United States
Environmental Protection
Agency
An Organizational Guide to
Pollution Prevention

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                        Legal  and  Other Requirements

                          Setting the legal framework for your EMS
Legal requirements include:

 •  Federal requirements

 •  State and local requirements

• Standards in locations where
   you sell products/services

• Permit conditions


  Other requirements might
     include (for example):

 •  Company-specific codes

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

 •  American Chemistry
   Council's (ACC)
   Responsible Care

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

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

           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
    25

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       For more information on EMS
       and compliance, see "Improving
       Environmental Performance and
       Compliance: Ten Elements of
       Effective Environmental
       Management Systems" (see
       Appendix F for details)
             Environmental Policy
             Objectives & Targets
             Training & Awareness
             Communication
             Operational Controls
       See Appendix A for information
       on resources for tracking
       environmental laws and
       regulations.
technical and compliance  assistance programs  to help
companies comply with air quality rules. In some cases,
these programs have expanded into other environmental
"media",  such as water and waste  management.  In
addition,  National Compliance Assistance Centers can
provide  compliance  assistance  for  certain  industry
sectors (see Appendix F for more information).

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

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

Resources to identify and track environmental laws and
regulations are described in the Tool Kit (Appendix A).
                   Commonly Applicable Federal Environmental Laws in the US
Clean Air Act (CAA)
[40 CFR Parts 50-99]
Clean Water Act (CWA)
[40 CFR Parts 100-145, 220-232, 410-471]
Federal Insecticide, Fungicide and
Rodenticide Act (FIFRA)
[40 CFR Parts 150-1 89]
Resource Conservation and Recovery
Act (RCRA)
[40 CFR Parts 240-299]
Toxic Substances Control Act (TSCA)
[40 CFR Parts 700-799]
Comprehensive Environmental
Response, Compensation and Liability
Act (CERCLA, also known as "Superfund")
[40 CFR Parts 300-311]
Emergency Planning and Community
Right-To-Know Act (EPCRA)
[40 CFR Parts 350-374]
Hazardous Materials Transportation Act
(HMTA) [49 CFR Parts 100-1 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 ...
©2001 NSF
27

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                              Objectives and Targets

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

          You determine what objectives  and  targets  are
          appropriate for your  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).
©2001 NSF
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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 ...
©2001 NSF
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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
©2001 NSF
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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.
©2001 NSF
       33

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

   If yes, does that process need to be
   revised?  In what way?
  What environmental management
  programs do we have in place 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 ...
©2001 NSF
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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?
  ©2001 NSF
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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).
©2001 NSF
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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.
©2001 NSF
37

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

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

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

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              Training, Awareness and Competency

                           Building internal capabilities
  Implementing and
  maintaining an EMS
  involves everyone
    Reasons for
      Training:
     motivation
     awareness
     commitment
     skills/
     capability
     compliance
     performance
    An example of a trainin log
    is provided in the Tool Kit
    (see Appendix A)
        Environmental Aspects
        Legal/Other
        Requirements
        Structure &
        Responsibility
        Operational Control
        Records
Here are two excellent reasons for training employees
about environmental management and your EMS:

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

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

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

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

Getting Started:

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

   • Look  at the training  you conduct already, for
    compliance with  environmental  and  health  and
    safety regulations and other purposes.  You may
    find that your existing training efforts  go a 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
     39

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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.
©2001 NSF
     40

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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
42

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                             Communications

                        Maintaining the flow of information
  Consider
  communication
  strategies for:

  0 neighbors
  0 community groups
  0 other interest groups
  0 local officials
  0 regulatory agencies
     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
             44

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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
46

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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
      47

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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
       48

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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
49

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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
      50

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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
      51

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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
52

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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
                        53

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                                        Hints:

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



Procedure
exists, but is not
documented

X
X

Procedure
exists and is
documented



X
No procedure
is needed




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

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

 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
     54

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

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

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

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

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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
    57

