United States
Environmental Protection
Agency
An Organizational Guide to
Pollution Prevention
-------
Legal and Other Requirements
Setting the legal framework for your EMS
Legal requirements include:
• Federal requirements
• State and local requirements
• Standards in locations where
you sell products/services
• Permit conditions
Other requirements might
include (for example):
• Company-specific codes
• International Chamber of
Commerce (ICC) Charter
for Sustainable
Development
• American Chemistry
Council's (ACC)
Responsible Care
• American Petroleum
Institute's Strategies for
Today's Environmental
Partnership (API STEP)
• Other industry codes or
programs to which your
organization voluntarily
subscribes.
KEY STEPS
Identify
Requirements
Analyze Impacts
Communicate
Act
In order to comply with laws and regulations that apply to
your organization, you must first know what the rules
are and how they affect what you do. As discussed
earlier, compliance with legal requirements is one of the
"three pillars" upon which your environmental policy
should be based. The potential costs of non-compliance
(possible damage to the environment, revenue loss and
impact on public image, for example) can be very high.
Thus, an effective EMS should includes processes to:
• identify and communicate applicable legal and
other requirements, and:
• ensure that these requirements are factored into the
organization's management efforts.
New or revised legal requirements might require
modification of your environmental objectives or other
EMS elements. By anticipating new requirements and
making changes to your operations, you might avoid
some future compliance obligations and their costs.
Getting Started
Your EMS should include a procedure for identifying,
having access to and analyzing applicable legal and
other requirements. "Other requirements" might include
industry codes of practice or similar requirements to
which your organization might subscribe.
Identifying applicable regulations, interpreting them, and
determining their impacts on your operations can be a
time-consuming task. Fortunately, there are many
methods for obtaining information about applicable laws
or regulations. These methods include:
commercial services (with updates offered on-line, on
CD-ROM or in paper form);
regulatory agencies (federal, state and local);
trade groups / associations;
the Internet (see USEPA web site at www.epa.gov);
public libraries;
seminars and courses;
newsletters / magazines;
consultants and attorneys; and
customers, vendors and other companies.
Small business assistance programs exist in every state.
Under the Clean Air Amendments of 1990, each state
environmental regulatory agency has established
©2001 NSF
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For more information on EMS
and compliance, see "Improving
Environmental Performance and
Compliance: Ten Elements of
Effective Environmental
Management Systems" (see
Appendix F for details)
Environmental Policy
Objectives & Targets
Training & Awareness
Communication
Operational Controls
See Appendix A for information
on resources for tracking
environmental laws and
regulations.
technical and compliance assistance programs to help
companies comply with air quality rules. In some cases,
these programs have expanded into other environmental
"media", such as water and waste management. In
addition, National Compliance Assistance Centers can
provide compliance assistance for certain industry
sectors (see Appendix F for more information).
Once applicable requirements have been identified and
analyzed for potential impacts, communicate these
requirements (and plans for complying with them) to
employees, on-site contractors and others, as needed.
Communicating "other applicable requirements" (as well
as their impacts on the organization) is an important but
often overlooked step. Keep in mind that different people
may have different information needs.
As with many EMS elements, this is not a "one time"
activity. Since legal and other requirements change
over time, your process should ensure that you are
working with up-to-date information.
Resources to identify and track environmental laws and
regulations are described in the Tool Kit (Appendix A).
Commonly Applicable Federal Environmental Laws in the US
Clean Air Act (CAA)
[40 CFR Parts 50-99]
Clean Water Act (CWA)
[40 CFR Parts 100-145, 220-232, 410-471]
Federal Insecticide, Fungicide and
Rodenticide Act (FIFRA)
[40 CFR Parts 150-1 89]
Resource Conservation and Recovery
Act (RCRA)
[40 CFR Parts 240-299]
Toxic Substances Control Act (TSCA)
[40 CFR Parts 700-799]
Comprehensive Environmental
Response, Compensation and Liability
Act (CERCLA, also known as "Superfund")
[40 CFR Parts 300-311]
Emergency Planning and Community
Right-To-Know Act (EPCRA)
[40 CFR Parts 350-374]
Hazardous Materials Transportation Act
(HMTA) [49 CFR Parts 100-1 80]
Establishes ambient and source emission standards and permit
requirements for conventional and hazardous air pollutants.
Establishes ambient and point source effluent standards and
permit requirements for water pollutants, including sources that
discharge directly to a waterbody or to a public sewer system.
Establishes a program for Federal review of, registration and
control of pesticides.
Establishes regulations and permit requirements for hazardous
waste management. Also, creates standards for underground
storage tanks that hold oil or hazardous substances.
Regulates the use, development, manufacture, distribution and
disposal of chemicals. Certain chemicals (such as PCB's) are
subject to specific management standards.
Establishes a program for cleaning up contaminated waste sites
and establishes liability for clean-up costs. Also, provides
reporting requirements for releases of hazardous substances
Establishes a program (also known as the "Toxic Release
Inventory") to inform the public about releases of hazardous and
toxic chemicals. Reporting requirements apply to companies that
use, process or store specific chemicals over specified quantities.
Establishes standards for the safe transportation of hazardous
materials.
©2001 NSF
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Capture the Learning: Legal & Other Requirements Worksheet
Do we have an existing process for
identifying applicable legal and other
requirements?
If yes, does that process need to be
revised? In what way?
Who needs to be involved in this
process within our organization? What
should their responsibilities be?
What sources of information do we
use to identify applicable legal and
other requirements?
Are these sources adequate and
effective? How often do we review
these sources for possible changes?
How do we ensure that we have
access to legal and other
requirements? (List any methods
used, such as on-site library, use of
web sites, commercial services, etc.)
How do we communicate information
on legal and other requirements to
people within the organization who
need such information?
Who is responsible for analyzing new
or modified legal requirements to
determine how we might be affected?
How will we keep information on legal
and other requirements up-to-date?
Our next step on legal and other
requirements is to ...
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Objectives and Targets
Establishing goals for environmental management
Environmental Objective:
"Overall environmental
goal, arising from the
environmental policy,
that an organization sets
itself to achieve, and
which is quantified
where practicable."
ISO 14001
Objectives and targets help an organization translate
purpose into action. These environmental goals
should be factored into your strategic plans. This can
facilitate the integration of environmental
management with your organization's other
management processes.
You determine what objectives and targets are
appropriate for your organization. These goals can
be applied organization-wide or to individual units,
departments or functions -- depending on where the
implementing actions will be needed.
In setting objectives, keep in mind your
environmental policy, including its three "pillars."
You should also consider your significant
environmental aspects, applicable legal and other
requirements, the views of interested parties, your
technological options, and financial, operational,
and other organizational considerations.
Environmental Target:
"Detailed performance
requirement, quantified
where practicable,
applicable to the
organization or parts
thereof, that arises from
the environmental
objectives and that
needs to be set and met
in order to achieve
those objectives?
Figure 6
Policy
Environmental
Aspects
Legal / Other
Requirements
Views of
Interested Parties
[ Technology 1 I Finance 1 [Operations]
There are no "standard" environmental objectives that
make sense for all organizations. Your objectives and
targets should reflect what your organization does,
how well it is performing and what it wants to achieve.
©2001 NSF
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Factors to consider
in setting objectives
and targets
0 ability to control
0 ability to track /
measure
0 cosf to track /
measure
progress reporting
links to policy
commitments
J
A sample process tool and
procedure for setting
objectives and targets are
included in the Tool Kit
(Appendix A).
• Environmental Policy
• Environmental Aspects
• Legal & Other
Requirements
• Structure &
Responsibility
• Operational Control
• Monitoring &
Measurement
• Management Review
Hints:
• Setting objectives and targets should involve people in
the relevant functional area(s). These people should be
well positioned to establish, plan for, and achieve these
goals. Involving people helps to build commitment.
• Get top management buy-in for your objectives. This
should help to ensure that adequate resources are applied
and that the objectives are integrated with other
organizational goals.
• In communicating objectives to employees, try to link
the objectives to the actual environmental
improvements being sought. This should give people
something tangible to work towards.
• Objectives should be consistent with your overall mission
and plan and the key commitments established in your
policy (pollution prevention, continual improvement, and
compliance). Targets should be sufficiently clear to
answer the question: "Did we achieve our objectives?"
• Be flexible in your objectives. Define a desired result,
then let the people responsible determine how to achieve
the result.
• Objectives can be established to maintain current levels
of performance as well as to improve performance. For
some environmental aspects you might have both
maintenance and improvement objectives.
• Communicate your progress in achieving objectives and
targets across the organization. Consider a regular report
on this progress at staff meetings.
• To obtain the views of interested parties, consider
holding an open house or establishing a focus group with
people in the community. These activities can have other
payoffs as well.
• How many objectives and targets should an organization
have? Various EMS implementation projects for small and
medium-sized organizations indicate that it is best to start
with a limited number of objectives (say, three to five) and
then expand the list over time. Keep your objectives
simple initially, gain some early successes, and then build
on them.
• Make sure your objectives and targets are realistic.
Determine how you will measure progress towards
achieving them.
• Keep in mind that your suppliers (of service or materials)
can help you in meeting your objectives and targets (e.g.,
by providing more "environmentally friendly" products).
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Comparing Objectives and Targets - Some Examples
Objectives
Reduce energy usage
Reduce usage of hazardous chemicals
Improve employee awareness of
environmental issues
Improve compliance with wastewater
discharge permit limits
Targets
• Reduce electricity use by 10% in 2001
• Reduce natural gas use by 15% in 2001
• Eliminate use of CFCs by 2002
• Reduce use of high-VOC paints by 25%
• Hold monthly awareness training courses
• Train 100% of employees by end of year
• Zero permit limit violations by the end of
2001
POLLUTION PREVENTION
Pfizer Global Research & Development (formerly Warner-Lambert Parke-Davis) has
a pollution prevention program that shows that improving the environment and the
bottom line can go hand-in-hand. For example:
By replacing chillers and redesigning chilling systems to be more efficient, the
company has realized $250,000 in energy savings. Also, because the company is
more energy efficient, it has reduced emissions from its local power supplier.
By redesigning and modifying its dust collection system, the company replaced its
100-hp motors with 40 hp motors, without compromising the effectiveness of the
dust collection system. This project lowered the company's operating costs and
reduced emissions at the local power plant.
POLLUTION PREVENTION
Some Motorola manufacturing sites have reduced their water consumption and
wastewater discharges by greater than 95% by installing ion exchange technology
and employing better operating techniques. These changes have lowered usage of
water treatment chemicals and have resulted in considerable cost savings.
EPA's Performance Track program requires organizations to consider the
following factors in setting measurable objectives and targets:
• Prevention of noncompliance,
• Prevention of pollution at the source
• Minimization of cross-media pollutant transfers, and
• Environmental performance improvement.
Participating organizations also must show continued improvement in specific
environmental categories, such as energy use, water discharges, or waste
generation, among others.
See Appendix B for more information.
©2001 NSF
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Capture the Learning: Objectives and Targets Worksheet
Do we have an existing process for
setting and reviewing environmental
objectives and targets?
If so, does that process need to be
revised? In whatway(s)?
Who needs to be involved in this
process within our organization?
Should any outside parties be
involved?
When is the best time for us to
implement this process? Can it be
linked to another existing
organizational process (like our annual
or strategic planning process?)
What are our existing environmental
goals? How were these developed?
Who was involved?
What factors were considered in
setting these goals?
Who are our interested parties?
How do we obtain their views?
How effective has our process been?
How can we effectively and efficiently
track our progress and communicate
the results?
Who is in the best position to do this?
Our next step on environmental
objectives and targets is to ...
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Environmental Management Program(s)
A road map for achieving environmental goals
Objectives and
Targets
Established
T
Environmental
Management Program
Defined
T
Monitoring and
Measurement
V
At St. Joseph's Mercy
Hospital (in Michigan),
mercury was in widespread
use. The Hospital had a
contract with a professional
environmental response
company to clean up and
dispose of any discarded
equipment and waste that
resulted from mercury spills.
Mercury was identified as
an environmental aspect
during EMS implementation,
leading to the development
of a Mercury Reduction
Initiative. This Initiative is
expected to save the
Hospital as much as
$20,000 per year.
So far, this Guide has focused on the foundations of an
EMS - the planning elements. An important part of this
planning effort is defining what your organization intends to
achieve in the environmental area. To achieve your
objectives and targets, you need an action plan - also
known as an environmental management program.
Your environmental management program should be linked
directly to your objectives and targets — that is, the
program should describe how the organization will translate
its goals and policy commitments into concrete actions
so that environmental objectives and targets are achieved.
To ensure its effectiveness, your environmental
management program should define:
• the responsibilities for achieving goals (who will do it?)
• the means for achieving goals (how will they do it?)
• the time frame for achieving those goals (when?)
Keep in mind that your program should be a dynamic one.
For example, consider modifying your program when:
• objectives and targets are modified or added;
• relevant legal requirements are introduced or changed;
• substantial progress in achieving your objectives and
targets has been made (or has not been made); or
• your products, services, processes, or facilities change
or other issues arise.
Your action plan need not be compiled into a single
document. A "road map" to several action plans is an
acceptable alternative, as long as the key responsibilities,
tactical steps, resource needs and schedules are defined
adequately in these other documents.
This program should not be developed in a vacuum — it
should be coordinated or integrated with other
organizational plans, strategies, and budgets. For
example, if you are planning for a major expansion in one of
your service operations, then it makes sense to look at the
possible environmental issues associated with this
operational expansion at the same time.
Hints:
• Build on the plans and programs you have now for
compliance, health & safety or quality management.
• Involve your employees early in establishing and
carrying out the program.
• Clearly communicate the expectations and
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"Before, we focused on
compliance issues without
the benefit of an EMS.
Now, we have a strategic
plan in place to look beyond
legal requirements and save
money. It makes my job
easier when I can prove my
department does not have
to be a cost center."
Charlie Saunders, EMS Manager,
Pfizer Global Research &
Development
Objectives & Targets
Structure &
Responsibility
Communication
Operational Control
Monitoring &
Measurement
responsibilities defined in the program to those who need
to know.
• In some cases, your environmental management
program may encompass a number of existing
operating procedures or work instructions for
particular operations or activities. In other cases, new
operating procedures or work instructions might be
required to implement the program.
• Re-evaluate your action plan when you are considering
changes to your products, processes, facilities or
materials. Make this re-evaluation part of your change
management process.
• Keep it simple (see sample tool, below) and focus on
continual improvement of the program overtime.
• There may be real opportunities here! Coordinating
your environmental program with your overall plans and
strategies may position your organization to exploit some
significant cost-saving opportunities.
Figure 7: Environmental Management Program (Sample Form)
A full-size copy of
this form and
another sample
form are provided in
the Tool Kit (see
Appendix A).
Objective / Tar
Action
Items
Priority
Responsibilities
aet #1 :
Schedule
Resources
Needed
Comments
POLLUTION PREVENTION
March Coatings operated a de-ionization unit to purify water for its coating process.
While effective, the unit required 39,000 pounds of hydrochloric acid to operate.
Concerns about potential spills and worker health & safety impacts led the company
to replace the de-ionizer with a reverse osmosis unit, which completely eliminated the
use of hydrochloric acid.
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Capture the Learning: Environmental Management Programs Worksheet
Do we have an existing process for
establishing environmental
management programs?
If yes, does that process need to be
revised? In what way?
What environmental management
programs do we have in place now?
What is the basis for our
environmental management programs
(for example, do they consider our
environmental objectives, our
environmental policy commitments and
other organizational priorities)?
Who needs to be involved in the
design and implementation of these
programs within our organization?
When is the best time for us to
establish and review such programs?
Can this effort be linked to an existing
organization process (such as our
budget, planning or auditing cycles?)
How do we ensure that changes to
products, processes, equipment and
infrastructure are considered in our
programs?
How will we otherwise keep our
programs up-to-date?
Our next step on environmental
management programs is to ...
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Structure and Responsibility
Aligning your resources to succeed
"Resources include human
resources and specialized
skills, technology, and
financial resources."
- ISO 14001
Characteristics of a
good management
representative:
• Knowledgeable
• Assertive
• Independent
For an EMS to be effective, roles and responsibilities
must be clearly defined and communicated. The
commitment of all employees is needed for an EMS to
live up to its full potential.
Top management plays a key role by providing
resources needed to implement the EMS. This is one of
the most important jobs of top management (see "Finding
Resources" on next page). In some organizations, "top
management" might be a single individual, while in others
it might be a group of people (such as a board of
directors).
An effective management system needs an advocate.
Thus, top management should appoint a management
representative. This representative (1) ensures that
the EMS is established and implemented; (2) reports on
its performance over time; and (3) works with others to
modify the EMS as needed. The management
representative can be the same person who serves as
the project champion (as discussed in Section 3), but
this is not mandatory. A business owner, plant or shop
manager, or any number of other people might serve as
an effective EMS management representative.
/ More organizational \
advantages of small business:
0 shorter lines of
communication
0 less complex organization
0 limited delegation
0 simpler access to
management
Getting Started
Look at:
0 Program Scope
0 Environmental
Aspects
0 Objectives
0 Previous audits
0 Other systems
Small and medium-sized organizations may have
advantages over larger ones in structuring their
resources for environmental management. Because
personnel and other resources are generally more
limited in smaller organizations, people often "wear more
than one hat" and have experience in performing
multiple functions. An individual responsible for
environmental management in a smaller organization
also might be responsible for quality, health & safety,
facilities, or other functions. In such cases, integrating
environmental responsibilities with other functions can
be greatly simplified.
Getting Started:
The following questions can help you determine the right
organizational structure for environmental management:
• What is the scope of our environmental
management program? What capabilities do we
need? Who will help to make the EMS effective?
What training or other resources do we need?
• What are pur significant environmental aspects
and compliance needs? What operations / activities
need to be controlled? Who needs to be involved to
ensure that controls are implemented?
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Consider integrating EMS
with your existing:
0 information systems
0 purchasing controls
0 quality procedures
0 work instructions
0 training programs
0 communication efforts
0 reporting systems
0 recruitment, appraisal
and disciplinary
processes
See Appendix C for information
on process mapping
What are the results of previous audits or other
assessments? What does this information tell us
about the effectiveness of our organizational structure
and how it might be improved?
• What are the current responsibilities for
environmental management? How can we
enhance ownership of environmental management
across the organization? How can other functions
support the EMS? (See next page.)
• What are our objectives and targets, including
those related to compliance and pollution
prevention? How will the organizational structure
help up achieve these goals?
• What quality management and / or other existing
management systems exist? What roles and
responsibilities exist in these management systems?
Do opportunities for system integration exist?
Consider flow charting your existing environmental
management activities. This can help you understand
how these processes work and the final product can be
a great communication and training tool. Flow charts
also can be useful to look at processes such as
chemical purchasing and distribution, employee
training, and preventive maintenance, among others.
Appendix C provides information on process mapping.
Hints:
Appendix A provides a sample
responsibility matrix
More information on resources
is found in Appendix F of this
Guide
Objectives & Targets
Training & Awareness
Communication
Management Review
Build flexibility into your organizational structure.
Recognize that environmental (and other)
management needs will change over time.
Communicate to people what their roles are (as well
as the roles of others). One tool for communicating
these responsibilities is a responsibility matrix.
(See the Tool Kit in Appendix A for an example of
such a matrix.)
Finding Resources
In most cases, developing and maintaining an EMS will
not require large capital outlays. What an EMS will
require is time. Many smaller organizations find they
can make effective use of interns or temporary
employees to perform potentially time-consuming EMS
development tasks (such as collecting data, drafting
procedures, etc.). This allows in-house personnel to
focus on more complex EMS development tasks. Also,
look for areas where environmental management can
support other organizational functions (and vice-versa —
see next page).
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How Various Functions Can Support Your EMS
Functions
Purchasing
Human Resources
Maintenance
Finance
Engineering
Top Management
Quality
Line Workers
How They Can Help (Possible Roles)
• Develop and implement controls for chemical / other material
purchases
• Define competency requirements and job descriptions for
various EMS roles
• Train temporary workers and contractors; maintain training
records
• Integrate environmental management into reward, discipline
and appraisal systems
• Implement preventive maintenance program for key
equipment
• Support identification of environmental aspects
• Track data on environmental-related costs (such as
resource, material and energy costs, waste disposal costs,
etc.)
• Prepare budgets for environmental management program
• Evaluate economic feasibility of environmental projects
• Consider environmental impacts of new or modified products
and processes
• Identify pollution prevention opportunities
• Communicate importance of EMS throughout organization
• Provide necessary resources
• Track and review EMS performance
• Support document control, records management and
employee training efforts
• Support integration of environmental and quality
management systems
• Provide first-hand knowledge of environmental aspects of
their operations
• Support training for new employees
For EPA's Performance Track program, organizations must provide
appropriate incentives for personnel to meet EMS requirements.
See Appendix B for more information.
See the EPA/NSF project report, Implementing an EMS in Community-Based
Organizations for more ideas on how organizations with limited resources can
implement an EMS. Download the report free of charge at www.nsf-isr.org or
www.epa.gov.
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Capture the Learning: Structure & Responsibility Worksheet
How do we define roles,
responsibilities and authorities for
environmental management now?
Is this process effective?
Who is / should be our EMS
Management Representative? Does
this individual have the necessary
authority to carry out the
responsibilities of this job?
Are our key roles and responsibilities
for environmental management
documented in some manner? If so,
how (e.g., job descriptions,
organizational charts, responsibility
matrix, etc.)?
How are EMS roles and responsibilities
communicated within our
organization?
How do we ensure that adequate
resources have been allocated for
environmental management? How is
this process integrated with our overall
budgeting process?
How are environmental expenditures
tracked?
How will we keep this information up-
to-date?
Our next step on structure and
responsibility is to ...
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Training, Awareness and Competency
Building internal capabilities
Implementing and
maintaining an EMS
involves everyone
Reasons for
Training:
motivation
awareness
commitment
skills/
capability
compliance
performance
An example of a trainin log
is provided in the Tool Kit
(see Appendix A)
Environmental Aspects
Legal/Other
Requirements
Structure &
Responsibility
Operational Control
Records
Here are two excellent reasons for training employees
about environmental management and your EMS:
• Every employee can have potential impacts on the
environment, and
• Any employee can have good ideas about how to
improve environmental management efforts.
Each person and function within your organization can
play a role in environmental management. For this
reason, your training program should cast a wide net.
Every employee and manager should be aware of the
environmental policy, the significant environmental
impacts of their work activities, key EMS roles and
responsibilities, procedures that apply to their work and
the importance of conformance with EMS requirements.
Employees also should understand the potential
consequences of not following EMS requirements
(such as spill, releases, fines or other penalties).
All personnel should receive appropriate training. Such
training should be tailored to the different needs of
various levels or functions in the organization.
However, training is just one element of establishing
competence, which is typically based on a combination
of education, training, and experience. For certain jobs
(particularly tasks that can cause significant
environmental impacts), you should establish criteria to
measure the competence of individuals performing
those tasks.
Getting Started:
• A critical first step in developing your training
program is assessing your training and skill
needs. In assessing these needs, you should
consider both general and specific needs (e.g.,
"What EMS procedures affect Joe's daily work and
what happens if they aren't followed?" "What
environmental impacts might Joe's work cause?"
"What broader understanding of environmental
issues and our EMS does Joe need?")
• Look at the training you conduct already, for
compliance with environmental and health and
safety regulations and other purposes. You may
find that your existing training efforts go a long way
towards satisfying the requirements for the EMS.
Competence might be established on the basis of
regulatory-required training, in some instances.
©2001 NSF
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Milan Screw Products found
that it could provide a great
deal of its training during
"brown bag" lunches, during
which employees bring their
lunches, participate in a
training session, and remain
"on the clock" for the lunch
period.
Key Steps in Developing a Training Program
Step 1: Assess training needs & requirements
Step 2: Define training objectives
Step 3: Select suitable methods and materials
Step 4: Prepare training plan (who, what, when,
where, how)
Step 5: Conduct training
Step 6: Track training (and maintain records)
Step 7: Evaluate training effectiveness
Step 8: Improve training program (as needed)
Training Resources:
internal trainers / experts
consultants
community colleges
vendors /suppliers
customers
technical / trade /
business associations
self-study or study
groups
training consortia
(teaming with other local
companies)
computer-based training
Hints:
• Because of the level of effort involved in training, this
is one EMS element where you don't want to start
from scratch. Many employees may be qualified on
the basis of their experience and previous training.
(Keep in mind that all training should be
documented.) Since some employees might require
training on how to operate equipment safely, on-the-
job training certainly can play an important role.
Computer-based training also may be an option,
especially for employees who spend much of their
time in the field.
• Plan and schedule training opportunities carefully.
While finding enough time for training can be a
challenge, you might find creative ways to make
"more time" (see "tip", above left). Use safety
meetings, staff meetings, and tool box meetings to
provide training and reinforce key messages.
• New employees can pose a significant training
challenge. Consider developing an EMS training
package for new employee orientation. Even
better, videotape one of your current EMS training
courses to show to new employees.
• In reviewing training needs, don't forget to consider
the qualifications and training needs of your
environmental manager and your trainers.
Professional certification programs may be
appropriate for certain functions.
• If the organization uses temporary or contract
workers, assess their training needs as well.
• Factor EMS skills requirements into your recruiting,
selection, and new employee orientation
processes.
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When Training
Might Be Needed:
New employee is hired
Employee is transferred to a
new job
Individual doesn't follow
procedure / instruction
Procedures are changed
New process, material or
equipment is introduces
Company changes objectives
and/or targets
New regulation affects
organization's activities
Job performance must be
improved
Establishing competency for various tasks can be a
challenge. Competency criteria for jobs that can
cause significant environmental impacts should be as
objective as possible.
One informal method for assessing competency is to
question employees in critical functions as to how
they perform various aspects of their jobs (e.g.,
"Show me how you..."). Use responses to determine
whether they have the requisite skills and
understanding to perform the job safely. This can
help you gauge whether additional training might be
needed.
Consider visual "job aids" to supplement training or
help establish competence. Examples of job aids
include written or pictorial job procedures, decision
tables or flow charts posted at the workstation.
Finally, some organizations have been successful in
blending environmental awareness training into
existing safety training programs. This can be
particularly effective where safety training is
mandated (i.e., by regulation or other organizational
requirements) and has strong management support.
A Few Thoughts About Adult Learning
Adults need the opportunity to integrate new ideas with what they already know.
Information that conflicts sharply with existing beliefs or has little conceptual
overlap with what is already known is acquired more slowly.
Adults prefer self-directed learning and want to have a hand in shaping the
training program.
Adults have expectations. It is important to clarify these up-front.
Adults prefer active participation to straight lecture.
- Adapted from "Adults Learning: What Do We Know For Sure"
(Training Magazine, June 1995)
For EPA's Performance Track, organizations must provide specific training for
employees whose responsibilities relate directly to achieving objectives and targets
and legal compliance.
See Appendix B for more information.
©2001 NSF
41
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Capture the Learning: Training, Awareness & Competence Worksheet
Do we have an existing process for
environmental training?
If so, does that process need to be
revised? In whatway(s)?
What types of training do we provide
now (e.g., new employee orientation,
contractor training, safety training)?
How would EMS-related training fit with
our existing training program?
Who is responsible for training
now? Who else might need to be
involved within our organization?
How do we determine training needs
now? (List methods used) Are these
processes effective?
Who is responsible for ensuring that
employees receive appropriate
training? How do we track training to
ensure we are on target?
How do we evaluate training
effectiveness? (List methods used,
such as course evaluation, post-
training testing, behavior observation)
How do we establish competency,
where needed? (List methods used,
such as professional certifications)
What are the key job functions and
activities where we need to ensure
environmental competency?
Our next step on training,
awareness & competence is to
©2001 NSF
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Communications
Maintaining the flow of information
Consider
communication
strategies for:
0 neighbors
0 community groups
0 other interest groups
0 local officials
0 regulatory agencies
emergency
responders
Pfizer Global Research &
Development (formerly
Warner-Lambert Parke-
Davis) has hosted local
community leaders, state
agencies, and federal
agencies, to share its
environmental activities and
programs and to obtain
feedback.
The importance of employee involvement in developing
and implementing your EMS has been discussed earlier.
In addition, there may be parties with an interest in your
environmental performance and management efforts
outside the organization. Effective environmental
management requires effective communications, both
internally and externally.
Effective communications will help you:
• motivate your workforce;
• gain acceptance for your plans and efforts;
• explain your environmental policy and EMS and how
they relate to the overall organizational vision;
• ensure understanding of roles and expectations;
• demonstrate management commitment;
• monitor and evaluate performance; and,
• identify potential system improvements.
Effective internal communication requires mechanisms for
information to flow top-down, bottom-up and across
functional lines. Since employees are on the "front lines,"
they can be an excellent source of information, issues,
concerns and ideas.
Proactive, two way communication with external parties is
also important for an effective environmental management
system. Taking steps to obtain the views of these
stakeholders, which can include neighbors, customers,
community groups, and regulators, will help you better
understand how your organization is perceived by others.
These stakeholders can also bring important
environmental issues to your attention that should be
addressed in your EMS. Your should also condiser ways
to get specific advice from these stakeholders when
developing critical elements of your EMS such as setting
objectives and targets. Involving these parties, however,
does not mean you should cede control of your EMS to
them, but rather use their input to make your EMS
stronger and more responsive to community concerns.
Doing so will usually provide long-term benefits to your
organization.
Thus, an effective EMS should include procedures for:
• communicating internally (between levels and
functions within the organization), and
• soliciting, receiving, documenting and responding to
external communications.
©2001 NSF
43
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Milan Screw Products' staff
interviewed neighbors,
customers, suppliers, and
employees' family members to
obtain the views of external
parties.
Getting Started:
The first step in designing a communications program is
determining your key audiences. Make a list of internal
and external audiences.
Once you have identified the audiences, determine what
you need to communicate to them. (What do they need to
know about your products, operations or management
efforts? What are their concerns?)
A sample procedure for
external communication is
provided in the Tool Kit (see
Appendix A)
Next, decide how you can best reach them. Appropriate
communication methods might vary from audience to
audience. Start by looking at your existing methods for
communicating, both internally and externally. These
might include:
Environmental Policy
Environmental
Aspects
Objectives & Targets
Structure &
Responsibility
Monitoring &
Measurement
Management Review
Internal Methods
• newsletters
• intranet
• staff meetings
• employee meetings
• bulletin boards
• brown bag lunches
• training
External Methods
• open houses
• focus or advisory groups
• web site or e-mail list
• press releases
• annual reports
• advertising
• informal discussions
Hints:
• Determine how proactive your external communications strategy
should be. Select an approach that fits your organization's
culture and strategy. Consider, for example, whether reporting
on environmental performance and progress might give you a
competitive edge.
• While a proactive external communications program may require
some resources, many organizations find that a proactive
communication strategy can be beneficial. Weigh the costs and
benefits for yourself, but keep in mind that you might have many
interested audiences.
• In communicating with employees, it is helpful to explain not only
what they need to do but also why they need to do it. For
example, when describing a requirement based on a regulation,
explain the purpose behind the rule and why it is important. Also,
make a clear connection between the requirement and how it
applies to each person's job.
• Keep the message simple, clear, concise, and accurate.
• Managing responses to external inquiries does not have to be
burdensome. Use a simple method, such as stapling an inquiry
to its written response and then filing them together. The key is
to be able to demonstrate that the organization has a process for
gathering and responding to external inquiries.
©2001 NSF
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** POLLUTION PREVENTION **
and Public Involvement
Motorola has conducted Household Waste Electronics Recycling Days for local residents.
Working in collaboration with local solid waste authorities, the Company has collected for
recycle a variety of home electronic and entertainment equipment, small appliances and other
products. At one of these events, over 21 tons of materials were collected and over 95% of
these materials were recycled.
For EPA's Performance Track, organizations must commit to public outreach and
performance reporting. Specifically, participating organizations must prepare an
annual report on their EMS, a summary of progress on performance commitments,
and of their public outreach activities.
See Appendix B for more information.
>\ /^
== The community as part of the solution....
In an effort to involve stakeholders in the EMS process the Town of Londonderry, NH and
the City of Lowell, MA engaged residents to collect information pertaining to environmental
issues that affect their communities. For example, the Town of Londonderry, NH in
conjunction with its household hazardous waste collection day, asked residents to complete
a survey to prioritize community related environmental issues. The residents identified the
fast pace at which the small community is growing as their top-priority issue. The City of
Lowell, MA's wastewater treatment plant asked local residents to assist with efforts to
address the plant's odor issues. A number of residents throughout the surrounding area
recorded weather information on days the odor was prevalent. This information identified
odor patterns which would aid the City's efforts to identify a solution to this problem.
©2001 NSF 45
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Capture the Learning: Communications Worksheet
Who are our key external
stakeholders?
How were these stakeholders
identified?
With regard to our organization, what
are the key concerns of these
stakeholders?
How do we know this?
What community outreach efforts
are we making now (or have we made
in the recent past)?
How successful have these efforts
been?
What methods do we use for external
communications? Which appear to be
the most effective?
Who has primary responsibility for
external communications?
How do we gather and analyze
information to be communicated?
Who has responsibility for this?
How do we communicate internally
(as well as with our suppliers and
contractors)? What processes do we
have to respond to internal inquiries,
concerns and suggestions?
How effective are these methods?
Our next step on communication
is to ...
©2001 NSF
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EMS Documentation
Describing the EMS and how the pieces fit together
' Rule of thumb:
Try to keep the EMS
description
document (or
manual) to no more
than one page per
EMS element
Easy to read and understand
equals
easy to implement
To ensure that your EMS is well understood and operating
as designed, you must provide adequate information to the
people doing the work. There also may be external parties
that want to understand how your EMS is designed and
implemented, such as customers, regulators, lending
institutions, registrars and the public. For these reasons,
the various processes that make up your EMS should be
documented.
The EMS Manual (or description document)
A "road map" or description that summarizes how the
pieces of the EMS fit together can be a very useful tool.
This roadmap generally takes the form of an EMS manual.
An EMS manual is a series of explanations of the
processes your organization implements to conform to the
EMS criteria (such as the elements discussed in the
Guide). While you don't need to maintain a single
"manual" that contains all of your EMS documentation, you
should maintain a summary of the EMS that:
• describes the system's core elements (and how the
elements relate to each other), and
• provides direction to related documentation.
Figure 8:
Hierarchy of EMS
Documentation
EMS Manual
Procedures
Forms, Drawings, etc.
Other EMS Documentation
In addition to the EMS manual, your organization should
maintain other documentation of its EMS.
First, you should document the processes used to meet
the EMS criteria. (For example, "How do we identify
environmental aspects?" "How do we implement
corrective actions?") This documentation generally takes
the form of system procedures. In addition, you might
maintain area-or activity-specific documentation (such as
work instructions) that instructs employees on how to carry
out certain operations or activities.
EMS documentation is related to (but not the same as)
EMS records. EMS documentation describes what
your system consists of (i.e., what you do and how you do
it), while EMS records demonstrate that you are doing
what the documentation said you would do. Document
control and records management are discussed later in
this Guide.
One way to think about your EMS documentation is to use
the figure shown at left, which also can be applied to
quality or other management system documents.
©2001 NSF
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V
Use flow charts or other
graphics where they help
explain the linkages from one
system element to another
Environmental Policy
Environmental
Management
Programs
Document Control
Operational Control
You can maintain EMS documentation either on paper or
electronically. There may be some advantages to
maintaining documents electronically, such as ease of
updating, controlling access, and ensuring that all readers
are using the most up-to-date versions of documents.
Hints:
• Keep EMS documentation simple. Choose a format
that works best for your organization. Your manual
does not need to describe every detail of your EMS.
Instead, the manual can provide references to other
documents or procedures.
• Use the results of your preliminary assessment to
prepare your EMS documentation. In the course of
conducting this assessment, you should have collected
or prepared useful material on how your organization
satisfies the selected EMS criteria. The box below
illustrates what constitutes EMS documentation.
• The usefulness of your EMS manual can be improved
by including the organization's mission statement, vision
or guiding principles (if these exist). These will improve
understanding of the organization and how the EMS
supports its overall goals.
• An EMS manual can be a useful tool for explaining your
EMS to new employees, customers and others. A
sample outline for an EMS manual is provided in the
Tool Kit (see Appendix A).
• EMS documentation should be updated as needed,
based on any system improvements you put in place.
However, if you put too much detail in an EMS manual,
you might need to update the manual frequently (see
first hint, above).
What Constitutes EMS Documentation? Consider the following:
your environmental policy
your organizational structure and key responsibilities
a description or summary of how your organization satisfies EMS requirements
(e.g., "How do we identify environmental aspects?". "How do we control
documents?" How do we comply with legal requirements?")
system-level procedures (e.g., procedure for corrective action)
activity- or process-specific procedures / work instructions
other EMS-related documents (such as emergency response plans, training
plans, etc.)
©2001 NSF
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Capture the Learning: EMS Documentation Worksheet
Do we have existing documentation
of our EMS?
If yes, how is this EMS documentation
maintained (electronically? In paper
form?)
Who is responsible for maintaining
EMS documentation within our
organization?
Do we have an EMS manual or other
summary document that describes the
key elements of the EMS?
If so, does this document describe the
linkages among system elements?
What does our EMS documentation
consist of? (List components such as
environmental policy, EMS manual,
activity-level procedures or work
instructions, emergency plans, etc.)
Is our EMS documentation integrated
with other organizational
documentation (such as human
resource plans or quality procedures)?
If so, how do we ensure proper
coordination between environmental
and these other functions?
How will we keep our EMS
documentation up-to-date?
Our next step on EMS
documentation is to ...
©2001 NSF
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Document Control
Ensuring that everyone works with the right tools
Suggested elements
of document control
0 issue / revision date
0 effective date
0 approval
(i.e., signature)
0 revision number
0 document number
(or other identifier
0 copy number
0 cross references
oe Document control
should address:
Preparation
Issuance / distribution
Revision
Periodic review
Disposition of obsolete
documents
People in your organization probably use various
documents (procedures, work instructions, forms,
drawings and the like) as they perform their duties. To
ensure that personnel are consistently performing their
jobs in the right way, the organization must provide them
with the proper tools. In the context of an EMS, the "tools"
needed are correct and up-to-date procedures,
instructions and other documents. Without a mechanism
to manage these EMS documents, the organization cannot
be sure that people are working with the right tools.
To ensure that everyone is working with the proper EMS
documents, your organization should have a procedure
that describes how such documents are controlled.
Implementation of this procedure should ensure that:
• EMS documents can be located (we know where to
find them),
• they are periodically reviewed (we check to make sure
they are still valid),
• current versions are available where needed (we make
sure the right people have access to them), and
• obsolete documents are removed (people don't use the
wrong documents by mistake).
