergency preparedness is not only
required by law, it is good business.
Properly maintained facilities and
trained personnel will help to limit
property damage, lost-time injuries, and
process down time.
Commitment to this principle is
demonstrated by the institution of
formal emergency-response procedures
(including appropriate training) and the
appropriate links between health and
safety programs (e.g., medical
monitoring for Federal employees
performing hazardous site work).
2.3 Pollution Prevention and Resource
Conservation. The agency develops a
program to address pollution prevention
and resource conservation issues.
An organization committed to
pollution prevention has a formal
program describing procedures,
strategies, and goals. In connection with
the formal program, the most advanced
organizations have implemented policy
that encourages employees to actively
identify and pursue pollution
prevention and resource conservation
measures, and instituted procedures to
incorporate such measures into the
formal program. Resource conservation
practices would address the use by the
agency of energy, water, and
transportation resources, among others.
Pollution prevention policies and
practices should follow the
environmental management hierarchy
prescribed in the Pollution Prevention
Act of 1990: (1) Source reduction; (2)
recycling; (3) treatment; and (4)
disposal.
Section 3-301(b) of Executive Order
12856 requires the head of each Federal
agency to make a commitment to
utilizing pollution prevention through
source reduction, where practicable, as
a primary means of achieving and
maintaining compliance with all
applicable Federal, State and local
environmental requirements.
Principle 3: Enabling Systems
The agency develops and implements
the necessary measures to enable
personnel to perform their functions
consistent with regulatory requirements,
agency environmental policies and it's
overall mission.
Performance Objectives
3.1 Training. The agency ensures that
personnel are fully trained to carry out
the environmental responsibilities of
their positions.
Comprehensive training is crucial to
the success of any enterprise. People
need to know what they are expected to
do and how they are expected to do it.
An organization will be operating at the
highest level when it has an established
training program that provides
instruction to all employees sufficient to
perform the environmental aspects of
their jobs, tracks training status and
requirements, and offers refresher
training on a periodic basis.
3.2 Structural Supports. The agency
develops and implements procedures,
standards, systems, programs, and
objectives that enhance environmental
performance and support positive
achievement of organizational
environmental and mission goals.
Clear procedures, standards, systems,
programs, and short- and long-term
objectives must be in place for the
organization to fulfill its vision of
environmental responsibility. A
streamlined set of procedures,
standards, systems, programs, and goals
that describe and support the
organization's commitment to
responsible environmental management
and further the organization's mission
demonstrate conformance with this
principle.
3.3 Information Management,
Communication, Documentation. The
agency develops and implements
systems that encourage efficient
management of environmentally-related
information, communication, and
documentation.
Information management,
communication, and documentation are
necessary elements of an effective
environmental management program.
The need for advanced information
management capabilities has grown
significantly to keep pace with the
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54065
volume of available information to be
sifted, analyzed, and integrated. The
ability to swiftly and efficiently digest
data and respond to rapidly changing
conditions can be key to the continued
success of an organization.
Organizations adopting this principle
have developed a sophisticated
information gathering and
dissemination system that supports
tracking of performance through
measurement and reporting. They also
have an effective internal and external
communication system that is used to
keep the organization informed
regarding issues of environmental
concern and to maintain open and
regular communication with regulatory
authorities and the public. Those
organizations operating at the highest
level ensure that employees have access
to necessary information and implement
measures to encourage employees to
voice concerns and suggestions.
Principle 4: Performance and
Accountability
The agency develops measures to
address employee environmental
performance, and ensure full
accountability of environmental
functions.
Performance Objectives
4.1 Responsibility, Authority and
Accountability. The agency ensures that
personnel are assigned the necessary
authority, accountability, and
responsibilities to address
environmental performance, and that
employee input is solicited.
At all levels, those personnel
designated as responsible for
completing tasks must also receive the
requisite authority to carry out those
tasks, whether it be in requisitioning
supplies or identifying the need for
additional personnel. Similarly,
employees must be held accountable for
their environmental performance.
Employee acceptance of accountability
is improved when input is solicited.
Encouraging employees to identify
barriers to effective performance and to
offer suggestions for improvement
provides a feeling of teamwork and a
sense that they control their own
destiny, rather than having it imposed
from above.
4.2 Performance Standards. The
agency ensures that employee
performance standards, efficiency
ratings, or other accountability
measures, are clearly defined to include
environmental issues as appropriate,
and that exceptional performance is
recognized and rewarded.
Organizations that identify specific
environmental performance measures
(where appropriate), evaluate employee
performance against those measures,
and publicly recognize and reward
employees for excellent environmental
performance through a formal program
demonstrate conformance with this
principle.
Principle 5: Measurement and
Improvement:
The agency develops and implements
a program to assess progress toward
meeting it's environmental goals and
uses the results to improve
environmental performance.
Performance Objectives
5.1 Evaluate Performance. The agency
develops a program to assess
environmental performance and analyze
information resulting from those
evaluations to identify areas in which
performance is or is likely to become
substandard.
Measurement of performance is
necessary to understand how well the
organization is meeting its stated goals.