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        Environmental Aspects
        Legal/Other
        Requirements
        Training & Awareness
        Communication
        Document Control
 Ask  yourself:  Does  everyone  (including   new
employees) know what to 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
  58

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

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

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

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                        Monitoring and Measurement

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

      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.
    ©2001 NSF
      60

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  EPA policies provide
  incentives for effective
  compliance management
  programs. See "Incentives for
  Self-Policing: Discovery,
  Disclosure, Correction and
  Prevention of Violations"
  (http://es. epa. 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).
©2001 NSF
      61

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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.
©2001 NSF
    62

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                                 Figure 10:
     Linking Monitoring Processes to Operational Controls: One Example
Operation with
Significant
Environmental
Aspect
Surface
Coating
Operation
(significant
aspect is VOC
emissions)




Liquid
Waste
Storage

(significant
aspect is
potential for
spills)

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 ...
    ©2001 NSF
64

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     Nonconformance and Corrective / Preventive Action

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

   identify the problem
   investigate to identify
   the root cause
   come up with solution
   implement solution
   document solution
   communicate solution
   evaluate effectiveness
   of solution
 Nonconformance"
means...

•  system does not 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.
©2001 NSF
      65

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 Why do EMS problems
 occur?
 Typical causes include:

0 poor communication
0 faulty or missing procedures
0 equipment malfunction
   (or lack of maintenance)
0 lack or training
0 lack of understanding
   (of requirements)
0 failure to enforce rules
0 corrective actions fail to
   address root causes of
   problems
               Legal & Other
               Requirements
               Operational
               Control
               Monitoring &
               Measurement
               EMS Audits
               Management Review
The amount of planning and documentation needed for
corrective & preventive  actions  will vary  with  the
severity  of the problem and its potential environmental
impacts.   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).
    ©2001 NSF
     66

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 People doing the
 work are often in
 the best position
 to see problems
 and suggest
 solutions
 The Tool Kit
 contains a sample
 corrective action
 procedure and
 tracking log
 (see Appendix A)
   Sources
  of change
Investigate and
 recommend
   solutions
Institutionalize
   Change
Corrective
  Action
 Process
                   Figure 12
                           POLLUTION PREVENTION
          By switching from a solvent-based paint that contained lead to a no
          lead, low-solvent, water-based paint, March Coatings dramatically
          decreased its volatile organic compound (VOC) air emissions from over
          19 tons in 1995 to less than 6 tons in 1999 while simultaneously
          increasing production. The company went from being a large quantity
          generator of hazardous waste to small quantity generator status under
          RCRA. March Coatings accomplished this by working closely with its
          paint supplier to find a formula that met their needs.
©2001 NSF
                 67

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

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

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                                  Records

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

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

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

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

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

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

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

• Establish a records 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?
©2001 NSF
      69

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           Key Questions

         what records are kept?
         who keeps them?
         where are they kept?
         how are they kept?
         how long are they kept?
         how are they accessed?
         how are they disposed? /
        .„		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
    ©2001 NSF
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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).
  ©2001 NSF
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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!
©2001 NSF
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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
    ©2001 NSF
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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 ...
  ©2001 NSF
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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).
 ©2001 NSF
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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)
         NSF
    76

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

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

Should we conduct reviews more or
less frequently?
Who is responsible for gathering the
information needed to conduct
management reviews? Who is
responsible for presenting this
information?
How do we ensure that changing
circumstances (both internal and
external to the organization) are
considered I this process?
How do we ensure that the
recommendations of management
reviews are tracked and acted upon?
Our next step on management
review is to ...
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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.
©2001 NSF
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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!
©2001 NSF
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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.
©2001  NSF
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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
©2001 NSF
81