Your procedure should designate responsibility and
authority for preparing documents, making changes to
them and keeping them up-to-date. In other words, you
need to make it clear who can actually generate and
change documents and the process for doing so.
' Key Questions:
Is everyone working with
the same set of
documents?
Do people who need
access have access?
Getting Started:
• EMS document control requirements are almost a
mirror image of the ISO 9001 requirements.
Organizations that have or are developing an ISO 9001
management system can enjoy some advantages here.
• Even if your organization doesn't have an ISO 9001
system, you might be better off than you think. Your
organization probably has document controls in place
for other purposes (such as finance, human resources
or purchasing). Assess how well these controls work
and if they can be adapted for your EMS.
©2001 NSF
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EMS Documentation
Operational Control
Records
The Tool Kit contains a sample
index of EMS-controlled
documents (see Appendix A).
Hints:
• Don't make your procedure more complicated than it
needs to be. While larger organizations often have
complex processes for document control, smaller
organizations can use simpler processes.
• Limiting distribution can make the job easier. Cpuld
everyone have access to one or a few copies?
Determine how many copies you really need and
where they should be maintained for ease of access.
• If the people that need access to documents are
connected to a local area network or have access to
the organization's internal web site, consider using a
paperless system. Such systems can facilitate control
and revision of documents considerably. There also
are a number of commercial software packages that
can simplify the document control effort.
• Prepare a document control index that shows all of
your EMS documents and the history of their revision.
Include this index in your manual. Also, if multiple
paper copies of documents are available at the facility,
prepare a distribution list, showing who has each copy
and where the copies are located.
• As your procedures or other documents are revised,
highlight the changes (by underlining, boldface, etc.).
This will make it easier for readers to find the changes.
What EMS documents should be controlled?
Consider the following:
Environmental policy
Objectives and targets
Roles, responsibilities and authorities
EMS description document ("manual")
System-level procedures
Process- or activity-level procedures / work instructions
Related plans (such as emergency response plans)
©2001 NSF
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Capture the Learning: Document Control Worksheet
Do we have an existing process for
controlling EMS documents?
If yes, does that process need to be
revised? In what way?
Who needs to be involved in this
process within our organization?
Who needs access to controlled
copies of EMS documents? How do
we ensure that they have access?
How do we ensure that EMS
documents are periodically reviewed
and updated as necessary?
Who has authority to generate new
documents or modify existing ones?
How is this process managed?
How are users alerted to the
existence of new EMS documents or
revisions to existing ones?
How do we ensure that obsolete
documents are not used?
Is our EMS document control process
integrated with other organizational
functions (such as quality)?
If so, how do we ensure proper
coordination between environmental
and other functions?
Our next step on document
control is to ...
©2001 NSF
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Operational Control
Building environmental performance into operations and activities
Figure 9
f N
Environmental
Policy
V J.
/•• N
Significant
Environmental
Aspects
V. , ,/f
^^
^\
f Operational \
V Controls j
^^^^ ^*<^.- '
\
Objectives &
Targets
Legal & Other
Requirements
To ensure that you satisfy the commitments in your
environmental policy, certain operations and activities
must be controlled. Where operations or activities are
complex and/or the potential environmental impacts are
significant, controls should include documented
procedures. Procedures can help your organization to
manage its significant environmental aspects, ensure
regulatory compliance and achieve environmental
objectives. Procedures can also play a prominent role in
employee training.
Documented procedures should be established where the
absence of procedures could lead to deviations from the
environmental policy (including the commitments to
compliance and pollution prevention) or from your
objectives and targets. Determining which operations
should be covered by documented procedures and how
those operations should be controlled is a critical step in
designing an effective EMS. Keep in mind that you might
need operational controls in order to manage significant
aspects or legal requirements, regardless of whether you
established objectives and targets for each of them.
In determining which operations and activities need to be
controlled, look beyond routine production or service.
Activities such as equipment maintenance, management
of on-site contractors, and services provided by
suppliers or vendors could affect your organization's
environmental performance significantly.
Examples of activities and
operations that might require
operational controls:
0 management / disposal of
wastes
0 approval of new chemicals
0 storage & handling of raw
materials and chemicals
0 equipment servicing
0 wastewater treatment
0 operation of paint line
0 operation of plating system
0 management of contractors
Getting Started:
• Start by looking at the environmental aspects and
legal requirements that you identified earlier. Identify
the operations and other activities that are related to
these significant impacts and legal requirements, then
consider what types of controls might be needed to
manage these aspects and compliance requirements. If
you have flow charts of these processes (or can
develop them), this may simplify the identification of the
process steps where some type of control might be
appropriate.
• Prepare draft procedures and review them with the
people who will need to implement them. This will help
to ensure that the procedures are appropriate, realistic
and practical. Don't be surprised if reviewers come up
with a simpler way to achieve the same results!
©2001 NSF
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Hints:
• Review procedures you already have in place to comply
with environmental and health & safety regulations.
Some of these may be adequate to control significant
impacts (or could be modified to do so). Develop a chart
to keep track of what controls are needed, such as:
Operation or
Activity
1
2
3
4
Procedure is
needed (none
exists)
X
Procedure
exists, but is not
documented
X
X
Procedure
exists and is
documented
X
No procedure
is needed
Rules of Thumb: In general, the more highly skilled and trained
your employees are, the less critical documented work instructions
become. As work becomes more complex or as the potential
impact on the environment increases, the more important these
documented work instruction will be.
Once you have identified operations that require control, consider
what kinds of maintenance and calibration may be appropriate.
Maintenance of equipment that could have significant
environmental impacts or result in non-compliance should be
considered, and the need for a plan to manage such maintenance
should not be overlooked. An elaborate preventive or predictive
maintenance program is not needed in all cases. Assess your
existing maintenance program and its effectiveness before making
significant changes.
' Factors that could affect
the need for documented
procedures
0 risk of activity
0 complexity of activity /
methods
0 degree of supervision
0 skills /training of
workforce
Hints on Writing Procedures
Understand the existing process. Start with a flow
chart, if one is available. Build on informal procedures
where possible.
Focus on steps needed for consistent implementation.
Use a consistent format and approach.
Review draft procedures with employees that will have
to implement them. (Better yet, enlist employees to
help write them.)
Keep procedures simple and concise. Excessive detail
does not provide better control and can confuse the
user.
©2001 NSF
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Some of your identified environmental aspects may relate
to the chemicals, raw materials, or other goods and
services you obtain from vendors/suppliers. Likewise,
the activities of your contractors can affect your
environmental performance. Communicate your
expectations (including any relevant procedures) to these
business partners.
Policy
Environmental
Aspects
Legal/Other
Requirements
Objectives &
Targets
Training
Monitoring &
Measurement
While the development of procedures can be time-
consuming, organizations have come up with creative
ways to reduce the burden. For example, consider using a
college intern or temporary employee to interview
employees "on the line", collecting information on what
employees do and how they do it.
If your organization uses a "work team" concept, ask the
work teams to draft procedures for their work areas (or to
modify existing procedures for EMS purposes).
POLLUTION PREVENTION
Rochester Midland Corporation, a manufacturer of cleaning and
other chemical products, formed a partnership with a cleaning
contractor that uses Rochester Midland's products, the owners of a
building where the products are used, and building tenants, to lessen
the risks associated with cleaning products. The partners began by
developing common goals, identifying alternative cleaning products and
processes, and identifying opportunities to reduce risks to building
occupants and cleaning staff. Over a two-month period, they were able
to: reduce chemical exposures; improve tenant satisfaction; improve
communication, awareness, and training; achieve a 50% reduction in
cleaning products; and achieve measurable cost savings.
For EPA's Performance Track program, organizations must have operation and
maintenance programs for equipment and operations that relate to legal compliance
and significant environmental aspects.
See Appendix B for more information.
©2001 NSF
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Capture the Learning: Operational Controls Worksheet
Have we identified operations and
activities associated with significant
environmental aspects, legal
requirements and environmental
objectives?
If not how will this be accomplished?
Who should be involved?
What operations and activities are
associated with significant
environmental aspects?
What operations and activities are
associated with legal requirements?
What operations and activities are
associated with environmental
objectives and targets?
How are the above operations and
activities controlled? (list methods)
How do we know whether these
controls are adequate (i.e., to
manage significant aspects, to ensure
compliance, to achieve objectives?
How do we train employees and
contractors on relevant operating
controls?
If new controls are needed (or
existing ones need to be revised),
what is our process for doing so?
Who needs to be involved in this
process?
Our next step on operational
control is to ...
©2001 NSF
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Emergency Preparedness and Response
Minimizing the impacts of uncontrolled events
Don't think only about
response - focus on how
to prevent accidents in the
first place
Review prior accidents
and incidents as one
guide to where future
incidents may occur.
Despite an organization's best efforts, the possibility of
accidents and other emergency situations still exists.
Effective preparation and response can reduce
injuries, prevent or minimize environmental impacts,
protect employees and neighbors, reduce asset losses
and minimize downtime.
An effective emergency preparedness and response
program should include provisions for:
• assessing the potential for accidents and
emergencies;
• preventing incidents and their associated
environmental impacts;
• plans / procedures for responding to incidents;
• periodic testing of emergency plans / procedures;
and,
• mitigating impacts associated with these incidents.
Consistent with the focus on continual improvement, it
is important to review your emergency response
performance after an incident has occurred. Use this
review to determine if more training is needed or if
emergency plans / procedures should be revised.
USEFUL INFORMATION
SOURCES:
• Material safety data sheets
• Plant layout
• Process flow diagrams
• Engineering drawings
• Design codes and
standards
• Specifications on safety
systems (alarms,
sprinklers, etc.)
V
Getting Started:
• This is another area where you should not have to start
from scratch. Several environmental and health and
safety regulatory programs require emergency plans
and/or procedures. Look at what you have now and
assess how well it satisfies the items discussed above.
• Two planning components that many organizations
overlook are how they identify the potential for
accidents and emergencies and how they mitigate
the impacts of such incidents. A cross-functional
team (with representatives from engineering,
maintenance and environmental health & safety, for
example) can identify most potential emergencies by
asking a series of "what if" questions related to
hazardous materials, activities, and processes
employed at the site. In addition to normal operations,
the team should consider start-up and shutdown of
process equipment, and other abnormal operating
conditions.
©2001 NSF
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Environmental Aspects
Legal/Other
Requirements
Training & Awareness
Communication
Document Control
Ask yourself: Does everyone (including new
employees) know what to do in an emergency? How
would contractors or site visitors know what to do in an
emergency situation?
Communicate with local officials (fire department,
hospital, etc.) about potential emergencies at your site
and how they can support your response efforts.
Hints:
Mock drills can be an excellent way to reinforce
training and get feedback on the effectiveness of your
plans / procedures.
Post copies of the plan (or at least critical contact
names and phone numbers) around the site and
especially in areas where high hazards exist. Include
phone numbers for your on-site emergency
coordinator, local fire department, local police, hospital,
rescue squad, and others as appropriate.
Revise and improve your plan as you learn from
mock drills, training or actual emergencies.
Checklist for Emergency Preparedness and Response Plans
Does your plan describe the following:
0 potential emergency situations (such as fires, explosions, spills or releases of hazardous
materials, and natural disasters)?
0 hazardous materials used on-site (and their locations)?
0 key organizational responsibilities (including emergency coordinator)?
0 arrangements with local emergency support providers?
0 emergency response procedures, including emergency communication procedures?
0 locations and types of emergency response equipment?
0 maintenance of emergency response equipment?
0 training / testing of personnel, including the on-site emergency response team (if
applicable)?
0 testing of alarm / public address systems?
0 evacuation routes and exits (map), and assembly points?
©2001 NSF
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Capture the Learning: Emergency Preparedness & Response Worksheet
Have we reviewed our operations
and activities for potential emergency
situations?
If not how will this be accomplished?
Who should be involved?
Do our existing emergency plans
describe how we will prevent incidents
and associated environmental
impacts?
If not how will this be accomplished?
Who should be involved?
Have we trained personnel on their
roles and responsibilities during
emergencies?
What emergency equipment do we
maintain? How do we know that this
equipment is adequate for our needs?
How do contractors and other
visitors know what to do in an
emergency situation?
When was our last emergency drill? Is
there a plan / schedule for conducting
future drills?
Have we established a feedback loop
so we can learn from our experiences?
Our next step on emergency
preparedness & response is to ...
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Monitoring and Measurement
Assessing how well the system is performing
"If you can't
measure it, you
can't manage it."
Peter Drucker
Management Expert
Which operations and
activities can have
significant environmental
impacts?
What are the key
characteristics of these
operations and activities?
How do we measure
these characteristics?
Attributes of effective
measurement programs
3 simple
3 flexible
3 consistent
3 ongoing
3 produce reliable data
3 communicate results
An EMS without effective monitoring and measurement
processes is like driving at night without the headlights on
—you know that you are moving but you can't tell where
you are going! Monitoring and measurement enables an
organization to:
• evaluate environmental performance;
• analyze root causes of problems;
• assess compliance with legal requirements;
• identify areas requiring corrective action, and,
• improve performance and increase efficiency.
In short, monitoring helps you manage your
organization better. Pollution prevention and other
strategic opportunities are identified more readily when
current and reliable data is available.
Your organization should develop procedures to:
• monitor key characteristics of operations and
activities that can have significant environmental
impacts and/or compliance consequences;
• track performance (including your progress in
achieving objectives and targets);
• calibrate and maintain monitoring equipment; and,
• through internal audits, periodically evaluate your
compliance with applicable laws and regulations.
Getting Started:
• Monitoring and measuring can be a resource-intensive
effort. One of the most important steps you can take is
to clearly define your needs. While collecting
meaningful information is clearly important, resist the
urge to collect data "for data's sake."
• Review the kinds of monitoring you do now for
regulatory compliance and other purposes (such as
quality or health and safety management). How well
does this serve your EMS purposes? What additional
monitoring or measuring might be needed?
• You can start with a relatively simple monitoring and
measurement process, then build on it as you gain
experience with your EMS.
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EPA policies provide
incentives for effective
compliance management
programs. See "Incentives for
Self-Policing: Discovery,
Disclosure, Correction and
Prevention of Violations"
(http://es. epa. gov/oeca/finalpo
lstate.pdf) and "Small
Business Compliance Policy"
(http://es. epa. gov/oeca/sbcp
2000.pdf)
Employees should have a
mechanism to report
regulatory violations (or other
EMS issues) without fear of
retaliation by their employer
Focus on things that you
can do something about
Hints:
• Monitoring key process characteristics: Many
management theorists endorse the concept of the "vital
few" — that is, that a limited number of factors can have
a substantial impact on the outcome of a process. The
key is to figure out what those factors are and how to
measure them. Process mapping can help you
determine what those factors might be.
• Most effective environmental measurement systems
use a combination of process and outcome measures.
Outcome measures look at results of a process or
activity, such as the amount of waste generated or the
number of spills that took place. Process measures
look at "upstream" factors, such as the amount of paint
used per unit of product or the number of employees
trained on a topic. Select a combination of process and
outcome measures that are right for your organization.
• Equipment calibration: Identify process equipment
and activities that truly affect your environmental
performance. As a starting point, look at those key
process characteristics you identified earlier. Some
organizations place critical monitoring equipment under
a special calibration and preventive maintenance
program. This can help to ensure accurate monitoring
and make employees aware of which instruments are
most critical for environmental monitoring purposes.
Some organizations find it is more cost-effective to
subcontract calibration and maintenance of monitoring
equipment than to perform these functions internally.
• Regulatory compliance: Determining your compliance
status on a regular basis is very important. You should
have a procedure to systematically identify, correct,
and prevent violations. Effectiveness of the
compliance assessment process should be considered
during EMS management review. EPA encourages
"systematic discovery" of regulatory violations, which
means detecting potential violations through
environmental audits or compliance management
systems that show due diligence in preventing,
detecting and correcting violations.
. Operational performance: Consider what information
you will need to determine if the company is
implementing operational controls as intended. The
example on Page 62 illustrates the relationship among
monitoring and measurement, operational controls and
significant environmental aspects.
. Progress on meeting objectives: You should measure
progress on achieving objectives and targets on a
regular basis and communicate the results of such
measurement to top management. To measure
progress in meeting objectives, select appropriate
performance indicators (see below).
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Environmental Aspects
Legal/Other
Requirements
Objectives & Targets
Operational Control
Corrective Action
Management Review
The value of periodic monitoring:
St. Joseph's Mercy Hospital
noticed an increase in its
discharge of silver to the local
wastewater treatment plant. They
investigated what had changed at
the Hospital and found that a new
x-ray processor had been installed
without a silver recovery system.
Once the recovery system was
installed, silver discharge levels
returned to permitted levels.
Selecting performance indicators: Performance
indicators can help you to understand how well your
EMS is working. Start by identifying a few performance
indicators that are:
- simple and understandable;
- objective;
- measurable; and
- relevant to what your organization is trying to
achieve (i.e., its objectives and targets)
Data collected on performance indicators can be quite
helpful during management reviews. So, select
indicators that will provide top management with the
information it needs to make decisions about the EMS.
Make sure you can commit the necessary resources
to track performance information over time. It is OK to
start small and build overtime as you gain experience
in evaluating your performance. Keep in mind that no
single measurement will tell your organization how it
is doing in the environmental area.
Communicating performance: People respond best
to information that is meaningful to "their world."
Putting environmental information in a form that is
relevant to their function increases the likelihood
they will act on the information. Be sure to link your
measurement program with your communications
program and other elements of the EMS (such as
management reviews, as discussed later).
Compliance auditing guidance: The USEPA has
prepared guidance documents and protocols for
conducting environmental compliance audits under a
number of its regulatory programs. For more
information, check the EPA web site at
www.epa.gov/oeca/index.html.
POLLUTION PREVENTION
A Pitney Bowes Inc. facility formed a Zero Discharge Task Team to design
projects to reduce emissions over a five-year period. Wastes were ranked
ordered in terms of their potential risks to the environment and employee
safety. Those with high rankings were evaluated on a priority basis.
Through the implementation of many projects, the facility has reduced
hazardous waste generation by 69%, EPCRA 313 air emissions by 98%
and treated wastewater by 93%. Projects included finding substitutes for
parts cleaning and degreasing, replacement of all cyanide processes, and
installation of fume scrubbers on plating lines, among others.
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Figure 10:
Linking Monitoring Processes to Operational Controls: One Example
Operation with
Significant
Environmental
Aspect
Surface
Coating
Operation
(significant
aspect is VOC
emissions)
Liquid
Waste
Storage
(significant
aspect is
potential for
spills)
Operational
Controls
• Approved list ^.
of coatings
• Coating work — ^
instruction
— ^
• Permit report — ^
procedure
• Generator — ^
• procedure
— ^
• Storage — ^
area procedure
-------
Capture the Learning: Monitoring and Measurement Worksheet
Have we identified operations and
activities associated with significant
environmental aspects, legal
requirements and environmental
objectives? If, not how will this be
accomplished?
What type(s) of monitoring and
measurement do we need to ensure
that operational controls are being
implemented correctly?
What type(s) of monitoring and
measurement do we need to ensure
that we are complying with applicable
legal requirements?
What type(s) of monitoring and
measurement do we need to ensure
that we are achieving our
environmental objectives & targets?
How do we identify the equipment
used for any of the monitoring or
measurement listed above? If not how
will this be accomplished?
How will we ensure that monitoring and
measurement equipment is properly
calibrated and maintained?
What process do we have to
periodically evaluate compliance with
legal requirements? How effective is
this process?
Our next step on monitoring and
measurement is to ...
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Nonconformance and Corrective / Preventive Action
Fixing EMS problems - and avoiding them in the future
Key Steps
identify the problem
investigate to identify
the root cause
come up with solution
implement solution
document solution
communicate solution
evaluate effectiveness
of solution
Nonconformance"
means...
• system does not meel
the EMS criteria
~ or -
• implementation is not
consistent with the
EMS description
No EMS is perfect. You will probably identify problems
with your system (especially in the early phases) through
audits, measurement, or other activities. In addition, your
EMS will need to change as your organization changes
and grows. To deal with system deficiencies, your
organization needs a process to ensure that:
• problems (including nonconformities) are identified
and investigated;
• root causes are identified;
• corrective and preventive actions are identified and
implemented; and,
• actions are tracked and their effectiveness is
verified.
EMS nonconformities and other system deficiencies
(such as legal noncompliance) should be analyzed to
detect patterns or trends. Identifying trends allows you
to anticipate and prevent future problems.
Focus on correcting and preventing problems.
Preventing problems is generally cheaper than fixing
them after they occur (or after they reoccur). Start
thinking about problems as opportunities to improve!
Management
Review
Figure 11:
= System Improvement
Hints:
• If your organization has an ISO 9001 management
system, you should already have a corrective and
preventive action process for quality purposes. Use
this as a model (or integrate with it) for EMS purposes.
• Some organizations find that they can combine some
elements of their management review and corrective
action processes. These organizations use a portion of
their management review meetings to review
noncomformities, discuss causes and trends, identify
corrective actions and assign responsibilities.
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Why do EMS problems
occur?
Typical causes include:
0 poor communication
0 faulty or missing procedures
0 equipment malfunction
(or lack of maintenance)
0 lack or training
0 lack of understanding
(of requirements)
0 failure to enforce rules
0 corrective actions fail to
address root causes of
problems
Legal & Other
Requirements
Operational
Control
Monitoring &
Measurement
EMS Audits
Management Review
The amount of planning and documentation needed for
corrective & preventive actions will vary with the
severity of the problem and its potential environmental
impacts. Don't go overboard with bureaucracy —
simple methods often work quite effectively.
Once you document a problem, the organization must
be committed to resolving it in a timely manner. Be
sure that your corrective & preventive action process
specifies responsibilities and schedules for
completion. Review your progress regularly and follow
up to ensure that actions taken are effective.
Make sure your actions are based on good information
and analysis of causes. While many corrective actions
may be "common sense," you need to look beneath
the surface to determine why problems occur. Many
organizations use the term "root cause" in their
corrective and preventive action processes. While this
term can be used to describe a very formal analysis
process, it can also mean something simpler - looking
past the obvious or immediate reason for a
nonconformance to determine why the nonconformance
occurred.
Rule of thumb: Corrective actions should (1) resolve
the immediate problem (2) consider whether the same
or similar problems exist elsewhere in the organization,
and (3) prevent the problem from recurring. The
corrective action process also should define the
responsibilities and schedules associated with these
three steps.
Initially, most EMS problems may be identified by your
internal auditors. However, over the long run, many
problems and good ideas may be identified by the
people doing the work. This should be encouraged.
Find ways to get employees involved in the system
improvement process (for example, via suggestion
boxes, contests or incentive programs).
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People doing the
work are often in
the best position
to see problems
and suggest
solutions
The Tool Kit
contains a sample
corrective action
procedure and
tracking log
(see Appendix A)
Sources
of change
Investigate and
recommend
solutions
Institutionalize
Change
Corrective
Action
Process
Figure 12
POLLUTION PREVENTION
By switching from a solvent-based paint that contained lead to a no
lead, low-solvent, water-based paint, March Coatings dramatically
decreased its volatile organic compound (VOC) air emissions from over
19 tons in 1995 to less than 6 tons in 1999 while simultaneously
increasing production. The company went from being a large quantity
generator of hazardous waste to small quantity generator status under
RCRA. March Coatings accomplished this by working closely with its
paint supplier to find a formula that met their needs.
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Capture the Learning: Corrective & Preventive Action Worksheet
Do we have an existing process for
corrective and preventive action?
If yes, does that process need to be
revised? In what way?
Who needs to be involved in this
process within our organization?
How are nonconformities and other
potential system deficiencies
identified? (List methods such as
audits, employee suggestions, ongoing
monitoring, etc.)
How do we determine the causes of
nonconformities and other system
deficiencies? How is this information
used?
How do we track the status of our
corrective and preventive actions?
How is / can information on
nonconformities and corrective actions
be used within the EMS (for example,
in management review meetings, in
employee training sessions, in review
of procedures, etc.)
How do we ensure the effectiveness
of our corrective and preventive
actions?
Our next step on corrective and
preventive action is to ...
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Records
Evidence that the EMS is working as intended
What are "records"?
Records provide evidence
that the processes that
make up your EMS are
being implemented as
described.
The value of records management is fairly simple — you
should be able to demonstrate that your organization is
actually implementing the EMS as designed. While
records have value internally, over time you may need to
provide evidence of EMS implementation to external
parties (such as customers, a registrar, or the public).
Records management is sometimes seen as
bureaucratic, but it is difficult to imagine a system
operating consistently without accurate records.
The basics of records management are straightforward:
you need to decide what records you will keep, how you
will keep them and for how long. You should also think
about how you will dispose of records once you no
longer need them.
If your organization has an ISO 9001 (or other)
management system, you should have a process in place
for managing records. This process could be adapted for
EMS purposes.
Records should be
important to the operation
of the EMS, including your
regulatory compliance
efforts.
Hints:
• Start by identifying what EMS records are required. Look
at your other procedures and work instructions to determine
what evidence is needed to demonstrate implementation.
Also consider records that are required by various legal
requirements.
• Focus on records that add value — avoid bureaucracy. If
records have no value or are not specifically required, don't
collect them. The records you choose to keep should be
accurate and complete.
• You may need to generate certain forms in order to
implement your EMS. When these forms are filled out, they
become records. Forms should be simple and
understandable for the users.
• Establish a records retention policy and stick to it. Make sure
that your policy takes into account records retention
requirements specified in applicable environmental
regulations.
• In designing your records management process, be sure to
consider:
- who needs access?
- to what records?
- in what circumstances?
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Key Questions
what records are kept?
who keeps them?
where are they kept?
how are they kept?
how long are they kept?
how are they accessed?
how are they disposed? /
.„ r-—!?>•*'
Virtually every element
of an EMS can result in
the generation of
records
The Tool Kit contains a tool
for organizing your filing
system (see Appendix A).
You can copy the pages, cut
out the tabs, and use them to
set up your filing system.
If your organization uses computers extensively,
consider using an electronic EMS records management
system. Maintaining records electronically can provide
an excellent means for rapid retrieval of records as well
as controlling access to sensitive records.
Think about which records might require additional
security. Do you need to restrict access to certain
records? Should a back-up copy of critical records be
maintained at another location?
Types of Records You Might Maintain (Examples):
• legal, regulatory and other code requirements
• results of environmental aspects identification
• reports of progress towards meeting objectives and
targets
• permits, licenses and other approvals
• job descriptions and performance evaluations
• training records
• EMS audit and regulatory compliance audit reports
• reports of identified nonconformities, corrective
action plans and corrective action tracking data
• hazardous material spill / other incident reports
• communications with customers, suppliers,
contractors and other external parties
• results of management reviews
• sampling and monitoring data
• maintenance records
• equipment calibration records
Capture the Learning: Records Management Worksheet
Have we identified what records
need to be maintained? Where is this
defined?
Have we determined records retention
times? Where is this defined?
Have we established an effective
storage and retrieval system?
Our next step on records is to
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EMS Auditing
Objective evidence of conformance with EMS requirements
Once your organization has established its EMS, verifying
the implementation of the system will be critical. To
identify and resolve EMS deficiencies you must actively
seek them out.
In a smaller organization, periodic audits can be
particularly valuable. Managers are often so close to the
work performed that they may not see problems or bad
habits that have developed. Periodic EMS audits will
help determine whether all of the requirements of the
EMS are being carried out in the specified manner.
Audits are vital to
continual
improvement
( EMS Audit
"A systematic and
documented verification
process of objectively
obtaining and evaluating
evidence to determine
whether an organization's
environmental
management system
conforms to the
environmental
management system
audit criteria set by the
organization, and for
communication of the
results of this process to
management.
- ISO 14001
For your EMS audit program to be effective, you should:
• develop audit procedures and protocols;
• determine an appropriate audit frequency;
• select and train your auditors; and,
• maintain audit records.
Results of your EMS audits should be linked to the
corrective and preventive action process, as described
earlier.
While they can be time-consuming, EMS audits are
critical to EMS effectiveness. Systematic identification
and reporting of EMS deficiencies to management
provides a great opportunity to:
• maintain management focus on the environment,
• improve the EMS and its performance, and
• ensure the system's cost-effectiveness.
Getting Started:
• How frequently do we need to audit?
To determine an appropriate frequency of your EMS
audits, consider the following factors:
- the nature of your operations and activities,
- your significant environmental aspects / impacts
(which you identified earlier),
- the results of your monitoring processes, and
- the results of previous audits.
As a rule of thumb, all parts of the EMS should be audited
at least annually. You can audit the entire EMS at one
time or break it down into discrete elements for more
frequent audits. (There may be advantages to
conducting frequent audits, but the decision is up to you).
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Audit procedures should
describe:
3 audit planning
3 audit scope (areas and
activities covered)
3 audit frequency
3 audit methods
3 key responsibilities
3 reporting mechanisms
3 recordkeeping
Traits of a good
auditor:
1 Independent
(of the activity
being audited
] Objective
1 Impartial
1 Tactful
] Attentive to detail
Who will perform the audits? You should select and
train EMS auditors. Auditor training should be both
initial and ongoing. Commercial EMS auditor training
is available, but it might be more cost-effective to link up
with businesses or other organizations in your area
(perhaps through a trade association) to sponsor an
auditor training course. Some local community colleges
also offer EMS auditor training courses.
Auditors should be trained in auditing techniques and
management system concepts. Familiarity with
environmental regulations, facility operations, and
environmental science can be a big plus, and in some
cases may be essential to adequately assess the EMS.
Some auditor training can be obtained on-the-job.
Your organization's first few EMS audits can be
considered part of auditor training, but make sure that
an experienced auditor leads or takes part in those
"training" audits.
Auditors should be independent of the activities
being audited. This can be a challenge for small
organizations. See the box on next page for ideas.
If your company is registered under ISO 9001, consider
using your internal quality auditors as EMS auditors.
While some additional training might be needed for
EMS auditing, many of the required skills are the same.
How should management use audit results?
Management can use EMS audit results to identify
trends or patterns in EMS deficiencies. The
organization also should ensure that identified system
gaps or deficiencies are corrected in a timely fashion
and that corrective actions are documented.
Hints:
Sources of Evidence
0 interviews
0 document review
0 observation of
work practices
Your EMS audits should focus on objective evidence
of conformance. During an audit, auditors should
resist the temptation to evaluate, for example, why a
procedure was not followed — that step comes later.
During an audit, auditors should review identified
deficiencies with people who work in the relevant
area(s). This will help the auditors verify that their
audit findings are correct. This also can reinforce
employee awareness of EMS requirements.
If possible, train at least two people as internal
auditors. This will allow your auditors to work as a
team. It also allows audits to take place when one
auditor has a schedule conflict, which is often
unavoidable in a smaller organization!
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V
Results of regulatory
compliance audits are often
good indicators of EMS
deficiencies. Use
compliance audit findings to
guide your EMS efforts
The Tool Kit includes a sample
EMS audit procedure, sample
EMS audit questions, and a
number of sample audit forms
(see Appendix A)
Structure & Responsibility
Training & Awareness
Corrective Action
Management Review
Options for Auditor Independence
Barter for audit services with other small organizations
in your area
Use external auditors
Have office personnel audit production areas
(and vice versa)
Before you start an audit, be sure to communicate
the audit scope, criteria, schedule, and other pertinent
information to the people in the affected area(s). This
helps to avoid confusion and facilitate the audit
process.
Consider integrating your EMS and regulatory
compliance audit processes, but keep in mind that
these audit processes have different purposes. While
you might want to communicate the results of EMS
audits widely within your organization, the results of
compliance audits might need to be communicated in a
more limited fashion.
Final thought: An EMS audit is a check on how well
your system meets your own established EMS
requirements. An EMS audit is not an assessment of
how well employees do their jobs. Auditors should
avoid the "gotcha" mentality. Audits should be judged
on the quality of findings, rather than on the number of
findings.
Figure 13:
Linkages among EMS audits, corrective action and
management reviews
Even if you have an
effective internal audit
program, consider periodic
external audits to ensure
objectivity
Periodic
EMS Audits
EMS
Established
Corrective Action
Process
Management
Reviews
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Capture the Learning: EMS Auditing Worksheet
Have we developed an EMS audit
program? If not, how will this be
accomplished?
Who need to be involved in the audit
process?
Is there another audit program with
which our EMS audits could be linked
(for example, our quality or health &
safety management system audits)?
Have we determined an appropriate
audit frequency? What is the basis
for the existing frequency? Should the
frequency of audits be modified?
Have we selected EMS auditors?
What are the qualifications of our
auditors?
What training has been conducted or
is planned for our EMS auditors?
Have we conducted EMS audits as
described in the audit program?
Where are the results of such audits
described?
How are the results of EMS audits
communicated to top management?
How are the records of these audits
maintained?
Our next step on EMS auditing
is to ...
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/ An effective EMS \
is one that:
ZI meets the
organization's
needs
produces results
conforms to EMS
criteria
has staying power
Management Review
Closing the continual improvement loop
Just as a person should have periodic physical exams,
your EMS must be reviewed periodically by top
management to stay "healthy". Management reviews are
one key to continual improvement and for ensuring that
the EMS will continue to meet your organization's needs
over time.
Management reviews also offer a great opportunity to
keep your EMS efficient and cost-effective. For
example, some organizations have found that certain
procedures and processes initially put in place were not
needed to achieve their environmental objectives or to
control key processes. If EMS procedures and other
activities don't add value, eliminate them.
The key question that a management review seeks to
answer:
"Is the system working?" (i.e., is it suitable,
adequate and effective, given our needs?)
"Many of the benefits
of an EMS cannot be
anticipated
beforehand. You will
have to discover them
as pleasant surprises
at some point after
implementation. They
will be there.
Milan
^roducts
The Tool Kit contains a
sample Management Review
procedure.
(See Appendix A)
Hints:
• Two kinds of people should be involved in the
management review process:
- people who have the right information / knowledge,
- people who can make decisions about the
organization and its resources (top management).
• Determine management review frequency that will
work best for your organization. Some organizations
combine these reviews with other meetings (such as
director meetings). Other organizations hold "stand-
alone" reviews. At a minimum, consider conducting
management reviews at least once per year.
• During management review meetings, make sure that
someone records what issues were discussed, what
decisions were arrived at, and what action items were
selected. Results of management reviews should be
documented.
• Management reviews should assess how changing
circumstances might influence the suitability,
effectiveness or adequacy of your EMS. Changing
circumstances might be internal to your organization
(such as new facilities, new raw materials, changes in
products or services, new customers, etc.) or might be
external factors (such as new laws, new scientific
information or changes in adjacent land use).
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Information sources to
consider:
3 Audit results
3 Internal suggestions
3 External communications
3 Progress on objectives
and targets
3 Other environmental
performance measures
3 Reports of emergencies,
spills, other incidents
3 New or modified
legislation and
regulations
3 New scientific / technical
data on materials and
processes used by the
organization
Consider holding
management review meetings
"after hours" to minimize
disruption of work.
All elements of the
EMS should be
considered as part
of Management
Review
After documenting the action items arising from your
management review, be sure that someone follows-up.
Progress on action items should be tracked to
completion.
As you assess potential changes to your EMS, consider
other organizational plans and goals. In this way,
environmental decision-making can be integrated into
your overall management and strategy.
Management Review: Questions to Ponder
Did we achieve our objectives and targets? If not,
why not? Should we modify our objectives?
Is our environmental policy still relevant to what we do?
Are roles and responsibilities clear, do they make
sense and are they communicated effectively?
Are we applying resources appropriately?
Are our procedures clear and adequate? Do we need
other controls? Should we eliminate some of them?
Are we fixing problems when we find them?
Are we monitoring our EMS (e.g., via system audits)?
What do the results of those audits tell us?
What effects have changes in materials, products, or
services had on our EMS and its effectiveness?
Do changes in laws or regulations require us to
change some of our approaches?
What other changes are coming in the near term?
What impacts (if any) will these have on our EMS?
What stakeholder concerns have been raised since
our last review? How are concerns being addressed?
Is there a better way? What can we do to improve?
Smaller organizations often favor employee experience overwritten procedures and
documented systems. However, personnel turnover without documented systems can
stall progress. When the manager of the Washtenaw County Home Toxics Reduction
Program took over his position, there had been a six-month gap since his predecessor
had left and very little in place to tell him what to do, whom to contact, or what the
history of the program was. Having an EMS can facilitate a smooth transfer of
responsibilities for environmental management.
YOU SHOULD NOW UNDERSTAND ALL OF
THE ELEMENTS OF AN EFFECTIVE EMS !!
NOW YOU'RE READY TO "GO"! (See next section)
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Capture the Learning: Management Review Worksheet
Do we have an existing process for
conducting management reviews?
If yes, does that process need to be
revised? In what way?
Who needs to be involved in this
process within our organization?
When is the best time for us to
implement this process? Can this
effort be linked to an existing
organization process (such as our
budget, annual planning or auditing
cycles?)
How frequently are management
reviews? What is the basis for this
frequency?
Should we conduct reviews more or
less frequently?
Who is responsible for gathering the
information needed to conduct
management reviews? Who is
responsible for presenting this
information?
How do we ensure that changing
circumstances (both internal and
external to the organization) are
considered I this process?
How do we ensure that the
recommendations of management
reviews are tracked and acted upon?
Our next step on management
review is to ...
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Section 5 : GO! (Roadmap for EMS Development)
A sequence of activities for building an EMS from the ground up
Once you gain an understanding the individual elements of
an EMS, you can begin the process of putting these
elements in place. Each of the individual EMS elements
is described in detail in Section 4. Also, several "up front"
EMS planning tasks (such as gaining top management
commitment) were described in Section 3.
Ford Motor Company
^ conducted ISO 14001
~"~ implementation
workshops for its
suppliers. Part of these
workshops was devoted
to a discussion of how to
"launch" the EMS effort
through a set of
implementation steps.
The Washtenaw County
^ Home Toxics Reduction
^ Program (HTRP)
successfully linked its
management review
process with its new
Business Improvement
Process (BIP). HTRP used
its environmental objectives
as input to the BIP and
reviewed progress annually
to determine what worked
and to make adjustments,
where needed. The output
of BIP will feed into the
County's budgeting
process.
Experience of many organizations shows that the order in
which EMS implementation activities should take place is
not always obvious or intuitive. Further, the optimal
sequence of implementation activities does not
necessarily follow the order in which elements are
described in various EMS models, such as ISO 14001.
Using a logical sequence can save time and money and
minimize the "false starts" an organization might make.
This section provides a step by step action plan for
developing and implementing the elements of an EMS. It
describes a logical sequence or "roadmap" for planning
and implementing EMS elements and explains how this
sequence can be important in building an effective EMS.
Keep in mind that this is just one way to do the job- you
might find other approaches that work just as well.