Businesses often measure their
performance by such indicators as net
profit, sales volume, or production. Two
approaches to performance
measurement are discussed below.
5.1.1 Gather and Analyze Data. The
agency institutes a systematic program
to periodically obtain information on
environmental operations and evaluate
environmental performance against
legal requirements and stated objectives,
and develops procedures to process the
resulting information.
Managers should be expected to
provide much of the necessary
information on performance through
routine activity reports that include
environmental issues. Performance of
organizations and individuals in
comparison to accepted standards can
also be accomplished through periodic
environmental audits or other
assessment activities.
The operation of a fully-functioning
system of regular evaluation of
environmental performance along with
standard procedures to analyze and use
information gathered during evaluations
signal an organization's conformance
with this principle.
5.1.2 Institute Benchmarking. The
agency institutes a formal program to
compare its environmental operations
with other organizations and
management standards, where
appropriate.
"Benchmarking" is a term often used
for the comparison of one organization
against others, particularly those that
are considered to be operating at the
highest level. The purpose of
Benchmarking is twofold: first, the
organization is able to see how it
compares with those whose
performance it wishes to emulate;
second, it allows the organization to
benefit from the experience of the peak-
performers, whether it be in process or
managerial practices.
Benchmarking against established
management standards, such as the ISO
14000 series or the Responsible Care
program developed by the Chemical
Manufacturers Association (CMA), may
be useful for those agencies with more
mature environmental programs,
particularly if the agencies' activities are
such that their counterparts in the
private sector would be difficult to find.
However, it should be understood that
the greater benefit is likely to result
from direct comparison to an
organization that is a recognized
environmental leader in its field.
5.2 Continuous Improvement. The
agency implements an approach toward
continuous environmental improvement
that includes preventive and corrective
actions as well as searching out new
opportunities for programmatic
improvements.
Continuous improvement is
approached through the use of
performance measurement to determine
which organizational aspects need to
have more attention or resources
focused upon them.
Continuous improvement may be
demonstrated through the
implementation of lessons learned and
employee involvement programs that
provide the opportunity to learn from
past performance and incorporate
constructive suggestions. In addition,
the agency actively seeks comparison
with and guidance from other
organizations considered to be
performing at the highest level.
IV. Responses From Federal Agencies
and Departments
EPA is requesting Federal agencies to
provide a brief written statement
declaring the agency's support for the
CEMP Principles along with a concise
explanation of how the agency plans to
implement the CEMP at the facility
level. To implement the CEMP the
agency may choose to employ voluntary
environmental management standards
developed by national or international
consensus groups or by industry trade
associations as long as the spirit of the
CEMP is evidenced by those chosen
standards. At this time, EPA is seeking
agency level commitment to the CEMP.
EPA recognizes that many Federal
agencies may have already begun
development of environmental
management systems or have chosen to
implement a particular environmental
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54066 Federal Register / Vol. 61, No. 201 / Wednesday, October 16, 1996 / Notices
management standard at their facilities.
EPA recommends that these agencies
leverage the work that has already been
accomplished, and perform some
comparative or gap analysis between the
existing environmental management
system, program or standard and the
CEMP to ensure that the principles of
the CEMP are fully implemented.
Therefore the CEMP can be
implemented concurrently and not in
addition to the work that is already
being performed at the agency.
Dated: September 23, 1996.
Steven A. Herman,
Assistant Administrator for Enforcement and
Compliance Assurance.
[FR Doc. 96-26451 Filed 10-15-96; 8:45 am]
BILLING CODE 6560-50-P
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OFFICE OF THE FEDERAL ENVIRONMENTAL EXECUTIVE
WHITE HOUSE TASK FORCE ON WASTE PREVENTION AND RECYCLING
1200 PENNSYLVANIA AVENUE, NW MAIL CODE 1600S WASHINGTON, DC 20460
(202) 564-1297 WWW.OFEE.COV TASK_FORCE@OFEE.GOV
PROMOTING SUSTAINABLE ENVIRONMENTAL STEWARDSHIP THROUGHOUT THE FEDERAL GOVERNMENT
MEMORANDUM
SUBJECT: EMS Self-Declaration Protocol
FROM: John Howard
Federal Environmental Executive 9
TO: Agency Environmental Executives
DATE: January 27, 2004
This memorandum formally transmits for your implementation the Enwonmental Management
System (EMS) Agency Self-Declaration Protocol for Appropriate Federal Facilities (Protocol).
dated September 10, 2003. This document was prepared by the Executive Order 13148
Interagency Environmental Management Workgroup in accordance wilh their responsibilities
under Section 306 to develop guidance for implementing the Order. The Protocol establishes the
framework to be used by each agency in formulating the process and guidance for its facilities to
self-declare compliance with the EMS requirements of the Order. The deadline for
implementation of the Protocol is December 31, 2004.
Implementation of the Protocol will ensure that each agency's guidance for declaring
conformance to that agency's selected EMS framework reflects accepted EMS principles and that
facility or organization EMSs have been properly developed and effectively implemented.