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

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

Keep in  mind that you  evaluated your  current environmental
programs  when  you performed  the preliminary review (see
Section 3), so you  should  understand how (and how well) you
are currently managing these key  issues.
         Define
       Key Roles
          and
    Responsibilities
Once the environmental policy has been written, you can begin
to define key roles and  responsibilities within the EMS.  At
this   stage   of  implementation,   focus   on   "higher-level"
responsibilities, such as the roles and responsibilities of senior
management, key functional leaders and environmental staff (if
one  exists).   EMS responsibilities  for  other specific jobs  or
functions will be identified in a later step.  Once the key roles
and responsibilities have been defined, obtain the input of these
individuals  in  the  next step of the process -  establishing
objectives and targets.
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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.
©2001 NSF
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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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Sample policy - Actual policy reproduced with permission. Policy is not in original format.


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

                        Saint Joseph Mercy Hospital

                    Administrative Policy  and Procedure

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

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

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

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


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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
©2001 NSF                                95

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                                            X
           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).
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                                           X
            Sample Procedure:
   Instructions for Environmental Aspects
            Identification Form
      (courtesy ofZEXEL Corporation)
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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
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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.
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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
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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.
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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
106

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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
109

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       Sample 2:  Environmental Aspect/Impact Scoring Worksheet

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

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

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

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

 Employees

Surrounding
 Community

  Global


 Air Quality

  Surface
  Water
  Ground
  Water
 Land / Soil

 Ecosystem
  Effects
   Noise


   Fuels
  Water
   Raw
 Materials
                                Pre-
                             Production
                                  3/2

                                  2/2


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

2/3


1/2
2/1

2/2


1/3
4/2

1/2


1/2
2/2

2/2


1/3
                                     TOTAL
                                     SCORE
22

20


17
       ©2001 NSF
                             110

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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
112

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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
114

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Step 4:  List the significant environmental impacts (you identified these earlier).  You can
        categorize these impacts by type:
Energy
Use
Raw
Materials
Air
Impacts
Water
Impacts
Waste
Impacts
Land
Issues
Other
(specify)
Step 5: Look at processes (such as plating or assembly) and activities (such as shipping or
       purchasing).  Are there any other issues the team should consider, in addition to those
       listed above as significant impacts? (For example, you might want to establish an
       objective to reduce spills of hazardous materials at the loading dock, even if this was not
       identified as a potentially significant environmental impact.)
    Process or activity
Issues
Possible Objectives & Targets
Step 6: List any new regulatory requirements that affect the facility (or other regulations for
       which the need for additional actions has been identified).
     Regulations, other requirements
               Possible Objectives & Targets
Step 7: Consider inputs from interested parties.  Any need for additional objectives related to
        views of neighbors, community groups or other parties?
        Inputs from Interested Parties
                 Possible Objectives & Targets
 ©2001 NSF
      115

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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
116

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                                            X
            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
122

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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
124

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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
131

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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
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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
142

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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
148

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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
150

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

 Nonconformance:   Major     Minor      Positive Practice  Recommendation

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

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

  For a complete list of EMS audit questions by function,
  download Part 2 of the project report from the NSF web
                site (www.nsf-isr.org)
©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
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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.
©2001 NSF                            160

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Policy

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

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

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

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

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

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

•  General environmental training programs for all employees, and specific training
2 An "environmental aspect" is defined as an "element of an organization's activities,
products, or services that can interact with the environment." Facilities are asked to use their
list of significant environmental aspects in selecting performance commitments under this
program.
©2001 NSF                              161

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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
©2001 NSF                             162

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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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                                         X
              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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                                         X
                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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                                              X
                 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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                                                                                                                                   X
                                                     Appendix  F (cont'd.)
                                 Additional Sources  of Information and Contacts
Note: This list is not intended to be comprehensive.  Appearance on this list should not be construed as an endorsement by NSF of any products/service.