Figure 14 illustrates the suggested implementation
process flow. Each of the steps (and a rationale for their
sequence) is discussed below.
A few hints to keep in mind as you build your EMS:
• You may already have some EMS elements in
place, as indicated by the preliminary review that
you performed earlier (see Section 3 for more
details).
• Make sure to build in the links between elements.
Refer back to Section 4 for information on the key
links. The effectiveness of your EMS depends as
much on the strength of its links as it does on the
strength of the individual elements themselves.
• For many EMS elements, you will need to design
and implement a process. In these cases, you
also should consider documenting the process in
the form of a procedure.
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Identify
Legal & Other
Requirements
Identify & Evaluate
Environmental
Aspects, Related
Operations & Activities
Define Views
of Interested
Parties
Prepare
Environmental
Policy
Define Key
Roles and
Responsibilities
Establish
Objectives
& Targets
Establish
Operational
Controls &
Monitoring
Processes
Establish
Procedures for
Corrective/
Preventive
Action,
Document
Control &
Records
Management
Environmental
Management
Programs
Identify
Monitoring &
Measurement
Needs
Identify
Operational
Controls
_\Sec. £
Define
Job-Specific
Roles and
Responsibilities
Initial
Employee
Awareness
Establish
Other
System-Level
Procedures
Prepare
EMS
Documentation
(manual)
Conduct Specific
Employee Training
Conduct
Internal
EMS Audits
Conduct
Management
Reviews
Figure 14: GO!
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Identify
Legal and
Other
Requirements
Identify
Environmental
Aspects and
Related Products,
Operations and
Activities
Creating Your EMS: Step by Step
A first step in the EMS-building process is understanding the
legal and other requirements that apply to what you do (i.e.,
that apply to your products, activities and services). This step is
important for understanding compliance obligations and how
these obligations affect the overall EMS design. For example,
you might have an operation that is covered by an air quality
permit or might provide a service that results in the generation
of regulated wastes. Your EMS should include processes to
ensure that such legal requirements are addressed when you
conduct these operations (or when they are modified).
Your EMS should be designed to help you accomplish more that
just compliance with applicable laws and regulations, but these
compliance requirements should be a major consideration.
Performing this step first allows you to understand how legal
requirements might relate to the environmental aspects and
impacts of your products, activities and services, as discussed
next.
Once you understand what "rules" apply, you should assess
how your organization interacts with the environment. This
is accomplished by identifying your environmental aspects and
impacts and determining which of them are significant. Some
of your environmental aspects may be regulated, while others
may not be.
As you identify and assess your aspects, you also should
identify specific products, operations and activities from
which these aspects / impacts arise. Likewise, you can identify
any monitoring that is performed of these operations or
activities for environmental purposes. For example, if you
identify the generation of a particular air emission as a
significant environmental aspect, it would help to know which
operation(s) generate such air emissions. It might also help to
know whether these air emissions are monitored or otherwise
measured in some manner.
Collecting this information at an early stage will help you
implement subsequent EMS elements. You can use a form
(such as Figure 15) to capture this information. One caveat -
just because you identify an existing control and/or monitoring
activity related to a particular operation or activity, don't
automatically assume that these controls are adequate for
EMS purposes. The adequacy of these controls will depend on
several factors, including your objectives and targets.
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Figure 15: Linking Operations, Aspects, Controls and Monitoring (example)
Source
Operations
Parts painting
Parts plating
Other A ctivities
Raw material
storage
Fleet maintenance
Products
Pumps
Services
Equipment servicing
at customer sites
Significant Aspect(s)
• Air emissions
(VOCs)
• Solvent waste
generation
• Waste generation
• Water discharges
• Potential spills
• Waste oil generation
• Potential spills
• Energy Use
• Chromium content
• Waste generation
• Fuel use
Regulated?
• Yes
• Yes
• Yes
• Yes
• Yes
• Yes
• Yes
• A/o
• A/o
• A/o
• A/o
Associated Controls
• Limits on VOC
content in paints
and operating hours
• SOP for HW
generation
• SOP for HW
generation
• Notification to site
effluent treatment
plant
• Stormwater
Pollution Prevention
Plan
• SOP for HW
generation
• Stormwater
Pollution Prevention
Plan
• None
• None
• SOP for equipment
service
• None
Associated
Monitoring
or Measurement
• Paint use records,
log of operating
hours
• Waste tracking
sheet
• Waste tracking
sheet
• Pre-discharge
sampling
• Weekly
inspections of
storage area
• Waste tracking
sheet
• Weekly
inspections of
storage area
• None
• None
• Waste tracking
sheet
• Fuel dispensing
records
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Define
Views of
Interested
Parties
Armed with information on applicable legal and other
requirements as well as the environmental attributes of your
products, activities and services, you should gather
information of the views of your "stakeholders" (or
interested parties). Stakeholders might include, for example,
your neighbors, interest groups, regulators and others. Their
views might address how your organization affects the
environment, how well you are meeting your environmental
obligations, and whether your organization is a "good neighbor",
among other topics. There are many ways to collect information
on stakeholder views, as discussed in Section 4 (See
"Communication").
Gathering this information now allows you to consider
stakeholder input in the development of your environmental
policy. Since you have already assessed your legal and other
requirements and your environmental aspects, you should be in
a good position to have meaningful dialogues with these
stakeholders.
Prepare
Environmental
Policy
At this point, you should have a sound basis for developing (or
possibly amending) your environmental policy. Using the
information developed in the previous three steps allows your
organization to prepare a policy that is relevant to the
organization and the key issues that it faces. For example, you
will have information on the views of your stakeholders that
might be valuable in developing an environmental policy.
Keep in mind that you evaluated your current environmental
programs when you performed the preliminary review (see
Section 3), so you should understand how (and how well) you
are currently managing these key issues.
Define
Key Roles
and
Responsibilities
Once the environmental policy has been written, you can begin
to define key roles and responsibilities within the EMS. At
this stage of implementation, focus on "higher-level"
responsibilities, such as the roles and responsibilities of senior
management, key functional leaders and environmental staff (if
one exists). EMS responsibilities for other specific jobs or
functions will be identified in a later step. Once the key roles
and responsibilities have been defined, obtain the input of these
individuals in the next step of the process - establishing
objectives and targets.
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Establish
Objectives
And
Targets
Figure 16
Develop
Environmental
Management
Programs
Identify
Monitoring and
Measurement
Needs
Identify
Operational
Controls
At this point you are ready to establish environmental
objectives and targets for your organization. These objectives
should be consistent with your environmental policy. Each of
your objectives also should reflect the analyses you carried out
on legal and other requirements, environmental aspects and
impacts, and the views of interested parties (as well as the other
factors discussed in Section 4).
You identified the operations and activities related to your
significant aspects and impacts in an earlier step. Also, you
defined certain key roles and responsibilities. This information
will help you to determine the relevant levels and functions
within the organization for achieving objectives and targets. For
example, if you set an objective to reduce hazardous waste
generation by 10% this year, you also should know which parts
of the organization must be involved in order to meet this
objective.
This brings us to one of the most challenging (and
potentially most valuable) steps in the overall process.
Armed with an understanding of legal requirements,
your significant environmental aspects and impacts,
and your objectives and targets, your are ready to
tackle several EMS elements simultaneously.
These elements include the design of environmental
management programs, the initial identification of
necessary operational controls, and the initial
identification of monitoring and measurement needs.
One reason combining these steps is that they can
often overlap significantly. For example, your
environmental management program for achieving a
certain objective (such as maintaining compliance with
regulations) might consist of a number of existing
operational controls (procedures) and monitoring
activities. Similarly, achieving an objective might
require a feasibility study or the implementation of
certain "new" operational controls. Likewise,
determining progress on achieving objectives often
requires some form of monitoring or measurement.
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An example of a form for
describing environmental
management programs that
shows the links between
programs and operational
controls is provided in the
Tool Kit (Appendix A)
One important caveat: Keep in mind that operational
controls and monitoring / measurement processes might
be needed even if no objective (or corresponding
management program) exists for a particular operation or
activity. For example, controls might be needed for
certain operations to ensure compliance with legal
requirements or to control a significant environmental
aspect, even where no specific objective has been set.
The initial identification of operational control needs at this
point in the process should be supplemented by a more
detailed design of operational controls and monitoring
processes, as described in a subsequent process step.
Also keep in mind that this process is usually iterative.
That is, you might need to "re-visit" your management
programs, operational controls and monitoring processes
over time to ensure they are consistent and up-to-date.
You should already have a head start on this step, since
you identified operations and activities related to your
significant environmental aspects (as well as existing
control and monitoring processes) several steps ago.
Remember how we said this was a good idea?
Your don't need to fully develop these operational
controls and monitoring activities yet - that step comes
later (see "Design Operational Controls & Monitoring
Processes"). What you need to do now is compile a list
of your operational control and monitoring needs. As
you develop your environmental management programs,
ask yourself the following questions:
• How do we control this operation or activity now?
• Are these controls adequate to meet our objectives
and to ensure compliance?
• If additional controls are needed, what types of
controls make sense?
• What type of monitoring / measurement is needed to
track our progress in achieving objectives and to
ensure that operational controls are implemented as
designed?
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Establish
Corrective Action,
Document Control &
Records Management
Processes
At this stage of implementation, your EMS will begin to
generate some documents (such as procedures and
forms) and records (that demonstrate that various
processes are being carried out). For this reason, it is a
good time to establish procedures for
corrective/preventive action, document control, and
records management. These three processes are
essentially "system maintenance" functions. As you
develop and implement other system-level procedures,
work instructions for various activities, and other EMS
documents, you need a process for controlling the
generation and modification of these documents.
Likewise, you will need a process to ensure that you can
fix (or correct) problems when they occur. In addition,
many of these processes (such as monitoring activities)
will generate records, so you need an effective way to
manage the records that your EMS generates.
Establish
Operational
Controls &
Monitoring
Once the system maintenance functions are in place, you
can start in earnest the establishment of activity- or
area-specific operational controls and monitoring
processes. As a starting point, refer back to the list of
operational control and monitoring needs that you
generated in preparing your environmental management
programs (see earlier step). Also, you should have a
template for the development of these work instructions
(or standard operating procedures), since your document
control process was established in the prior step.
Remember that you might need operational controls and
monitoring processes to meet your policy commitments
and control significant environmental aspects, even
where no specific objectives or environmental
management programs have been established.
Employees that work in relevant operations or activities
can provide a lot of support here. Also, note that these
operational controls and monitoring processes can play
an important role in employee training, as discussed later.
Also keep in mind that you also need a procedure for
conducting periodic compliance evaluations.
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Define
Job-Specific
Roles and
Responsibilities
Plan and
Conduct
Initial
Employee
Awareness
Establish
Other
System-Level
Procedures
Prepare
EMS
Documentation
(manual)
As part of the process described above, you should
define job-specific roles and responsibilities. Such
roles and responsibilities should address the specific
operational controls and monitoring processes discussed
above. You might want to document these
responsibilities in a responsibility matrix or in some
other form that is easily communicated to employees.
Initial employee awareness training should be
conducted to promote understanding of the organization's
EMS efforts and the progress made to-date. As a first
step, train employees on the environmental policy and
other elements of the EMS. Discuss the environmental
impacts of their activities, any new / modified procedures,
the organization's objectives and targets, as well as their
EMS responsibilities. If you have contractors or others at
your site who are not employees of your organization,
consider whether these other individuals should be
included in these EMS awareness sessions.
Some system-level procedures (such as the procedures
for identification of environmental aspects and access to
legal and other requirements) were developed at earlier
stages of the process. At this point, you can establish
any other procedures required for the EMS. These
other system-level procedures might include, for example:
• employee training and awareness,
• internal and external communication,
• emergency preparedness and response,
• EMS auditing, and
• management review.
Once you have established roles and responsibilities and
defined all of your system-level procedures, preparing
the EMS manual should be a relatively simple matter.
The manual should summarize the results of your efforts
so far (that is, it should describe the processes you have
developed, the roles and responsibilities you have defined
as well as other EMS elements). Also, it is important to
describe the links among system elements and provide
direction to other system documents. Keep the manual
simple - there is no need to provide great detail on any
particular system process. Readers can be referred to
the detailed procedures if more information is needed.
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Plan and
Conduct
Specific
Employee
Training
Once the procedures and other system documentation
have been prepared, you are ready to conduct specific
employee EMS training. As a first step, identify specific
training needs. Employee training should be designed to
ensure understanding of:
• key system processes,
• operational controls related to their specific jobs, and
• any monitoring or measurement for which they are
responsible.
Job-specific training should also cover topics such as
EMS auditing for those employees that will conduct
internal EMS audits.
Conduct
Internal
EMS
Audits
Once internal auditors have been selected and trained,
you should design and initiate the internal auditing
process. At this point, you should have sufficient EMS
processes in place to conduct meaningful audits. Many
organizations find that it is easier to start with smaller,
more frequent audits that to audit the entire EMS at once.
These early audits can serve as a learning tool for the
auditors.
Once the audit results are known, use the corrective and
preventive action process you developed earlier to
address any identified problems. Audit records should be
managed in accordance with the records management
process.
Conduct
Management
Reviews
Use the results of your internal audits (along with other
information on the EMS) to conduct management
reviews. Management should consider the need for any
changes to the EMS and make assignments for any
changes needed. Such assignments should be
consistent with the roles and responsibilities established
previously.
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Appendix A: TOOLKIT
Sample Environmental Policies 89
Environmental Impact Identification and Evaluation: Techniques and Data Sources..96
Sample Procedure: Instructions for Environmental Aspects Identification Form 98
Environmental Aspects Identification Form 103
Sample Environmental Aspect Evaluation and Scoring Tools 104
Resources for Tracking Environmental Laws and Regulations 106
Sample Process Tool: Setting Objectives & Targets 108
Sample Procedure: Setting Objectives & Targets 111
Sample Tools: Environmental Management Program 113
Sample Responsibility Matrix 117
Sample Environmental Training Log 120
Sample Procedure: Communications with External Parties 123
Sample Document Index 125
Outline of Sample EMS Manual and Other EMS Documents 127
Sample Records Management Form (supplied courtesy of 130
General Oil Company) 132
Sample Procedure: Corrective and Preventive Action 134
(includes tracking log) 134
Sample Environmental Records Organizer 136
Sample Procedure: EMS Audits 136
Sample EMS Audit Forms 141
Sample EMS Audit Questions 143
Sample Procedure: Management Review 149
Note: The examples in the Tool Kit are drawn from many different sources. They are not
designed to be used together in EMS development.
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X
Sample
Environmental
Policies
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Sample policy - Actual policy reproduced with permission. Policy is not in original format.
NEO INDUSTRIES
HEALTH, SAFETY AND ENVIRONMENTAL POLICY
Neo Industries is committed to managing health, safety and environmental (HS&E) matters as an
integral part of our business. In particular, it is our policy to assure the HS&E integrity of our processes
and facilities at all times and at all places. We will do so by adhering to the following principles:
Compliance
We will comply with all applicable laws and regulations and will implement programs and procedures
to assure compliance. Strict compliance with HS&E standards will be a key ingredient in the training,
performance reviews and incentives of all employees.
Where existing laws and regulations are not adequate to assure protection of human health, safety
and the environment, we will establish and meet our own HS&E quality standards.
Prevention
We will employ management systems and procedures specifically designed to prevent activities and /
or conditions that pose a threat to human health, safety or the environment. We will minimize risk and
protect our employees and the communities in which we operate by employing safe technologies and
operating procedures, as well as being prepared for emergencies.
We will strive to prevent releases to the atmosphere, land or water. We will minimize the amount and
toxicity of waste generated and will ensure the safe treatment and disposal of waste.
Communication
We will communicate our commitment to HS&E quality to our employees, vendors and customers. We
will solicit their input in meeting our HS&E goals and in turn will offer assistance to meet their goals.
Continuous Improvement
We will continuously seek opportunities to improve our adherence to these principles, and will
periodically report progress to our stakeholders.
{Signature}
Neil K. Holt
President
March 1995
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Sample policy - Actual policy reproduced with permission. Policy is not in original format.
Pacific Gas and Electric Company
Environmental Quality
statement
PG&E is committed to a
clean, healthy environment.
We will provide our
customers with safe,
reliable, and responsive
utility service in an
environmentally sensitive
and responsible manner
We believe that sound
environmental policy
contributes to our
competitive strength and
benefits our customers,
shareholders, and
employees by contributing
to the overall well-being
and economic health of the
communities we serve.
September 1995
(Actual policy is printed on recycled paper)
We will:
Comply fully with the letter and spirit of
environmental laws and regulations, and
strive to secure fundamental reforms that will
improve their environmental effectiveness
and reduce the cost of compliance.
Consider environmental factors and the full
acquisition, use, and disposal costs when
making planning, purchasing, and operating
decisions.
Work continuously to improve the
effectiveness of our environmental
management.
Provide appropriate environmental training
and educate employees to be environmentally
responsible on the job and at home.
Monitor our environmental performance
regularly through rigorous evaluations.
Seek to prevent pollution before it is
produced, reduce the amount of waste at our
facilities, and support pollution prevention by
our customers and suppliers.
Manage land, water, wildlife, and timber
resources in an environmentally sensitive
manner.
Use energy efficiently throughout our
operations, and support the efficient use of
gas and electricity by our customers and
suppliers.
Re-use and recycle whenever possible.
Use environmentally preferred materials.
Clean up residual pollution from past
operations in a cost-effective manner.
Work cooperatively with others to further
common environmental objectives.
Communicate and reinforce this policy
throughout the company.
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Sample policy - Actual policy reproduced with permission. Policy is not in original format.
CAMPBELL & CO. ENVIRONMENTAL POLICY
Campbell & Go's commitment to improve the
environment is an expression of our Guiding
Principles, and a demonstration of "think
globally and act locally" sensibilities.
We strengthen this commitment by
employing Quality Operating System
methodology as the framework to identify
objectives and targets for addressing areas
of environmental significance.
Campbell & Co. is improving the condition of
our environment by preventing pollution,
specifically through the reduction of natural
resource usage. We are also helping to
preserve the environment by promoting
recycling as well as continuing to make
responsible environmental choices when
purchasing products.
Campbell & Co. will comply with all federal,
state and local legislation and regulatory
requirements, as well as those requirements
adopted through the Michigan Business
Pollution Prevention Partnership Policy.
Above all, Campbell & Co. employees will
strive to continuously improve our efforts to
create a cleaner and safer environment.
David Scheinberg, President & CEO
Created: June 6, 2000
Revised: October 6, 2000
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Sample policy - Actual policy reproduced with permission. Policy is not in original format.
Village Of Chelsea, Michigan
Statement Of Environmental Policy
The Village of Chelsea is committed to continual improvement of its Environmental
Management System and is in compliance with all relevant federal, state, and local
environmental legislation and regulations. The Village of Chelsea will meet and
strive to exceed all environmental requirements and will seek to prevent pollution
before it is produced. To sustain this commitment, the requirements of the
Environmental Management System described in this Manual apply to all activities
and employees. The Village's Department Superintendents are the Village's
Management Representatives who have the responsibility and authority to plan,
enforce, and maintain the Village's Environmental Management System. This
responsibility also includes stoppage of activities that deviate from the
requirements of this Manual. The EMS Management Representative may
delegate some of this authority downward through the organization in order to
implement the system effectively. We will continuously seek opportunities to
improve our adherence to the principles of environmental management.
Policy adopted by Village Council on March 11, 1997.
Village President
Village Clerk
[Signatures included in original policy.]
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Saint Joseph Mercy Hospital (in Michigan) demonstrated that an environmental policy can
be written in the form of a procedure. One advantage of this approach is that hospital staff can
make a direct connection between the policy and their departmental responsibilities for
implementing the policy. The hospital includes its policy in the Administrative Policy Manual
because that manual was already well established and widely distributed. Integrating EMS
requirements with existing manuals, procedures, training, and responsibilities was a key
implementation strategy for the hospital.
Saint Joseph Mercy Hospital
Administrative Policy and Procedure
Subject: Environmental Compliance Policy
Effective Date: September 14, 1998
Revised Date:
Approved By: President and CEO
POLICY
It is the policy of St. Joseph Mercy Hospital (SJMH), which includes all SJMH owned and
operated buildings and services, to conduct all of its operations in an environmentally
responsible and sensitive manner. St. Joseph Mercy Hospital will fully comply with both
the letter and the spirit of all applicable federal, state and local regulatory requirements
governing hazardous materials and wastes, pollution prevention and environmental
protection. It is recognized that the health and well being of the environment contributes to
the health and well being of the communities and populations we serve. St. Joseph Mercy
Hospital will strive to continuously improve its systems and procedures related to
environmental protection and pollution prevention activities. St. Joseph Mercy Hospital will
manage its facilities and properties in an environmentally responsible manner. St. Joseph
Mercy Hospital will participate as appropriate in community, industry, and/or governmental
sponsored groups addressing environmental issues affecting the communities we serve.
NARRATIVE
Environmental protection is the responsibility of all SJMH departments and employees. As a
health care organization, SJMH must handle and manage a wide variety of potentially
hazardous or polluting materials including medical wastes, radioactive materials and
hazardous chemicals and wastes. Many of our processes present potential water and air
quality issues that demand continuous monitoring and control. Proper and responsible
handling of these materials and processes is imperative to prevent pollution, reduce waste
and protect our environment. A host of federal, state and local regulatory requirements are in
place to guide this organization in achieving environmental compliance.
PROCEDURE
I. Each department will continuously assess its operations to identify potential safety
hazards and pollution risks. Each department is responsible for establishing and
maintaining department specific policies and procedures designed to reduce or
eliminate environmental hazards and minimize any negative environmental impact
when applicable.
A. Potential risks will be minimized to the extent possible by seeking out less
environmentally hazardous products, equipment or procedures.
B. Appropriate engineering controls will be implemented when it is not
possible to eliminate an environmentally hazardous material or
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Sample policy - Actual policy reproduced with permission. Policy is not in original format.
procedure.
C. All departments and employees will strive to reduce all types of wastes
through identifying and eliminating wasteful practices and products and
participate in organizational recycling and waste reduction programs.
D. Departments will educate and communicate organizational and
department specific environmental policies, goals and objectives to
employees as required.
E. Departments will consider using products that have recycled content
taking economic and quality factors into account.
II- The Safety Steering Committee is responsible for monitoring environmental
compliance issues recommending and assuring that corrective action is
implemented as warranted to correct deficiencies.
A. Objectives and targets will be established to assure continuous
improvement in organizational environmental performance. Safety
Committee structure is responsible for establishing goals and
implementing programs to meet targets. The Safety Steering Committee
is responsible for monitoring progress and reporting activities to
Executive Management.
REFERENCES
• Safety Steering Committee
• Hazardous Material and Waste Committee
• Product Value Analysis Committee
• Safety Policy Manual Section lll_300 - "Hazardous Materials and Waste"
• Departmental Specific Hazardous Material/Pollution Prevention Policies and Procedures
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Environmental Impact
Identification and Evaluation:
Techniques and
Data Sources
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SOME TECHNIQUES AND DATA SOURCES FOR IDENTIFYING AND
EVALUATING ENVIRONMENTAL IMPACTS
Process Hazard
Analyses
Used to identify and assess potential impacts associated
with unplanned releases of hazardous materials.
Methodology in common use due to OSHA Process Safety
Management regulations. Typically employs team approach
to identify and rank hazards.
Failure Mode and
Effects Analyses
Commonly used in quality field to identify and prioritize
potential equipment and process failures as well as to
identify potential corrective actions. Often used as a
precursor to formal root cause analyses.
Process Mapping
See Appendix C for details of this technique.
Environmental Impact
Assessments
Used to satisfy requirements of National Environmental
Policy Act (NEPA) regarding the evaluation of environmental
impacts associated with proposed projects. Methodology in
common use, but not typically used to assess environmental
impacts associated with existing operations.
Life Cycle
Assessments
Used to assess full range of impacts from products, from
raw material procurement through product disposal.
Methodologies somewhat subjective and can be resource
intensive. Described in ISO 14040-14048.
Risk Assessments
Used to assess potential health and/or environment risks
typically associated with chemical exposure. Variety of
qualitative and quantitative methodologies in common use.
Project Safety / Hazard
Reviews
Used to assess and mitigate potential safety hazards
associated with new or modified projects. Methodologies in
common use. Typically do not focus on environmental
issues.
Used to quantify emissions of pollutants to the air. Some
data may already by available to the organization, based on
EPCRA requirements and CAA Title V permitting program.
Emission Inventories
Pollution Prevention
or Waste Minimization
Audits
Used to identify opportunities to reduce or eliminate pollution
at the source and to identify recycling options. Requires
fairly rigorous assessment of facility operations. Typically
does not examine off-site impacts.
Environmental
Property Assessments
Used to assess potential environmental liabilities associated
with facility or business acquisitions or divestitures. Scope
and level of detail is variable. Typically do not assess
impacts associated with products or services.
Environmental Cost
Accounting
Used to assess full environmental costs associated with
activities and/or products. Emerging protocols require
comprehensive assessment to quantify costs.
Environmental
Compliance Audits
Used to assess compliance with federal, state and local
environmental regulations. Methodologies in common use.
Scope and detail vary. Not typically directed at examining
environmental impacts (particularly for products).
©2001 NSF
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X
Sample Procedure:
Instructions for Environmental Aspects
Identification Form
(courtesy ofZEXEL Corporation)
©2001 NSF 98
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OPERATIONAL PROCEDURE
Number:
Title:
1 Author:
Ronda Moore
Environmental Aspects & Impacts
Issue Date:
August 04, 2000
Approval:
Vice President Operations
Reviewed By:
Waste Water Group Leader
1.0 Purpose
The purpose of this procedure is to provide a system and instructions to identify
environmental aspects of ZEXEL's activities, products, and services in order to
determine those which may have a significant impact on the environment.
2.0 Scope
This procedure covers all activities, products, and services associated with ZEXEL. For
purposes of evaluation, activities, products, and services with similar characteristics may
be grouped together.
Document Number
3.0 Reference Documents
Document Name
Objectives and Targets OP-EV0103
Management Review OP-ZX006
Aspect/Impact Evaluation Form WF-ES002
Aspect/Impact Listing - Decatur WF-ES008
Aspect/Impact Listing - Arcola WF-ES058
Initial Production Control OP-ZX001
Contract Review OP-SA001
4.0 Procedure
4.1 The procedure consists of an initial screening of activities, products, and services, based
on data submitted to the ISO 14000 Task Force by the Area Managers. The Task Force
assesses the aspects, determines associated impacts, and assigns an impact rating.
The Task Force will review the evaluation results, and up-date as needed.
4.2 Area Managers are responsible for developing a flowchart for their department(s)
showing all inputs and outputs to their processes. Inputs into the process may include
supplies, raw materials, chemicals, packaging, and energy consumption. Outputs from
the process may include products, solid wastes, liquid wastes, emissions, noise, and
odor. The flowcharts shall also include the current method of handling generated
wastes.
4.3 The Task Force shall evaluate the information submitted on the flowcharts. The Task
Force may call upon other ZEXEL Team Members to assist, as needed. Each activity,
product, and service shall be evaluated from the time the material is accepted on site
through the time of sale, at the sale location. If a waste is being evaluated, the timeline
to consider is the time the material is accepted on site through ultimate disposal, as
displayed by the diagram below.
©2001 NSF
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Accept Material
-Product-
-Waste—
Sale Location
I Ultimate Disposal
4.4 The Task Force shall assign an impact rating according to the scales described below,
while considering each of the following stages: raw material storage, production
(accidents, start up, and normal operation), product and waste storage, transportation,
and ultimate disposal.
4.5 The Task Force shall ask for each aspect / impact evaluation:
a) Is it in our permits / permittable?
b) Is it regulated by law?
c) Do we have control over it?
If the answer to a and/or b is "yes", the impact must be included on the list of significant
impacts. If the answer to c is "no", the impact shall not be included on the list of significant
impacts. The following table explains the different possible answers.
Possible Answer
yes
No
Permitted /
Permittable
must include
may include
Regulated by Law
must include
may include
Do we have
Control
may include
shall not include
4.6 When evaluating the "frequency", the number shall be determined from the following
scale, based on documented evidence, by asking the following questions to determine
frequency of use and of accidents: (1). How often does the process occur? and (2).
How often has a problem occurred?
Frequency
Continuously
once per shift
once per day
Weekly
Monthly
Quarterly
semi-annually
Annually
once every 1 to 5 years
over 5 years
Never
Scale
10
9
8
7
6
5
4
3
2
1
0
©2001 NSF
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4.7
4.8
4.9
When evaluating the "severity" the task force shall assign an impact number by selecting
the highest evaluated rate from the scale below, based on documented evidence. When
considering human impact, it is important to include contractors, neighbors, customers,
etc., as well as team members.
Severity
Scale
10
9
8
7
6
5
4
3
2
1
Human Impact
multiple deaths
single death
disabling injury
long term health
effects
lost time
Injury/Illness
restricted duty
medical only
first aid treatment
Discomfort
None
Animal /Plant
Effect
widespread
permanent
destruction
on-site permanent
destruction
widespread genetic
impact
on site genetic
impact
wide spread
disfigurement
on-site disfigurement
wide spread
appearance
reduction of natural
beauty
on-site appearance
none
Public Relations
plant closure
permanent public
disfavor
interrupted
operations
loss of historical
assets
state or national
protest
city or county protest
employee protest
public inconvenience
public disfavor
none
4.10
Impact ratings shall be determined by multiplying the frequency and severity numbers.
The Task Force shall determine an appropriate cutoff level for significant impacts.
The Environmental Manager shall work closely with ZEXEL's Plant Management to
ensure that the identified significant environmental aspects are considered in
establishing environmental objectives and targets for ZEXEL, as stated in the Objectives
and Targets OP.
The results of the most recent environment aspect / impact identification is reviewed as
part of the Management Review process, as specified in the Management Review OP.
From this review ZEXEL Management determines the need to update the environmental
impact evaluation. Factors considered in the determination to update the assessment
include improved methodologies, and major changes in ZEXEL's policies, products, or
processes. Aspect reviews may also be triggered from the Initial Production Control
(I PC) and Contract Review process. Environmental impact evaluations shall be
conducted at least, on an annual basis, by the end of each calendar year, even if none
of the factors listed above dictate a review.
©2001 NSF
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ASPECT / IMPACT EVALUATION
Aspect/Impact/Activity:
Date:
Category
Air Quality
Water
Quality
Land Quality
Consumption
Stages
Raw Material
Storage
Production
(Start-Up)
Production
(Normal)
Product/
Waste Storage
Transportation
Ultimate
Disposal
Freq
Use
uency
Incident
Severity
Human
Impact
Animal/Plant
Public
Impact
Rating
Overall Rating \ \
Please note. Significant Impact if
- permittable
- required by law
- over the establish cut off
Frequency
continuously
1 per shift
1 per day
weekly
monthly
quarterly
semi-annually
annually
1 every 1 - 5 yrs
over 5 yrs
never (Use Only)
Severity
Human Impact
multiple deaths
single death
disabling injury
long term health
effects
lost time injury/
illness
restricted duty
medical only
first aid
treatment
discomfort
none
Animal/ Plant Effect
widespread perm.
destruction
on-site permanent
destruction
widespread genetic
impact
on-site genetic impact
widespread
disfigurement
on-site disfigurement
widespread appearance
reduction of natural
beauty
on-site appearance
none
Public Relations
plant closure
permanent public
disfavor
interrupted
operations
loss of historical
assets
state or national
protest
city or county
protest
employee protest
public
inconvenience
public disfavor
none
Scale
10
9
8
7
6
5
4
3
2
1
0
©2001 NSF
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Environmental Aspects Identification Form
(courtesy of Johnson Controls, Inc. -
Automotive Systems Group)
Note: The instructions and form were developed within the context of a comprehensive
EMS. References are made to processes outside of the instructions.
This is intended as an example, not a stand-alone document.
©2001 NSF 103
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Provided courtesy of Johnson Controls, Inc., Automotive Systems Group
Instructions for Environmental Aspect Identification Form
Responsibilities
The facility Cross Functional Team (CFT) led by the Management Representative (MR) is
responsible for completing this form for each Core Process and Supporting Activity within a
facility. If possible, members of the CFT must conduct a physical inspection when completing
this form. The completed form is a material balance of a process or activity and is used to
identify Environmental Aspects. The facility CFT compares the resulting material balance and
list of facility-specific aspects to any information available in the form of generic "HSE Process
Profiles" produced for similar type processes or activities.
At a minimum, the CFT will review and revise the completed forms, by means of physical
inspection, as necessary at issuance, annually, prior to and immediately following
implementation of new or modified processes/activities.
All environmental aspects are evaluated for significance and managed as defined in the
Environmental Aspects Control Plan form.
Conducting a Material Balance
The material balance consists of identifying all raw materials, chemicals, and utilities used as
input along with their relative usage rates, and all output as product and by-products produced.
The latter is all wastes produced, all recycled materials, water discharges, and air emissions
known for the process(es), and any available rates of production.
1.0 Record the Plant Name, Process/Activity Name, and Location.
2.0 Provide a description of the process/activity.
3.0 Determine and record if the Process/Activity is a Contracted Process/Activity.
4.0 Record Material Inputs and Outputs. If the Process/Activity is installed or in place,
conduct the identification by means of physical inspection.
Raw material inputs
• Parts: Enter the major, non-chemical parts/supplies used in the process.
• Chemical: Enter any chemical materials used in the process.
• Energy: Enter energy type and usage. (Levels are relative to the facility.)
• Other Input: Enter inputs that are not covered clearly in other categories, (e.g.
packaging, containers)
• Water Use: Enter water type (e.g. city, well, storm, process, chilled) and usage.
(Levels are relative to the facility.)
©2001 NSF 104
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Provided courtesy of Johnson Controls, Inc., Automotive Systems Group
Process Output
• List all products produced by the process specifically produced for sale.
Recyclable and Chemical By-Product (e.g. Rebond) outputs are entered in the
waste section.
• List all air emissions whether they are drawn directly through a stack or are
discharged into the room and escape as fugitive emissions. Include noise and
odor as an air emission if potentially noticeable outside the facility.
• Enter wastes. Wastes are any materials intended to be discarded or disposed of,
whether regulated or not, and include liquids, solids, and gases. Also include
recycled materials, returnable containers and chemical by-products under this
category
• Check the recycled box if the material is currently recycled, internally or
externally. It does not include materials that go directly back into the process
(i.e., Calibration shots returned to day tanks, etc.)
• Include containerized wastewater transported off-site.
• Enter all wastewater streams that discharge directly to storm or sanitary sewer
systems or surface waters. Containerized wastewater should be included in the
waste section. In the bottom portion of the wastewater section, list any treatment
that occurs before the water is discharged.
5.0 Compare the completed form to any information available in the form of generic "HSE
Process Profiles" produced for similar type processes or activities.
6.0 Sign and date the form with the date the form was completed or revised.
7.0 Collect all completed Aspect Identification forms and enter data into the supporting
Environmental Aspect Control Plan form.
©2001 NSF 105
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Environmental Aspects Identification
Process Overview
Establish Cross
Functional Team
(CFT)
Determine Core
Processes and
Supporting Activities
Inspect each
Process/Activity and
conduct material
blanace
Identify and record
aspects
Compare to available
profiles
Proceed to
Environmental
Aspects
Analysis and
Control Form
©2001 NSF
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Plant
ENVIRONMENTAL ASPECTS IDENTIFICATION
Process/Activity:,
Contracted'5
Process Activity Location:
RAW MATFR1W INPUTS
cmmcu_mmmL
TYPE
Natural <3K
frepsme
Cotr^sressecJ M
Hvdrswfics
BlfcRGVL
High
USACt
Ntefium
LOM**
SISfisttffiUE
TYPE
WATtRU
K
USAGt
MecSwrt
Lovv
-1
WAItR
pa ocsw^cbVEy
*wS|stffiT^i ASscl'i 8ffdl wcls plr^o
siiSdi drawr^, d^aeeci (fesc
^
WATER DISCHARGE
On sle Tremmgft fTvi^t
HIOOOCT OUTPUTS
WASTE (tBVPROOUCIS)
_n
_n
J3
_D
J2
_D
J3
_D
_I3
_D
_n
©2001 NSF
107
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X
Sample Environmental
Aspect Evaluation and
Scoring Tools
©2001 NSF 108
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Sample 1: Environmental Aspect/Impact Scoring Worksheet
A company identified "Spills from Unloading Trucks" as an environmental aspect of its
operations. The company used the following worksheet and rating criteria to determine
whether the environmental impacts (on water quality and/or soil contamination) of this
aspect should be considered significant.
First, the company determined that the LIKELIHOOD of a spill was low, since it had not
experienced any spills of this type in the prior three years. Second, they determined that the
MAGNITUDE (or SEVERITY) of the environmental impact would be moderate for most of
the types of materials that they unload from trucks at the loading dock. The company noted,
however, that certain chemicals are regulated and that spills of such materials in reportable
quantities would require an appropriate response to regulatory agencies.
Using the "Key to Impact Rating" (see below), an environmental impact with a Low
Likelihood and a Moderate Magnitude received an overall score of "low impact
significance". Thus, "spills from unloading trucks" was not considered a significant
environmental aspect.
Area or
Activity
Shipping
Dock
Aspect
Spills from
Unloading
Trucks
Impacts
Water Quality
and
Soil
Contamination
Impact Scoring
(see below)
Likelihood is
low
Magnitude
is moderate
A
OVERALL \
IMPACT / \
SCORE IS / \
LOW \
Significance
Not
Significant
(Note: spills
of
reportable
quantities of
certain
chemicals
\must be
\ Yeported)
Key to Impact Rating
Likelihood of
Occurrence
or Impact(s)
High
Medium
Low
Magnitude
(severity of impacts, actual or pc/
Severe
High
Significance
High
Significance
Medium
Significance
Moderate /
High
Significance
Medium
Significance
Low
Significance
r^ I
t
/
ential
Low
Medium
Significance
Low
Significance
Low
Significance
Excerpted from "Environmental Management Systems: A Guide for Metal Finishers"
(NSF International), available for free download at www.nsf-isr.org.
©2001 NSF
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Sample 2: Environmental Aspect/Impact Scoring Worksheet
Approach
For each product, service or activity (or group of products, services or activities), each
element in the table is assigned two scores, based on (1) the degree of impact and (2)
frequency or likelihood of the associated environmental impacts.
Degree of Impact
4 = serious (likely to result in severe or widespread damage to human health or the
environment)
3 = moderate
2 = minor
1 = no impact (unlikely to have an adverse impact on human health or the environment)
Frequency/Likelihood of Impact
4 = continuous (impact occurs on an on-going basis)
3 = frequent (impact occurs more than once / month)
2 = infrequent (impact occurs more than once / year but less than once / month)
1 = improbable / never (impact has never occurred or is highly unlikely to occur)
Scores are added for each indicator across the relevant life cycle stages (as shown in the
example below) to generate a total impact score.