Further, the document will allow review of the entire Federal government's progress in achieving
the EMS goals in the Order while maintaining flexible conformance criteria that can be adapted
for unique application by each agency. The Protocol must be implemented by December 31,
2004 to support each agency's facility-level implementation of the EMS requirement prior to the
December 2005 deadline established in the Order. I encourage agencies to share then- agency
self-declaration guidance with EPA or my office as soon as it is available. The E.O. 13148
annual report request for calendar year 2004 will also ask each agency to supply a copy of its
self-declaration guidance.
I appreciate the continued efforts of the E.O. 13148 Workgroup to provide the tools to streamline
progress towards our goal of environmental leadership in the Federal government. As your
agency prepares guidance for facility or organization self declaration, please follow the guidance
in the Self-Declaration Protocol. Thank you for your continued support:.
Minimum 30 percent postconsumer recycled content naoer
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Environmental Management Systems
Agency Self-Declaration Protocol for Appropriate Federal Facilities
Final Version September 10, 2003
Introduction and Purpose:
The process used by federal agencies and their facilities or organizations to self-declare
conformance with their selected environmental management systems (EMS) must ensure
credibility. In order to meet this goal, agencies must develop a process that provides for
effective and objective assessment of these systems in a manner that not only ensures the
system is conformant, but is also designed for ongoing evaluation and continual improvement.
Such a process must not only verify that appropriate documentation is developed, but affirm that
the facility or organization is actually implementing their EMS as defined in their documentation
and doing what they say they are doing. This process must also include the degree of
transparency and objectivity necessary to make the self-declaration credible.
This protocol outlines procedures for federal agencies developing processes that will ensure
the credibility of self-declaration of EMS for their appropriate facilities as set forth in Executive
Order 13148. Specifically, this protocol is designed to satisfy the following principles:
1. Result in accurate and reliable information on federal facilities' progress as they
adopt improved business practices associated with EMS implementation.
2. Focus responsibility for initial EMS verification and on-going quality assurance at the
agency / bureau level.
3. Provide agencies / bureaus flexibility to implement EMS in ways that support their
overall public mission.
4. Provide an independent basis for verifying the status of a facility or organization
EMS, and appropriately communicating that status to internal and external
stakeholders.
5. Ensure that system verification is more than a documentation review, and that the
effectiveness of implementation is also reviewed.
6. Use existing EMS elements where possible so that self-declaration becomes an
integral part of the organization's EMS.
Protocol:
Agencies / bureaus shall direct their facilities or organizations to use one or more EMS
evaluation guide(s) in conducting EMS self-declarations. Examples of evaluation guides
are included in:
• Appendix A, The Global Environmental Management Initiative (GEMI) "ISO 14001
Environmental VlEn-.gcrncnt System Self Assessment Checklist" [Hotlink title text to
document]
• Appendix B, "Oregon Green Permits Program Guide - Attachment B: EMS
Description and References." [Hotiink title text to document]
• Appendix C, The National Aeronautics and Space Administration's "Environmental
Functional Review Checklist." [Hotlink title text to document]
1. In directing use of the selected evaluation guide, agencies / bureaus shall establish a
procedure including the following:
a) direction on the use of the chosen evaluation guide(s).
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b) direction on the frequency of self-declaration internal evaluations; the frequency of
agency / bureau independent reviews, makeup oT the independent review learn (e.g.,
Headquarters, other facility, other agency, or contractor), and qualifications of
independent reviewers, a requirement for facility or organization management to
make a self-declaration statement that the EMS is in place when that conclusion is
reached.
c) direction on documenting and using the results of EMS evaluations. This shall
include steps for acknowledging adequate facility EMSs, follow-up actions to
address inadequacies in the EMSs, and reporting results of evaluations for inclusion
in agency-wide annual EMS reviews.
d) a schedule for reviewing agency / bureau EMS Self-Declaration Procedures. This
review shall consider changes in agency / bureau programs and missions when
appropriate but on a schedule that does not exceed five years. This is designed to
allow a phased approach and continual improvement. An example of an agency
EMS Self-Declaration Procedure is included in Appendix D, The National
Aeronautics and Space Administration's "Environmental Functional Review Standard
Operating Procedure." [Hotlink title text to document]
2. Agencies / bureaus shall communicate their choice of guide(s) ;and procedures
described above in accordance with their internal and external EMS communication
procedures.
3 Agencies / bureaus shall establish their procedures for EMS self-declaration as soon as
practical but not later than NLT December 31, 2004.
4. Agencies / bureaus shall include appropriate guidance to ensure that facilities desiring
to participate in a Federal or state EMS recognition program (e.g., National
Environmental Performance Track, Oregon Green Permits Program, New Jersey Silver
Track Program) reflect the respective requirements in their self declaration procedures.