                                                       :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.
©2001 NSF
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                                                                                                                                         X
                        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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                                                                                                                                          X
      Organization

 State Environmental
 Protection Agencies
          Resource

Environmental Assistance
Programs
                        Small Business Assistance
                        Programs (Mandated under Title
                        V of the Federal Clean Air Act).
   STATE AGENCIES

 Telephone Number / Internet Address

Contact your state's Environmental
Protection Agency
                               Call the EPA Small Business
                               Ombudsman (800/368-5888) for the
                               phone number and address of the Small
                               Business Assistance Program in your
                               state.
              Description

Many state environmental protection
agencies provide publications, technical
assistance, and information on pollution
prevention technologies, waste reduction,
and regulatory compliance, at little or no
charge.

Provides information and technical
assistance to small businesses regulated
under the Clean Air Act.
 State Environmental
 Protection Agencies
 (cont'd)
                        State and Local Pollution
                        Prevention Programs
Michigan Department of
Environmental Quality
                               Contact the National Pollution Prevention
                               Roundtable (202/466-7272) for the phone
                               number and address of the pollution
                               prevention program in your state.
http://www.deq.state.mi.us
                                       Provides information and technical
                                       assistance on pollution prevention.
Fact sheets, training, and technical
assistance.
                        Minnesota Technical Assistance
                        Program

                        Ohio Department of
                        Environmental Protection

                        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
©2001 NSF
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                                                                                                                                       X
                                                    EMS SOFTWARE PACKAGES
Organization
Greenware
EMSoft2000
ISOXpert
ISOSoft 14001
Contact Info
1-800-474-0627
www.greenware.com
1-800-241-3618
www.rmtinc.com
1-800-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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                                                                                                                                           X
                          Resource
 ANSI Online
 Business Resource Center
 Canadian Standards Association
INTERNET RESOURCES

                Internet Address

     http://www.ansi.org




     http://www.kciLink.com/brc



     http://www.csa.ca/isotcs
 Clean Technologies Center (UCLA)                             http://cct.seas.ucla.edu

 Consortium on Green Design and Manufacturing (DC-Berkeley)    http://euler.berkeley.edu/green/cgdm.html

 Environmental Technology Gateway                            http://iridium.nttc.edu/environmental.html
 International Corporate Environmental Reporting Site
 Industrial Technology Institute Home Page
 International Network for Environmental Management
     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
©2001 NSF
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                                                                                                                                      X
                         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
©2001 NSF
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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
©2001 NSF
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                                Bibliography

•  Canadian Standards Association, Competing Leaner, Keener and Greener: A Small
  Business Guide to ISO 14000, 1995.

•  Cascio, Joseph, editor. The ISO 14000 Handbook. CEEM Information Services with ASQC
  Quality Press, 1996.

•  Diamond, Craig P., "Voluntary Environmental Management System Standards: Case
  Studies in Implementation." Total Quality Environmental Management, (Winter 1995/1996),
  pp. 9-23.

•  GETF, The USEPA Environmental Management System Pilot Program for Local
  Government Entities, January 2000.

•  Hillary, Ruth, Evaluation of Study Reports on the Barriers, Opportunities and Drivers for
  Small and Medium Sized Enterprises in the Adoption of Environmental Management
  Systems, October 1999.

•  Institute of Quality Assurance, Quality Systems in the Small Firm: a Guide to the Use of the
  ISO 9000 Series, March 1995.

•  International Organization for Standardization, ISO 14001: Environmental Management
  Systems - Specification with Guidance for Use. 1996.

•  International Organization for Standardization, ISO 14004: Environmental Management
  Systems - General Guidelines on Principles, Systems, and Supporting Techniques. 1996.

•  Kuhre, W. Lee, ISO 14001 Certification: Environmental Management Systems, 1995.

•  Lucent Technologies, Best Current Practices: Design for Environment, February 1997.

•  Michigan Department of Commerce and Natural Resources, Environmental Services
  Division, Business Waste Reduction:  Creating an Action Plan, November 1994.

•  Northern Environmental, ISO 14001 Guide for Small to Medium-Sized  Companies, 2000.