Category
Human Health
Environment
Resource Use
Indicator
Employees
Surrounding
Community
Global
Air Quality
Surface
Water
Ground
Water
Land / Soil
Ecosystem
Effects
Noise
Fuels
Water
Raw
Materials
Pre-
Production
3/2
2/2
1/2
Manufact- Production/ Use / Waste
uring Distribution Service Mgt
2/2
2/3
1/2
2/1
2/2
1/3
4/2
1/2
1/2
2/2
2/2
1/3
TOTAL
SCORE
22
20
17
©2001 NSF
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X
Resources for Tracking Environmental
Laws and Regulations
©2001 NSF 111
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Resources for Tracking Environmental Laws and Regulations
Over the last few years, the Internet has emerged as a tremendous tool for tracking and
obtaining information on environmental laws and regulations. For example, the USEPA
home page (see address below) in one quite useful Internet source. See Appendix F for
additional information on resources.
This table describes a variety of commercial and non-commercial sources of information on
federal and state environmental laws and regulations. This list is not intended to be
comprehensive. Appearance on this list should not be construed as an endorsement by
EPA or NSF of any commercial products listed here.
Source
USEPA
Small Business Ombudsman
(1-800-368-5888)
USEPA Web Site
Small Business Assistance
Programs (various states)
US Small Business
Administration
US Government Printing Office
(202-512-1800)
Trade and Professional
Associations (various)
Counterpoint Publishing
(1-800-998-4515)
Bureau of National Affairs
(1-800-372-1033)
Thompson Publishing Group
(1-800-677-3789)
Business & Legal Reports, Inc.
(1-800-727-5257)
Aspen Law and Business
(1-800-638-8437)
Description
Regulatory explanations and guidance, research, case
studies, contacts for additional information. Variety of hotlines
available for particular statutes (such as RCRA). Internet
access also available (http://www.epa.gov).
Provides a variety of information of environmental laws and
regulations as well as tools and compliance guidance.
(http://www.epa.gov).
Guidance on regulations and compliance issues. Initially
focused on clean Air Act requirements, but expanding into
other environmental media.
Various services available to small businesses in the US.
Federal Register published daily with all federal proposed and
final rules. (Also available on line via GPO Access)
Provide a variety of services related to environmental laws
and regulations, including regulatory updates and training.
Contact individual associations for details.
CD-ROM and Internet dial-up access to legal / regulatory
information for federal government and all 50 states, updated
daily.
Information on EHS laws, regulations and activities at
international, national and state level. Paper and electronic
access available.
Manuals on a variety of federal and state environmental
programs with monthly updates and newsletters.
Access to federal and state regulations with monthly, updates
on available on CD-ROM.
Publishes compliance manuals with regular update service for
RCRA and Clean Air Act.
©2001 NSF
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X
Sample Process Tool:
Setting Objectives & Targets
©2001 NSF 113
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Sample Process Tool for Setting Objectives & Targets
Step 1: A cross-functional team is a good way for your organization to set realistic objectives
and targets. List here who needs to be involved on the team:
Name
Contacted?
Step 2: Think about what information sources your team will need to establish objectives and
targets. Pull together information sources such as:
Information Sources
process maps
waste, and emission data
site maps
compliance audit reports
list of identified environmental aspects and
impacts
communications from interested parties
others??
(you may also want to do a plant tour or "walk
through" to identify other issues)
How they will help
e.g.,
• identify process steps with environmental
aspects
• determine current wastes and sources
• etc.
Step 3: Is there other information that might be helpful to the team?
Other Information Needed
Where we will get it
©2001 NSF
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Step 4: List the significant environmental impacts (you identified these earlier). You can
categorize these impacts by type:
Energy
Use
Raw
Materials
Air
Impacts
Water
Impacts
Waste
Impacts
Land
Issues
Other
(specify)
Step 5: Look at processes (such as plating or assembly) and activities (such as shipping or
purchasing). Are there any other issues the team should consider, in addition to those
listed above as significant impacts? (For example, you might want to establish an
objective to reduce spills of hazardous materials at the loading dock, even if this was not
identified as a potentially significant environmental impact.)
Process or activity
Issues
Possible Objectives & Targets
Step 6: List any new regulatory requirements that affect the facility (or other regulations for
which the need for additional actions has been identified).
Regulations, other requirements
Possible Objectives & Targets
Step 7: Consider inputs from interested parties. Any need for additional objectives related to
views of neighbors, community groups or other parties?
Inputs from Interested Parties
Possible Objectives & Targets
©2001 NSF
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Step 8: Look at the lists of possible objectives developed in Steps 4 -7. Brainstorm
with the team on whether these objectives are:
• reasonable,
• technologically feasible,
• consistent with other organizational plans/goals, and
• affordable.
List preliminary objectives and targets based on this exercise:
Selected Preliminary Objectives
Step 9: Determine how you will measure each of the selected preliminary objectives. (If you
cannot establish an effective way to measure it, put that objective "on-hold" for later
consideration).
Selected Objectives
Performance Indicator(s)
Step 10: For each objective that you selected, determine who is going to develop the action plan
(who, what, when, where, how). List these names below:
Selected Objectives
Responsibility for Action Plan
©2001 NSF
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Sample Procedure:
Setting Objectives & Targets
©2001 NSF 117
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EMS PROCEDURE: SETTING AND TRACKING OF ENVIRONMENTAL
OBJECTIVES AND TARGETS
I. Purpose
The purpose of this procedure is to ensure that the organization establishes and maintains
documented environmental objectives and targets.
II Scope
This procedure applies to environmental objectives and targets set at all relevant levels
within the organization.
III. Definitions
Environmental (or environmental) objective- A site goal that is consistent with the
environmental policies and considers significant environmental impacts and applicable laws
and regulations. Objectives are quantified wherever practicable.
Environmental (environmental) target- A detailed performance requirement (quantified
wherever practicable) based on an environmental objective. A target should be met in order
for the underlying objective to be achieved.
IV. General
The organization establishes environmental objectives and targets in order to implement the
environmental policies. Objectives and targets also provide a means for the organization to
measure the effectiveness of its environmental efforts and improve the performance of the
environmental management system. In establishing environmental objectives, the
organization considers:
• applicable laws and regulations (and requirements of other programs, such as ...);
• environmental aspects of the organization's activities and products;
• technological, financial, operational, and other organizational requirements; and,
• the views of employees and other interested parties.
Based on the organization 's environmental objectives, targets are established for different
functions within the organization and for different areas of the plant. For example, the
organization may establish an environmental objective to "reduce waste generation by 10%
per year". Based on this objective, different areas of the plant might set targets for reducing
individual waste streams in order to ensure that the organization's objective was achieved.
An organization-wide environmental objective might also be translated into individual
projects (such as changes in production processes, materials or pollution control equipment)
in different plant areas.
©2001 NSF 118
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V. Procedure
A. The organization's top management is responsible for establishing environmental
objectives on an annual basis. To initiate the process, the Plant Manager holds a
meeting of all staff members to discuss the development of environmental objectives.
B. Objectives are action- and prevention-oriented and are intended to result in meaningful
improvements in the organization 's environmental performance.
C. Each plant area or functional manager is responsible for providing input from his / her
own function (Finance, Engineering, etc.) or shop area (Fabrication, Assembly, Shipping /
Receiving, etc.). The organization's environmental manager is responsible for providing
input on applicable laws and regulations, significant site environmental impacts, and the
views of interested parties. (These inputs are obtained from the separate analyses
required by Procedure #'s).
D. As a starting point, the organization's management evaluates its performance against
environmental objectives for the current year. As part of this effort, management
examines the results of its environmental performance evaluations.
E. Preliminary environmental objectives are developed for further discussion and evaluation.
Each manager is responsible for evaluating the potential impacts within his / her
functional or shop area (if any) of the proposed environmental objectives. The
organization's environmental manager reviews proposed objectives to ensure
consistency with the overall environmental policy.
F. Environmental objectives are finalized, based on review comments from site managers
and employees. Each manager identifies the impacts of the objectives in his / her
function or shop area, establishes targets to achieve the objectives, and develops
appropriate measures to track progress towards meeting the objectives and targets.
G. Each manager is responsible for communicating objectives and targets (and the means
for achieving them) to others in his / her part of the organization.
H. Progress towards the objectives and targets is reviewed on a regular basis at
management meetings. The progress is also communicated to plant employees via
bulletin boards and other similar means.
I. At the end of each calendar year, the organization's management reviews its performance
with regard to achieving the objectives and targets. This information is used as input to
setting objectives and targets for the succeeding year.
©2001 NSF 119
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X
Sample Tools:
Environmental Management Program
©2001 NSF 120
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Sample Environmental Management Program Form
(Note: Use one form per objective)
Date Individual Responsible:
I I I )
Environmental Objective:
Related Target(s):
Related Significant Environmental Aspect(s):
Specific Function and/or Department:
Target Date (Month/Year): (_
Environmental Management Program: Action Plan
How will this objective be met? (attach additional pages as necessary)
What operational controls might support the achievement of this objective?
How will this objective be tracked? (attach additional pages as necessary)
What resources will be required to achieve this objective? (attach additional
pages as necessary)
Adapted from the EPA/NSF guide "Environmental Management Systems: A Guide for Metal
Finishers" (December 1998). Available for free download at www.nsf-isr.org.
©2001 NSF 121
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Environmental Management Program - Sample Tool
Objective / Target #1
Action Items
Priority
Respon-
sibilities
•
•
Schedule
Resources
Needed
Comments
©2001 NSF
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X
Sample Responsibility Matrix
©2001 NSF 123
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Legend:
L = Lead Role
S = Supporting Role
Responsibility Matrix
Communicate importance of
environmental management
Coordinate auditing efforts
Track / analyze new
regulations (and maintain
library)
Obtain permits and develop
compliance plans
Prepare reports required by
regulations
Coordinate communications
with interested parties
Train employees
Integrate environmental into
recruiting practices
Integrate environmental into
performance appraisal
process
Communicate with
contractors on
environmental expectations
Comply with applicable
regulatory requirements
Conform with organization's
EMS requirements
Maintain equipment /tools
to control environmental
impact
Monitor key processes
Coordinate emergency
response efforts
Identify environmental
aspects of products,
activities, or services
Establish environmental
objectives and targets
Develop budget for
environmental management
Maintain EMS records
(training, etc.)
Coordinate EMS document
control efforts
Plant
M'gr
L
L
L
L
S
L
EHS
M'gr
S
L
L
L
L
S
L
L
S
S
L
S
S
L
HR
M'gr
L
L
L
S
S
S
Maintenance
S
S
S
L
S
Purchasing /
Materials
L
S
S
S
S
Engineering
S
S
S
S
Production
Supervisor(s)
S
S
L
S
S
L
S
S
Finance
S
S
S
L
EMS
Mg't Rep.
S
S
S
L
Employees
S
S
©2001 NSF
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X
Sample Environmental Training Log
©2001 NSF 125
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EMS Training Log (Sample)
Training Topic
EMS Awareness
Supervisor EHS Training
Hazardous Waste
Management
Hazardous Waste
Operations
Spill Prevention &
Response
Chemical Management
Emergency Response
Accident Investigation
Hazardous Materials
Transport
Hazard Communication
Personal Protective
Equipment
Fire Safety
Electrical Safety
Hearing Conservation
Confined Space Entry
Lock-out/Tag-out
Bloodborne Pathogens
Job-Specific Training (list)
Attendees*
Frequency
Course Length
Course
Method
Comments
Date
Completed
Attendees Code
1: All Employees
2: Supervisors / Managers
3: Operators
4: Maintenance
5: Material Handlers
6: Engineering
©2001 NSF
126
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X
Sample Procedure:
Communications with External
Parties
©2001 NSF 127
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EMS PROCEDURE: COMMUNICATIONS
WITH EXTERNAL PARTIES
I. Purpose
This procedure is intended to establish a process for outreach and communication
with external parties regarding the organization's environmental management system
(Note: the organization should also consider external communication regarding its
significant environmental aspects).
II. Scope
This procedure describes how the organization receives, documents, and responds to
communications from external parties. In addition, it discusses proactive steps that
the organization takes to maintain a meaningful dialogue with external parties on
environmental matters.
III. Definitions
Interested Parties- Individuals or groups with an interest in the environmental impacts
of the organization's products, activities or services. These parties include regulators,
local residents, employees, stockholders, insurers, customers, environmental groups
and the general public (adapted from ISO 14001).
IV. General
The organization uses a number of mechanisms to ensure effective communication
with interested parties. These mechanisms include regulatory filings (such as permit
applications and reports), open houses, the media, and informal discussions with
regulators, community representatives, and local business leaders.
To solicit the views of interested parties, the organization may use additional
techniques, including (but not limited to) surveys, community advisory panels,
newsletters, or informal meetings with representatives of external groups.
General rules for external communications require that the information provided by the
organization:
• be understandable and adequately explained to the recipient(s); and
• present an accurate and verifiable picture of the organization and its
environmental management system, its environmental performance, or other
related matters.
©2001 NSF 128
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V. Procedure
A. Management of Communications from External Parties
1. Inquiries and other communications (received by mail, fax, telephone, or in
person) from external parties concerning the organization's EMS or
environmental performance may be received by a number of the
organization's representatives, including the Plant Manager, the
environmental manager, and the human resources manager, among others.
All such communications are reviewed by the Plant Manager or his / her
designee to determine the appropriate response.
2. Communication with representatives of regulatory agencies is delegated to
the organization's environmental manager, who maintains records of all
such communications (both incoming and outgoing). In the absence of the
environmental manager, communications with regulatory officials are
delegated to the human resources manager.
3. Copies of all other written communications on environmental matters are
maintained by the human resources manager. All non-written
communications from external parties are documented using telephone logs
or similar means. All records of external communications are maintained as
discussed in Procedure # (Records Management).
4. A record of the responses to all communications from external parties is
maintained by the human resources manager in files designated for that
purpose.
B. Outreach to Interested Parties
1. The organization solicits the views of interested parties on its environmental
management system, its environmental performance, and other related
matters. In particular, such outreach is conducted when significant changes
at the facility are being considered, such as facility expansion or other
actions that might affect the actual or potential environmental impacts of the
organization's products, activities, or services.
2. As part of the Management Review process, the team designated to
conduct the Review evaluates proactive efforts to communicate with
external parties. Based on this evaluation and other factors, the
organization's management determines the need for outreach with external
parties in the coming year and how such communications can be carried
out most effectively.
External Hazard and Emergency Communication
Note: All external communications regarding emergency response are addressed in
Procedure #.
©2001 NSF 129
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X
Sample Document Index
©2001 NSF 130
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Sample Document Index
(sample indicates individual that revised document, his/her Dosition/deoartment and date(s) of
revision) Revision Number
Document
Environmental Policy
Environmental Manual
Procedure 1 :
Environmental Aspects
Identification
Procedure 2: Access to
Laws and Regulations
Procedure 3: Setting
Objectives & Targets
Procedure 4:
Environmental Training
Procedure 5: External
Communications
Procedure 6: Internal
Communications
Procedure 7: Document
Control
Procedure 8:
Emergency
Preparedness
Procedure 9: Corrective
Action
Procedure 10: Records
Management
Procedure 1 1 : EMS
Audits
Procedure 12:
Management Reviews
Procedures 13-X(list
individually)
EMS Audit Checklist
Other plans &
documents related to
above procedures (list
separately, e.g. SPCC
Plan, Emergency
Response Plan, etc.).
Other forms and
checklists (list)
1
John Smith
Plant Manager
1/1/98
2
John Smith
Plant Manager
1/1/99
3
4
5
6
©2001 NSF
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X
Outline of Sample
EMS Manual and
Other EMS Documents
©2001 NSF 132
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Outline of Sample EMS Manual and Other EMS Documents
Basic EMS Manual
• Index / Revision History / Distribution List
• Environmental Policy
• Description of How Our EMS Addresses Each of the EMS Elements (and linkages
among these elements)
- How We Identify Significant Environmental Aspects
- How We Access and Analyze Legal and Other Requirements
- How We Establish and Maintain Objectives and Targets
- How the Organizational Structure Supports EMS (organization charts, key
responsibilities)
- How We Train our Employees and Ensure Competence
- How We Communicate (internally and externally)
- How We Control EMS Documents
- How We Identify Key Processes and Develop Controls for them
- How We Prepare for and Respond to Emergencies
- How We Monitor Key Characteristics of Operations and Activities
- How We Identify, Investigate and Correct Nonconformance
- etc.
Environmental Management Program Description
• Annual Objectives and Targets
• Action Plans (to achieve objectives and targets)
• Tracking and Measuring Progress
EMS Procedures
• Index / Revision History / Distribution List
• Organization-wide Procedures (for some EMS elements there might be more than
one procedure)
- Environmental Aspects Identification
- Access to Legal and Other Requirements
- Training, Awareness and Competence
- Internal Communication
- External Communication
- Document Control
- Change Management Process(es)
- Management of Suppliers / Vendors
- Emergency Preparedness and Response
- Monitoring and Measurement
- Calibration and Maintenance of Monitoring Equipment
- Compliance Evaluation
- Corrective and Preventive Action
- Records Management
- EMS Auditing
- Management Review
• Procedures /Work Instructions for Specific Operations or Activities
- Waste Management
- Wastewater Treatment (These are examples only)
- Operation of the Paint Line
Other EMS Documentation (Emergency Response Plans, etc.)
©2001 NSF 133
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X
Sample Records Management Form
(supplied courtesy of
General Oil Company)
©2001 NSF 134
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Title: EMS RECORDS MANAGEMENT TABLE
Revision Date: November 7, 2000
Print Date: February 15, 2001 (Uncontrolled document if
printed)
Doc. No.: EMF-4.5.3
Approval by:
Page 135 of 1
EMS Records Management Table
The following table lists records related to the Environmental Management System, in
accordance with EMP-4.5.3 (Record keeping procedure).
Record Type
ADMINISTRATION
Records on costs - purchasing,
operations, and disposal
Utility bills
Record of annual waste quantity
received
Certificates of Insurance
Waste Analysis Sheets
Waste Manifests - outgoing
ENVIRONMENTAL
Incident Reports
Complaint Reports
EMS Communications with external
parties
Decision regarding external
communication of significant
environmental aspects
Major Source Determination Records
Title V Permit Exemption
Correspondence regarding Air Notices
Odor Control System Permit
Air Emission Reports
Records on waste disposal sites used
EMS Monitoring Inspection reports
Person Responsible
Office Manager
Office Manager
Office Manager
Office Manager
Office Manager
Office Manager
Env. Dept.
Env. Dept.
Env. Dept.
Env. Dept.
Env. Dept.
Env. Dept.
Env. Dept.
Env. Dept.
Env. Dept.
Env. Dept.
Env. Dept.
Location
Admin. Office
Admin. Office
Admin. Office
Admin. Office
Admin. Office
Admin. Office
Env. Office
Env. Office
Env. Office
Env. Office
Env. Office
Env. Office
Env. Office
Env. Office
Env. Office
Env. Office
Env. Office
File
Method
Date order
Date order
Date order
Date order
Customer
name
Date order
Date order
Date order
Issue
Date order
Date order
Date order
Date order
Date order
Date order
Site name
Date order
Retention
minimum
3 years
3 years
Life of Co.
Life of
Company
3 years
3 years
3 years
3 years
3 years
3 years
Life of Co.
Life of
Company
5 years
5 years or
per Permit
5 years
Life of Co.
5 years
©2001 NSF
135
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X
Sample Procedure:
Corrective and Preventive Action
(includes tracking log)
©2001 NSF 136
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EMS PROCEDURE: PREVENTIVE AND CORRECTIVE ACTION
I. Purpose
The purpose of this procedure is to establish and outline the process for identifying,
documenting, analyzing, and implementing preventive and corrective actions.
II. Scope
Preventive or corrective actions may be initiated using this procedure for any environmental
problem affecting the organization.
III. General
A. Corrective action is generally a reactive process used to address problems after they
have occurred. Corrective action is initiated using the Corrective Action Notice (CAN)
document as the primary vehicle for communication. Corrective action may be triggered
by a variety of events, including internal audits and management reviews. Other items
that might result in a CAN include neighbor complaints or results of monitoring and
measurement.
B. Preventive action is generally a proactive process intended to prevent potential problems
before they occur or become more severe. Preventive action is initiated using the
Preventive Action Notice (PAN). Preventive action focuses on identifying negative trends
and addressing them before they become significant. Events that might trigger a PAN
include monitoring and measurement, trends analysis, tracking of progress on achieving
objectives and targets, response to emergencies and near misses, and customer or
neighbor complaints, among other events.
C. Preventive and corrective action notices are prepared, managed and tracked using the
preventive and corrective action database.
D. The ISO Management Representative (or designee) is responsible for reviewing issues
affecting the EMS, the application and maintenance of this procedure, and any updates to
EMS documents affected by the preventive and corrective actions.
E. The ISO Management Representative is responsible for logging the PAN or CAN into the
database, and tracking and recording submission of solutions in the database. The
requester and recipient of the CAN or PAN are responsible for verifying the effectiveness
of the solution. The ISO Management Representative is responsible for overall tracking
and reporting on preventive and corrective actions.
F. Personnel receiving PAN's and CAN'S are responsible for instituting the required
corrective or preventive action, reporting completion of the required action to the ISO
Management Representative, and assuring sustained effectiveness.
©2001 NSF 137
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///. General (cont'd.)
G. Completed records of PAN's and CAN'S are maintained in the database for at least two
years after completion of the corrective or preventive action.
IV. Procedure
A. Issuing a CAN or PAN
1. Any employee may request a CAN or PAN. The employee requesting the CAN or
PAN is responsible for bringing the problem to the attention of the ISO Management
Representative. The ISO Management Representative is responsible for
determining whether a CAN or PAN is appropriate and enters the appropriate
information into the corrective and preventive action database. Responsibility for
resolving the problem is assigned to a specific individual ("the recipient").
2. The ISO Management Representative, working with the recipient, determines an
appropriate due date for resolving the CAN or PAN.
B. Determining and Implementing Corrective and Preventive Actions
1. The CAN or PAN is issued to the recipient, who is responsible for investigation and
resolution of the problem. The recipient is also responsible for communicating the
corrective or preventive action taken.
2. If the recipient cannot resolve the problem by the specified due date, he / she is
responsible for determining an acceptable alternate due date with the ISO
Management Representative.
C. Tracking CAN'S and PAN's
1. CAN'S or PAN's whose resolution dates are overdue appear on the Overdue
Solutions report. The ISO Management Representative is responsible for issuing
this report on a weekly basis to the Plant Manager and the recipients of any
overdue CANs or PANs.
2. Records of PANs and CANs are maintained in the database for at least two years
after completion of the corrective or preventive action.
D. Tracking Effectiveness of Solutions
1. The recipient of a CAN or PAN, in conjunction with the requester, are responsible for
verifying the effectiveness of the solution. If the solution is deemed not effective, the
CAN or PAN will be reissued to the original recipient.
©2001 NSF 138
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SAMPLE CORRECTIVE ACTION NOTICE
CAN Number: Issue Date: Solution Due Date:
Name Location Phone:
Requested By:
Issued To:
Problem Statement (completed by ISO Management Representative):
Most Likely Causes (completed by ISO Management Representative):
Implemented Solutions (completed by recipient- include dates as applicable):
Results (confirming effectiveness):
Closed by: Closing Date:
©2001 NSF 139
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CORRECTIVE ACTION TRACKING LOG
CAN
Number
Requested
By
Issued
To
Plan
Due
(Date)
Plan
Completed
(Date)
Corrective
Action
Completed
(Date)
Effectiveness
Verified
(Date)
CAN
Closed
(Date)
©2001 NSF
140
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X
Sample Environmental
Records Organizer
©2001 NSF 141
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Environmental Records Organizer (SAMPLE)
Air Emissions Regulations
Air Emissions Fees
Air Emissions Inventories
Air Emissions Permits
Air Permit Applications
Air Permit(s): Historical
Annual Licenses & Fees
Compliance Reporting
Compliance Plans
Community Right-to-Know
EPCRA Regulations
EPCRA Reporting
Hazardous Waste Regulations
Hazardous Waste Permit/ID Number
Hazardous Waste Fees
Hazardous Waste Biennial Report
Hazardous Waste: Open Manifests
Hazardous Waste: Closed Manifests
Historical Data
Indoor Air Quality
Loss Prevention Information
Other Permits & Permit Applications
Pollution Prevention (P2) Regulations
Pollution Prevention Fees
Pollution Prevention Reporting
Recycling Information
Recycling Projects
Special Wastes
Solid Waste Permit
Solid Waste Fees
Spill Reports
Spill Response Actions
Stormwater Regulations
Stormwater Permit
VOC/HAPs Reporting
VOC Annual Analysis
Wastewater Regulations
Wastewater Fees
Wastewater Permit
Wastewater: Semi-Annual Reporting
©2001 NSF
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X
Sample Procedure: EMS Audits
©2001 NSF 143
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EMS Procedure: Environmental Management System Audits
I. Purpose
To define the process for conducting periodic audits of the environmental management
system (EMS). The procedure defines the process for scheduling, conducting, and
reporting of EMS audits.
II. Scope
This procedure applies to all internal EMS audits conducted at the site.
The scope of EMS audits may cover all activities and processes comprising the EMS or
selected elements thereof.
III. General
Internal EMS audits help to ensure the proper implementation and maintenance of the EMS
by verifying that activities conform with documented procedures and that corrective actions
are undertaken and are effective.
All audits are conducted by trained auditors. Auditor training is defined by Procedure #.
Records of auditor training are maintained in accordance with Procedure #.
When a candidate for EMS auditor is assigned to an audit team, the Lead Auditor will
prepare an evaluation of the candidate auditor's performance following the audit.
The ISO Management Representative is responsible for maintaining EMS audit records,
including a list of trained auditors, auditor training records, audit schedules and protocols,
and audit reports.
EMS audits are scheduled to ensure that all EMS elements and plant functions are audited
at least once each year.
The ISO Management Representative is responsible for notifying EMS auditors of any
upcoming audits a reasonable time prior to the scheduled audit date. Plant areas and
functions subject to the EMS audit will also be notified a reasonable time prior to the audit.
The Lead Auditor is responsible for ensuring that the audit, audit report and any feedback to
the plant areas or functions covered by the audit is completed per the audit schedule.
The ISO Management Representative, in conjunction with the Lead Auditor, is responsible
for ensuring that Corrective Action Notices are prepared for audit findings, as appropriate.
©2001 NSF 144
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IV. Procedure
A. Audit Team Selection - One or more auditors comprise an audit team. When the team
consists of more than one auditor, a Lead Auditor will be designated. The Lead Auditor is
responsible for audit team orientation, coordinating the audit process, and coordinating
the preparation of the audit report.
B. Audit Team Orientation - The Lead Auditor will assure that the team is adequately
prepared to initiate the audit. Pertinent policies, procedures, standards, regulatory
requirements and prior audit reports are made available for review by the audit team.
Each auditor will have appropriate audit training, as defined by Procedure #.
C. Written Audit Plan - The Lead Auditor is responsible for ensuring the preparation of a
written plan for the audit. The Internal EMS Audit Checklist may be used as a guide for
this plan.
D. Prior Notification - The plant areas and / or functions to be audited are to be notified a
reasonable time prior to the audit.
E. Conducting the Audit
1. A pre-audit conference is held with appropriate personnel to review the scope, plan
and schedule for the audit.
2. Auditors are at liberty to modify the audit scope and plan if conditions warrant.
3. Objective evidence is examined to verify conformance to EMS requirements,
including operating procedures. All audit findings must be documented.
4. Specific attention is given to corrective actions for audit findings from previous audits.
5. A post-audit conference is held to present audit findings, clarify any
misunderstandings, and summarize the audit results.
F. Reporting Audit Results
1. The Team Leader prepares the audit report, which summarizes the audit scope,
identifies the audit team, describes sources of evidence used, and summarizes the
audit results.
2. Findings requiring corrective action are entered into the corrective action database.
©2001 NSF 145
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IV. Procedure (cont'd.)
G. Audit Report Distribution
1. The ISO Management Representative is responsible for communicating the audit
results to responsible area and / or functional management. Copies of the audit
report are made available by the ISO Management Representative.
2. The ISO Management Representative is responsible for ensuring availability of audit
reports for purposes of the annual Management review (see Procedure #).
H. Audit Follow-up
1. Management in the affected areas and / or functions is responsible for any follow-up
actions needed as a result of the audit.
2. The ISO Management Representative is responsible for tracking the completion and
effectiveness of corrective actions.
I. Record keeping
1. Audit reports are retained for at least two years from the date of audit completion.
The ISO Management Representative is responsible for maintaining such records.
©2001 NSF 146
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Audit Plan
Area or
Function to be
Audited
Purchasing
•
•
•
•
•
•
Lead
Auditor
• Jim H.
•
•
•
•
•
•
Audit Team
Members
• Linda B.
• Joe S.
•
•
•
•
•
•
Target
Date
• 11/10/00
•
•
•
•
•
•
Special Instructions
- Verify corrective actions
from previous audit
- Interview new employee
in department
•
•
•
•
•
•
©2001 NSF
147
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Sample Communications to Audit Team
ENVIRONMENTAL MANAGEMENT SYSTEM AUDIT
Lead Auditor:
Audit Team Members:
Audit Area:
Target Due Date:
Listed above is the area to be audited. The due date given is the target to have the entire audit
completed, including the report and follow-up meeting with the responsible area management. Listed
below are the areas of environmental management systems criteria that you are to assess. If you
have any questions, please call me. Special instructions, if any, are listed below. Thank you for your
help. Effective audits help make an effective environmental management system.
Policy
Environmental Aspect identification
Environmental Management Program
Training, Awareness, Competence
EMS Documentation
Operational Controls
Monitoring and Measurement
Records
Management Review
Legal and Other Requirements
Objectives and Targets
Structure and Responsibility
Communication
Document Control
Emergency Preparedness
Nonconformance / Corrective Action
Management System Audits
Special Instructions:
ISO Representative (signature)
©2001 NSF
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X
Sample EMS Audit Forms
©2001 NSF 149
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EMS AUDIT SUMMARY SHEET
Organization Audited:,
Lead Auditor:
Date:
ELEMENT NUMBER AND DESCRIPTION
4.2
4.3
Environmental Policy
Planning
AUDIT RESULTS
No. of Majors / No. of Minors
4.3.1 || Environmental Aspects ||
4.3.2
4.3.3
4.3.4
4.4
4.4.1
4.4.2
4.4.3
4.4.4
4.4.5
4.4.6
Legal and Other Requirements
Objectives and Targets
Environmental Management Program(s)
Implementation and Operation
Structure and Responsibility
Training, Awareness, and Competence
Communication
EMS Documentation
Document Control
Operational Control
A, N, orX*
II
«
II
«
4.4.7 || Emergency Preparedness and Response ||
4.5
4.5.1
4.5.2
4.5.3
4.5.4
4.6
Checking and
Corrective Action
Monitoring and Measurement
Corrective and Preventive Action
Records
EMS Audit
Management Review
TOTAL
Legend:
A = Acceptable: Interviews and other objective
evidence indicate that the EMS meets all the
requirements of that section of the standard.
N = Not Acceptable: The auditor has made
the judgment that, based on the number and
type of nonconformances, the requirements
of that the section of the standard are not
being met.
X= Not Audited
©2001 NSF
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EMS AUDIT FINDINGS FORM
Type of Finding (circle one):
Nonconformance: Major Minor Positive Practice Recommendation
Description (include where in the organization the finding was identified):
ISO 14001 (or other EMS criteria)
Reference:
Date:
Finding Number:
Auditor:
Auditee's Rep.
Corrective Action Plan (including time frames):
Preventive Action Taken:
Individual Responsible for Completion of the
Corrective Action:
Date Corrective Action Completed:
Corrective Action Verified By:
Date:
©2001 NSF
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Sample EMS Audit Questions
(by organizational function)
The following questions are excerpted from a
comprehensive list of EMS audit questions contained in
the NSF-ISR project report, "Implementing Environmental
Management Systems in Community-Based
Organizations: Part 2".
For a complete list of EMS audit questions by function,
download Part 2 of the project report from the NSF web
site (www.nsf-isr.org)
©2001 NSF 152
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Function: TOP MANAGEMENT
4.2 Environmental Policy
Top Management
a. Describe your role in the development of the
environmental policy.
b. How do you know that your policy is
appropriate for your activities, products, and
services?
c. What is management's role in the review and
revision of the policy?
d. How does management ensure continued
adherence to the policy throughout the
company?
e. How does the policy help guide organizational
decisions?
f. How are employees made aware of the
environmental policy?
g. How is the policy made available to the public?
[Auditor Note: Is there evidence that the policy was
issued by top management? (e.g., Is the policy signed?
By whom? At what level in the organization are they?)]
Objective Evidence
Notes:
©2001 NSF
153
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Function: TOP MANAGEMENT
4.3.3 Objectives and targets
Top Management
a. What are the environmental objectives and
targets for your organization? What is your role
in approving them?
What are the relevant functions and levels within
your organization that support the attainment
each of the objectives and targets?
b. How are the environmental objectives linked to
other organizational goals (and vice versa)?
c. Are the objectives/targets consistent with the
goals of the environmental policy for prevention
of pollution and continual improvement?
d. How were the objectives and targets developed
by or communicated to management?
e. How does management keep up with progress
in meeting their objectives and targets
throughout the year?
f. How often are you informed of the status of the
objectives and targets?
g. On what basis are the objectives and targets
reviewed and modified?
Objective Evidence
Notes:
©2001 NSF
154
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Function: TOP MANAGEMENT
4.4.1 Structure and responsibility
Top Management
a. At what level within the organization is the
designated EMS representative placed?
Auditor Note: Is the EMS representative at a level within
the organization to effectively implement an EMS for
his/her organization?]
b. What authority does the EMS representative
have to carry out his/her responsibilities?
c. How does the organization assess its resource
needs for environmental management? How
are these factored into operating and strategic
plans (and vice-versa)?
d. What resources (financial, technical personnel)
has management provided to develop or
maintain the EMS?
e. How are you informed on the performance of
the EMS? Do you receive routine reports?
f. Are responsibilities for the environmental
management of the organization documented?
If so, where?
Is an integrated structure in place in which
accountability and responsibility are defined,
understood, and carried out?
g. How are these responsibilities communicated to
all employees (including managers)?
Objective Evidence
Notes:
©2001 NSF
155
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Function: TOP MANAGEMENT
4.4.3 Communication
Top Management
Objective Evidence
a. How are you informed of the environmental
issues within your organization? How often
does this take place? Does this include
compliance issues?
b. How are you kept up to date with progress in
meeting your organization's environmental
objectives and targets?
How is this information passed on to your
managers?
c. How do you communicate with the
organization on environmental issues?
How is this done? How frequently?
d. How does the organization handle inquiries
from interested parties (e.g., the public,
regulators, other organizations) on
environmental matters?
Who has responsibility for responding to such
inquiries?
4.6 Management review
Top Management
a. Describe the organization's management
review process.
b. How often are management reviews
performed? How was this frequency
determined?
c. Who is involved in the management review
process? What are their roles in this process?
d. What changes have been made to the EMS as a
result of the last review?
Objective Evidence
Notes:
©2001 NSF
156
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X
Sample Procedure:
Management Review
©2001 NSF 157
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EMS PROCEDURE: MANAGEMENT REVIEW
I. Purpose
The purpose of this procedure is to document the process and primary agenda of issues to
be included in the Management Review meetings for evaluating the status of the
organization's environmental management system (EMS).
II. Scope
This procedure applies to all Management Review meetings conducted by the organization.
III. General
The Management Review process is intended to provide a forum for discussion and
improvement of the EMS and to provide management with a vehicle for making any
changes to the EMS necessary to achieve the organization's goals.
IV. Procedure
A. The ISO Management Representative is responsible for scheduling and conducting a
minimum of two Management Review meetings during each 12-month period. The ISO
Management Representative is also responsible for ensuring that the necessary data and
other information are collected prior to the meeting.
B. At a minimum, each Management Review meeting will consider the following:
• suitability, adequacy and effectiveness of the environmental policy;
• suitability, adequacy and effectiveness of the environmental objectives (as well as
the organization's current status in achieving these objectives);
• overall suitability, adequacy and effectiveness of the EMS;
• status of corrective and preventive actions;
• results of any EMS audits conducted since the last Management Review meeting;
• suitability, adequacy and effectiveness of training efforts; and,
• results of any action items from the previous Management Review meeting.
C. Minutes of the Management Reviews will be documented and will include, at a minimum
the list of attendees, a summary of key issues discussed and any actions items arising
from the meeting.
D. A copy of the meeting minutes will be distributed to attendees and any individuals
assigned action items. A copy of the meeting minutes will also be retained on file.
©2001 NSF 158
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X
Appendix B:
EPA's National Environmental Performance
Track and Other Government EMS Initiatives
©2001 NSF 159
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National Environmental Performance Track Program
The National Environmental Performance Track is designed to recognize and encourage top
environmental performers - those who go beyond compliance with regulatory requirements
to attain levels of environmental performance and management that benefit people,
communities, and the environment. As top environmental performers, participants earn
access to a unique reward package that includes recognition, better information, and
administrative streamlining.
The Performance Track consists of two levels. The first level, the National Environmental
Achievement Track, is available now and is open to facilities of all types, sizes, and
complexity, public or private, manufacturing or service-oriented. It is designed to recognize
facilities that consistently meet their legal requirements and have implemented high-quality
environmental management systems, as well as encourage them to even better
achievement by continuously improving their environmental performance and informing and
involving the public. The second level, the National Environmental Stewardship Track, is
designed to recognize and encourage broader and higher levels of voluntary environmental
performance than those expected under the Achievement Track. The Stewardship Track is
still under development, and EPA plans to have it available by May 2001.
Any program for improving environmental performance must aim for participation by small
businesses and other small entities, such as local governments. EPA is making every effort
to make the Achievement Track accessible for small entities. This effort is reflected in
several aspects of the design. For example, depending on the nature and extent of a
facility's operations, the EMS for a small facility may be simpler than one for a larger, more
complex facility. For the same reason, a small facility may have fewer environmental
aspects. In addition, a small facility is not asked to make as many performance
commitments as other participants.
Environmental Management System (EMS) Requirements
Facilities wanting to participate in the Performance Track must meet several requirements.
A facility will certify that it has an EMS in place.1 The EMS will include the elements listed
below and will have gone through at least one full cycle of implementation (i.e., planning,
setting performance objectives, EMS program implementation, performance evaluation, and
management review). A facility that has adopted systems based on EMS models with a
Plan-Do-Check-Act framework would meet most of these elements.