5. Facilities or organizations that wish to self declare their EMS before agency procedures
are in place may:
a) adopt a recognized independent review process such as third-party registration to
ISO 14001 or
b) document the information described in protocol iteml (b), (c) and (d) above and
communicate that information to external parties in accordance with their EMS
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RCRA ENFORCEMENT AND COMPLIANCE
CONTENTS
1. Introduction 1
2. Statutory Summary 2
2.1 Enforcement Authorities 2
2.2 Inspections and Information Gathering 2
2.3 Monitoring, Analysis, Testing, and Reporting 5
2.4 Enforcement Mechanisms 5
2.5 Compliance Orders and Penalties 8
2.6 Corrective Action 8
2.7 Imminent Hazard 8
2.8 Citizen Suits 9
3. Special Issues 10
4. Compliance Incentives and Assistance 12
5. Small Business Regulatory Enforcement Fairness Act 14
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RCRA Enforcement and Compliance - 1
1. INTRODUCTION
The effective implementation of the RCRA program depends on whether the regulated
community complies with the various RCRA requirements. The goals of the RCRA
enforcement program are to ensure that the regulatory and statutory provisions of
RCRA are met, and to compel necessary action to correct violations. To achieve these
goals, EPA and the states closely monitor hazardous waste handlers, taking expeditious
legal action when noncompliance is detected. EPA also has various programs to
provide compliance incentives and assistance.
Many of the questions the Hotline receives on enforcement are purely legal and beyond
our purview. We do not interpret the law or legal concepts; we only answer questions
relating to statutory and regulatory programs and how enforcement and compliance
tools are used as part of the RCRA process.
When you have completed this module you will be able to explain RCRA enforcement
and describe the enforcement mechanisms. Specifically, you will be able to:
• Describe enforcement procedures and mechanisms and cite the statutory
authorities
• Describe the three different types of enforcement actions, administrative, civil,
and criminal
• Explain when and how EPA can enforce the RCRA regulations in authorized
states
• State the differences between enforcement at interim status and permitted
facilities and describe enforcement at federal facilities
• Describe some of EPA's compliance incentive and assistance policies.
Use this list of objectives to check your understanding of this topic after completing the
training session.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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2 - RCRA Enforcement and Compliance
2. STATUTORY SUMMARY
The success of the RCRA program depends on the regulated community's compliance
with the regulations. To ensure compliance with the program, Congress gave EPA
certain distinct powers, or authorities, for enforcement. EPA has the authority to
inspect and collect information from facilities and, if a violation is discovered, employ
any one of several enforcement actions to bring facilities into compliance. EPA uses a
combination of monitoring, administrative actions, and civil actions to reduce the
number of waste handlers that are out of compliance and to deter future violators. EPA
works with the Regional offices, the states, and, where appropriate, the Department of
Justice (DOJ) to implement the RCRA enforcement program.
2.1 ENFORCEMENT AUTHORITIES
EPA's hazardous waste enforcement program is designed to promote compliance with
statutory and regulatory requirements and to abate imminent hazards. Enforcement
provides EPA and citizens with mechanisms for carrying out the RCRA program and
promotes the protection of human health and the environment. Since EPA has not
codified regulations covering enforcement, with the exception of some administrative
procedures found in 40 CFR Parts 22 and 24, RCRA enforcement personnel rely on the
following statutory authorities to enforce the RCRA program:
• Section 3007 - Inspections and Information Gathering
• Section 3008
(a) Compliance Orders
(b) Public Hearings
(c) Violation of Compliance Orders
(d) Criminal Penalties
(e) Knowing Endangerment
(g) Civil Penalties
(h) Interim Status Corrective Action Orders
• Section 3013 - Monitoring, Analysis, and Testing
• Section 7002 - Citizen Suits
• Section 7003 - Imminent Hazards.
2.2 INSPECTIONS AND INFORMATION GATHERING
An important component of the enforcement process is the authority to monitor
facilities for verification of compliance with the regulations. The Agency collects
compliance monitoring information primarily through facility inspections and
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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RCRA Enforcement and Compliance - 3
information requests. An inspection is a formal visit by an EPA or state representative
to a facility to review records, take samples, and observe facility operations. Congress
granted EPA the authority to conduct such inspections and collect necessary
information to determine compliance under RCRA §3007.
Section 3007 gives EPA the authority to inspect facilities that handle or have handled
hazardous wastes. In addition, the inspection authority is applicable to facilities that
handle mixtures of hazardous wastes and domestic sewage (§3018(d)). Furthermore,
§4005(c)(2)(B) extends EPA's §3007 authority to facilities that handle wastes from
households and conditionally exempt small quantity generators.
A number of different types of inspections are conducted under RCRA authority.
Inspections are conducted by EPA, authorized states, or both, or authorized
representatives of either EPA or authorized states. Typically, either the state or EPA
has overall responsibility, or the lead, for conducting the inspection. The inspector's
role is to gather information that will then be used by the Region and/or state to
determine compliance status. Some of the different kinds of inspections are described
below.
COMPLIANCE EVALUATION INSPECTION
The compliance evaluation inspection (CEI) is an on-site evaluation of a hazardous
waste handler's compliance with RCRA regulations and permit standards. The purpose
of the CEI is to gather information necessary to determine compliance and support
enforcement actions. The inspection may include a characterization of the handler's
activities, identification of the types of hazardous wastes managed on-site, a record
review of reports, documents, and on-site plans, and the identification of any units that
generate, treat, store, or dispose of hazardous waste. Treatment, storage, and disposal
facilities (TSDFs) must be inspected every two years, except facilities owned or operated
by a federal or state agency, which must be inspected every year (§§3007(c), (d), and
(e)).