•  NSF-ISR, Implementing Environmental Management Systems in Community-Based
  Organizations, 1998.

•  NSF-ISR, Environmental Management Systems: A Guide for Metal Finishers, 1998.

•  Tibor, Tom with Ira Feldman, ISO 14000: A Guide to the New Environmental Management
  Standards,  Irwin Professional Publishing, 1996.

•  United Nations Environment Programme (UNEP), the International Chamber of Commerce
  (ICC), and the International Federation of Consulting Engineers (FIDIC).  Environmental
  Management System Training Resource Kit. Version 1.0, December 1995.

•  United States Postal Service, Environmental Resources Handbook.  November 1995.

•  Us Environmental Protection Agency, Implementation Guide for The Code of Environmental
  Management Principles for Federal Agencies, March 1997.

•  Voehl, Frank; Jackson; and Ashton, ISO 9000: An Implementation Guide For Small and Mid-
  Sized Businesses, St. Lucie Press, 1994.
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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

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information to the right people at the right time. Of course, having an EMS in place
does not by itself guarantee the competence or abilities of those responsible for
compliance activities.  Appropriate training and assignment of responsibilities are
also needed and should be identified as components of the EMS.

EMS IN THE CONTEXT OF OTHER INITIATIVES

Federal facilities face a complex array of statutory and executive mandates, and
operate in a dynamic context. EMSs offer new challenges and opportunities for
integration with other  initiatives.   For example, EPA has developed several
programs to  test regulatory innovation and flexibility.  Both the Environmental
Leadership Program (ELP) and Project XL (excellence and Leadership) involve the
use of EMSs and are open to Federal participation.  Furthermore, a thoughtfully
implemented EMS can help integrate  management practices for  environment,
safety,  and  health  (ESH)  programs.  Other  statutory  and  programmatic
requirements which relate to an EMS include:

> National Technology Transfer and Advancement Act of 1995 (NTTAA): With
passage of NTTAA, Federal agencies  are required to consider  using technical
standards. This includes standards for "related management practices" developed
by voluntary consensus bodies, unless inappropriate or illegal.  However, NTTAA
does not expressly require adoption of EMS or other standards. Agencies may use
self-developed standards if approved by OMB or, if necessary, retain agency-
specific standards.

> Government Performance  	
and  Results  Act of 1993
(GPRA):    GPRA   requires
Federal agencies to report on
their goals and how well  they
achieved them.   GPRA does         a) goals and objectives
                              GPRA Mandates:
                                 Agencies must have strategic plans prior
                                 to FY 1998:
                                   b)  plans for meeting goals and
                                       objectives
                                   c)  resources necessary
                                   d)  key external factors
                                 Agencies must submit annual plans
                                 describing their goals and comparing
                                 performance to goals
not require agencies to include
environmental  measures.
However,  should  an agency
choose to do so, performance
indicators used to meet EMS
goals and  targets could be
combined on an agency-wide
basis and included  in  an
agency's  GPRA   measures
(e.g., reducing  toxic emissions, conserving energy or water, or decreasing solid
waste).

> National Environmental Policy Act fNEPA): Federal agencies are required
under NEPA to evaluate the environmental impacts of their proposed activities.
The outcome of the evaluation can range from a Finding of No Significant Impact,
to a Categorical Exclusion, to a Programmatic Environmental  Impact Statement

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     CEMP Principles

     1.  Management Commitment:  The agency makes a written top-management
        commitment to improved environmental performance by establishing policies that
        emphasize pollution prevention and the need to ensure compliance with
        environmental requirements.

     2.  Compliance Assurance and Pollution Prevention:  The agency implements
        proactive programs that aggressively identify and address potential compliance
        problem areas and utilize pollution prevention approaches to correct deficiencies
        and improve environmental performance.

     3.  Enabling Systems:  The agency develops and implements the necessary
        measures to enable personnel to perform their functions consistent with
        regulatory requirements, agency environmental policies, and its overall mission.