EPA recognizes that the scope and level of formality of the EMS will vary, depending on the
nature, size, and complexity of the facility. EPA's experience with a variety of programs
suggests that these EMS elements are within the capability of small facilities and can be met
through a variety of approaches. To help small facilities implement an EMS, EPA will make
guidance documents and assistance materials available.
A facility will certify that it has implemented an EMS that includes these elements:
1 For purposes of the Achievement Track, an EMS represents an organization's systematic
efforts to meet its environmental requirements, including maintaining compliance and
achieving performance objectives that may be related to unregulated aspects of the
organization's activities.
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Policy
A written environmental policy, defined by top facility management, that includes
commitments to: (1) compliance with both legal requirements and voluntary
commitments; (2) pollution prevention (based on a pollution prevention hierarchy
where source reduction is the first choice); (3) continuous improvement in
environmental performance, including areas not subject to regulations; and (4)
sharing information about environmental performance and the operation of the EMS
with the community.
Planning
• Identification of significant environmental aspects2 and legal requirements, including
procedures for integrating anticipated changes to the facility's requirements or
commitments into the EMS.
• Measurable objectives and targets to meet policy commitments and legal
requirements, to reduce the facility's significant environmental impacts, and to
meet the performance commitments made as part of the facility's participation in
the program. In setting objectives and targets, the facility should consider the
following criteria: preventing non-compliance, preventing pollution at its source,
minimizing cross-media pollutant transfers, and improving environmental
performance.
• Active, documented programs to achieve the objectives, targets, and
commitments in the EMS, including the means and time-frames for their
completion
Implementation and Operation
• Established roles and responsibilities for meeting objectives and targets of the
overall EMS and compliance with legal requirements, including a top
management representative with authority and responsibility for the EMS.
• Defined procedures for: (1) achieving and maintaining compliance and meeting
performance objectives; (2) communicating relevant information regarding the
EMS, including the facility's environmental performance, throughout the
organization; (3) providing appropriate incentives for personnel to meet the EMS
requirements; and (4) document control, including where documents related to
the EMS will be located and who will maintain them.
• General environmental training programs for all employees, and specific training
2 An "environmental aspect" is defined as an "element of an organization's activities,
products, or services that can interact with the environment." Facilities are asked to use their
list of significant environmental aspects in selecting performance commitments under this
program.
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for those whose jobs and responsibilities involve activities directly related to
achieving objectives and targets and to compliance with legal requirements.
• Documentation of the key EMS elements, including the environmental policy,
significant environmental aspects, objectives and targets, a top management
representative, compliance audit program, EMS audit program, and overall EMS
authority.
• Operation and maintenance programs for equipment and for other operations
that are related to legal compliance and other significant environmental aspects.
• An emergency preparedness program.
Checking and Corrective Action
• An active program for assessing performance and preventing and detecting non-
conformance with legal and other requirements of the EMS, including an
established compliance audit program and an EMS audit program.
• An active program for prompt, corrective action of any non-conformance with
legal requirements and other EMS requirements.
Management Review
• Documented management review of performance against the established
objectives and targets and the effectiveness of the EMS in meeting policy
commitments.
Although a third-party audit of the EMS is not necessary to qualify for the Achievement
Track, a facility is asked in the application form if it has undergone such an audit. If it has
not, it will have conducted a self-assessment. A facility will retain EMS documentation and
provide a summary of its performance, including performance against objectives and
targets, and a summary of the results of compliance and EMS audits, in its Annual
Performance Report.
For more information about the National Environmental Performance Track, contact the EPA
via:
Web: www.epa.gov/performance track
E-Mail: ptrack@indecon.com
Phone: 888-339-PTRK
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The Multi-State Working Group on Environmental Management
Systems Overview of Organizational and State Activities
MSWG is an organization that convenes government, non-government, business and
academic interests to conduct research, promote dialogue, create networks and establish
partnerships that improve the state of the environment, economy and community through
systems-based public and private policy innovation. Its quarterly meetings move around the
US to accommodate participation. Meetings are open; everyone is welcome. All have a right
to speak. Decisions are by consensus. The Council of State Governments (CSG) handles
administration and to accommodate gifts has 501(c)(3) status. Voluntary dues support
MSWG. NGOs do not pay dues. New members are welcome, especially businesses and
NGOs. All 50 states are enrolled in MSWG and linked by e-mail. About 25 states regularly
participate at quarterly meetings and 30-40 states attend the annual meeting and workshop.
Check www.mswg.org for information.
What activities does MSWG sponsor?
• Pilot projects: In partnership with the U.S. EPA, the Environmental Law Institute, and
University of North Carolina-Chapel Hill, MSWG states sponsor about 75 EMS pilot
projects that produce data for a national database project funded by the EPA's Office of
Water. The purpose of the pilots is to evaluate the ability of environmental management
systems to improve the environment. Information is at: www.eli.org/isopilots.htm
• EMS Research: MSWG held six EMS research roundtables at major universities that led
to a Research Summit, held in 1999 at The Brookings Institution in cooperation with
CSG and the National Academy of Public Administration. The Summit produced an EMS
research agenda. Summit papers are included in a textbook, edited by Harvard
University and the Massachusetts Institute of Technology, published in 2001 by
Resources for the Future. Plans are being made for a second summit.
• EMS Policy Academy: Wth funding from The Joyce Foundation to CSG and support of
business, MSWG has a design team of business, government, academic and NGO
appointees preparing recommendations fora national EMS Policy Academy. The
"virtual" Academy will focus on learning about public policy EMSs, not those within the
confines of a private organization and will complement and not compete with existing
services. Public policy EMSs have designed to have credibility with business,
government, NGO, consumer and enlightened shareholder interests.
• Workshops: Each June or July, MSWG sponsors, with support from EPA and
businesses, an annual EMS workshop. It is a "hands-on" event that hosts EMS
practitioners from the US and abroad. It has grown from 75 participants in Gary, NC
1998 to nearly 300 in San Diego, CA in 1999.
• Networking: MSWG provides a networking function between states and EMS support
functions, especially those focused on EMSs that fit into a public policy strategy.
Technical assistance centers in Florida, Georgia, Iowa, Kentucky, Massachusetts and
South Carolina help MSWG participants.
• Other activities: MSWG members contribute to numerous public policy-related
environmental initiatives and discussions including EPA's Performance Track, ISO
14001 revisions; Environmental Council of States forums; Global Environmental
Management Initiative meetings; professional and trade association programs and
Commission for Environmental Cooperation.
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MSWG is state-driven. Several states sponsor EMS pilot projects and contribute data to the
UNC-ELI database. They are: AZ, CA, IL, IN, NC, NH, OR, PA VT and Wl. These states
have or are developing public-policy-related EMS policies, programs, internal EMSs or
environmental laws that recognize EMSs: AZ, CA, CT, FL, IA, IL, IN, LA, MA, ME, MN, NC,
NH, OH, OR, PA, SC, TX, VA, WA, VT and Wl. Contact Marci Carter, carterm@uni.edu for
state contact information or questions. Many MSWG states participate in EPA's performance
track program, whose businesses use EMSs for public policy purposes.
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Implementing Environmental Management Systems
In Government Entities
Fourteen government entities were selected from an applicant pool of 50 to participate in a
pilot project designed to assist public-sector organizations develop and implement an
environmental management system (EMS) based on the ISO 14001 protocol. The U.S.
Environmental Protection Agency's (U.S. EPA) Office of Water, Office of Compliance, and
Office of Air and Radiation, including Regions I and IX, jointly sponsor this initiative which
runs from April 2000 to January 2002.
Each participating organization has selected a facility/organization ("fenceline") in which to
implement the EMS, as noted below.
Public Entity
City of Berkeley, CA
City of San Diego, CA
City of Detroit, Ml
Florida Gulf Coast University - Fort Myers, FL
Port of Houston, TX
Jefferson County, AL
Little Blue Valley Sewer District - Independence, MO
Louisville and Jefferson County Metropolitan Sewer
District Louisville, KY
Wisconsin Department of Natural Resources -
Madison, Wl
Tri-County Metropolitan Transportation District
Portland, OR
King County Solid Waste Division - Seattle, WA
Massachusetts Department of Environmental
Protection Lawrence, MA
University of Massachusetts - Lowell, MA
New Hampshire Department of Transportation
Concord, NH
Fenceline
Solid Waste Management Division
Refuse Disposal Division
Department of Recreation & Public
Lighting
Solid Waste Activities and Services
Container Terminal and the Central
Maintenance Department
General Services Department
Wastewater Treatment Facility
All operations
Wastewater Treatment Facility and
Purchasing Department
Air Management Bureau
Maintenance Facilities
Entire Division - Eight Transfer Stations &
one Regional Landfill
Wall Experiment Station
Analytical Laboratory
Olney Science Building - Laboratory
Bureau of Traffic
In 1997, U.S. EPA sponsored the first two-year EMS project for nine local governments.
Participants experienced compelling environmental and economic benefits over the two-year
project period:
• Improved Environmental Awareness - "There's a much better understanding of
environmental issues in every department of the fenceline, not just in the environmental
department. We are recognizing simple internal "housekeeping" measures that are
having a positive effect on our environmental performance. We have self-imposed
additional requirements to help prevent pollution, reduce energy use, manage our
contractors, and expand environmental education for our citizens. Employees are
bringing ideas for reducing our waste streams, for less toxic products. There has been a
definite improvement in involvement and morale."
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• Improved Efficiency - "Systematically analyzing compliance issues revealed an
opportunity for cost savings. Fifteen departments were responsible for obtaining their
own air quality permits - 23 altogether. The implementation team consolidated these
permits into eight, saving the city $16,000 per year."
• A Positive Effect on Environmental Compliance and Performance - "With regards to
environmental compliance, we have a better understanding of our legal requirements.
We have better-trained employees whose competence in their work area is critical to the
environment. We expect that our EMS efforts will increase our ability to stay in
compliance."
For case study information, see the final report atwww.getf.org/projects/muni.cfm.
THE SECOND GOVERNMENT EMS INITIATIVE
Due to the overwhelming success of the first program and local governments' growing
interest in EMSs, U.S. EPA decided to conduct a second EMS initiative to gather additional
data about the value of EMS tools in government organizations. The Global Environment &
Technology Foundation (GETF) was again selected to lead the effort, providing in-depth
training, coaching and on-site technical assistance to help participants design and
implement their EMS's.
Jim Home, the National Project Manager, from U.S. EPA's Office of Water said,
"The U.S. EPA team was extremely gratified by the level of interest shown by local
governments for this second initiative and the level of sophistication of the applications. It is
clear that public-sector organizations are rapidly becoming aware of the value of
implementing EMS's and the value of working with U.S. EPA. We are delighted with the
diverse range of organizations that were selected and expect great things from each of
them."
During the two-year project, participants attend five comprehensive workshops. At each they
receive training, materials, and technical assistance to help them accomplish EMS
milestones in each of the four implementation phases.
The Houston Port Authority, TX had the following to say about the project:
"This will be an interesting two-year process, learning with and from other organizations who
share our interest in protecting the environment while providing public services. We plan to
convey all that we learn to our tenants, the city and county, and other port authorities so that
we can all do a better job as stewards of the environment."
For more information on the Local Government EMS Initiative, please contact Craig Ruberti
(cruberti@getf.org) at 703-750-6401, Faith Leavitt (fleavitt@earthvision.net) at 941-489-
1647, or Jim Home (horne.james@epa.gov) at 202-260-5802 or visit the project web site
(http://www.getf.org/projects/muni.cfm) for regular updates on the project.
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NEIC Compliance-Focused Environmental Management System
Since the late 1980s, civil multimedia compliance investigations conducted by the EPA
National Enforcement Investigations Center (NEIC) have increasingly involved identifying
causes of observed noncompliance. In a significant number of cases, the causes arise from
inadequate environmental management systems (EMSs). NEIC, in response, developed
key elements for a compliance-focused EMS (CFEMS) model, which have been used as the
basis for EMS requirements in several settlement agreements. The CFEMS, which includes
a guide for using it in settlement agreements, was published in August 1997 and revised in
January 2000.3
The CFEMS elements are as follows:
1. Environmental Policy
2. Organization, Personnel, and
Oversight of EMS
3. Responsibility and Accountability
4. Environmental Requirements
5. Assessment, Prevention and Control
6. Environmental Incident and
Noncompliance Investigations
7. Environmental Training, Awareness,
and Competence
8.
Environmental Planning and
Organizational Decision-Making
Maintenance of Records and
Documentation
Pollution Prevention Program
Continuing Program Evaluation and
Improvement
12. Public Involvement/Community
Outreach
9.
10
11
To achieve maximum benefit from the CFEMS elements, the overall EMS in which they are
incorporated should embody the "plan, do, check, and act" model for continuous
improvement. Consequently, the compliance-focused EMS model described here is
intended to supplement, not replace, EMS models developed by voluntary consensus
standards bodies, such as the ISO 14001 EMS standard developed by the International
Organization for Standardization.
Settlement agreements that require an EMS typically include a requirement that the
organization conduct an initial review of its current EMS, followed by development of a
comprehensive CFEMS that must be documented in a manual. The EMS manual must
contain policies, procedures, and standards for the 12 key elements, at a minimum, and
should also identify other, more detailed procedures and processes (e.g., inspections and
self-monitoring) that may be located elsewhere at the facility. After the organization has
had sufficient time to implement and refine the EMS (usually 2 to 3 years), the agreement
should require at least one EMS audit by an independent third-party auditor, with results
reported to both the organization and EPA. However, additional audits may be required, as
individual circumstances dictate
3The document is available on NEIC's website.
http://es.epa.gov/oeca/oceft/neic/12elmenr.pdf
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The intended result of this approach is twofold: first, to have the organization develop an
EMS that will both improve its compliance with applicable environmental requirements and,
second, to improve its environmental performance by achieving the organization's
environmental targets and objectives.
The January 2000 revision involved enhancing several of the elements and more completely
incorporating the due diligence provisions of the EPA audit policy. Refinement continues
through settlement negotiations, and discussions with EPA staff, EMS consultants, and
environmental personnel from several companies with medium-size and large facilities.
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Appendix C:
Information on Process Mapping and Design
for Environment
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Introduction to Process Mapping
Organizations operate using a collection of processes. A process can be defined as a
method of doing something, generally involving a number of steps or actions. An EMS is
one example of linked organizational processes that are directed at a specific purpose.
Most organizations employ a variety of processes to carry out their core functions, such as
manufacturing a product or providing a service.
A process typically has four components. Two of these are inputs (the items to which action
is done) outputs (the results of those actions). In addition, a process has controls (which
direct the action) and mechanisms (which are the resources that actually perform the
action). Mechanisms can be people or machines that change the inputs to the outputs.
Other concepts that are important to process mapping are process boundaries (which define
the limits of a particular process from its larger environment), suppliers (who provide the
process inputs) and customers (whoever receives the output of the process).
Process mapping is a tool that allows an organization to visualize and understand how work
gets accomplished and how its work processes can be improved. It is a simple but powerful
tool through which an organization can focus its efforts where they matter most and
eliminate process inefficiencies. Used properly, process mapping can help an organization
understand its environmental aspects and reduce wastes and pollution. It also can help an
organization to reduce operating costs by identifying and eliminating unnecessary activities.
As an EMS tool, process mapping can help an organization to:
• improve its understanding of existing processes, including the key inputs
(such as chemicals, raw materials and other resources used), outputs (including
products, wastes, air emissions, etc.) and interactions with other processes.
• identify areas for process improvement that can result in environmental
performance improvements (such as pollution prevention opportunities)
Over time, processes are often modified many times in seemingly small ways. Over time,
these process modifications can result in a process that is ineffective. This is one of the
bases for the concept of "re-engineering" which seeks to examine processes in a holistic
manner to ensure they are effective and necessary to achieve an organization's mission.
Getting Started on Process Mapping
• Select a process (or set of related processes) to examine. Processes might be
prioritized for review based on a number of criteria, such as relevance or importance to
the organization, prior assessments of the process, existing knowledge of the
environmental significance of the process, or history of problems with the process,
among others. Define the process boundaries.
• Use a team to understand and map how these existing process(es) work. At a
minimum, the team should include the process "owner" as well as individuals that are
actively involved in carrying out the process. Many organizations use a facilitator that is
independent of the process under review to manage team meetings. Don't be surprised
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if a diversity of opinions exists among team member exist regarding how the existing
process works.
• Clarify the objectives of the process under review. Each process should have a
primary customer and a primary performer, although additional (secondary) customers
and performers also might exist.
• As a team, determine the level of detail needed to accurately map your processes.
Initially, you might map at a fairly high level, then get into more detail as improvement
opportunities as identified.
• Decide on a set of symbols that the team will use to visually describe the process. For
example, use one symbol for work steps, another symbol for process inputs, a third
symbol for process outputs, a fourth symbol for decision points, a fifth symbol for
measurement points, etc.
• Identify the key steps (or "unit operations") in the process first, then go back and
analyze each of these steps in more detail. Use lines or arrows to show the
relationships among individual process steps. Use brainstorming and/or storyboarding
techniques to identify the process steps, then agree upon the sequence of these steps.
• Start with the preparation of an "as is" map that describes how the process works
now, including key process inputs to and outputs. For environmental purposes, key
inputs might include energy and other resources consumed, and raw materials and
chemicals used. Outputs might include products or services, air emissions, wastewater
discharges, solid and hazardous wastes. This "as is" map can be analyzed to identify
environmental aspects and key opportunities for improvement.
• Some processes can be extremely complex and might consist of numerous sub-
processes. If the team gets bogged down, it might examine and map some of the key
sub-processes first, rather than trying to tackle the entire process at once. As a rule of
thumb: If the process is so complex that it cannot be shown on a single page, then it
might be a good candidate for re-engineering.
• Depending on the purpose of the process mapping exercise, the analysis of the "as is"
map can lead to the preparation of a modified map that defines how the re-engineered
process is intended to function.
• A variety of tools and materials can be used to prepare process maps. For example, a
number of commercial software packages exist. However, you can also employ simpler
methods, such as self-sticking removable ("Post-It") note pads. These are particularly
useful for moving individual process steps around on a board.
A sample process map for a printing operation is shown at the end of this section.
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Conclusion
Process mapping can provide a solid foundation for understanding and continually
improving an organization's processes.
Viewing processes graphically helps an organization to see things that otherwise might not
be apparent. Once a process map has been prepared, it can be used as training tools as
well as for internal and external communications.
Process mapping has several important benefits for an EMS. First, it allows an organization
to understand its current environmental aspects and impacts as well as the specific
operations and activities from which they arise. Second, it provides a basis for enhancing
an organization's processes in a manner that can improve both environmental and financial
performance.
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Sample Process Map for Printing Operation
Packaging
- skids & pallets
kraft wraps
PRODUCTS
brochures
catalogs
art prints
annuals
waste paper
recycled |
fugitive air
emissions
3
[ atmosphere |
Supplies
- spray powder
- shop towels
Raw
Materials
- plates
- paper & ink
- water
; Chemicals
- cleaning
solvents
ink preservers
plate gums
PRINTING PRESS
web dryer
emissions
thermal
oxidizer
atmosphere
waste ink
waste solvents
waste solutions
waste plates
waste packaging
waste oil & antifreeze
recycled~|
fuel blencT|
recycled~|
sewer ~|
recycled~|
recycled~|
trash
recycled |
1
r
spun shop
towels
secondary use in
parts washers
commercial laundry
recycled back to company
sewer
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Information on Design for Environment
Every product or service has some impact on the environment. Such impacts can occur at
many stages of the product or service's life cycle, from raw material acquisition to ultimate
disposal or reuse. Just as the quality and performance characteristics of a product are
significantly affected by decisions made at the development stage, so are the product's
environment attributes. Consideration of potential environmental impacts throughout the
product or service development process can improve both environmental and financial
performance. By looking at each stage of a product or service life cycle, an organization
can better understand and control the potential environmental impacts.
Design for Environment (DFE) is based on techniques for integrating environmental
considerations into an organization's decisions concerning its products and services, as well
as manner in which these products and services are generated. In involves an
understanding of materials flows (and the environmental effects of such material flows) as
well as the comparison of alternative approaches to producing a product or service.
DFE is grounded in the use of life cycle assessment to evaluate the full range of impacts
associated with a product or service. Such life cycle assessments allow an organization to
evaluate potential environmental impacts and identify opportunities to make improvements.
DFE is based on an assessment of the performance, costs and risks associated with
alternatives. The technique seeks to encourage front-end innovation through product or
service redesign, rather than reliance on "end of pipe" controls in order to manage risks to
the environment. As such, use of the technique might result in redesign of a product
formulation, a manufacturing process, or a management practice, among other possibilities.
In general, the earlier that environmental considerations are taken into account in the
product or service development process, the more effective the results will be with respect to
environmental performance. Organizations can use an approach that includes:
• Evaluating information on the environmental attributes of a product or service,
• Designing specific measures to reduce associated environmental impacts.
• Testing alternatives that seek to reduce impacts, while considering other importance
product characteristics (such as quality and performance), and
• Applying the resulting "lessons learned" to subsequent product or service
development.
While it might be simpler to implement DFE practices on new products or services, an
organization also might find opportunities to apply DFE in their existing products or services.
In conducting such evaluations, an organization could consider a number of goals, such as:
Minimizing the use of toxic materials
Minimizing compliance costs
Avoiding chemicals that are banned or
restricted by customers / other parties
Minimizing packaging
• Minimizing energy use
• Minimizing use of water, other resources
Maximizing reuse potential
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A product or service's environmental impacts are largely based on the inputs used to make
the product (or provide the service) and the outputs generated at various stages of its life
cycle. An organization can start to apply DFE concepts by using a simple matrix to assess
the environmental impacts associated with a product, such as shown below (1).
Potential Environmental Issues
Product Life
Cycle Stages
Premanufacture
(Product design)
Product
Manufacturing
Product
Packaging &
Delivery
Product
Use
Product Disposal
or Reuse
Material
Selection
Energy
Use
Air
Emissions
Water
Discharges
Solid
Wastes
For many organizations, the effective application of DFE concepts involves working closely
with their suppliers and customers. Effective communications with supply chain partners
can be critical in ensuring that an organization's products or services satisfy all their
performance needs (i.e., performance, durability, environmental, safety, cost, etc.)
More information on DFE can be obtained from a variety of sources (see Appendix F for
additional information sources). In particular, organizations can access information on DFE
tools and projects on EPA's DFE web site at www.epa.gov/opptintr/dfe.
(1) Adapted from "Best Current Practices: Design for Environment", Lucent Technologies,
February 1997.
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US. EM
Integrated Environmental Management Systems
What is EPA's DIE Program?
EPA's Design for the Environment Program partners with stakeholders to help businesses
help the environment. DfE projects help businesses design products, processes, and
management systems that are cost-effective, cleaner, and safer for workers and the public.
The DfE goals are to
*• Encourage businesses to incorporate environmental information into their decision
criteria, and
*• Effect behavior change to facilitate continuous environmental improvement.
To accomplish these goals DfE and its partners use several approaches including cleaner
technology and life-cycle assessments, environmental management systems (EMS),
formulation improvement, best practices, and green supply chain initiatives.
To date, the DfE Program has brought environmental leadership to over 2 million workers at
over 170,000 facilities. Small- and medium-sized businesses recognize DfE as a unique
source of reliable environmental (as well as performance and cost) information.
DIE'S Approach to EMSs
EPA's Design for the Environment (DfE) Program has developed an enhanced EMS
approach called Integrated Environmental Management Systems (IEMS) to help companies
achieve continuous environmental improvement. I EMSs emphasize reducing risk to
humans and the environment, pollution prevention, and wise resource management. DfE's
IEMS combines continuous improvement principles and tools with proven environmental
assessment methodologies.
Key IEMS components that might not be included in traditional EMSs are
* Paying close attention to process and material flows,
* Obtaining knowledge of chemicals used and their hazards and exposures,
* Conducting substitutes assessments that can include full-cost accounting, and
* Considering and selecting cleaner technologies.
I EMSs assist companies in making sound environmental decisions as part of daily business
practices. As a result, I EMSs help companies to
* Reduce cross-media impacts and Use energy and other resources efficiently,
* Better manage the risk associated with using hazardous chemicals (both regulated
and unregulated),
* Practice extended product and process responsibility, and
* Integrate environmental and worker safety and health requirements.
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DfE's I EMS approach was piloted with several small and large screen printing companies
and the Screenprinting & Graphic Imaging Association International. The pilots
demonstrated that both small and large companies can develop and implement
sophisticated, action-oriented lEMSs. Several of the pilot companies are applying for ISO
14001 certification.
What IEMS Materials Are Available?
To help organizations create and document their own lEMSs, DfE has developed an IEMS
Implementation Guide (EPA 744-R-00-011), an IEMS Company Manual Template (EPA
744-R-00-012), and a website. The Implementation Guide walks an organization through
the steps of developing an IEMS. It provides simple, thorough directions that are clear even
to those unfamiliar with environmental management planning. The Guide includes
worksheets, examples, and step-by-step guidance on process mapping, environmental
policy development, risk assessment, and evaluating cleaner alternatives.
IEMS information and materials may be obtained by visiting the DfE website at
www.epa.gov/dfe or by contacting EPA's Pollution Prevention Information Clearinghouse via
email (ppic@epa.gov) or phone (202-260-1023).
Possible IEMS Roles for Lead Organizations, Associations, Technical Assistance
Providers, and Large Companies
A lead organization such as an association, a technical assistance provider, or a large
company can greatly facilitate development of lEMSs among its members, clients, or small
suppliers. DfE's IEMS experience shows that the IEMS development process can be much
more cost- and time-efficient and more fun if a lead organization takes on common
activities, such as developing a basic process map or providing group training, that each
company would otherwise do separately. Some additional ways in which a lead
organization could help companies with lEMSs include
* Adapt the IEMS Implementation Guide and other tools to reflect a given industry
sector's unique conditions,
* Organize and lead participating companies to develop an IEMS,
* Develop sector-specific pollution prevention and regulatory information,
* Help establish environmental improvement targets and evaluate results, and
* Recognize or certify companies that participate and demonstrate results.
Opportunities For IEMS Partnerships With DfE. If you are interested in becoming an
IEMS partner and in leading IEMS efforts for an industry group or supply chain call DfE at
202-260-1678.
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Appendix D:
Registration of Environmental
Management Systems
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Registration of Environmental Management Systems
1st Party Audit
Internal Audit
2nd Party Audit
Customer audit of a
supplier
3rd Party Audit
Audit by another party
independent of a
supplier and its
customer
Registration
vs.
Certification
Both terms refer to
describe the third-
party audit process.
Technically speaking,
"registration" applies
to management
systems, while
"certification" applies
to products.
However, in common
usage, they are
synonymous.
Scope of
Registration....
..is the activities and
organizations that are
included within the
EMS.
The scope should be
discussed with your
registrar before
Stage 1.
EMS registration in this appendix refers to the process
whereby a non-biased third-party attests that an
organization's EMS conforms with the requirements of the
ISO 14001 Standard. ISO 14001 was written to describe the
requirements for registration/self declaration and is the only
one of the ISO series of environmental standards (such as
environmental labeling or environmental performance
evaluation) to which an organization may register. The third-
party organization that performs the registration services is
called the "registrar," and is selected by the organization that
desires registration services.
An accredited registrar is one whose competence is
evaluated by an independent third-party. Each country of the
world has its own accreditation body established either
nationally or by their government. In the United States, the
accrediting body for both ISO 9000 and ISO 14001 is the
American National Standards Institute/Registrar
Accreditation Board (ANSI/RAB). ANSI/RAB has
established criteria which registrars must meet in order to
achieve accreditation. Accreditation is not a legal
requirement. However, accreditation provides organizations
assurance that their registrar has met ANSI/RAB
requirements for things such as impartiality, confidentiality, a
documented registration system, quality assurance, and
policies to handle complaints and appeals.
The Registration Process
ANSI/RAB has established a two-stage registration approach
for accredited registrars. Registrars may have different
registration processes but must follow the basic two stage
process:
Stage 1 Planning for the Audit
The purpose of Stage 1 is to determine the organization's
preparedness for the registration audit. This stage includes a
document review as well as on-site visit. A review of the EMS
in light of the possible significant environmental aspects is a
primary objective of Stage 1.
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Stage 2: Evaluating Implementation
What does registration
really mean?
Registration to ISO 14001
does not mean that your
organization is a "green"
facility, is environmentally
friendly or that you have
demonstrated superior
environmental
performance.
It means that your
organization can claim it
has a documented EMS
that is fully implemented
and consistently followed.
Major Nonconformance
occurs when
One or more of the
numbered requirements
of ISO 14001 have not
been addressed and/or;
One or more of the
numbered requirements
of ISO 14001 have not
been implemented
and/or;
Several
nonconformances taken
together lead a
reasonable auditor to
conclude that one or
more of the numbered
requirements of ISO
14001 have not been
addressed or
implemented
Stage 2 always takes place at the organization's location.
An audit team conducts an on-site audit to evaluate and
verify through objective evidence (interviews, procedures,
records, etc.) that the EMS conforms to the requirements in
the ISO 14001 Standard and is implemented and maintained.
Once you achieve registration, regular surveillance audits by
the registrar are required by ANSI/RAB. These may be
conducted once per year (with a re-audit after three years) or
at least twice per year with all 17 elements audited in a three
year period.
To what do you conform?
The answer may surprise you. Naturally you have to conform
to ISO 14001 Standard requirements but you also have to
conform to:
• Your own organization's policies and procedures: The
EMS an organization designs often goes above and
beyond ISO 14001 requirements. Did your environmental
policy say your organization would promote sustainable
development? Be an environmental leader? Continually
improve environmental performance? During a
registration audit, your policies and procedures become
criteria to which you will be audited.
• The policies and procedures of the registrar: You will not
be audited to the registrar's policies and procedures but
they will include your responsibilities (such as timeframes
for corrective actions) and rights within the registration
process (such as auditor approval), and processes you
should be aware of (such as confidentiality and dispute
resolution).
Why Register?
The ISO 14001 Standard does not require third-party
registration. However, for some industries such as
automotive, a registered EMS is a mandated requirement for
thousands of suppliers to the major auto makers. In addition,
organizations that sell their goods or services internationally
may find that EMS registration is a strong selling point in the
global marketplace and may enable them to obtain preferred
supplier status.
Where registration is not a direct market driver, organizations
may pursue registration for many reasons including:
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"Sufficient data on an
organization's
compliance with
relevant legislation
and regulations,
gathered during the
registration review
and surveillance, are
relevant and
necessary to
determine whether or
the organization's
systems conform to
the standard."
-ANSI/RAB Criteria for
Bodies Operating
Registration of
Environmental
Management Systems
(E3.2)
"...while compliance is
part of the
management system,
the registration audit
is not an audit of full
compliance with all
applicable regulatory
requirements."
- ANSI/RAB Criteria
for Bodies Operating
Registration of
Environmental
Management Systems
(E3.2).
• Maintenance of current market position;
• Opportunities for a competitive advantage;
• Help ensure regulatory compliance;
• Improve relationships with regulators and/or the
surrounding community; and
• Support state and Federal regulatory incentive programs.
There are also important but often unrecognized internal
benefits to registration. Registration is a way to protect the
investment your organization has made in your EMS.
Knowing that you will be audited regularly by an outside party
helps to keep management's attention on the EMS and
ensure that it has the resources it needs to improve over
time.
Registration and Compliance
A registration audit is not a compliance audit. Difference in
the two types of audits are highlighted in Table 1. An EMS
auditor will not perform a detailed compliance inspection but
the will gather data on how your organization manages its
compliance program. Pertinent questions may include; How
do you stay informed of new requirements? How are these
communicated to employees? How do you evaluate
compliance with regulations? What process do you have for
resolving any noncompliances identified?
Occasionally, an EMS auditor may identify a regulatory
noncompliance during the registration audit. Does this mean
you automatically fail the audit? No, it does not. The registrar
must verify that the EMS is set up to handle noncompliances
and that taken together, the noncompliances do not indicate
a major nonconformance.
Accredited registrars are required to have a method for
handling and reporting regulatory noncompliance identified
during a registration audit. Ask your registrar for their policy
or procedure for handling this situation.
Table 1. Difference between EMS and Compliance Audits
EMS Audit
• Focus is on systems
• Information gathered
largely through interviews
and document review
• Corrective action involves
individuals outside of the
environmental staff
Compliance Audit
• Focus is on details of
regulations
• Observation of activities
is important
• Corrective actions
involve only
environmental staff
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Appendix E:
Integration of Environmental Management
Systems and Quality Management Systems
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Integration of Management Systems
Integrating management systems has become an increasingly important competitive issue. A
growing body of information indicates that organizations that integrate their EMS and quality
management systems (QMS) can realize significant benefits, such as streamlined operations and
decision-making, simplified employee training, more efficient of resources and reduction in audit
costs. Systems for managing health & safety and other organizational functions can be similarly
integrated.
The two most common models for QMS and EMS (ISO 9001 and ISO 14001, respectively) share
many common elements. This should be no great surprise, since ISO 9001 was one of the source
documents used by the drafters of ISO 14001. The two standards are very compatible in their
current forms. The ISO committees responsible for the development and maintenance of these two
standards continue to examine potential opportunities to increase the compatibility or alignment of
the two standards.
Organizations that choose to implement both of these standards generally find that they can use
many common processes to conform. In general, the elements of a QMS and an EMS can be
categorized as either (1) essentially the same, (2) similar or (3) unique (see table below). System
elements in both the "essentially the same" and "similar" categories can often be addressed by a
common procedure (or parallel procedures), although some customization may be needed to
address the differing overall purposes of these systems. Unique elements are typically dealt with in
separate (EMS or QMS) procedures. Some of the typical elements for integration include:
document control, corrective/preventive action, training, records management and management
review. However, some organizations have gone much further - for example, some have
developed common (quality and environmental) policies. The degree of system integration varies
widely from organization to organization.
While an EMS can be readily integrated with an existing QMS, the overall purposes of these two
systems must be kept in mind. A QMS is intended primarily to ensure that an organization satisfies
its customers by assuring the quality of its products. An EMS generally has a broader context - the
relationship between an organization and the environment in which it operates. Also, an EMS often
concerns itself with a broader range of stakeholders, such as neighboring communities, customers
and regulatory agencies.
System integration can have environmental benefits. By linking environmental management more
closely with day-to-day planning and operation, some organizations have been able to raise the
visibility of environmental management as a core organizational issue. In addition, these
organizations enhance their abilities to address environmental issues when making modifications to
products or processes for quality purposes.
Organizations that have a QMS in place generally are better off when implementing an EMS for
several reasons. First, employees typically are already familiar with management system concepts
and are involved in making the system work. Second, many of the processes needed for the EMS
might already be in place. Finally (and perhaps most importantly), top management has committed
the use of management systems to achieve organizational goals.
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A Few Tips on System Integration
For organizations that have an existing QMS and wish to integrate an EMS with it, some
suggestions are provided below.
®° Understand the existing QMS, its effectiveness and how the workforce perceives the
system. Is the existing QMS documentation clear and workable? Do employees
believe that the system is helping the organization to achieve desired results?
®° Ensure that the scope of the two systems will be consistent (i.e., that the systems will
cover the same facilities, products, activities and/or services). In particular, this will be
an important issue if third-party registration will be sought.
®° Establish a cross-functional team (including, at a minimum, representatives from the
environmental and quality functions) to determine the optimal approach to system
integration.
®° As needed, manage resistance to change. Some employees and managers may be
reluctant to change a system that they are already familiar with and/or in which they
have important roles.
®° Understand how QMS and EMS differ in purpose. While there are many common
management system elements, there are elements of each system that are unique (see
below). In the case of EMS, these include for example, environmental aspects,
communications, emergency preparedness and response. These differences must be
acknowledged and accommodated within the integrated management system.
Relationship of EMS Elements to QMS (based on ISO 9001: 1994)
Elements that are Essentially the Same Elements that are Similar
®° Training, Awareness & Competence ®° Environmental Policy
®° Document Control ^ Structure and Responsibility
®° Nonconformance, Corrective & Preventive ®° EMS Documentation
Action ®° Operational Control
^ Calibration (part of the Monitoring & ^ Monitoring & Measurement
Measurement element) ®° EMS Audit
®° Records ^ Management Review
Elements that are Unique
Environmental Aspects
Legal and Other Requirements
Objectives & Targets
Environmental Management Program(s)
Communications
Emergency Preparedness & Response
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• Modify system documentation as required. Keep procedures simple and clear for
users. Review proposed changes with affected managers and employees.
• On a procedure-by-procedure basis, consider whether to integrate procedures or keep
them separate. While integration can reduce the total number of procedures or work
instructions, it also can confuse the overall purpose of such procedures in some cases.
• Once the integrated system documentation has been prepared, train managers and
employees on the integrated system.
• Audit the integrated system and take actions as necessary.
A few final thoughts on system integration:
• Can your organization afford to have two or more separate systems?
• Are there compelling reasons to keep these systems separate?
• What is the optimal approach from a strategic and operational standpoint?
• What approach is best suited for the organization's change and growth?
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Appendix F:
Additional Sources of Information and
Contacts
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Appendix F: Additional Sources of Assistance
There are many resources available to help your organization develop and implement an EMS that are
free of charge or relatively inexpensive. The following is a description of some of these resources.
Federal Government Agencies
The U.S. Environmental Protection Agency (USEPA) provides information on a number of topics
that can be useful in the development and implementation of an EMS. Some of these resources
include: assistance with interpretation of environmental laws and regulations; information on pollution
prevention technologies (case studies and fact sheets); and hotlines to answer questions about
environmental issues. The Agency also has web sites for information on EMS's and Design for
Environment. The USEPA's Office of Compliance has established national Compliance Assistance
Centers for various industry sectors.
The Small Business Administration (SBA) provides assistance to small and medium-sized
organizations. The SBA can provide information and assistance related to: operation and
management of a business; sources of financial assistance; international trade; as well as laws and
regulations.
State Agencies
Your state environmental regulatory agency can provide assistance with the development of an EMS.
Contact your state environmental agency and inquire about education and outreach programs for
organizations that are developing an EMS. Many state environmental agencies also can provide
publications, pamphlets, and on-line help related to state environmental laws, innovative pollution
prevention technologies, waste reduction, and permitting. Some states (such as North Carolina,
Wisconsin and Virginia) have developed programs to help organizations implement and EMS and/or
seek ISO 14001 registration. Recently, several states (including Texas and Virginia) established
"EnviroMentor" programs within their Small Business Assistance Offices. These mentoring programs
are intended to help small companies comply with regulations.
Associations
Industry trade associations can provide assistance with the development of an EMS. These
organizations can provide information on industry-specific environmental management issues, and can
put you in contact with other organizations that can share their experience and expertise in EMS
implementation.