COMPLIANCE SAMPLING INSPECTION
EPA sometimes finds it necessary to inspect a facility in order to collect samples for
laboratory analysis. These sampling inspections are very resource-intensive because
they require advanced planning for the sampling scheme and laboratory analysis. A
sampling inspection may be conducted in conjunction with a CEI or any other
inspection.
COMPREHENSIVE GROUNDWATER MONITORING EVALUATION
During the comprehensive groundwater monitoring evaluation (CME), enforcement
officials evaluate the adequacy of the design and operation of a facility's groundwater
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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4 - RCRA Enforcement and Compliance
monitoring system. This evaluation should be completed by a hydrogeologist and
includes a review of the owner and operator's characterization of the hydrogeology
underlying the hazardous waste management units; monitoring well placement, depth,
and spacing; and well design and construction. The CME is used to determine whether
a facility implementing detection monitoring should instead be using compliance or
assessment monitoring. CMEs at compliance or assessment monitoring facilities
include a detailed examination of the assessment monitoring plan and implementation
of the plan.
CASE DEVELOPMENT INSPECTION
The case development inspection (GDI) is an intensive investigation that is conducted to
gather sufficient information to support an enforcement action. The GDI can be used to
collect supplemental data to support a forthcoming enforcement action identified
through a CEI, a CME, or a record review.
OPERATION AND MAINTENANCE INSPECTION
The operation and maintenance inspection (OMI) occurs periodically, evaluating
whether a groundwater monitoring system is continuing to function as designed. The
OMI focuses on the condition of the wells and their associated sampling devices. The
findings from an OMI will indicate whether case development is warranted or will
serve to focus future CMEs.
INFORMATION GATHERING
In addition to authorizing EPA to conduct inspections, §3007 allows the Agency to
request specific information from "...any person who generates, stores, treats,
transports, disposes of, or otherwise handles or has handled hazardous wastes." This
means EPA may request information from past generators as well as those parties who
may not have been subject to the RCRA regulations, but who have actually handled
hazardous waste.
Normally the public has access to the information obtained under §3007 authority. The
facility owner and operator may, however, claim records or other information gathered
by EPA as confidential business information by submitting the information with a cover
sheet stamped "confidential," "trade secret," or "proprietary information" (§3007(b)).
EPA will then determine whether or not the material is confidential.
In addition to obtaining information for enforcement proceedings, EPA may use §3007
authority to gather data to assist in the development of regulations and to track
program progress and accomplishments.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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RCRA Enforcement and Compliance - 5
2.3 MONITORING, ANALYSIS, TESTING, AND REPORTING
When EPA receives information showing that hazardous waste is present or has been
released at a facility or site, or that the release of any such waste may present a hazard,
the Agency may issue an administrative order or obtain a judicial injunction requiring
the owner and operator to conduct monitoring, analysis, or testing to ascertain the
extent and nature of the hazard (§3013). Information means some reliable data upon
which a reasonable person would base a decision to take action, and may include
citizen complaints and inspection reports. With respect to §3013 orders, the statutory
definition of hazardous waste is used, rather than the regulatory definition (§1004(5)).
EPA has the authority to issue administrative orders to any past or present owner and
operator who would reasonably have knowledge of the presence of hazardous waste
and potential releases (§§3013(b) and (c)). The orders may compel him or her to
perform monitoring, testing, analysis, and reporting. The Agency also retains the
option of performing the work and recovering costs from the owner and operator. EPA
may sue anyone who fails to comply with a §3013 administrative order for up to $5,500
per day of noncompliance.
The mere presence of hazardous waste at a site or facility is sufficient cause to issue a
§3013 order, provided that the information indicates that the presence of the waste may
present a substantial hazard. Only the potential for harm, as opposed to actual harm, to
human health and the environment must be ascertained to determine whether a
substantial hazard exists.
2.4 ENFORCEMENT MECHANISMS
When the Agency determines that a facility is in noncompliance with the hazardous
waste regulations, an enforcement action may be taken. Under RCRA, EPA uses three
types of enforcement mechanisms: administrative, civil, and criminal actions. The
Agency has substantial latitude in deciding which action or combination of actions to
pursue, depending on the nature and severity of the problem.
ADMINISTRATIVE ACTIONS
An administrative action is a nonjudicial enforcement action taken by EPA or a state
under its own authority. These actions can be broken down into two general categories:
informal and formal. Both of these actions provide for enforcement response outside
the court system. This means the Agency takes direct enforcement action against the
violator based on its authority granted by the statute, and does not rely on a court of
law for enforcement authority.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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6 - RCRA Enforcement and Compliance
Informal Actions
Once a decision is made to utilize an informal enforcement mechanism, the facility
owner and operator should be given notice of its noncompliance and the steps to take to
correct the violations. Examples of informal actions are letters or phone calls to the
facility. For informal actions, EPA or the state notifies the facility owner and operator
that the facility is out of compliance with hazardous waste regulations. Informal
actions are most appropriate where the violation is a minor threat to human health and
the environment. A warning letter, sometimes referred to as a Notice of Violation
(NOV), may be sent, which lays out the specific actions that need to be taken by the
facility owner and operator to correct the violation(s). The letter should require
demonstration of a facility's return to compliance within an appropriate timeframe, not
to exceed 90 days, to ensure that enforcement is escalated appropriately should the
facility fail to return to full physical compliance by the established date.
Formal Actions (Administrative Orders)
In cases where a facility has been classified as a significant non-complier or the facility
owner and operator have failed to respond to an informal action, EPA can issue an
administrative order. Administrative orders impose enforceable legal duties. For
example, orders can be used to compel the facility owner and operator to comply with
specific regulations, to take corrective action, to perform testing, monitoring, or
analysis, or to pay fines.
The four authorities for issuing administrative orders under RCRA are:
• Section 3013 Orders to conduct monitoring, analysis, and testing
• Corrective Action Orders under §3008(h)
• Compliance Orders under §3008(a), including revocation of permits
• Section 7003 Orders for imminent hazards.
Each of these authorities is discussed in detail elsewhere in this module.
CIVIL ACTIONS
A civil action is a formal lawsuit filed in a federal district court by DOJ against a person
who has either failed to comply with a statutory or regulatory requirement or
administrative order, or who has contributed to a release of hazardous wastes or
hazardous constituents. The statutory authorities for judicial actions under RCRA are:
• Section 3013 - injunctions to conduct monitoring, testing, and analysis
• Section 3008 - compliance orders and criminal penalties
• Section 7003 - injunctions to address violations which pose an imminent and
substantial endangerment to health or the environment.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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RCRA Enforcement and Compliance - 7
For example, §3008(a) gives EPA the right to take administrative or judicial action for
violations of RCRA that have transpired since November 19,1980. If the facility owner
and operator violate a compliance order, §3008(c) gives EPA the authority to issue a
civil penalty of up to $27,500 per day per violation or to revoke or suspend the facility
permit. Civil penalties are described in §3008(g). Specifically, each violation of a
Subtitle C requirement is subject to a fine of up to $27,500 per day per violation. This
means that each day of noncompliance is considered a separate violation. For detailed
information on penalties, refer to the RCRA Civil Penalty Policy (OSWER Directive
9900.1A). This contains information on the classes of violations, and possible injunctive
relief and other fines and penalties that may be assessed.
CRIMINAL ACTIONS
A criminal action is an action by EPA or the state pursuant to §3008(d) that can result in
the imposition of fines and/or imprisonment. The key to criminal liability is that a
person knowingly violated RCRA requirements. Seven actions identified in §3008 carry
criminal penalties. Six of these seven actions carry a penalty of up to $50,000 per day of
violation and up to 5 years in jail. These acts are:
• Knowingly transporting waste to a nonpermitted facility
• Knowingly treating, storing, or disposing of waste without a permit or in
violation of a permit or interim status standards
• Knowingly omitting information from or making a false statement on a label,
manifest, report, permit, or compliance document
• Knowingly generating, storing, treating, or disposing of waste without
complying with recordkeeping and reporting requirements
• Knowingly transporting waste without a manifest
• Knowingly exporting waste without the consent of the receiving country.
The seventh criminal act is knowingly transporting, treating, storing, disposing, or
exporting waste in a way that places another person in imminent danger of death or
serious bodily injury. This act carries a possible penalty of up to $250,000 and 15 years
in prison for an individual, and a $1 million dollar fine for a corporation (§3008(e)).
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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8 - RCRA Enforcement and Compliance
2.5 COMPLIANCE ORDERS AND PENALTIES
EPA may issue a compliance order assessing a civil penalty for any past or current
violation, requiring compliance immediately or within a specified time period, or both
(§3008). A "person" is defined in §1004(15) as an "...individual, trust, firm, joint stock
company, corporation, partnership, association, state, municipality, commission,
political subdivision of a state, or any interstate body...."
2.6 CORRECTIVE ACTION
Just as the Agency can request or obtain information and can require a facility to
conduct testing and analysis, it can also require a facility to perform a cleanup. The
corrective action program is one of the primary mechanisms to facilitate cleanup of
contamination at TSDFs. EPA can issue an administrative order to compel the owner
and operator to undertake corrective action, or EPA can sue (i.e., bring a civil action) to
have the court order the owner and operator to clean up. The authority for requiring
corrective action at permitted facilities is found in §§3004(u) and (v); EPA uses §3008(a)
to enforce the corrective action requirements found in §§3004(u) and (v).
Interim status corrective action authority is found in §3008(h). The opening clause of
§3008(h) authorizes the Agency to make the determination that there is or has been a
release on the basis of "any information." In practice, EPA will obtain appropriate
information from a variety of sources, including lab analyses, inspection reports, and
photographs. For the purposes of §3008(h), actual sampling is not needed to verify a
release. An inspector may find other evidence that a release has occurred, such as a
broken dike at a surface impoundment or stressed vegetation. Less obvious indications
might also be adequate to make the determination. For example, EPA might have
sufficient information on the hydrogeology of the site to conclude that there may have
been a release.