Colleges and Universities
Some colleges and universities provide EMS-related training or manage EMS demonstration projects.
Chambers of Commerce
Your local or state chamber of commerce might be helpful in providing information about legislative
and regulatory issues that affect environmental management for small and medium- sized
organizations. Other services that are commonly offered include handbooks, workshops, conferences
and seminars.
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Non-Profit Organizations
Another resource to consider is the Manufacturing Extension Partnership (MEP), which is a growing
nationwide system of services that provide technical support to businesses interested in assessing and
improving their current manufacturing processes. The MEP is a partnership of local manufacturing
extension centers which typically involve federal, state, and local governments, educational
institutions, and other sources of information and funding support. The MEP can also often provide
assistance with quality management, development of training programs and business systems.
The Industrial Technology Institute (ITI) is a non-profit organization dedicated to expanding technology
access and technology management among U.S. manufacturers. ITI provides technical assistance to
small and medium-sized organizations through the Michigan Manufacturing Technology Center. ITI
also has experience with the development of business performance tools and provides services for
energy, environment, and manufacturing assessments; as well as, QS 9000 and ISO 14000 training
and implementation.
Other Organizations
Another recommended source of information and expertise is the organizations with which you do
business. It is likely that your suppliers and customers have experience with many of the aspects of
an EMS, and might be willing to share their experiences and provide advice to your organization.
On-line Resources
There is a wealth of information related to EMS implementation available electronically via the Internet.
Many state, federal, and local agencies have home pages on the Internet containing information that
can be useful to your organization. Numerous non-governmental organizations have home pages that
contain information on topics such as ISO 14000, pollution prevention, recycling and waste
minimization, environmental laws and regulations, innovative manufacturing technologies, and
materials substitution. If your organization does not have Internet access, contact your local library to
see if it provides Internet access to users.
Additional EMS resources and contacts are described on the following table.
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Appendix F (cont'd.)
Additional Sources of Information and Contacts
Note: This list is not intended to be comprehensive. Appearance on this list should not be construed as an endorsement by NSF of any products/service.
:EDERAL AGENCIES
Organization
US Environmental
Protection Agency
Resource
Small Business Compliance
Assistance Centers:
Design for Environment Guide,
Fact Sheets and DFE EMS
Template
Small Business Compliance
Policy
Compliance-Focused EMS •
Enforcement Agreement
Guidance
Environmental Compliance
Auditing Protocols
Code of Environmental
Management Principles
Pollution Prevention
Clearinghouse
Telephone Number / Internet Address
202/564-7066 (general information)
www.epa.gov/opptintr/dfe/tools/ems/
ems.html
202/564-7072
www.epa.gov/oeca/smbusi.html
http://es.epa.gov/oeca/oceft/neic/
12elemnr.pdf
EPA National Service Center
1-800-490-9198
www.epa.gov/oeca/ccsmd/profile.html
www.epa.gov/oeca/cemp/cemptoc.html
202/260-1023
Description
Centers are Internet Web Sites with
comprehensive environmental compliance,
technical assistance, & pollution prevention
information for various industry sectors.
Website contains information on EMS and
how to incorporate DFE into an EMS.
Provides a how-to manual for implementing
a DFE-based EMS and a set of integration
tools for companies that already have an
EMS.
Effective May 11, 2000, this policy
supercedes the June 1996 version.
Published in the Federal Register on April
11, 2000 (65FR19630).
Presents the key elements of a compliance
focused EMS model.
These protocols are intended to guide
regulated entities in the conduct of
compliance audits and to ensure that audits
are conducted in a thorough manner.
Collection of five broad principles and
performance objectives that provide a basis
for environmental management among
Federal agencies.
Technical Information on materials and
processes, including publications related to
waste minimization and pollution prevention.
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Office of Wastewater
Management
Public Information Center
RCRA / Superfund Hotline
AGENCI
www.epa.gov/owm/iso2/htm
202/260-7751
800/424-9346
202/382-3000
Provides information on various EPA-
sponsored EMS projects.
General information about EPA programs.
Provides information about hazardous waste
regulations and handles requests for federal
documents and laws.
Small Business and Asbestos 800/368-5888
Ombudsman 202/557-1938
Information and advice on compliance
issues for small quantity generators of
hazardous waste.
U.S. Small Business
Administration
Technology Transfer and
Support Division
TSCA Hotline
Enviro$en$e
US EPA Home Page
SBA Answer Desk
SBA Home Page
513/569-7562
202/554-1404
http://es.inel.gov
http://www.epa.gov
1-800-8-ASK-SBA
http://www.sbaonline.sba.gov
Access to the ORD research information and
publications.
Assistance and guidance on TSCA
regulations.
Solvent alternatives, international, federal
and state programs, other research and
development. Also, environmental profiles
of various industrial categories.
Information about EPA regulations,
initiatives, and links to the home pages of
other agencies and EPA regional offices.
Information about SBA programs, and
telephone numbers for local offices.
Information about business services
available to your organization, with links to
other related sites.
Government Printing GPO Superintendent of
Office Documents
202/512-1800
US Department of Pollution Prevention Information http://www.er.doe.gov/production/esh/
Energy Clearinghouse epic.html
Information about available documents and
instructions on ordering GPO publications.
Pollution prevention and environmental
design information.
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Organization
State Environmental
Protection Agencies
Resource
Environmental Assistance
Programs
Small Business Assistance
Programs (Mandated under Title
V of the Federal Clean Air Act).
STATE AGENCIES
Telephone Number / Internet Address
Contact your state's Environmental
Protection Agency
Call the EPA Small Business
Ombudsman (800/368-5888) for the
phone number and address of the Small
Business Assistance Program in your
state.
Description
Many state environmental protection
agencies provide publications, technical
assistance, and information on pollution
prevention technologies, waste reduction,
and regulatory compliance, at little or no
charge.
Provides information and technical
assistance to small businesses regulated
under the Clean Air Act.
State Environmental
Protection Agencies
(cont'd)
State and Local Pollution
Prevention Programs
Michigan Department of
Environmental Quality
Contact the National Pollution Prevention
Roundtable (202/466-7272) for the phone
number and address of the pollution
prevention program in your state.
http://www.deq.state.mi.us
Provides information and technical
assistance on pollution prevention.
Fact sheets, training, and technical
assistance.
Minnesota Technical Assistance
Program
Ohio Department of
Environmental Protection
Wisconsin Department of
Natural Resources
http://es.inel.gov/techinfo/facts/mpca/mpc
a.html
http://arcboy.epa.ohio.gov
http://es.inel.gov/techinfo/facts
Fact sheets on pollution prevention,
materials substitution.
Fact sheets on pollution prevention,
materials substitution.
Fact sheets on pollution prevention,
materials substitution.
Note: The list shown above represents only a sample of the resources that may be available from state agencies. Contact your state
agency for details of existing programs and other forms of assistance available
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EMS SOFTWARE PACKAGES
Organization
Greenware
EMSoft2000
ISOXpert
ISOSoft 14001
Contact Info
1-800-474-0627
www.greenware.com
1-800-241-3618
www.rmtinc.com
1-800-ISO-EASY
416-679-0119
www.isogroup.simplenet.com/soft14k
Description
Provides ISO 14001 assessment, implementation and audit
software
Software package based on LotusNotes to support EMS
implementation
Built on LotusNotes platform. Customizable document formats.
Provides ISO 14001 assessment, implementation and audit
software. Co-developed with BSI.
Organization
Industrial Technology Institute (ITI)
Manufacturing Extension Partnership
(MEP)
NON-PROFIT ORGANIZATIONS
Address Phone Number
2901 Hubbard Road
P.O. Box 1485
Ann Arbor, Michigan 48106-1485
Building 301, Room C121
National Institute of Standards and
Technology
Gaithersburg, Maryland 20899-
0001
1-800-292-4484
Fax: 1-313-769-
4064
1-301-975-5020
1-800-MEP-4MFG
Fax: 1-301-963-
6556
Description
Technical assistance to small and mid-sized
manufacturers. Energy, environment, and
manufacturing assessments, as well as
performance benchmarking, and QS 9000
and ISO 14000 implementation assistance.
Assists manufacturers with assessing
technological needs, and works to help small
manufacturers solve environmental problems
with cost-effective solutions.
North American Commission on
Environmental Cooperation
"Improving Environmental Performance
and Compliance: 10 Elements of Effective
Environmental Management Systems"
www.cec.org/pubs_info_resources/
publications/enforce_coop_law/ems
.cfm?varlan=english
514/350-4334 Joint expression from three North American
(Commission) governments regarding how voluntary EMS's
designed for internal management purposes
202/564-7048 can also serve broader public policy goals,
(USEPA) such as compliance assurance and improved
environmental performance.
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Resource
ANSI Online
Business Resource Center
Canadian Standards Association
INTERNET RESOURCES
Internet Address
http://www.ansi.org
http://www.kciLink.com/brc
http://www.csa.ca/isotcs
Clean Technologies Center (UCLA) http://cct.seas.ucla.edu
Consortium on Green Design and Manufacturing (DC-Berkeley) http://euler.berkeley.edu/green/cgdm.html
Environmental Technology Gateway http://iridium.nttc.edu/environmental.html
International Corporate Environmental Reporting Site
Industrial Technology Institute Home Page
International Network for Environmental Management
www.enviroreporting.com
http://www.iti.org
www.inem.org
ISO 14000 Information Center
http://www.iso14000.com
Description
Contains information related to the
American National Standards
Institute, including meetings, events,
and standards information databases.
Provides information on a variety of
topics, including tips on management,
recycling, and financing.
A center for information and services
related to ISO 9000 and ISO 14000,
maintained by the Canadian
Standards Association.
Innovative technologies for pollution
prevention.
Environmental design and
sustainable develooment.
Access to other environmental links
and information, environmental
technologies.
International news about
environmental issues and resources
for environmental reporting.
Information about ITI, how to find
environmental information on the
Internet, and links to other
organizations.
Case studies, publications and how-
to information on environmental
management. Interactive tools for
assessing environmental policies and
reports.
Answers to questions on ISO 14000
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Resource
ISO 14000 Integrated Solutions (ANSI/GETF)
ISO Online
INTERNET RESOURCES
Internet Address
http://www.gnet.org
http://www.iso.ch
Description
standards.
Multi-State Working Group www.mswg.org
National Environmental Information Resources Center (NEIRC) http://www.gwu.edu/~greenu/
NSF-ISR Home Page
http://www.nsf-isr.org
AUTHORIZED SOURCES OF THE ISO 14000 STANDARDS
Will provide training, conferencing,
on-line information services and
publications on a fee basis.
The ISO homepage provides
information on ISO, its structure,
members, technical committees,
meetings, and events.
Describes the activities of this group
regarding EMS and ISO 14001.
Provides access to a wide variety of
information about environmental
matters, with links to hundreds of
organizations.
Contains information on NSF
International and its pilot projects in
EMS implementation.
NSF International (NSF)
American National Standards Institute (ANSI)
American Society for Quality (ASQ)
American Society for Testing and Materials (ASTM)
Phone: 1-888-NSF-9000
Fax: 1-734-827-6801
Phone: 1-212-642-4900
Fax: 1-212-398-0023
Phone: 1-414-272-8575
Fax: 1-414-272-1734
Phone: 1-610-832-9585
Fax: 1-610-832-9555
789 N. Dixboro Road
Ann Arbor, Ml 48105
11 West 42nd Street
New York, NY 10036
Milwaukee, Wl
West Conshohocken, PA
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Glossary of Acronyms
ACC American Chemistry Council
ANSI American National Standards Institute
API STEP American Petroleum Institute's "Strategies for Today's Environmental Partnership"
CAA Clean Air Act
CEC Commission for Environmental Cooperation
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
CERES Coalition for Environmentally Responsible Economies
CFCs Chlorofluorocarbons
CMA Chemical Manufacturers Association
CWA Clean Water Act
DFE Design for Environment
EHS Environment, Health and Safety
EMAS Eco-Management and Audit Scheme
EMS Environmental Management System
EPA (Also USEPA) U.S. Environmental Protection Agency
EPCRA Emergency Planning and Community Right-to-Know Act
FIFRA Federal Insecticide, Fungicide and Rodenticide Act
HMTA Hazardous Materials Transportation Act
ICC International Chamber of Commerce
ISO International Organization for Standardization
ITI Industrial Technology Institute
MEP Manufacturing Extension Partnership
OSHA Occupational Safety and Health Administration
PCBs Polychlorinated Biphenyls
P2 Pollution Prevention
QMS Quality Management System
RCRA Resource Conservation and Recovery Act
SBA U.S. Small Business Administration
SPCC Spill Prevention Control and Countermeasure
TC 207 Technical Committee 207 (of ISO)
TSCA Toxic Substances Control Act
TQM Total Quality Management
USTAG U.S. Technical Advisory Group (to TC 207)
VOCs Volatile Organic Compounds
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Bibliography
• Canadian Standards Association, Competing Leaner, Keener and Greener: A Small
Business Guide to ISO 14000, 1995.
• Cascio, Joseph, editor. The ISO 14000 Handbook. CEEM Information Services with ASQC
Quality Press, 1996.
• Diamond, Craig P., "Voluntary Environmental Management System Standards: Case
Studies in Implementation." Total Quality Environmental Management, (Winter 1995/1996),
pp. 9-23.
• GETF, The USEPA Environmental Management System Pilot Program for Local
Government Entities, January 2000.
• Hillary, Ruth, Evaluation of Study Reports on the Barriers, Opportunities and Drivers for
Small and Medium Sized Enterprises in the Adoption of Environmental Management
Systems, October 1999.
• Institute of Quality Assurance, Quality Systems in the Small Firm: a Guide to the Use of the
ISO 9000 Series, March 1995.
• International Organization for Standardization, ISO 14001: Environmental Management
Systems - Specification with Guidance for Use. 1996.
• International Organization for Standardization, ISO 14004: Environmental Management
Systems - General Guidelines on Principles, Systems, and Supporting Techniques. 1996.
• Kuhre, W. Lee, ISO 14001 Certification: Environmental Management Systems, 1995.
• Lucent Technologies, Best Current Practices: Design for Environment, February 1997.
• Michigan Department of Commerce and Natural Resources, Environmental Services
Division, Business Waste Reduction: Creating an Action Plan, November 1994.
• Northern Environmental, ISO 14001 Guide for Small to Medium-Sized Companies, 2000.
• NSF-ISR, Implementing Environmental Management Systems in Community-Based
Organizations, 1998.
• NSF-ISR, Environmental Management Systems: A Guide for Metal Finishers, 1998.
• Tibor, Tom with Ira Feldman, ISO 14000: A Guide to the New Environmental Management
Standards, Irwin Professional Publishing, 1996.
• United Nations Environment Programme (UNEP), the International Chamber of Commerce
(ICC), and the International Federation of Consulting Engineers (FIDIC). Environmental
Management System Training Resource Kit. Version 1.0, December 1995.
• United States Postal Service, Environmental Resources Handbook. November 1995.
• Us Environmental Protection Agency, Implementation Guide for The Code of Environmental
Management Principles for Federal Agencies, March 1997.
• Voehl, Frank; Jackson; and Ashton, ISO 9000: An Implementation Guide For Small and Mid-
Sized Businesses, St. Lucie Press, 1994.
©2001 NSF 196
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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
1
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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
-------
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
-------
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.
8
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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,
10
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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?
11
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How can continual improvement in environmental issues be effectively
communicated?
12
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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
13
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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?
14
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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.
15
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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.
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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.
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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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f 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.
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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.
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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.
60
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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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X
X
X
X
X
X
X
X
X
X
X
4
1
1
1
1
1
1
1
1
5 X
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
X
X
X
X
X
X
X
X
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
67
-------
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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P2 and the EMS Model
Chapter 6 of the Guide demonstrates how a P2 program can be implemented
through an environmental management system (EMS). While many EMS
programs only require a "commitment" to pollution prevention, the EMS implemen-
tation team can certainly go much further than this. This section of the CD-ROM is
designed to provide more information to help an organization take full advantage
of the EMS implementation. Information is provided in the following categories:
EMS Information - A number of Internet links are provided to help secure infor-
mation on preparing an EMS. You will need to have your Internet connection
activated to use these links directly from the CD-ROM.
EMS Manuals - Some excellent references are made available on this CD-ROM
to assist in preparing an EMS. This information can be used with the information
in Chapter 6 of the EPA Guide to implement a P2 program
EMS Examples - Some examples of specific EMS work products are available to
help your organization appreciate what is involved. You will need to have your
Internet connection activated to use these links directly from the CD-ROM.
Back HOME
EMS Info.
EMS Manuals
EMS Examples
-------
EMS Information Web Sites
In order to help you understand environmental management systems (EMS),
there are a number of Internet sites provided below. These sites contain informa-
tion on ISO 14001 and let you know how to order this copyrighted standard.
There are links to the U.S. Environmental Protection Agency's (EPA) web page and
other groups offering assistance in the design and implementation of EMS. Make
sure you consult with your state technical assistance provider for additional informa-
tion on EMSs. You will need to have your Internet connection ready to be activated
when you use these links.
Back HOME
Back to EMS Page
Click on the Web Site Name Below to View it on the Web. WWW
ISO 14001 Standard - EPA EMS Home Page
Ordering Information
EPA Standards Network
Kentucky EMS
Information
Multi-State Working
Group Home Page
Eco-Management and
Audit Scheme (EMAS)
EPA ISO 14QQQ Documents
CORD Tech Transfer Branch1)
-------
EMS Manuals
To provide you with some more practical information on EMS use, a number of
manuals have been placed on this CD-ROM. Some of these manuals reside
directly on this disk while others will require that you have your Internet connection
prepared to be activated by the link.
Click on the manual title below to view it.
EPA Integrated
Environmental
Management Systems -
Implementation Guide
NSF Environmental
Management Systems:
An Implementation Guide
for Small and Medium
Sized Organizations
DOE/EPA Environmental
Management System
Primer for Federal
Facilities
EPA Implementation
Guide for the Code of
Environmental
Management Principles
for Federal Agencies
NSF Environmental
Management System
Demonstration Project
Ford Motor Co.
Environmental
Management System
Notebook
Back to EMS Page
WWW
-------
P2 and the EMS Model
Chapter 6 of the Guide demonstrates how a P2 program can be implemented
through an environmental management system (EMS). While many EMS
programs only require a "commitment" to pollution prevention, the EMS implemen-
tation team can certainly go much further than this. This section of the CD-ROM is
designed to provide more information to help an organization take full advantage
of the EMS implementation. Information is provided in the following categories:
EMS Information - A number of Internet links are provided to help secure infor-
mation on preparing an EMS. You will need to have your Internet connection
activated to use these links directly from the CD-ROM.
EMS Manuals - Some excellent references are made available on this CD-ROM
to assist in preparing an EMS. This information can be used with the information
in Chapter 6 of the EPA Guide to implement a P2 program
EMS Examples - Some examples of specific EMS work products are available to
help your organization appreciate what is involved. You will need to have your
Internet connection activated to use these links directly from the CD-ROM.
Back HOME
EMS Info.
EMS Examples
-------
United States
Environmental Protection
Agency
Office of Enforcement and
Compliance Assurance
EPA -300 -R-00-006
August 2000
&EPA
An Environmental
Management System
Review of the National
Park Service:
Based on the Code of Environmental
Management Principles
-------
CEMP Evaluation of the National Park Service
EXECUTIVE SUMMARY
In early 1998, the U. S. Environmental Protection Agency (EPA) and the Department of the Interior (DOI)
agreed to work jointly to enhance regulatory compliance assistance across DOI Bureaus and facilities with the
overall goal of raising the level of regulatory awareness and compliance with environmental regulation at all DOI
facilities. While EPA's federal facilities program had previously conducted limited compliance assistance
initiatives with specific environmental programs in other federal agencies, this was the first time that EPA
committed to provide compliance assistance across an entire federal agency. One of the most innovative and far-
reaching efforts that resulted from the EPA/DOI compliance initiative was an analysis of environmental
management systems (EMS) within the National Park Service (NPS). This analysis was conducted by comparing
existing management systems within the NPS against the Code of Environmental Management Principles (CEMP)
for federal agencies.
The CEMP was developed by EPA in coordination with other federal agencies in response to requirements
of Executive Order 12856, "Federal Compliance with Right-to-Know Laws and Pollution Prevention
Requirements." The Executive Order required the federal community to agree to a set of principles that reflect
state of the art environmental management programs. The CEMP is a collection of five broad management
principles and underlying performance objectives that provide a basis for federal agencies to achieve and maintain
effective and responsible environmental management.1 The five principles are:
Management commitment;
Compliance assurance and pollution prevention;
Enabling systems;
Performance and accountability; and
• • Measurement and improvement.
The analysis of the NPS environmental management system was a broad-based review that examined current and
planned environmental management practices against an accepted systematic framework of principles. While the
body of this document provides substantial information regarding the findings and recommendations of this review,
highlights of those findings and recommendations are presented below.
The analysis and recommendations contained in this document are meant to support and enhance the
current NPS environmental management system. EPA and NPS worked jointly to conduct this review in the hope
that it will provide a basis for continued discussion within NPS regarding the future direction of the NPS
environmental program. This effort has also stimulated dialogue between NPS and EPA field personnel and has
lead to a better understanding of the respective roles of each entity in achieving and maintaining environmental
leadership. Finally, results of CEMP analysis conducted for NPS will assist other federal agencies in recognizing
the benefit of such an assessment across the federal community. EPA would like to express its appreciation to the
NPS for participating in this review.
HIGHLIGHTS
Management Commitment
The NPS CEMP review found that bureau-wide, the NPS mission actively supports environmental
stewardship and sustainability as a founding philosophy of the NPS. The review did reveal, however, that there is
not currently a stand-alone statement that explicitly defined an NPS environmental policy. In addition, existing
environmental guidelines do not emphasize compliance with environmental regulatory requirements. Development
and wide distribution of a distinct environmental policy statement, along with the clear, high-level management
commitment that would necessarily accompany such a statement would emphasize the NPS policy to employees and
information regarding the CEMP can be found in, "Implementation Guide for the Code of
Environmental Management Principles for federal Agencies (CEMP), EPA document number 315-B-97-001.
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CEMP Evaluation of the National Park Service
park users and explicitly demonstrate the goal of the NFS to be a leader in environmental stewardship and
regulatory compliance. Moreover, an explicit and comprehensive policy would clearly signal internal NFS support
for funding and personnel resources necessary to ensure a robust environmental program. Finally, such a policy
would encourage NFS support and outreach components, such as concessioners and interpretive elements, to
incorporate environmental stewardship and compliance into facility-level activities.
Compliance Assistance and Pollution Prevention
Current NFS support programs responsible for ensuring compliance with environmental regulations and
promoting pollution prevention are housed under separate entities within the NFS organization. In addition, while
many parks have programs for support of pollution prevention and recycling efforts, these programs do not fully
exploit reduced compliance liabilities resulting from their efforts. Development and support of comprehensive
regulatory compliance activities would significantly contribute to ensuring both compliance with applicable
environmental regulations and pursuit of pollution prevention opportunities throughout the NFS system. This effort
would integrate all current regulatory components at NFS and it would support and reflect ongoing efforts to
implement environmental auditing procedures at NFS facilities. A comprehensive compliance assurance and
pollution prevention program would also serve as a bureau-wide source for communicating both changing
environmental compliance requirements and innovations in pollution prevention applicable to facility-level
operations.
Enabling Systems
The various support and enabling systems that affect environmental management aspects of the NFS reflect
a separate, media-based approach toward awareness and compliance. Additionally, the principal environmental
review mechanism is the NEPA review process which may not adequately address day-to-day operations of NFS
facilities. Identification of facility level operational training needs and implementation of broad-based training
programs for facility personnel would ensure adequate knowledge and understanding of NFS environmental
priorities as well as external environmental requirements. Further, facility personnel who are not directly
responsible for facility environmental compliance but who may contribute to success of the facility's environmental
program, should have a recognized role in contributing to overall NFS facility-level policies and goals for
environmental excellence.
Performance and Accountability
Responsibility and authority for compliance with environmental requirements at NFS facilities is generally
limited to collateral duties of facility management personnel who are also responsible for a broad range of other
facility operations. This approach limits the ability of those personnel to concentrate on environmental management
and compliance at the facility and restricts the degree of authority and accountability relative to facility
environmental performance. This situation could be significantly enhanced by the establishment of an NFS policy
that secures adequate authority for ensuring facility environmental compliance and gives that authority to the
responsible party at each NFS facility. In addition, development of performance standards and performance
evaluations for those facility personnel responsible for compliance and other environmental priorities should fully
recognize those responsibilities. Additionally, goals for environmental performance that reflect overarching NFS
environmental policies should be developed and included into regional and park operational standards. Finally,
while individual "champions" are important to the success of any environmental program, policies and practices
should be in place to ensure that environmental leadership is standard procedure and lack of a champion does not
preclude sound environmental performance.
Measurement and Improvement
Results of the NFS CEMP review indicate that current systems for evaluation and measurement of
environmental performance at NFS facilities are limited to certain regional efforts and developing audit systems.
Evaluation of program performance is critical to the ultimate success of any environmental program. Support and
further development of planned auditing systems with appropriate mechanisms to collect and analyze audit results
-------
CEMP Evaluation of the National Park Service
across the bureau will contribute significantly to the success of the NFS environmental program. Evaluation of
audit results including root cause analysis of environmental problems and non-compliance would enable NFS to
develop tools to support regulatory compliance and transfer cost-effective innovations and solutions throughout the
NFS system. Additionally, effective measurement will provide necessary information for budgetary and personnel
decision making to respond to problem areas as well as enhance efforts that meet the policies and goals established
for the NFS environmental management program.
in
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CEMP Evaluation of the National Park Service
CONTENTS
Executive Summary i
Contents iv
List of Acronyms v
Introduction vi
OEPC Relationship with NFS and Other DOI Bureaus viii
Principal 1: Management Commitment 1-1
Performance Objective 1.1— Obtain Management Support 1-1
Performance Objective 1.2 - Environmental Stewardship and Sustainable Development 1-4
Principle 2: Compliance Assurance and Pollution Prevention 2-1
Performance Objective 2.1 — Compliance Assurance 2-1
Performance Objective 2.2 - Emergency Preparedness 2-3
Principle 3: Enabling Systems 3-1
Performance Objective 3.1 — Training 3-1
Performance Objective 3.2 - Structural Supports 3-2
Performance Objective 3.3 - Information Management, Communication & Documentation 3-4
Principle 4: Performance and Accountability 4-1
Performance Objective 4.1 - Responsibility, Authority, and Accountability 4-1
Performance Objective 4.2 - Performance Standards 4-2
Principle 5: Measurement and Improvement 5-1
Performance Objective 5.1 - Evaluate Performance 5-1
Performance Objective 5.2 — Continuous Improvement 5-4
Matrix of CEMP Findings and Recommendations A -1
iv
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CEMP Evaluation of the National Park Service
LIST OF ACRONYMS
Acronym
BLM
CAP
CEMP
CERCLA
CERL
CFA
DOD
DOE
DOI
EIMS
EMR
EMS
EPA
FRP
GMP
GPRA
HWMPP
1C
IMR
ISWAP
KSA
MOU
MWR
NEPA
NER
NPS
NRDA
NREL
NRI
OEPC
OSHA
P2
P2OA
PHS
PMIS
PWR
QA
RCRA
SER
SPCC
WASO
Definition
Bureau of Land Management
Compliance Assistance Project
Code of Environmental Management Principles
Comprehensive Environmental Response, Compensation, and Liability Act
Construction Engineering Research Laboratory
Civilian Federal Agency
Department of Defense
Department of Energy
Department of the Interior
Environmental Information Management System
Environmental Management Review
Environmental Management System
Environmental Protection Agency
Facility Response Plan
General Management Plans
Government Performance Results Act
Hazardous Waste Management and Pollution Prevention
Incident Command
Inter-Mountain Region
Integrated Solid Waste Alternatives Program
Knowledge, Skills and Abilities
Memorandum of Understanding
Midwest Region
National Environmental Policy Act
Northeast Region
National Park Service
Natural Resource Damage Assessment
National Renewable Energy Laboratory
Natural Resource Initiative
Office of Environmental Policy and Compliance
Occupational Safety and Health Administration
Pollution Prevention
Pollution Prevention Opportunity Assessment
Public Health Service
Project Management Information System
Pacific West Region
Quality Assurance
Resource Conservation and Recovery Act
Southeast Region
Spill Prevention, Control, and Countermeasures
Washington Area Support Office
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CEMP Evaluation of the National Park Service
INTRODUCTION
Background
During discussions held in January of 1998, U. S. Environmental Protection Agency (EPA) and the
Department of the Interior (DOI) agreed to work jointly to enhance compliance assistance across DOI Bureaus and
facilities with the overall goal of raising the level of regulatory awareness and compliance at all DOI facilities.
While EPA's federal facilities program had previously conducted limited compliance assistance initiatives with
specific environmental programs in other federal agencies, this was the first time that EPA pledged to provide
compliance assistance across an entire federal agency. One of the most innovative and far-reaching efforts that
resulted from the EPA/DOI compliance initiative was an analysis of environmental management systems (EMS)
within the National Park Service (NPS), including an analysis of support relationships between NPS field-level
facilities and NPS and DOI Headquarters environmental offices. This analysis was conducted the Code of
Environmental Management Principles (CEMP).
CEMP
In coordination with other federal agencies, EPA developed the Code of Environmental Management
Principles for federal agencies (CEMP) in response to requirements of Executive Order 12856. The CEMP is a
collection of five broad management principles and underlying performance objectives that provide a basis for
federal agencies to achieve and maintain effective and responsible environmental management. The five principles
are:
• • Management commitment;
Compliance assurance and pollution prevention;
Enabling systems;
Performance and accountability; and
• • Measurement and improvement.
The five principles and accompanying objectives provide federal agencies with guidance to ensure environmental
performance that is cost-effective, integrated, and sustainable.
Scope of the Assessment
The scope of the CEMP assessment was defined by: (1) assessed organization; (2) assessment period; and
(3) assessment criteria. Additional information on each is presented below.
Assessed Organization: The assessed organization was the NPS. Formal and informal aspects of
the NPS environmental management system (EMS) were reviewed at the field, regional and
headquarters levels. The review also addressed portions of the "parent" DOI organization which
directly influence NPS environmental management activities. In this regard, the DOI Office of
Environmental Policy and Compliance (OEPC) and additional DOI-level units were included in
the review.
Assessment Period: The assessment period for the CEMP review began in July 1998 and was
completed in December 1998. During the assessment period, several changes to the NPS EMS
were either underway or planned; the review documented those changes to the EMS as well.
Consequently, the final document presents information collected during the assessment period
about the existing EMS, as well as information on changes underway or planned.
• • Assessment Criteria: The assessment criteria for the NPS CEMP review were the performance
objectives supporting each of the CEMP principles. Details on the performance objectives were
extracted from the CEMP Implementation Guide prepared by EPA in 1997. Specifically, both the
VI
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CEMP Evaluation of the National Park Service
text of the CEMP Implementation Guide and the Guide's Self-Assessment Matrix were used as a
reference for the assessment study and results.
Assessment Approach
The first stage of the assessment focused on gathering DOI and NFS organizational baseline information
with an emphasis on how the two organizations administered environmental management responsibility internally.
The assessment also included a review of administrative relationships between EPA, NFS and DOI. Collection of
this information provided a common understanding of existing management systems. For example, the EPA,
DOI/OEPC, and the NFS each have a regional management structure but the geographical territory associated with
each region is different. A summary of collected baseline information is included in the final assessment
document.
The approach of phase two of the assessment focused on field and regional level aspects of environmental
management at NFS. EPA, DOI/OEPC, and NPS were informed of assessment progress through monthly reports,
meetings, and through informal discussions.
The assessment team collected information through interviews, record reviews, and by direct observations.
Further information on each aspect is presented below:
Interviews: Over 75 interviews were conducted. Initial interviews, addressing all five principles,
were broad in scope and lengthy (up to 2 hours). Towards the end of the assessment period,
shorter interviews were used to fill information gaps or test initial conclusions on
recommendations related to the principles. Nearly all interviews were structured to ensure
specific objectives were met; however, there was no standard set of questions asked of all
interviewees. Each interview was designed for specific information sought. In conducting
interviews, the assessment team shared information about the CEMP as background and assured
interviewees that their specific comments would remain confidential.
Record Reviews: Over 85 individual EMS-related records were reviewed. These documents
included guides, manuals, policy statements, and training documents.
Direct Observations: A direct observation was defined as first hand information collected by the
assessment team which was not derived from an interview or record review. Examples are:
Internal meetings where the assessment team observed information being shared; and
Observations on the availability of selected EMS related records. For example, in
requesting information about records, observations were made on whether the records
were available, understood, and/or used.
Only corroborated information is reported as findings in the document. For example, information based
upon a single interview was not, for the purposes of the assessment, considered sufficiently reliable. To be reported
as a finding, single interview information had to be supported by documentation or direct observation.
Findings
A set of recommendations was developed for each of the CEMP performance objectives as suggested areas
for future improvement. The findings were designed to encourage further NPS review of the applicability of the
CEMP in supporting the overall success of the NPS environmental management, system. While the main body of
the assessment focuses on NPS , an additional section presents EMS related findings on the relationship between
DOI and NPS.
VII
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CEMP Evaluation of the National Park Service
OEPC RELATIONSHIP WITH NFS AND OTHER DOI BUREAUS
The Office of Environmental Policy and Compliance (OEPC), within the Office of Policy, Management
and Budget, provides national and regional leadership, bureau coordination, and program evaluation in
environmental management for DOI. The operations of this office were evaluated as part of the CEMP study of the
NPS. It should be noted, this evaluation focused on OEPC relationships with the NPS. It was not a comprehensive
review of OEPC environmental management systems or the office's relationship with other bureaus.
Existing Environmental Management Activities
Management Commitment
OEPC's role is to provide assistance and coordination on environmental policy and program
implementation for inter-bureau, inter-agency, and other external activities. OEPC does not have responsibility for
management or direct oversight of bureau environmental programs. OEPC develops departmental environmental
policies and guidance. These policies are subject to approval by bureaus and offices. Environmental policies that
have been promulgated include: Departmental Manual Part 515, Chapters 2 and 3, which address environmental
auditing and recycling programs; Part 516, which addresses NEPA compliance; Part 518, Chapters 1 and 2, which
address waste management; Part 602, which addresses pre-acquisition site assessment.
With the exception of the central hazmat fund, OEPC has no responsibility for management or review of
NPS or other bureau environmental budgets.
Compliance Assurance and Pollution Prevention
A baseline of DOI environmental compliance has not been completed. Regulatory notices and guidance
are developed on an as-needed basis by OEPC and are disseminated to NPS and other bureaus in two ways: 1) to
Regional Environmental Officers for distribution to NPS and other bureau and office regional contacts; and 2) to
bureau and office headquarters for distribution to regions and field units. There is no mechanism to track or assure
distribution of this information to the field level once it leaves OEPC.
Criteria for NEPA documentation review at the departmental level have been developed. Internal and
external NEPA documentation describing significant impacts are subject to OEPC review. A majority of bureau
environmental impact statements are tracked by OEPC.
A departmental system is in place to address emergency response and is coordinated with the NPS and
other bureaus and offices.
Enabling Systems
OEPC does not have resources or agency-wide initiatives for training. Environmental training
responsibility is predominantly delegated to the bureaus and offices; occasional inter-bureau training may be
provided at the headquarters or regional level.
OEPC has a web site and electronic bulletin board. The web site currently provides limited environmental
compliance data. The site contains linkages to the Construction Engineering Research Laboratory (CERL) TEAM
Guide, Green Seal environmentally preferable product reports, damage assessment training modules, tools and
regulations. With the assistance of one of the Bureaus, OEPC conducts periodic nationwide environmental
conferences to assist Bureaus in addressing a wide variety of environmental issues. There is no linkage to relevant
environmental compliance policies. OEPC is currently benchmarking it's site against those of other civilian federal
agencies.
Vlll
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CEMP Evaluation of the National Park Service
Performance and Accountability
OEPC has no line authority for environmental compliance of the NFS or other bureaus. Office
performance measures relate to success in coordinating and facilitating bureau programs and inter-agency
partnerships. OEPC staff performance goals are not based on individual bureau performance.
Measurement and Improvement
DOI has developed policy mandating environmental audits of all facilities by September 2002. Transmittal
of bureau audit results to OEPC is not required by the policy; however, OEPC has developed an audit summary
report. The report format was revised based on comments from the bureaus.
Calls for other environmental data are made by OEPC to complete mandated summary reports (e.g., USTs,
CERCLA sites). The completeness and/or timeliness of this data is at the discretion of the bureaus and offices.
Recommended Next Steps
A number of opportunities were identified where OEPC has the opportunity to enhance the environmental
performance of individual bureaus and DOI as a whole. These improvements can be made within the existing
OEPC mission framework of providing national leadership, bureau coordination, and program evaluation. In
particular, enhancements can be taken in five specific areas:
Policy;
Guidance;
Strategic tool development and deployment;
Information management; and
Quality assurance.
Policy
OEPC should develop minimum standards for all environmental program areas. These minimums should
be clearly identified, and have specific emphasis on departmental applicability. They should not simply restate
laws, regulations, and Executive Orders.
Policy developed by OEPC is subject to review and approval by each of the bureaus. This consensus
building process often leads to a "watering down" of policy requirements. OEPC should issue interpretive guidance
(which is not subject to the same level of bureau approval) to augment and re-strengthen the policy. OEPC should
also develop strong strategic plans with bureau-level goals and measurement requirements which are tied to
compliance requirements (e.g., EO 12856 pollution prevention goals).
Guidance
Guidance to bureaus is generally useful for any environmental management topic, but is especially
important where:
Consistency is essential (e.g., roll-up reporting of environmental audit findings);
There are common bureau needs (e.g., affirmative procurement procedures and reporting);
Bureaus do not have sufficient resources or determination; and
IX
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CEMP Evaluation of the National Park Service
Timeliness is important.
OEPC should look use these criteria to identify opportunities to develop environmental program guidance that will
be most beneficial to the bureaus.
Strategic Tools
Efficiency and economy of scale can be realized by department-level tools benefitting most bureaus.
Examples may include model plans, budget models, training curriculum and tools, fact sheets (e.g., new issues,
lessons learned), and resource guides.
Information Systems
OEPC should work to become a value-added environmental point of contact for internal and external (e.g.,
EPA) communications and a preferred resource and information center within the department. The provision of the
CERL Team Guide and Green Seal environmentally preferable products reports on the DOI web site are good
examples of environmental information OEPC can provide to assist bureaus in maintaining environmental
compliance. Other useful information may include regulations, relevant departmental manual chapters, interpretive
guidance and strategic tools.
Quality Assurance
OEPC should conduct routine and as-needed program evaluations and audits. These may be CEMP- or
NEPA-related, or address other key factors. These evaluations can serve to assess the quality of bureau programs
and be used by OEPC for targeting root causes such as resources and commitment. This information can be used in
the strategic planning of OEPC programs and/or provide guidance and direction to the Secretary (e.g., budget
requirements).
Implementation
OEPC can take several steps to help enhance the departmental environmental management program:
Seek opportunities to develop an integrated staff with bureaus through details or special
assignments;
Host key leadership-focused intra-departmental initiatives (e.g., the active role OEPC has taken in
the development of the federal strategic plan for EO 13101);
Create Centers of Excellence at selected bureaus to recognize and encourage superior
performance (e.g., BLM for military munitions);
Promote OEPC capabilities and successes internally and externally; and
demonstrate the economic, efficiency and quality benefits from OEPC involvement.
Organization of the Document
The remainder of this document summarizes the results of the CEMP assessment of the NFS EMS. It is
organized according to the five CEMP principles.
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CEMP Evaluation of the National Park Service
PRINCIPAL 1: MANAGEMENT COMMITMENT
Performance Objective 1.1 — Obtain Management Support
Sub-Objective 1.1.1: Policy Development — The agency establishes an environmental policy followed by an
environmental program that complements its overall mission strategy.
There is no stand-alone environmental policy for the NFS. The document, NFS Management Policies,
which is only revised on a ten-year cycle, serves as a Service-wide or Level 1 policy document. However, the need
for environmental compliance is only implied in the foreward of the document. In addition, a number of
subsections mandate compliance with specific federal laws and regulations, such as:
• • Chapter 2 - Park System Planning addresses National Environmental Policy Act (NEPA).
Chapter 4 - Natural Resource Management mandates compliance with the Clean Water Act and
Clean Air Act and associated federal, state and local regulations.
Chapter 9, Park Facilities addresses compliance with all applicable laws and regulations
associated with solid and hazardous waste, hazardous materials management and site restoration.
Special Directives and Staff Directives are considered Level 2 internal working policy. They are prepared
and updated as necessary and provide more detail than the NFS Management Policies. The Special and Staff
Directives are being replaced by Directors Orders as part of an overall revision to the NFS Directives System.
Level 2 policy has been issued to address waste management, underground storage tank management, integrated
solid waste management, pesticide use and other environmental programs.
Level 3 NFS Guidelines provide guidance on the implementation of Level 1 and Level 2 policy. Some
policy is included in theses guidance documents. NFS guidance with environmental compliance aspects include:
NFS 12 ~ NEPA Compliance Guideline, NFS 50 - Loss Control Management (hazardous materials management,
respiratory protection and hazard communication programs, and others), NFS 77 - Natural Resources, and NFS 83
~ Public Health (water and wastewater treatment system management).
Under Development and Planned
The entire NFS policy system is being revised. This provides an opportunity to address environmental
aspects more directly. There has been a broad call for input from NFS stakeholders on ways of strengthening policy
language relative to environmental programs.
Several NFS program offices are in the process of updating or developing new Level 2 policy with stronger
environmental language. Both the Concessions and Public Health policies are being revised. The Hazmat policy is
also under review and an Oil and Hazardous Materials Spill Response policy has been drafted.
Other efforts may result in environmental policy. For example, the Environmental Leadership program
currently under development includes environmental principles, which, if approved, could become policy. In
addition, a proposed Natural Resources Initiative (NRI) includes Principal 9 that states "The NFS will comply with
all environmental laws and apply the highest standards of environmental stewardship to its operations." The
Environmental Leadership program and other initiatives with environmental aspects have growing key stakeholder
involvement. An Environmental Leadership senior stakeholder meeting was held on January 6 and 7, 1999 and
included discussions on NFS environmental policy goals.
1-1
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CEMP Evaluation of the National Park Service
The NFS plans to share the messages from initiatives such as the Environmental Leadership program and
NRI internally by integrating it in management training and other "normal" channels, as well as externally to
concessioners and other stakeholders through training, conferences, and public information mechanisms.
Recommended Next Steps
The following are recommended next steps to more fully address Sub-Objective 1.1.1.
Develop a comprehensive environmental policy. To be most effective, this policy should
stand-alone and cross program lines. This policy should fully address traditional compliance
aspects, but also consider pollution prevention and "beyond compliance" aspects, such as
sustainability, which are key to the mission of the NFS. This policy should include and address
independent efforts currently underway. It should be developed with wide internal and external
participation at all levels to build consensus and assure completeness. The policy should establish
goals for key environmental indicators so that performance can be tied to policy requirements.
Educate all employees and park users on the content of and management commitment to a
robust environmental policy. NFS should include environmental policy review in staff and
stakeholder education (e.g., staff Compass training, concessioner training). In addition, NFS can
spread the policy message through periodic management-supported promotions such as
conferences, brochures, contract language, training, and web page posted documents.
Include specific reference to concessioners in environmental leadership policy. The NFS is
currently developing an "umbrella" policy on environmental leadership. The policy will reinforce
the NFS commitment to baseline environmental compliance, pollution prevention, sustainability,
and education. The Directors Order on environmental leadership should include a specific
reference to concessioner compliance with the policy.
Sub-Objective 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.
Several NFS budget processes have been established to account for environmental aspects. The Annual
Hazardous Waste Management and Pollution Prevention (HWMPP) team project funding review involves project
selection based on four categories:
Waste reduction and management;
Fuel storage;
Contaminated sites; and
Technical support.
Each category has ranking criteria. NPS planned to integrate the existing system into a Project Management
Information System (PMIS) in FY 1999. The annual natural resources program funding allocation process also
employs environmental management criteria.
Environmental due diligence reviews occur for property acquisition. The bureau also formed a
Contaminants Technical Advisory Group that meets quarterly.
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Under Development and Planned
Through the EPA/DOI Compliance Assistance Partnership, NPS offered itself as a pilot subject for a
CEMP study to obtain a Service-wide baseline environmental management system assessment and recommendations
on ways to improve these systems. Participation in this study may also improve NPS's working relationship with
EPA.
The Environmental Leadership program is being developed within the NPS to enhance the bureau's
environmental management systems. The program has broad NPS participation. It is intended to link independent
initiatives and move the NPS toward Service-wide environmental goals of environmental compliance, pollution
prevention and sustainability, and internal and external environmental education. Environmental staff and budget
requirements are being addressed as part of Environmental Leadership program development.
Regional environmental support capability is being expanded through the NPS internal audit program.
Regional environmental coordinators have been assigned for the program, park-level points of contacts are to be
established prior to site visits. Responsibility for environmental management and corrective actions identified
during the audits will be specified. The incorporation of environmental audit program data into the budget/funding
allocation process is also planned.
Recommended Next Steps
To integrate environmental management more effectively throughout the organization and meet
Sub-Objective 1.1.2, the following next steps are recommended:
Develop and provide environmental "awareness" training to all levels of management to
foster environmental compliance and sustainability concepts throughout the organization.
Broaden the scope of environmental categories and criteria (e.g., waste and water) in the
budget process so that all project funding requests are addressed in one integrated evaluation of
environmental aspects and priority.
Integrate environmental aspects in the resource allocation and planning process at the park,
region and headquarters level by requiring that environmental performance be specifically
addressed in strategic and general management plans.
Develop policy that recognizes and endorses support for the Service-wide need for funding
and personnel allocated specifically to environmental compliance.
Develop a Concessions Division environmental policy that mandates concessioners comply
with "Concessions Environmental Guidelines" (see Principle 3.2).
Modify concessions contracts and facility operating plans to include performance criteria
related to the Concessions Environmental Program (e.g. requirements for environmental
audits).
Incorporate environmental program needs into Concessions Program budget process. The
NPS Concessions Program should integrate environmental program development/implementation
needs into the budget allocation process for the Division. Elements of this budget process could
include:
Direction of funds from new sources, such as the 20/80% budget process, and
Use of partnership/cost sharing to provide integrated NPS staff/concessioner
environmental services (e.g. environmental auditing and training).
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Performance Objective 1.2 — Environmental Stewardship and Sustainable Development
The agency strives to facilitate a culture of environmental stewardship and sustainable development.
Existing
Environmental stewardship and sustainability are founding philosophies of the NFS. The NFS
Management Policies, Level 2 policies, and Level 3 guidelines such as NFS 11— Natural Resources, address
resource stewardship and sustainable design.
The Guiding Principals of Sustainable Design were published by NFS and are considered by some to be
the quintessential work on sustainable design. These guidelines and other sustainable design tools are on the NFS
"Renew" web site. NFS line item budget projects are designed following a sequence recommended in the Draft
NFS 70 ~ Design Process Guideline: The Built Environment. This guideline uses a "design for the environment"
approach that incorporates ecosystem planning, life cycle cost, value analysis, and choosing by advantage methods.
Alternative energy programs are promoted through on-going partnerships with the Department of Energy (DOE).
The NFS has an Environmental Quality Division within the Natural Resource Stewardship and Science
Directorate that is responsible for managing internal and external NEPA reviews, the NFS integrated pest
management program, and internal and external natural resource damage assessment and environmental response.
The NFS also reportedly established a site restoration cost recovery program that includes a potentially responsible
party search manual and a Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
manual.
Draft Environmental Leadership training has been developed. The training is geared toward program and
project managers and addresses environmental management, sustainability, and pollution prevention. The
Environmental Leadership senior stakeholder summit conducted in January 1999 also had a strong emphasis on
sustainability.
Regional and park-level efforts have also occurred. Green procurement training has been conducted
(Northeast and National Capital Area). Sustainable Re-Development Addenda have been prepared for selected
general management plans (GMPs) (e.g., Grand Canyon National Park).
Under Development and Planned
A Service-wide NRI is being developed and is supported by the Director. The NRI establishes natural
resource stewardship goals and programs that include resource planning, environmental stewardship, and education.
The ongoing Environmental Leadership program has a strong emphasis on sustainable practices. The
Denver Service Center is planning training telecast via satellite in partnership with academia. The NFS also
participated in the DOI environmental conference in April 1999, which had a focus on sustainability and green
procurement as well as other environmental topics.
The NFS is continuing its partnerships with DOE to conduct energy audits design and install alternative
energy systems. A Memorandum of Understanding (MOU) between the DOE Federal Energy Management
Program and NFS for participation in DOE regional contracts was signed in January 1998. A National Renewable
Energy Laboratory (NREL) MOU focuses on sustainable design for energy systems. Sustainable transportation
system demonstration projects are being conducted or are planned under a Department of Transportation/DOI MOU
signed in November 1997.
Regional sustainability programs are also being launched in the Midwest Region (MWR), Northeast
Region (NER), and Pacific West Region (PWR). Green team surveys and opportunity assessments are being
conducted in the NER and Sustainability Program Opportunity Projects are being conducted in the PWR.
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Recommended Next Steps
To more fully and efficiently address Sub-Objective 1.1.2 and to account for existing and planned
environmental management responsibilities (e.g., compliance) in Service-wide and regional sustainability initiatives,
NFS should implement the following:
Ensure communication and coordination between sustainability coordinators and
compliance coordinators (e.g., HAZMAT, Solid Waste, Fuel Storage Tank Coordinators). In
this way, compliance realities can be better understood and considered in sustainability project
planning and implementation.
Merge/coordinate various environmental initiatives and projects to minimize redundancy
and provide an integrated approach. This approach can provide a focus on sustainable
solutions, but within the context of a "compliance first" strategy. For example, sustainability
assessments could be coordinated with the environmental audit program. Sustainable pollution
prevention solutions could be promoted as the best solution for waste management compliance
issues during compliance assistance projects.
Ensure that sustainability and stewardship initiatives are integrated into the NFS
environmental management system. Build a system that will address all current issues and be
sufficiently flexible to address future needs. For example, the environmental management system
should integrate pollution prevention projects such as point source air permitting and
transportation plans designed to minimize traffic in the park, both which contribute to establishing
a program to sustain regional/park air quality.
Increase awareness of understanding and dealing with environmental impacts (i.e., NEPA).
One means to accomplish this is NEPA training for managers and staff. The Environmental
Quality Division offered this in the past. Training has not been conducted recently due to budget
constraints.
Enhance the enforcement capability and posture for actions damaging NFS resources (e.g.,
illegal dumping). The recent enforcement action conducted at Mojave National Park where a
large illegal dumping action was successfully prosecuted demonstrates that this activity occurs. It
is also a model environmental crimes team approach within the NFS that could be effective at
other locations.
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PRINCIPLE 2: COMPLIANCE ASSURANCE AND POLLUTION PREVENTION
Performance Objective 2.1 — Compliance Assurance
The agency institutes support programs to ensure compliance with environmental regulations and encourages
setting goals beyond compliance.
Two headquarters programs have the most involvement in management of environmental compliance
programs. The Parks and Operations Directorate is responsible for hazardous materials and waste management,
solid waste, water and wastewater treatment, CERCLA, storage tanks and PCB management, energy and water
conservation. The Natural Resources Directorate manages the NFS NEPA and pest management programs. There
are some cross-directorate environmental management programs. An example is the management of air and water
pollution sources in which Park Operations is responsible for park pollution source management, while Natural
Resources is responsible for regional air and water quality. Similarly, affirmative procurement issues effect both the
Administration Directorate (Contracting and Procurement) and the Parks and Operations Directorate.
Environmental compliance guidance is currently distributed via standard means (i.e., a hard copy is sent to
regions for dissemination to parks). Guidance has been promulgated for hazardous waste management, solid waste
management, CERCLA compliance, fuel storage tanks, water and wastewater treatment (Public Health Service),
NEPA, and pesticide management, affirmative procurement (Contracting Officers Technical Memorandum 93-1)
and others. There is no formalized regulatory update process. The NFS relies on information provided by the DOI
OEPC and ad hoc sources for information.
The NFS is participating in a EPA/DOI Environmental Compliance Assistance Partnership. Partnership
projects include the CEMP study. There are also regional EPA/DOI and NFS partnerships (e.g., Inter-Mountain
Region (IMR)/EPA Region 8 Compliance Assistance Projects, OEPC San Francisco/EPA Region 9 Hazardous
Waste Management Training).
A draft Environmental Audit program document and 21 draft Envirocheck Sheets have been developed for
the NFS audit program. Audit program training was also conducted in October 1998. Regional audit initiatives
have also been developed. P2OAs have occurred at 76 locations in the IMR; Compliance Assistance Projects
(CAPs) have been conducted at 12 parks in the Midwest Region (MWR) and National Capital regions. Contracted
audits have been conducted at five locations in the Southeast Region (SER).
Under Development and Planned
The draft Environmental Leadership implementation strategy documents environmental compliance and
beyond compliance sustainable practices as key objectives. Beyond compliance goals are to be integrated into the
NFS strategic plan through the Government Performance Results Act (GPRA) process. A number of ongoing
projects have been incorporated in the draft Implementation Strategy. Other tasks have been identified that address
current deficiencies in the NFS environmental management system.
Twenty-eight Envirofact Sheets are in the final phase of production. They provide background compliance
information and serf-assessment checklists for waste streams, environmental compliance, and management programs
at parks. The Envirofact Sheets were disseminated via the Internet in FY 1999. Additional Envirofact Sheets are
planned as needs are identified.
The National audit program is currently under development. Thirty draft Envirocheck Sheets (i.e.,
environmental audit protocol sections) have been prepared and are undergoing review.
Audits will be conducted by individual regions with oversight and program management by headquarters.
The audit program is being designed to meet the following objectives:
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Establish baseline compliance;
Identify needs for compliance guidance;
Encourage pollution prevention as a management approach;
Elevate issues to upper management;
Encourage serf-audit and reporting; and
Address non-regulated risk.
Following completion of baseline audits, periodic audits of each park-level facility are planned. A system will be
developed to track corrective actions identified during the audit program.
The NFS Concessions program is developing new environmental standards and a self-audit/awards
program. A regional pilot program in hazard analysis is underway in the IMR. Staff from NFS headquarters and
regions have participated in the EPA/Civilian Federal Agency (CFA) Task Groups and Roundtable and intend to
participate in the future.
Recommended Next Steps
The following steps are recommended to more fully address Objective 2.1:
Establish a reliable regulatory information transfer and updating system to communicate
changing environmental compliance needs to parks.
Develop a multi-media compliance workgroup to ensure that all environmental program areas
are addressed and compliance requirements and goals are evaluated comprehensively. For
example, ensure that air quality and water quality issues are addressed by involving Natural
Resource Air Quality and Water Quality Divisions in program development. This workgroup
should be established at an appropriate level to ensure adequate management support.
Include an assessment of the risk of non-compliance in the budget assessment and planning
process and strategic planning process at the park, region and Service level.
Seek and exploit opportunities to make good use of DOI (OEPC), other bureaus and other
agencies for cost-effective solutions to department-wide challenges. These could include:
Training;
• Policy;
Quality assurance - audits;
Regulatory updating;
Reporting; and
Sharing lessons learned.
Beyond compliance activities
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Performance Objective 2.2 — Emergency Preparedness
The agency develops and implements a program to address contingency planning and emergency response
situations.
The NFS instituted an Incident Command (1C) system that is used for fire and flood management. The
program includes both national and regional incident commanders. Superintendents are provided with 1C training
through the Parks and Education Directorate fire management program.
Other Service-wide programs include a dam, bridge and road safety program managed through the Park
Facility Management Division and a natural resource damage assessment (NRD A) program for oil spill response
and assessment managed through the Environmental Quality Division.
Spill response systems at the park level vary widely. Comprehensive emergency response teams are
established at some parks (e.g., Padre Island). Over 500 park staff have received hazardous waste operation and
emergency response (HAZWOPER) training. Some parks have spill prevention, control, and countermeasures
(SPCC) plans, facility response, OSHA emergency response, and/or Resource Conservation and Recovery Act
(RCRA) contingency plans. However, a comprehensive needs analysis and park emergency planning compliance
assessment has not been completed for the NPS.
Under Development and Planned
SPCC, facility response plans (FRP) and RCRA contingency plan applicability and plan deficiencies for
parks will be assessed through the national audit program. Draft Envirocheck Sheets have been prepared for both
SPCC and RCRA programs.
A hazard analysis pilot is underway at five parks in the IMR. Plan automated response and communication
system software to develop park integrated contingency plans is being develop by the Environmental Quality
Division with the assistance of the University of Virginia.
Spill response management has historically been divided between the Park Facility Management Division
and Environmental Quality Division. Directors Order #79 on emergency response is being prepared to clarify roles
and responsibilities.
Recommended Next Steps
Establish park-level emergency response task forces and procedures to enhance the emergency
response and contingency planning process at Park facilities. Procedures should include the periodic review of park
emergency response and contingency plans to ensure currency and compliance with regulatory requirements.
Ensure adequate facility hazardous waste training for emergency response and preparedness.
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PRINCIPLES: ENABLING SYSTEMS
Performance Objective 3.1 — Training
The agency ensures that personnel are fully trained to carry out the environmental responsibilities of their
positions.
The NFS does not currently have a Service-wide environmental training curriculum. The only consistently
offered training courses are HAZWOPER and integrated pest management. Approximately 10 HAZWOPER
training courses are offered per year. The Public Health Service currently conducts these courses. The course is a
NPS customized program and consists of four hours of HAZCOM training, an eight-hour HAZWOPER refresher
training, 24 hours of HAZWOPER training, and two to four hours of pollution prevention training. The
Environmental Quality Division offers the integrated pest management training to park and regional integrated pest
management coordinators.
Over the last five years, other courses have been offered on a sporadic or one time basis. These have
included training on CERCLA, hazardous waste, underground storage tanks, solid waste, and NEPA compliance.
Regions have offered additional, unique environmental training (e.g., green procurement, hazardous materials
transport, SPCC, etc.). NPS personnel, other bureaus and agencies, NPS contractors, and academic institutions
provide this training.
Bureau of Land Management (BLM) environmental compliance training courses have been made available
to the NPS. These courses include an introduction to environmental compliance and pollution prevention,
emergency response/removal actions and emergency preparedness, environmental site characterization, hazardous
materials recognition for field employees, and CERCLA site assessment.
The NPS has conducted several pilot training courses over the last year. A draft Environmental Leadership
training for managers was piloted in April 1998. In November 1998, a distance learning pilot was conducted on the
NPS Envirofact Sheets through a partnership between the Hazardous Waste Management and Pollution Prevention
Team and Indiana University. The NPS has also begun investigations into distance learning opportunities in
partnership with the USEPA Region 8 and Front Range Community College in Colorado.
Under Development and Planned
The NPS maintenance training program in cooperation with the Hazardous Waste Management and
Pollution Prevention Team, in cooperation with Indiana University is developing a core environmental training
curriculum. This process involves the identification of "essential competencies" for all relevant positions in the
NPS and the development of a plan on what and how to deliver the required training.
In conjunction with the development of the curriculum, the NPS is continuing to investigate training
presentation methods. A distance learning pilot in hazardous waste management is underway. The NPS is also
planning to move forward with the Environmental Leadership training first piloted in April 1998. A pilot of the
complete training course was held in 1999.
Recommended Next Steps
The following are recommended next steps to more fully address Objective 3.1.
Expand environmental training requirements to address training needs beyond
"traditional" environmental career paths. Personnel conducting environmental functions are
in a variety of career tracks, particularly at the park level, where staff often have multiple duties.
For example, environmental compliance jobs such as hazardous materials management at the park
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level may involve the Safety Officer (Rangers), Buildings and Utilities Staff (Maintenance), Fire
Management and Aviation personnel, and Contract and Procurement Staff (Administration).
Develop an integrated training function. This should begin with a training needs assessment
which can reflect various NFS career fields. The integrated training function should address a
variety of environmental management programs including:
Environmental compliance;
Pollution prevention;
Sustainable practices;
Energy;
NEPA;
Integrated pest management;
Natural resources;
Environmental management systems; and
Health and safety.
The NFS environmental training program should extend beyond first line workers to senior staff
and managers and provide the appropriate type and level of training. For example, HAZWOPER
training may not be appropriate for personnel only requiring HAZCOM training or a
comprehensive RCRA course may not appropriate for staff at a park that is defined as a
conditionally exempt small quantity generator under RCRA.
Pursue training partnerships where resources are already available or efficiencies can be
gained. Joint training opportunities should be implemented with other DOI offices and bureaus.
The EPA should be used as a training resource both at headquarters and the regions. Other
government agencies should also be explored such as the Department of Defense (DOD) and
DOE.
Develop a tracking system to verify that training is received and completed, particularly
where there is a regulatory requirement for the training. This program should be developed on a
Service-wide basis to ensure consistency.
Training requirements should be reflected in position descriptions; completion of training
should be recognized in employee evaluations.
Conduct a training needs assessment for concessioners. The information from this needs
assessment should be considered in the training needs assessment and training implementation
plan for the NFS.
Conduct awareness training for concessioners. This training should address general
environmental stewardship, environmental issues of particular importance to concession
operations, and NFS and Concessions Division-specific environmental policy programs and
procedures.
Performance Objective 3.2 — Structural Supports
The agency develops and implements procedures, standards, systems, programs, and objectives that enhance
environmental performance and support positive achievements of organizational environmental and mission goals.
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The NFS has established planning and budget processes that can account for environmental impacts and
guidance documents which can enhance environmental performance. Some organizational goals have been
established.
There is currently no formal process for the review of environmental regulations and the dissemination of
updated information to the field. The Hazardous Waste Management and Pollution Prevention Team subscribes to
the Environmental Reporter published by the Bureau of National Affairs. The Reporter is reviewed and regulatory
updates are disseminated to the field on an ad hoc basis.
A formal NEPA process to evaluate environmental impacts has been developed within the NPS. A NEPA
Guideline, NPS 12 is currently used for all NPS proposed actions. The Environmental Quality Division at
headquarters manages the NEPA program. Procedures have been developed for internal and external NEPA
evaluation, documentation, and review. The NEPA process is addressed in the NPS Management Policies and
Level 2 policies.
The new Service-wide PMIS budget prioritization processes can include environmental ranking criteria. A
priority ranking process is in place for hazardous waste management and pollution prevention-specific program
funding.
Manuals and guidance containing operational procedures related to environmental management have been
prepared and updated. Manuals include an Integrated Solid Waste Alternatives Program (ISWAP) Manual (1996),
Hazardous Waste Handbook (1994), CERCLA Manual (revised in 1998), Fuel Storage Tank Management
Handbook (1996). NPS Guidance include NPS-77, Chapter 2, Integrated Pest Management (revised 1997),
NPS-50, Loss Control (OSHA programs) (1991), NPS-83, Public Health (Water and Wastewater Treatment)
(1993).
A draft Environmental Leadership implementation plan provides an environmental management
system-based three-year strategic plan for the NPS. The plan was developed based on park level, regional,
Washington Area Support Office (WASO) and senior NPS management stakeholder input. General mission and
goals for Environmental Leadership have been established as part of the planning process. A workgroup consisting
of park, regional and WASO representatives from various programs are spearheading the Environmental Leadership
effort.
Although general goals have been establish through the Environmental Leadership and strategic planning
processes, defined, measurable, environmental program goals for most environmental programs at the national level
have not yet been established. The only documented NPS goal is for solid waste reduction and recycling under the
ISWAP. The IMR has established a specific set of environmental performance goals through its Goals 2000
program.
Under Development and Planned
Implementation of various aspects of the Environmental Leadership strategic plan is currently underway.
These include policy development, development and promulgation of several environmental management tools (e.g.,
Envirofact Sheets), and others. Full implementation of the plan was planned for 2000.
The NPS is in the process of reviewing its Level I Management Policies and Level 2 policies to reflect
Environmental Leadership goals and ensure completeness relative to environmental programs. A Level 2 policy on
Environmental Leadership is under development. This policy will be overarching and provide comprehensive
standards and procedures for the majority of environmental management programs within the NPS. These will
include hazardous materials and waste management, affirmative procurement, fuels management, energy and water
efficiency, and others. An environmental audit policy is also planned. This policy may be stand-alone or part of the
Environmental Leadership policy.
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Several other Level 2 policies and guidance are being revised. These include those for the Public Health
Service (NFS water and wastewater treatment), Risk Management (OSHA programs) and NEPA compliance. An
updated HAZWOPER Manual and Lands Acquisition Guidance and Forms are currently being developed.
The Environmental Leadership training which is being developed, will provide awareness training in
environmental management systems, sustainability, contracted relationships, and other environmental management
programs.
Two objectives of Environmental Leadership strategic plan are the linking of action items to GPRA based
Service-wide strategic planning goals and the integration of the plan with other NPS initiatives (Natural Resource
Initiative, DOE/NPS Energy Partnership, Sustainability Initiatives). The later is already underway, the former is
one of the higher priority action items in the Environmental Leadership implementation plan. The encouragement
and promotion of Centers of Environmental Excellence is also planned.
Recommended Next Steps
The following are recommended next steps to more fully address Objective 3.2.
Clearly and explicitly link environmental compliance and sustainability needs and any
results of needs analysis to budget and resource planning and requests.
Ensure that all environmental-related initiatives throughout the organization are integrated
and coordinated to minimize redundancy, share lessons learned, and provide consistency
throughout the organization. This includes national initiatives (e.g., Natural Resources Initiative,
Energy Initiatives, Cultural Resource Program, Training and Development Program, Ranger
Activities) and regional/program initiatives (e.g., regional audit programs, regional sustainability
and pollution prevention programs, Denver Service Center and regional design processes).
Extend the National Environmental Leadership program to the regional and park level.
Establish regional and park Environmental Leadership strategic plans which will complement the
national plan and consider regional/park specific goals and needs.
Establish a process to review and revise existing environmental management structural
supports (i.e., procedures, standards, systems, programs, objectives, and goals) to ensure
performance and currency. For example, if a new Executive Order is promulgated that establishes
new federal agency energy efficiency goals, the bureau should have processes in place to identify
these new requirements and change policy, standards and implementation tools to meet these new
requirements. The NPS must also be able to react to and change procedures if they are determined
to be inefficient or outdated (e.g., technological changes).
The Concessions Division should develop NPS "Level 3" guidelines that outline operational
requirements for concessioners to comply with federal, state, and local regulations, and DOI
and NPS policy (at a minimum).
Performance Objective 3.3 — Information Management, Communication & Documentation
The agency develops and implements systems that encourage efficient management of environmentally related
information, communication, and documentation.
The Hazardous Waste Management and Pollution Prevention Team manages an Environmental
Information Management System (EIMS) to track their environmental project status. The bureau also maintains a
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tracking system for internal and external NEPA actions. The Team maintains a full time consultant on-site at
headquarters as an environmental information advisor.
Information management projects considered by the Hazardous Waste Management and Pollution
Prevention team are ranked like all other projects based on established environmental criteria. These projects
include green products databases, web site design, document conversion to web-compatible files for uploading.
DOI and the bureau have a number of electronic environmental information management/ communications
systems. The Park Facility Management Division manages a Green Alert bulletin board on which NPS personnel
can post information on environmental compliance, pollution prevention, and sustainable design and practices. The
IPM program of the Environmental Quality Division has an on-line pesticide application approval and reporting
system. The bureau also maintains a "Renew" web site that provides information on energy and water efficiency
and sustainable design. OEPC maintains a web site that provides some policy and guidance and provides links the
CERL Team Guide for those with password access. Regional web sites also provide information on sustainability
and NEPA program compliance.
In addition to distribution of materials by electronic means, hard copy documents such as manuals and
memorandum are distributed as needed. The typical distribution is to regional support office environmental
program coordinators who distribute the materials to the field.
Under Development and Planned
The PMIS, which is a Service-wide interactive, web-based system is likely to supercede the existing EIMS.
However, it is anticipated that the functionality (e.g., environmental ranking criteria) of the existing system will be
maintained.
The CERL Team Guide is planned to be used to update federal regulatory requirements. The NPS is
developing a Service-wide audit reporting and tracking system to support the national audit program currently under
development.
The Hazardous Waste Management and Pollution Prevention team is planning to offer Envirofact Sheets,
guidance documents and other environmental management tools on the web. As part of the Environmental
Leadership implementation plan, this web site may be integrated with other NPS environmental management web
sites such as the Renew energy and sustainable design site.
Recommended Next Steps
The following next steps are recommended to improve the existing, underway and planned information
management, communication and documentation systems at the NPS.
Develop an integrated environmental information strategy. Such a strategy should include the
following:
Assessment of critical information needs;
Inventory of existing information sources;
Strategy that integrates existing tools (national and regional, internal and external),
considers emerging technologies and has an architecture that will provide for expansion;
and
Implementation program to address information gaps by priority.
The NPS should establish or rely upon a periodic organization-wide update (e.g., newsletter) to
provide a reliable communication mechanism for routine but important information.
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Develop and implement guidance on centralized filing and recordkeeping systems at the
regional and park level for all environmental records and documents. Such an approach will
help assure compliance with regulatory reporting and recordkeeping requirements and facilitate
park/region internal reporting. It can also be helpful in identifying environmental management
deficiencies on an ongoing basis and at the time of audits, and will provide a consistent program
which environmental program managers and superintendents will understand even if transferred
from one location to another.
The Concessions Division should develop electronic (Internet) and other systems to
effectively transmit environmental program information and data to concessioners (e.g.
policy and procedures, environmental audit data).
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PRINCIPLE 4: PERFORMANCE AND ACCOUNTABILITY
Performance Objective 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.
Park superintendents and regional directors maintain line responsibility for park and regional activities,
respectively.
Regional environmental program coordinators have been identified in each region. These coordinators
address Hazmat, CERCLA, underground storage tanks, and solid waste programs. Staff range from a single
coordinator in a region, to coordinators for each of the programs. NEPA environmental compliance coordinators
are also present in each region. These staff have no line authority. Their role is primarily advisory; they also assist
in the annual environmental budget prioritization process.
Regional environmental audit coordinators have been designated to conduct the NFS internal audit
program in their regions. This is not a new position, but an additional duty for the existing regional environmental
program coordinators.
Park level environmental coordinators have been established in less than 15 percent of the parks.
Environmental program management responsibility at the park resides with the superintendent. Maintenance staff,
the park safety officer, or others conduct day-to-day operations, often as a collateral duty.
Under Development and Planned
The NER is developing an accountability management system for its park superintendents. The system
includes a best practice measurement criteria on Environmental Leadership which states that the park must, "meet or
exceeds all environmental laws, and fosters sustainability in all aspects of park operations."
Under the Service-wide environmental audit program, NPS plans to develop park-level audit points of
contact. These individuals may be responsible for coordinating the audit and follow-up actions. A Service-wide
environmental coordinator position has also been proposed. This coordinator would help implement the NPS
Environmental Leadership strategy currently under development. The coordinator would be responsible for
overseeing multi-directorate environmental management activities including some with regulatory compliance
aspects (e.g., hazardous waste management, affirmative procurement). Direct line responsibility for compliance
would still reside with the Director, Regional Directors, and Superintendents.
The Environmental Leadership training which was piloted in April 1998 provides awareness of
management responsibility for environmental compliance programs.
Recommended Next Steps
The following next steps are recommended to more fully address Objective 4.1.
Assign responsibility and authority to manage environmental programs and ensure
environmental compliance at each park. These individuals should be responsible for managing
environmental information systems and assuring environmental training and facility management
requirements are met at the park level. They should be responsible for all overseeing all aspects
of environmental management so that environmental compliance can be addressed through an
integrated approach. They should be answerable to the superintendent on park environmental
performance. The time commitment for this position should be commensurate with the
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CEMP Evaluation of the National Park Service
complexity of the park and associated environmental programs/issues. The position may be
accomplished as one of several assigned duties at a smaller park. At a larger park, the duties may
be full-time.
Establish environmental coordinators in each region. These individuals would serve as a
single environmental management point of contact for oversight and coordination of regional
environmental programs and a technical support clearinghouse to the parks. Responsibilities
would include environmental information dissemination, coordinated reporting and budget
requests, and integration of tasks with multi-program implications (e.g., green procurement that
involves facility management (requisition) and administration (contracting and procurement).
Efforts of individual regional program coordinators would not necessarily be eliminated, but could
be facilitated and coordinated. The coordinator would be accountable for ensuring parks and
headquarters have the information necessary to be environmentally compliant.
Establish a policy on environmental accountability and include this in the Service-wide
environmental policy (see Objective 1.1). This policy could serve to standardize expectations
across the bureau. The policy should establish environmental compliance as a minimum
requirement for parks, not as a best management practice.
Provide a Service-wide environmental coordinator with the authority to resolve conflicting
spheres of authority and designate line responsibility where not established (e.g., emergency
response, water and air pollution control). This position should not be expected to have full
responsibility for overall bureau environmental performance.
Performance Objective 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.
The DOI and the NFS have award programs for exceptional environmental achievement. DOI and NFS
environmental achievement awards may be given to specific individuals, project teams, or external stakeholders
(organizations and contractors). DOI and NFS also established awards for natural resource stewardship
(Departmental Conservation Award and Directors Award for Natural Resource Management).
Environmental criteria have been incorporated into performance standards for most regional environmental
program coordinators and for a number of NFS headquarters staff (6 to 8 full-time equivalents). These individuals
reside primarily in the Hazardous Waste Management and Pollution Prevention Team and Environmental Quality
Division. The performance criteria for these personnel are for duties in an advisory capacity, which are not based
on park/region/bureau performance.
Environmental performance is infrequently used as a performance measure for park staff. Only a small
number of park have staff accountable for environmental programs (safety officers or environmental protection
specialists).
Under Development and Planned
The development of standardized Environmental Leadership language is planned for position descriptions
and performance standards as part of the Service-wide Environmental Leadership program.
Incentive programs (monetary rewards and publicity) are planned to promote Centers of Environmental
Excellence in the NFS. It is anticipated that monetary rewards will help offset some of the cost associated with
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CEMP Evaluation of the National Park Service
providing assistance outside standard job requirements. The existing NFS environmental awards program is
planned to be expanded to include all career fields and programs. Monetary awards and protocols for regional and
park Environmental Leadership rewards are planned.
Recommended Next Steps
The following next steps are recommended to enhance the performance standards and reward programs at
the NFS:
Measure personnel performance in light of the environmental responsibilities that have
been assigned.
Develop organizational environmental compliance goals. Use this information to develop and
customize regional and park level goals.
Ensure that park-level personnel with environmental management and/or compliance
responsibilities have those responsibilities included in their performance standards. Link
individual environmental compliance and management performance standards with organizational
goals. Also ensure that personnel environmental performance goals are linked specifically to
compliance as well as other sustainable practice measures.
Ensure that performance criteria are formally incorporated into the managerial and
employee performance evaluation process. Performance goals and standards are not effective
unless they are instituted. Make sure that environmental criteria are adequately weighted based on
the level of accountability and responsibility. Provide means to penalize poor performance as well
as reward good performance.
Institutionalize environmental compliance into the NFS by fostering the development of
environmental compliance as a professional and valued career path in the NPS. In addition, make
environmental management experience a required Knowledge Skills and Abilities (KSA) for NPS
Managers. This will 1) institutionalize an understanding of environmental management
importance and issues in senior management (having experienced it first-hand) and 2) generate a
pool of professionals to do the environmental management work by creating the market.
Promote the DOI and NPS environmental achievement awards so that they become valued
rewards within the department/bureau and also with other Agencies. As a bureau that has a
mission responsibility of environmental stewardship, an environmental achievement award should
be highly valued. Recognition by the Director and public promotion of the program and recipients
should be considered as well as monetary compensation.
Develop an environmental recognition program for concessioners that have demonstrated
consistent environmental compliance and implemented "beyond compliance," pollution
prevention, and sustainable operations.
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CEMP Evaluation of the National Park Service
PRINCIPLE 5: MEASUREMENT AND IMPROVEMENT
Performance Objective 5.1 — Evaluate Performance
Sub-Objective 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.
For the past few years, selected NFS regions have developed and implemented systems to collect
environmental performance data. These have included:
Environmental audits in the SER where a contractor has completed five audits to date.
• • CAPs in the MWR, where 14 of 56 park units have been addressed and in the NER, where 3 of 96
park units have been addressed. CAPs are traditional environmental compliance audits with an
emphasis on pollution prevention as a preferred approach for follow-up actions. The MWR also
includes safety and health issues in the CAP scope.
Pollution prevention opportunity assessments (P2OAs) conducted in the IMR. Since 1995, 79 of
81 park units have been addressed.
RCRA Subtitle C compliance audits completed by the Alaska Department of Environmental
Conservation. These audits are funded by EPA through the EPA/DOI partnership. Of the 13
planned, two have been completed.