2.7 IMMINENT HAZARD
Section 7003 gives EPA a broad and powerful enforcement tool to use in abating
imminent hazards caused by hazardous or solid wastes. RCRA §7003 states that upon
receipt of evidence that the past or present handling, storage, treatment, transportation,
or disposal of any solid waste or hazardous waste may present imminent and
substantial endangerment to human health or the environment, EPA may bring suit
against any person who has contributed or who is contributing to the handling of the
waste to restrain the person, order the person to take any action that may be necessary,
or both.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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RCRA Enforcement and Compliance - '
The action taken by EPA may be administrative or civil. To issue a §7003 order, EPA
must possess evidence that the waste handling may present an imminent and
substantial endangerment to human health or the environment. Evidence may be
documentary, testimonial, or physical and may be obtained from a variety of sources,
including inspections, investigations, or requests for production of documents or other
data pursuant to §§3007, 3013, or the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) §104. This evidence must be reliable
enough to enable a reasonable person to conclude that the action is appropriate. The
phrase "may present" indicates that the standard of proof does not require certainty.
That is, an order may be issued if there is sound reason to believe that an endangerment
exists; evidence of actual harm is not required.
2.8 CITIZEN SUITS
Administrative or civil actions are mechanisms that EPA can employ against violators,
but RCRA also offers a course of action for citizens. Section 7002 provides that any
person may sue any past or present generator, transporter, treater, storer, or disposer
who has contributed or who is contributing to the past or present handling of waste
which may present an imminent and substantial endangerment, or may be in violation
of a permit, standard, regulation, condition, requirement, or order. Prior to HSWA, the
only actions allowed under §7002 were suits brought by any person on his or her own
behalf against any person who was alleged to be in violation of any permit, standard,
regulation, condition, requirement, prohibition, or order. HSWA broadened this
provision significantly.
Pursuant to §7002(a)(l)(B), suits may be undertaken by any person against any person,
including the United States or any governmental instrumentality, when that person has
in the past or present handled any solid or hazardous waste in a way so as to present an
imminent or substantial endangerment to health or the environment.
Citizens may sue EPA where the Agency fails to perform any action or duty that is not
discretionary (§7002(a)(2)). Section 7002(a) also gives the courts the power to restrain
any person who is out of compliance or whose actions in handling solid or hazardous
waste present an imminent or substantial endangerment to human health or the
environment. Section §7002(e) allows the court to award, when appropriate, court costs
to the prevailing or substantially prevailing party in the citizen suit.
Some legal actions by citizens are prohibited. According to §7002(b), if the
Administrator of EPA or a state has begun an action to bring the violator into
compliance, no citizen suit will be allowed. Section 7002(d) gives EPA the right to
participate, or intervene, in any action brought under this section as long as EPA is not
a party to the original suit.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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10 - RCRA Enforcement and Compliance
3. SPECIAL ISSUES
Because the majority of enforcement issues are determined on a case-by-case basis
depending on the factual details of a given situation, enforcement is full of anomalies.
Three situations require particular attention.
ENFORCEMENT IN AUTHORIZED STATES
Determining which agency, either EPA or the state, will take the enforcement lead in an
authorized state generally depends on whether the state is fully authorized to enforce
the applicable provisions (state authorization is discussed in detail in the module
entitled State Programs). If the provision being enforced was promulgated as a pre-
HSWA provision, the authorized state has the primary responsibility for ensuring
compliance. As states become authorized for all aspects of HSWA, they will assume
enforcement authority for HSWA enforcement actions. In authorized states, EPA
maintains the authority to take independent enforcement actions. It is EPA's policy to
take enforcement actions in authorized states when (1) the state requests EPA to do so
and provides information on the case-specific circumstances; (2) the state fails to take
timely and/or appropriate action; (3) a case could establish a legal precedent or federal
involvement is needed to ensure national consistency; or (4) it is a federal lead action.
According to §3008(a)(2), in order to enforce a provision for which a particular state has
authorization, EPA shall notify the state prior to issuing an order or starting a civil
action. For provisions promulgated pursuant to HSWA, EPA has the sole authority for
enforcement until the state either becomes fully authorized for that provision (§3006(g)),
or receives interim authority for that provision.
ENFORCEMENT AT INTERIM STATUS VS. PERMITTED FACILITIES
The applicable regulations for interim status facilities are directly enforceable pursuant
to §3008(a). This means that if a facility is not in compliance with a specific regulation,
enforcement actions of any kind may be taken against that facility. For permitted
facilities, however, the site-specific conditions of the written permit are enforceable.
Even if the permit is poorly written or does not conform to the regulations, the owner
and operator need only comply with the requirements detailed in the permit. This is an
example of the "permit as a shield" provision, codified at §270.4(a). This section states
that compliance with a RCRA permit constitutes compliance for purpose of
enforcement. The exceptions to this provision are those requirements that are not
included in the permit; those provisions that become effective by statute subsequent to
the issuance of the permit; and those provisions that are promulgated under the land
disposal restrictions, land disposal unit leak detection requirements, or the air emission
standards.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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RCRA Enforcement and Compliance - 11
ENFORCEMENT AT FEDERAL FACILITIES
Many federal agencies (e.g., Department of Energy, Department of Defense) are
hazardous waste handlers subject to RCRA. Initially in the RCRA program, there was
some question whether sovereign immunity protected federal agencies from some EPA
and state enforcement actions. In the Federal Facility Compliance Act of 1992 (FFCA),
Congress amended RCRA to explicitly waive sovereign immunity for purposes of
RCRA enforcement. RCRA now specifically states that all RCRA penalties or fines
"...punitive or coercive in nature or ... imposed for isolated, intermittent, or continuing
violations" apply to the federal government. Therefore, EPA and authorized states can
issue orders and penalties against federal facilities in the same manner as against
private parties.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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12 - RCRA Enforcement and Compliance
4. COMPLIANCE INCENTIVES AND ASSISTANCE
Given the complexity of the various federal environmental regulatory programs and
the size of the regulated community, EPA's task of enforcing RCRA and other federal
environmental laws is enormous. In reality, EPA can only accomplish the ultimate goal
of ensuring protection of public health and the environment by supplementing a strong
enforcement program with programs designed to encourage and assist compliance.
The Office of Enforcement and Compliance Assurance (OECA) has produced several
policies and programs designed to encourage and assist compliance. While EPA is
aggressively pursuing compliance assistance and incentive programs, a strong, formal
enforcement program is still the best tool to ensure compliance. Therefore, EPA's
compliance incentive and assistance programs are only a complement to, and not a
replacement of, the enforcement tools described elsewhere in this module. Some of the
incentive and assistance programs are described below.
SMALL BUSINESS COMPLIANCE CENTERS
EPA has established four Small Business Compliance Centers (SBCCs) (62 FR18115;
April 14,1997). These are information centers where businesses with less than 10
employees can get regulatory compliance assistance. In cooperation with states,
universities, and trade groups, EPA has established centers for the metal finishing,
printing, auto services, and agriculture industries. EPA plans to establish centers for
transportation, local governments, chemical manufacturers, and printed wiring board
manufacturers.
COMPLIANCE INCENTIVES FOR SMALL BUSINESSES
EPA has also established a policy to encourage businesses to use the SBCCs. Under the
Interim Policy on Compliance Incentives for Small Businesses (61 FR 27894; June 3,
1996), when businesses make a good faith effort to comply with environmental
regulatory programs by utilizing SBCCs or other nonconfidential governmental or
government-supported compliance assistance programs, the businesses can qualify for
reduced civil penalties for violations.
COMPLIANCE INCENTIVES FOR SMALL COMMUNITIES
The EPA Policy on Flexible State Enforcement Responses to Small Community
Violations describes the circumstances in which the EPA will generally defer to a state's
efforts to return small communities to environmental compliance. This deference will
be based on an assessment of the adequacy of the process a state uses to address small
community noncompliance.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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RCRA Enforcement and Compliance - 13
AUDIT POLICY
On December 22,1995, EPA issued the Incentives for Self-Policing: Discovery,
Disclosure, Correction, and Prevention of Violations Policy (60 FR 66706). This EPA-
wide policy (commonly knows as the "Audit Policy") contains incentives for the
regulated community to voluntarily identify, evaluate, disclose, and correct violations.
Incentives include substantially reduced or eliminated penalties and deferral of criminal
enforcement in settlements for violations disclosed and corrected pursuant to the
policy.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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14 - RCRA Enforcement and Compliance
5. SMALL BUSINESS REGULATORY ENFORCEMENT
FAIRNESS ACT
The Small Business Regulatory Enforcement Fairness Act (SBREFA, P.L. 104-121)
addresses the enforcement of environmental regulations against small businesses and
small entities, and amends the rulemaking process to ensure that environmental
regulations do not unreasonably impact small businesses.
For purposes of SBREFA, "small entity" includes small businesses, small governmental
jurisdictions, and not-for-profit organizations that are not dominant in their field. U.S.
Small Business Administration (SBA) defines "small business" in terms of the number
of persons employed and in some case by annual revenues as well. In general,
businesses employing 500 persons of less are considered small, however, businesses
with as many as 1500 employees or up to $25 million in annual receipts may be defined
as small (see 13 CFR §121). Small governmental jurisdictions include towns, cities, and
counties of 50,000 persons or less.
SBREFA was signed into law on March 29,1996, and consists of five subtitles. These
subtitles are:
• Subtitle A - Regulatory Compliance Simplification - EPA requirements for
providing assistance to small entities
• Subtitle B - Regulatory Enforcement Reforms - process for small businesses to
comment on agency enforcement and compliance activities;
• Subtitle C - Equal Access to Justice Act - the award of attorney fees and costs to
prevailing and non-prevailing parties in administrative or civil judicial
enforcement actions
• Subtitle D - Regulatory Flexibility Act Amendments - requirement that any final
rule promulgated after June 26,1996 that will have a significant economic impact
on a substantial number of small entities be supported by a final "regulatory
flexibility analysis."
• Subtitle E - Congressional Review of Agency Rulemaking - Congress has the
opportunity to review and potentially disapprove rules promulgated on or after
March 1996.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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