In 1998 the NFS initiated a national environmental auditing program in response to DOI Departmental
Manual 515, Chapter 2. Initial steps taken to establish the new program included assignment of a national program
manager and regional program managers. A national program orientation and planning meeting was held (10/98)
with all regions participating. Substantial regional input was incorporated into the national program.
The US Public Health Service (PHS) conducts sanitation orientated evaluations of park-units independent
of the audit program. These address water and wastewater treatment systems and food services.
Under Development and Planned
The NPS plans to strengthen the national auditing program to ensure consistency in evaluation, follow-up,
and information management, including reporting. To do this, the following are expected:
Development and dissemination, internally and externally, of an audit program guide that will
document key aspects of the national program, including expectations for regional program
implementation.
Development and implementation of an auditor training program. Currently envisioned as week
of hands-on auditing instruction and a periodic refresher course.
Development and dissemination of NPS audit tools, including: compliance-focused checklists
emphasizing pollution prevention and sustainable practices, NPS functional summaries, reporting
formats, and compliance assistance tools such as fact sheets. In the initiation phase, the national
program is expected to provide regional program staff with these tools. The tools will specify
minimum national program requirements. Regional audit program staff will be allowed to
customize the tools to address unique regional needs or priorities, as long as national program
needs are met.
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CEMP Evaluation of the National Park Service
Development and deployment of an audit information management and reporting system. Data on
audit findings and corrective action status will be maintained in a regional/national database to
facilitate efficient periodic and ad-hoc analyses and reporting. The database is expected to be
used to evaluate environmental performance and identify areas requiring additional attention.
Development and implementation of a NFS audit protocol that is unique to NFS facilities and
operations. The protocol will be designed for an internal audit function and wide-ranging staff
experience and expertise.
Development of audit criteria for evaluating management support for environmental programs at
the park-unit level.
Development and implementation of an audit data utilization plan. Audit data will be used in
management-level decision-making on topics including: project funding, training, policy, staff
performance evaluations, and environmental management program planning.
The NER and the PWR plan to develop supplemental audit criteria. In the regard, the NER is developing
"green" audit criteria and the PWR is developing "sustainability" audit criteria. These criteria may be addressed
during regional audits or by a separate evaluation process.
Recommended Next Steps
The following are recommended next steps to more fully address Sub-Objective 5.1.1.
Develop and implement a quality assurance (QA) function for the audit program. At a
minimum, the QA function should be designed to ensure national consistency in auditing and
evaluate the effectiveness of the audit program. Suggested quality indicators include: (1) number
and severity of audit findings; (2) number and timeliness of corrective actions; and (3) quantities
of pollution prevented. Quality indicators should be linked to audit program performance
objectives.
Ensure that root cause analysis is included in park-level audits. Root cause issues should be
addressed as both audit findings and as the basis of corrective actions. Root cause analysis should
be linked to EMS issues already planned to be addressed in audit criteria and account for portions
of the CEMP relevant to park-units.
Ensure that all audit functions remain independent and objective. To be independent,
auditors must be organizationally separate from the facilities and operations audited. To be
objective, auditors must not have an actual or perceived conflict of interest; must not suffer
negative consequences or enjoy rewards resulting from audits; and must not have a general bias
that affects their work. To do this, NFS may find it necessary to implement organizational
changes, such as creating an independent audit group.
Ensure that audit data and information is widely used in NFS facility and organization
management. Audit information should be heavily weighted and integrated into project
planning, budgeting, and performance evaluation decisions. Audit information should routinely
be considered by senior management as a reliable indicator of environmental performance at the
park level and higher.
Ensure that facility-level concession operations are included in the service-wide
environmental auditing program currently being implemented and that environmental
performance results should be tied to contract evaluation.
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CEMP Evaluation of the National Park Service
Sub-Objective: 5.1.2: Institute Benchmarking — The agency institutes a formal program to compare its
environmental operations with other organizations and management standards, where appropriate.
Formal and documented benchmarking activity comparing the NFS environmental organization against
others and standards has not occurred. To a large extent, NFS environmental staff consider their organization and
activities unique, and therefore incomparable.
During the interview portion of this review, various NFS staff indicated that they were leaders in
environmental management simply because, "they were the Park Service." Thus, there appears to be a perception
that NFS environmental management is a de facto standard for other organizations, and therefore it is not necessary
to benchmark against other organizations.
A few NFS staff expressed some interest in understanding how their EMS and compliance record
compared with other civilian federal agencies; however, evidence of a widespread NFS commitment to a
comprehensive inter-organizational understanding was absent. Such an absence seemed incongruous with the
recently launched Environmental Leadership program. However, "Leadership" in this case, seems to refer to the
development of leadership internal to the NFS, not of the NFS compared to other organizations. This approach
overlooks the potential benefit of learning from others.
Informal benchmarking activities have included:
Occasional NFS staff participation in EPA Regional and headquarters roundtable discussions;
Staff participation in the DOI environmental and energy task groups;
Staff participation in internal (NFS and DOI) environmental meetings as presenters or attendees;
and
Staff participation in external interest groups and professional associations, especially related to
sustainability.
It is entirely possible that NFS is an EMS leader in some areas, however, benchmark data to demonstrate such
leadership was not available.
Under Development and Planned
Formal EMS benchmarking activities were neither under development nor planned.
Recommended Next Steps
Benchmarking offers an attractive path to NFS EMS performance improvement through adoption of
practices already proven to be effective by other organizations. To do this the NFS should take the following steps:
• • Identify specific management areas most likely to benefit from benchmarking. These
include key EMS elements defined by the CEMP (e.g., auditing, training, and others) and key
NFS functional or organizational characteristics (e.g., civilian federal agency, natural or cultural
resource management, or eco-tourism). These may be public or private.
Participate in or conduct periodic documented benchmark studies. Use the resulting
information to advance development of a refined EMS.
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CEMP Evaluation of the National Park Service
Explore a formal EMS protegee relationship with a more advanced organization in each of
the targeted areas identified in the previous step. One organization is not likely to be a perfect
mentor in all relevant areas so several may be necessary.
Maintain a constant level of benchmark activity with other DOI bureaus and offices. Given
many similarities among these organizations, the participants (NFS and other DOI units) should
reap significant short-term benefits. This activity will likely result in a more cohesive and cost-
effective DOI-wide EMS.
Explore the possibility of mentoring another organization. By serving as a mentor, the NFS
should be motivated to maintain a more advanced EMS. The mentored organization may be
public or private. A regional or state park organization may be a good candidate.
Support and encourage active staff participation in relevant professional organizations and
conferences. This should be considered an essential activity for key staff career advancement.
Performance Objective 5.2 — Continuous Improvement
The agency implements an approach toward continuous improvement that includes preventive and corrective
actions as well as searching out new opportunities for programmatic improvements.
Suggestions for environmental management improvement within NFS are generally encouraged. Some
specific mechanisms include:
Annual regional NFS environmental coordinators meetings. At past meetings a list of action items
for improvement was developed and included in staff objectives.
The Green Alert BBS is an internal electronic communication system to share information on
environmental experiences. The BBS also has been used to solicit input on environmental issues
and to post notices on issues of broad interest.
The MWR newsletter "CAP Tion" focuses on sharing information on audits (i.e., CAPs) lessons
learned, compliance issues, and pollution prevention.
Informal networks of focused interest groups. Some examples include the sustainability task
group, and groups on solid waste management. Additionally, when groups assemble for regional
training, (e.g., HAZWOPER) there is often informal discussion about ideas for environmental
program improvement.
The PWR assembles a meeting of zone coordinators annually where EMS issues are raised.
Environmental projects are considered and discussed at annual budget meetings. These typically
focus on facility (e.g., building) improvements.
It is clear that NFS staff eagerly seek information on EMS improvements in multiple ways; however,
operating procedures for environmental management are evaluated by NFS regions and headquarters on an
as-needed, rather than periodic, basis. In addition, "sustainability champions" actively seek lessons learned from
other agencies, the commercial sector, and international organizations. In general, the onus for continuous
improvement efforts appears to lie with committed individuals. An organization-wide continuous improvement
mechanism addressing the NFS EMS was not apparent.
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CEMP Evaluation of the National Park Service
Under Development and Planned
The environmental audit program is expected to be used extensively to identify opportunities for
improvement.
The audit tools "EnviroCheck Sheets" will provide information on lessons learned to educate both
auditors and staff at audited entities during site visits.
Regional based audit programs will allow internal comparisons and sharing of best management
practices.
Root-cause analysis will be included in audit findings to identify underlying needs which, if
addressed, will prevent future occurrences.
Audit data will be extrapolated to identify national or regional needs so they can be addressed
earlier.
The Draft Environmental Leadership program training is expected to include lessons learned in
key environmental management system areas. Examples include procurement, training, response,
and waste management.
Recommended Next Steps
The following steps are recommended to the NFS to establish and maintain a continuous improvement
process.
Seek ways to integrate compliance issues into other environmental or green initiatives. All
related initiatives must acknowledge the importance of regulatory compliance.
Conduct periodic review of operating procedures. Most aspects of NFS operations are
addressable by an EMS. Consequently, all NFS operational procedures should be reviewed
periodically for current EMS issues. This includes, for example, internal operations, concessioner
and other contracted relationships, and visitor programs. Ensure that identified improvements are
incorporated into the next planning cycle.
Formalize an organization-wide EMS improvement suggestion system. The system should be
open to staff, concessioners, visitors or others. Ensure that suggestions are considered by
management with sufficient knowledge of EMS objectives and with authority to implement.
Consider implementing a reward system for "best" suggestions.
Employ results of environmental audit program and related root cause analyses to identify
opportunities for EMS improvement (not just compliance) and periodically assess the
effectiveness of corrective actions.
Establish partnerships with "Best in Class" organizations to jump start ideas for EMS
improvement. These leading organizations can be identified from benchmarking activities. See
related recommendations in 5.1.2 on mentor and protegee relationships.
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CEMP Evaluation of the National Park Service
MATRIX OF CEMP FINDINGS AND RECOMMENDATIONS
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CEMP Study of the National Park Service
Principle 1: Management Commitment
Performance Objective: 1.1 Obtain Management Support
Sub-Objective: 7.7.7 Policy Development - The agency establishes an environmental policy followed by an environmental program that
complements its overall mission strategy.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. Current policy (1988) addresses
environmental aspects (e.g.
recycling, waste management)
as part of overall Management
Policies. Compliance addressed
in :
• CH 2: NEPA
• CH 4: Air and Water
• CH 9: Water, Wastewater,
Hazmat, Toxic Waste, and
Solid Waste.
Overall "compliance" is
implicit.
2. Special Directives and Staff
Directives (considered internal
working policy) address waste
management, USTs, ISWAPS,
pesticide use, and other
environmental programs.
Entire policy system is under revision at this time.
1. Existing Management Policies are under
review (~10 year cycle), providing
opportunities to address environmental
aspects more directly. Broad call for
involvement.
2. Various efforts addressing environmental
policy:
• Proposed EL initiative includes
environmental principles which, if
approved, could become policy.
• Proposed NR initiative addresses
environmental compliance in Principle
No. 9. "The NPS will comply with all
environmental laws and apply the highest
standards of environmental stewardship to
its operations."
(EL , NR, and other initiatives with environmental
aspects have growing key stakeholder
involvement.)
• Concessions Operations is revising
environmental policy applicable to
contracted services.
• Hazmat policy collection under review.
Share results of
initiatives (e.g. EL and
NR) internally and
externally (e.g.
concessions) through
management training
(e.g. EL) and "normal"
channels.
Obtain additional input
on NPS policy goals
through EL initiative
senior stakeholder
meeting.
1. Develop a comprehensive
environmental policy. In doing
this:
• Account for: (1) traditional
(e.g. compliance); (2) planned
(e.g. sustainability); and (3)
independent efforts underway.
• Prepare draft and final policy
with wide internal and external
participation.
• Use policy development as a
consensus building exercise for
key stakeholders at all levels.
• Set goals for key environmental
indicators.
2. Include environmental policy in
staff and stakeholder education
(e.g Compass I, II). Make sure
message gets out through
periodic and management
supported promotion (e.g.
brochure, contract language,
awareness training, web page,
posted document).
3. Include specific reference to
concessioners in environmental
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CEMP Study of the National Park Service
Principle 1: Management Commitment
Performance Objective: 1.1 Obtain Management Support
Sub-Objective: 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.
EXISTING
UNDER
DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. Annual HWMPP team project review
funding occurs with selection based on
relevance to four categories: Waste
Reduction and Management; Fuel Storage;
Contaminated Sites; and Technical Support.
Each category has ranking criteria; system
to be integrated into a Project Management
Information System (PMIS).
2. Environmental due diligence reviews occur
with property transfer.
3. Annual report to DOI on project status and
resources for site restoration. Included in
DOI FY Accountability Report.
4. Concessions Operations has an
environmental coordinator on staff.
NPS Comments/Additions
1. Annual natural resources funding allocation
process.
2. Contaminants Technical Advisory Group
quarterly meetings.
Regional support capability
is being made more broad
(e.g. multimedia) through
internal audit program.
1. Through the proposed
environmental audit
program:
• A park-level POC is to
be established in
advance of the site visit;
and
• Responsibility for
environmental
management and
specific corrective
actions will be specified.
2. Incorporate environmental
audit program data into
budget/funding decisions.
1. Develop and provide "awareness"
level training to all levels of
management (different than
environmental training in 3.1).
2. Broaden scope of environmental
criteria (e.g. waste and water) to
review all project funding requests
in one integrated environmental
aspects evaluation.
3. Acknowledge Service-wide need
for funding and personnel
allocated specifically to
environmental compliance.
4. Develop a Concessions Division
environmental policy that
mandates concessioners comply
with "Concessions Environmental
Guidelines" (see Principle 3.2).
5. Modify concessions contracts and
facility operating plans to include
performance criteria.
6. Incorporate environmental
program needs into Concessions
Program budget process.
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CEMP Study of the National Park Service
Principle 1: Management Commitment
Performance Objective: 1.2 Environmental Stewardship and Sustainable Development - The agency strives to facilitate a culture of
environmental stewardship and sustainable development.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. Stewardship and sustainability are
founding philosophies of the NFS.
2. Sustainable Design Guidelines and web
site.
3. A few regions (e.g. NER, NCR) offer
training in green procurement and
sustainable design.
4. Sustainable Re-Development Addendum's
to selected GMPs (e.g. GCNP).
5. Management Policies and internal
direction (e.g. Natural Resources,
Concessions Operations) include
sustainable design.
6. Draft Environmental Leadership Towards
Sustainability training.
7. Design for Environment concepts
incorporated into building design.
8. NPS experts participate in external
projects (Easter Island, Australia).
9. NPS cost recovery program (PRP search
manual, CERCLA manual).
1. Training telecast via satellite
on sustainability in
partnership with academia
(Denver Service Center).
2. Annual DOI environmental
meeting participation with
focus on sustainability (and
other environmental topics).
3. DOE-sponsored
sustainability initiative with
DOI-focused on
transportation
4. NR initiative.
5. NER/PWR sustainability
initiatives.
1. Assistant Secretary
directed EL initiative
focused on sustainability.
2. National Renewable
Energy Laboratory
(NREL) Memo of
Understanding focused on
sustainability.
1. Account for existing and planned
environmental management
responsibility (e.g. compliance) in
sustainability initiatives.
• Link sustainability coordinators
with compliance coordinators to
facilitate harmony.
• Merge and coordinate various
environmental initiatives (e.g. DOI,
DOE-NREL, EPA, NPS)
1. Ensure integration of sustainability
and stewardship initiatives in NPS
environmental management system.
Build a system that will address all
current issues and be sufficiently
flexible to address future needs.
2. Link and increase awareness of
understanding and dealing with
environmental impacts (e.g. NEPA).
3. Enhance enforcement capability (i.e.,
additional resources) and posture for
actions damaging NPS resources
(e.g., illegal dumping).
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CEMP Study of the National Park Service
Principle 2: Compliance Assurance and Pollution Prevention
Performance Objective: 2.1 Compliance Assurance - The agency institutes support programs to ensure compliance ~with environmental
regulations and encourages setting goals beyond compliance.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT STEPS
1. Compliance guidance distributed via
standard means for: hazwaste, solid
waste, CERCLA, tanks, water and
wastewater treatment, NEPA,
pesticide management.
2. Participate in EPA/DOI partnership.
3. Other regional (e.g. IMR) EPA/DOI
partnerships exist; EMR's being
implemented at several parks.
4. Rely on DOI/OEPC and ad-hoc
sources for regulatory updating.
5. P2/sustainability is a preferred
enviromental management approach.
6. Two HQ groups focused on
compliance: park operations and
education - hazmat, hazwaste;
natural resources - NEPA, air, water,
pesticides.
7. Regional Initiatives: P2OAs in IMR
(76); Compliance Assistance Projects
(CAPs) in the MWR and NER (12);
and contracted audits in the SER(5).
8. Draft Envirocheck Sheets and
training for 21 audit criteria areas.
1. Twenty nine EnviroFacts on
waste streams, compliance,
and environmental
management programs for
parks; to be disseminated on
the Internet.
2. National Environmental Audit
Program:
• Baseline compliance;
• Identify needs for compliance
guidance;
• Encourage P2 as an
approach;
• Elevate issues to upper
management;
• Encourage self audit and
reporting; and
• Addresses non-regulated
risks.
1. Participate in EPA/CFA Task
Group.
2. Regional pilot program in
hazard analysis (IMR).
1. Periodic audits of each park-
level facility.
2. Track corrective actions via
new information system
(Environmental Audit
Program).
3. Establish standard records
management system.
4. Establish "beyond
compliance" goals and assure
completion.
5. Additional EnviroFacts and
Envirocheck Sheets.
6. Concessionaire self-audit
program.
1. Establish a reliable regulatory
updating system to communicate
changing needs to parks.
2. Develop multimedia compliance
workgroup to ensure all
environmental program areas are
addressed and program
environmental compliance
requirements and program and goals
can be evaluated comprehensively.
3. Include compliance liability risk
assessment as a park-level
management decision tool.
4. Seek opportunities with DOI (OEPC)
for cost-effective solutions to
Department-wide challenges.
• Lessons learned.
• Cost sharing solutions benefiting
other bureaus and offices. For
example:
* training
* policy
* QA - audits
* regulatory updating
* reporting
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CEMP Study of the National Park Service
Principle 2: Compliance Assurance and Pollution Prevention
Performance Objective: 2.2 Emergency Preparedness - The agency develops and implements a program to address contingency planning
and emergency response situations.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT STEPS
1. Regulatory programs include:
• SPCC Plans
• Facility Response Plans
1. Dam, Bridge, and Road Safety
program
2. NRDA component (e.g. oil spill)
3. Incident Command (1C) system;
national and regional incident
commanders; superintendent 1C
training via Parks and Education
Fire Management Program
4. Preventive Maintenance and
Rehabilitation programs
5. >500 HAZWOPER trained staff
nationally.
6. Fully established emergency
response teams at some parks
(e.g. Padre Island).
1. Hazard Analysis Pilot at five
parks in IMR.
2. Plan Automated Response
and Communications System
(PARCS) software to
develop integrated
contingency plans.
3. Directors Order #79 on
emergency response clarifies
roles and responsibilities.
1. SPCC FRP and RCRA
contingency requirements for
parks to be screened in NPS
environmental audit program.
1. Establish park-level ER task forces and
procedure for periodic park-level
emergency planning task force review.
2. Identify non-regulated, but
unacceptable, risk areas (e.g., known
PCB contamination below action levels,
non-NPS transport incidents on NPS
property) and include in preparedness
programs.
3. Seek advanced prevention programs for
remote or highly sensitive areas.
4. Implement Integrated Medical
Monitoring program (e.g. RPP gaps).
5. Provide awareness to parks on
emergency response team support
requirements (training, H&S Plan,
equipment, etc.).
6. Confirm programs for:
• EAPs (OSHA)
• RCRA Contingency Plans (EPA)
• "One" Plan Utilization
7. Expand superintendent 1C training
beyond parks by including fire
management requirements.
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CEMP Study of the National Park Service
Principle 2: Compliance Assurance and Pollution Prevention
Performance Objective: 2.3 Pollution Prevention and Resource Conservation - The agency develops a program to address pollution
prevention and resource conservation issues.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. National evaluation of recycling in NFS
conducted in 1993. Waste stream analysis
conducted in 10 parks in 1995.
2. National Integrated SW Management
program established: policy, guidance,
training; waste reduction/recycling goals.
3. Most parks have established SW recycling
programs; feasibility studies conducted for
composting at larger parks.
4. P2 is a preferred management approach.
5. P2 assessments in the IMR (76);
sustainability assessments in regions (e.g.
PWR).
6. LCC and material reuse is promoted
through NFS Sustainable Design Guidelines.
Some regional sustainability guidelines
(MWR, NER).
7. Energy conservation projects/audits
completed through NPS/FEMP and
university (JMU) partnerships.
8. Green product cost differential
underwriting program through HQ.
1. Green product selection
database pilot in IM region.
2. Green procurement, waste
reduction, recycling
EnviroFacts.
3. Full scale alternative energy
projects (PV, geothermal)
via NPS/FEMP partnership.
4. Concessionaire polices being
developed which encourage
waste reduction and green
procurement.
5. Environmental Leadership
training includes modules on
waste management with P2
focus and contracted
relationships with focus on
EPP principals.
6. Chemical substitution fact
sheets (IM region).
1. Green procurement pilot
for concessionaire
operations at Yellowstone.
2. Green procurement, water
conservation, energy
conservation, and solid
waste management
screening during
environmental auditing. P2
opportunities to be
addressed in audits.
3. NPS/University/FEMP
partnership energy audits
(6+ parks).
4. Standard contract language
encouraging green
procurement.
NPS Comments/Additions
1. Employ P2 strategies as a
means of reducing
potential compliance
liabilities (e.g., toxics use
reduction/ elimination)
1. Update waste stream analyses for
NPS to determine current
recycling/reuse opportunities and to
track ISWAP success.
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Principle 2: Compliance Assurance and Pollution Prevention (Continued)
Performance Objective: 2.3 Pollution Prevention and Resource Conservation - The agency develops a program to address pollution
prevention and resource conservation issues.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
NFS Additions/Comments
1. Developed SOP for solid waste stream
characterization.
1. Implement pollution
prevention and waste
reduction programs at
parks based on
environmental audit
program recommendations.
2. Integrate EPP purchasing
into NPS procurement
procedures (national
program and in parks).
3. Conduct P2 opportunity
assessments (PPOA) in all
NPS regions or include
PPOA in audit program
protocol.
4. Develop and implement
Service-wide green
procurement programs.
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CEMP Study of the National Park Service
Principle 3: Enabling Systems
Performance Objective: 3.1 Training - The agency ensures that personnel are fully trained to carry out the environmental responsibilities of
their positions.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. Environmental awareness training
has occurred sporadically on: USTs,
hazmat, and solid waste
management; and periodically
(10x+/yr) for HAZWOPER (PHS).
2. Customized HAZWOPER training
available (~10 per yr.) to cover:
• HAZCOM (4 hr)
• HAZWOPER Refresher (8 hr)
• HAZWOPER (24 hr)
• P2 (2-4 hr)
1. BLM environmental compliance
training program is available to
NFS.
2. Distance learning pilot (via IU) on
EnviroFacts occurred 11/98.
3. Draft environmental leadership
training piloted (4/98).
4. Courses in solid waste, CERCLA,
hazwaste and fuel storage tanks, and
NEPA offered over last five years.
5. Annual pesticide management
training.
6. Regions have additional unique
1. Distance learning program
pilot in hazardous waste
management.
2. Environmental Leadership
Towards Sustainability
training pilot for
management.
1. Explore effectiveness of
distance learning for
environmental requirements.
2. Environmental training core
curriculum analysis.
1. Update training needs assessment by
NPS career path and environmental
management program; address full
dissemination of training beyond
first line workers.
2. Implement joint training
opportunities with other DOI
bureaus and offices.
3. Pursue EPA as a training resource
(regions/HQ).
4. Pursue other government training
source opportunities (e.g.
DOD/COE).
5. Form an integrated training function
addressing:
• Health and Safety
• Natural Resources
• Energy
• Sustainability
• Environmental Compliance and
Beyond
• P2
• EMS
6. Develop means of verifying that
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Principle 3: Enabling Systems (Continued)
Performance Objective: 3.1 Training - The agency ensures that personnel are fully trained to carry out the environmental responsibilities of
their positions.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
7. Conduct a training needs
assessment for concessioners.
8. Conduct awareness training for
concessioners.
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CEMP Study of the National Park Service
Principle 3: Enabling Systems
Performance Objective: 3.2 Structural Supports - The agency develops and implements procedures, standards, systems, programs, and
objectives that enhance environmental performance and support positive achievements of organizational environmental and mission goals.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. Internal and External NEPA
program through EQD.
Guidelines established.
2. New NFS-wide PMIS budget
prioritization processes can
include environmental ranking
criteria. A priority ranking
process is in place for HWMPP
specific program funding.
3. Manuals and guidance containing
operational procedures have been
prepared or updated: (e.g. Solid
Waste (ISWAP) ('96), Hazwaste
Handbook ('94); CERCLA
Manual (rev. '98); Tank Manual
('96); Pesticides ('97); Loss
Control (OSHA programs) ('91);
Public Health ('93)).
4. Draft EL strategy provides EMS-
based plan for NFS. 1,2,3-yr plans
and estimated funds. Developed
based on stakeholder input.
Active ELI workgroup.
1. Level I and II policy review for
environmental programs
completeness and to reflect ELI
goals. Part of ongoing Directives
Management Program revisions
and 10-yr Level I Management
Policies review.
2. Revised PHS (water and
wastewater treatment), risk
management, and NEPA
guidelines.
3. Updated HAZWOPER training
manual.
4. ELI training which will provide
awareness training in EMS,
sustainability, contracted
relationships, and others.
5. Natural Resources Initiative
establishes goal for
environmental stewardship
through environmental
compliance.
6. Revised lands acquisition
guidance and forms.
1. Integrate GPRA and EL to
establish measurable goals tied to
NPS strategic plan.
2. Implement EL strategic plan.
3. Policy Office review of policies to
address new Directive
Management System
requirements (e.g. policy in level
I and II, implementation
guidance in Level III).
4. EL/NR integration between
DOE/NPS.
5. Encourage development of and
promote existing or new Centers
of Environmental Excellence.
1. Integrate all environmental
related initiatives throughout
organization (e.g. ELI, NRI,
energy, risk management, and
sustainability).
2. Develop Park Strategic
Environmental Management
Plans.
3. Establish internal management
review program and conduct
periodic evaluation (e.g. annual)
to ensure currency.
4. The Concessions Division should
develop "Level 3" guidelines that
outline operational requirements
for concessioners to comply with
federal, state, and local
regulations, and DOI and NPS
policy (at a minimum).
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CEMP Study of the National Park Service
Principle 3: Enabling Systems
Performance Objective: 3.3 Information Management, Communication, Documentation - The agency develops and implements systems that
encourage efficient management of environmentally-related information, communication, and documentation.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. HWPPT manages an
Environmental Information
Management System (MS/Access)
to track their environmental
project status. Parallels
FEDPLAN.
2. NEPA tracking database.
3. Green Alert bulletin board
system.
4. Sustainable design web site.
5. Regional web sites provide
information on sustainability and
NEPA.
6. Resident FTC environmental
information advisor (HWPPT).
7. Information management projects
are ranked for implementation as
are all other projects - based on
environmental criteria (HWPPT)
such as green products database.
8. Hard copy documents distributed
(manuals) as needed.
PMIS (interactive web-based)
likely to supersede EIMS but
maintain functionality.
NFS to use CERL Team Guide
for Federal and state
regulation updating for
Service-wide environmental
audit program. Will link with
NPS audit checksheets.
Developing audit reporting and
tracking system.
1. Web page offering EnviroFacts,
guidance documents, and other
environmental management
tools.
1. Develop integrated environmental
information strategy.
• Inventory critical information
needs.
• Identify universe of existing
information sources.
• Address information gaps by
priority.
1. Establish or rely upon a periodic
organization-wide update (e.g.
newsletter) to provide a reliable
communication mechanism for
routine, but important information.
2. Develop and implement guidance on
centralized filing and
recordkeeping system (region and
park-level).
3. The Concessions Division should
develop electronic (Internet) and
other systems to effectively transmit
environmental program information
and data to concessioners (e.g.
policy and procedures,
environmental audit data).
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CEMP Study of the National Park Service
Principle 4: Performance and Accountability
Performance Objective: 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.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. Regional environmental
program coordinators identified
(hazmat/waste, CERCLA,
USTs, solid waste); no line
authority.
2. WASO and Regional
environmental audit
coordinators designated.
3. Park-level environmental
coordinators established in
parks (<15%).
4. Park superintendent and
regional directors maintain line
responsibility, authority, and
accountability for park or
region activities.
1. Accountability management
system for superintendents.
Best practice for environmental
leadership "meets or exceeds all
environmental laws..."
2. Environmental Leadership
training providing awareness of
management responsibility for
environmental compliance
programs.
1. Park-level environmental
coordinators/ points of contact at
all parks.
1. Assign responsibility and authority
to a specific individual to ensure
environmental compliance at park-
level.
2. Establish policy on environmental
accountability and include in
Environmental Policy (see 1.1).
3. Review performance in light of
environmental responsibility issues
(see 4.2).
4. Service-wide environmental
Coordinator position.
5. Empower environmental
coordinator position with authority
to resolve conflicting spheres of
authority and designate clear
responsibility where not established
(e.g. emergency response, water
pollution control).
6. Regional environmental coordinator
positions.
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CEMP Study of the National Park Service
Principle 4: Performance and Accountability
Performance Objective: 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.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. DOI and NFS award programs
for exceptional environmental
achievement.
2. In many cases environmental
program coordinator
performance goals are
established by supervisors
which do not have
environmental performance
responsibility or accountability.
3. Environmental performance
standards are not clearly
defined for many environmental
program personnel
(particularly park-level).
4. Environmental criteria are
incorporated into performance
standards for regional support
staff (0.5-2 FTE/ region), HQ
(6-8 FTE) as advisors but
infrequently at the park-level
as managers or environmental
protection specialists.
Procedures for the evaluation of
superintendent performance.
Incentives to encourage
development of Centers of
Environmental Excellence.
1. Develop environmental compliance
performance goals, then address
P2/sustainability. Use to develop
customized regional or park
standards.
2. Link individual environmental
compliance and management
performance standards with
organizational goals, then address
P2/sustainability.
3. Develop procedures for evaluation
of environmental compliance
performance, then address
P2/sustainability.
4. Develop procedures for rewarding
or penalizing responsible staff based
on environmental compliance
performance, then address
P2/sustainability.
5. Elevate visibility of environmental
achievement awards, particularly
with respect to other agencies, then
address P2/sustainability.
Page A - 14
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Principle 4: Performance and Accountability (Continued)
Performance Objective: 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.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
6. Institutionalize environmental
program accountability by
specifying environmental
performance criteria in managerial
and employee performance
evaluations. Recognize importance
of environmental management in
staffing.
• Formalize concept of one lead
point-of-contact responsible for
environmental management at
each park.
• Formalize coordinated and
integrated HQ advisory and
management environmental
function.
• Make environmental management
experience a required KSA for
management.
7. Develop an environmental
recognition program for
concessioners.
Page A - 15
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CEMP Study of the National Park Service
Principle 5: Measurement and Improvement
Performance Objective: 5.1 Evaluate Performance
Sub-Objective: 5.7.7 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.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. Regional activities:
• MWR, NER - Compliance
Assistance Projects.
• IMR - Pollution Prevention
Opportunity Assessments.
• SER - Contracted Audits.
• AR - RCRA Compliance
Audits conducted by state.
1. National environmental audit
program manager.
2. Regional and park
environmental staff
participating in audit program
development.
3. PHS park evaluation process
covers water and wastewater
treatment and food service.
1. National environmental audit
program with:
• Audit program guidance
document.
• Auditor training program.
• Audit criteria focusing on
compliance and screening for
P2 and sustainable practices.
• An information management
and reporting system.
• Unique audit protocol.
• Audit criteria for evaluating
park management support for
environmental program.
2. NER "green" audits.
3. PWR sustainability audits.
1. Develop corrective action
tracking and issue forecasting
system.
2. Audit data utilization plan to:
• Identify environmental program
needs (e.g. training, policy).
• Set priority to funding and
project decisions.
• Encourage and reward top
performance.
• Transfer solutions internally
(lessons learned).
1. System for updating audit
criteria.
2. System for addressing state and
local audit criteria.
1. Develop and implement a quality
assurance function to evaluate audit
program performance.
2. Include root cause analysis in audit
program criteria.
3. Create independent audit group.
4. Integrate audit information and
reporting (e.g. corrective actions)
with related systems (e.g. projects
and budget). Make sure audit
program data is used in project and
program decision-making.
5. Ensure that facility-level concession
operations are included in the
environmental auditing program
and that environmental
performance results are tied to
contract evaluation.
Page A - 16
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CEMP Study of the National Park Service
Principle 5: Measurement and Improvement
Performance Objective: 5.1 Evaluate Performance
Sub-Objective: 5.1.2 Institute Benchmarking - The agency institutes a formal program to compare its environmental operations ~with other
organizations and management standards, where appropriate.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. Some interest in benchmarking.
2. Some participation in EPA
Regional Environmental
Ron nd table.
1. Participate in benchmark studies
for appropriate sectors such as:
• Federal
• Resource Management
• Eco-Tourism
to learn about environmental
practices proven to be effective.
2. Explore establishing an EMS
protege relationship with a more
advanced organization such as
Forest Service.
3. Explore the possibility of mentoring
another organization:
• Federal: land management
• Resource Management: museums,
International World Heritage sites.
• Eco-Tourism: concessionaires,
recreation, tourism, hospitality
• Full participation in EPA
Roundtables
4. Consider benchmarking against
other DOI bureaus.
Page A - 17
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CEMP Study of the National Park Service
Principle 5: Measurement and Improvement
Performance Objective: 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.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. Suggestions for environmental
program management
improvement are encouraged
generally and specifically
through:
• Annual regional environmental
coordinators meeting.
• Green Alert BBS.
• Informal networks (e.g.
sustainability taskgroups).
• PWR annual zone coordinators
meeting.
• Contaminants Technical
Advisory Group.
1. Operating environmental
management procedures are
evaluated as needed by region
(e.g. new staff) and at HQ (e.g.
new budgeting system).
2. Sustainability champions
actively seek to borrow lessons
learned from other organizations
(internationally).
Environmental audit program to
eventually address root cause of
current deficiencies and, through
information sharing, prevent
future occurrences.
Draft ELI training includes lessons
learned in key environmental
management issues.
1. Establish partnerships with "Best in
Class" organizations to jump start
ideas for improvement (See
potential mentors 5.1.2).
2. Formalize an environmental
management improvement
suggestion system. Include staff,
concessionaires, and visitors.
3. Explore the possibility of champions
from various initiatives (e.g.
sustainability); adopt and include
environmental compliance as part
of their mission.
4. Employ results of environmental
audit program to identify
opportunities for improvement and
assess effectiveness of corrective
actions.
Page A - 18
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CEMP Study of the National Park Service
List of Acronyms
BLM - Bureau of Land Management PFMD - Park Facility Management Division
CAP — Compliance Assistance Project PMIS - Project Management Information System
CFA - Civilian Federal Agency PPOA - Pollution Prevention Opportunity Assessment
COE - Corps of Engineers PWR - Pacific West Region
DfE - Design for Environment RPP - Respiratory Protection Program
DoD - Department of Defense SER - Southeast Region
DOE - Department of Energy SOP - Standard Operating Procedure
DOI - Department of the Interior ST - Underground Storage Tank
EL - Environmental Leadership
EMR - Environmental Management Review
EMS - Environmental Management System
EPA - Environmental Protection Agency
EPP - Environmentally Preferable Products
EQD - Environmental Quality Division
FEMP - Federal Energy Management Program
GCNP - Grand Canyon National Park
GMP - General Management Plans
GPRA - Government Performance Results
HWMPP - Hazardous Waste Management and Pollution Prevention
1C - Incident Command
IMR - Inter-Mountain Region
ISWAP - Integrated Solid Waste Alternatives Program
IU - Indiana University
JMU - James Madison University
KSA - Knowledge, Skills and Abilities
MOU - Memorandum of Understanding
NEPA — National Environmental Policy Act
NER - Northeast Region
NFS - National Park Service Act
NREL - National Renewable Energy Laboratory
NR- Natural Resource
OEPC - Office of Environmental Policy and Compliance
OSHA - Occupational Safety and Health Administration
P2 - Pollution Prevention
PHS - Public Health Service
Page A - 19
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Page A - 20
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xvEPA
Implementation Guide for the Code
of Environmental Management
Principles for Federal Agencies
(CEMP)
The following documents are in Adobe Acrobat format. If you do not have
the Acrobat Reader and/or need basic information or configuration
instructions click here.
Front Page
Introduction
What is the Code of Environmental Management Principles (CEMP)?
What is an Environmental Management System (EMS)?
Is the CEMP an EMS Standard?
How does the CEMP tie into other EPA programs?
What you will find in this document
Federal Agency Responses to the CEMP
• CEMP Development Process
• Responses from Federal Agencies and Departments
Management Commitment (Principle 1)
• 1.1 Obtain Management Support
• 1.1.1 Policy Development
• 1.1.2 System Integration
• 1.2 Environmental Stewardship and Sustainable Development
-------
Compliance Assurance and Pollution Prevention
(Principle 2)
• 2.1 Compliance Assurance
• 2.2 Emergency Preparedness
• 2.3 Pollution Prevention and Resource Conservation
Enabling Systems (Principle 3)
• 3.1 Training
• 3.2 Structural Supports
• 3.3 Information Management, Communication, Documentation
Performance and Accountability (Principle 4)
• 4.1 Responsibility, Authority and Accountability
• 4.2 Performance Standards
Measurement and Improvement (Principle 5)
• 5.1 Evaluate Performance
• 5.1.1 Gather and Analyze Data
• 5.1.2 Institute Benchmarking
• 5.2 Continuous Improvement
Cemp Self-Assessment Matrix
• How the Cemp Matrix Works
• Moving From Level to Level
Appendix 1. Agency Responses Tables and
Figures
• Table 1 Summary of Agency Responses to the CEMP
• Figure 1 Environmental Processes in a Management System
• Figure 2 Pollution Prevention Act Environmental Management
Hierarchy
• Figure 3 Federal Agency Environmental Compliance Management
System
-------
Principles of Cemp Self-Assessment Matrix
• Principle 1: Management Commitment
• Principle 2: Compliance Assurance and Pollution Prevention
• Principle 3: Enabling Systems
• Principle 4: Performance and Accountability
• Principle 5: Measurement and Improvement
Contact Information
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Last Updated: June 16, 1998
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