     4.  Performance and Accountability: The agency develops measures to address
        employee  environmental performance, and ensure full accountability of
        environmental functions.

     5.  Measurement and Improvement: The agency develops and implements a program
        to assess  progress toward meeting its environmental goals and uses the results
        to improve environmental performance.
covering  many  sites.   The NEPA process requires  public notification  and
participation, and can be lengthy.  An operating EMS can contribute to fulfilling
NEPA requirements by drawing on EMS data for the NEPA scoping and analysis
efforts. Conversely,  existing  NEPA  data  can be  used  in  identifying  the
environmental  aspects  and impacts  of  a  site's  activities  and provide  the
management system framework to ensure effective implementation of mitigation
measures.
> Code of Environmental Management Principles fCEMP): The CEMP is a set
of five management principles developed by EPA to provide Federal agencies with
a framework for developing  EMSs at government facilities.  EPA modeled the
CEMP on common elements found in a  number of EMS standards but with a
stronger emphasis on sustainable development and regulatory compliance.  EPA
recognizes the similarities between the CEMP principles and ISO 14001, and has
accepted ISO 14001 as an option for Federal agencies to use in implementing the
CEMP.  Sixteen Federal agencies have endorsed principles of the CEMP and
several are using ISO 14001 at the facility-specific level. The CEMP (published on
October 16,1996,  61 Federal Register 54062) was developed in coordination with
other  Federal agencies, as required by  Executive  Order 12856, "Federal
Compliance with Right-to-Know Laws and Pollution Prevention Requirements."

>• Contract  Reform:   An  EMS can  aid  Federal  managers in  translating
environmental risk management into  common performance terms, allowing all

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facility elements (and their contractors and vendors) to "plug into" a set of general
structures and performance expectations.  Performance-based contract language
that references use of an EMS allows Federal managers to define acceptable
management practices and  environmental outcomes for their operations, while
providing cost-saving flexibility to contractors  and  vendors.  This lets  the
government harness the legitimate commercial  interests of contractors and
suppliers, consistent with productivity and mission goals at Federal facilities.
OBTAINING RESOURCES

Because an EMS builds upon existing programs, fewer new costs are incurred in
adopting an EMS than in designing a whole new system. Nevertheless, obtaining
the resources needed to put the system in place can be a hurdle in any Federal
office facing budget constraints. It is worth noting, therefore, the many  benefits
that an EMS can provide that yield tangible returns on an EMS investment:

  —  Provides an agency-wide environmental management framework: cuts costs
      associated with each site developing its own programs from scratch
  —  Reduces support costs:  integrates site contractors and activities
  —  Supports risk management: reduces risk profile and diminishes liability
  —  Supports performance-based contracting: defines acceptable management
      practices and environmental outcomes for Federal facility operations, and
      provides cost saving flexibility to contractors
  —  Helps avoid gaps and overlaps: improves cost-effectiveness as well as
      performance
  —  Shows  due diligence: demonstrates to regulators objective, documented,
      systematic procedures to prevent, detect, and correct violations
  —  Integrates related ES&H activities  (e.g., pollution prevention  and worker
      safety)
  —  Improves recognition of pollution prevention opportunities: saves on storage
      and disposal costs and reducing liability
  —  Eases deployment of new technologies: avoids high start-up and transition
      costs.
WHAT THIS DOCUMENT CONTAINS

This Primer reviews key EMS issues affecting Federal agencies and facilities.
Following this introduction, Chapter 2, Getting Started, provides suggestions for
accessing information and understanding and applying EMS elements. Chapter
3 addresses  Measuring  Performance.   Chapters  4 through  7 discuss  the
relationship of EMS to key environmental institutions: Compliance and Regulations,
Innovative Programs, Pollution Prevention, and NEPA issues. Chapter 8 deals with
Audits and Certification, and  Chapter 9  is An Invitation  to  Environmental
Leadership.  Appendices provide reference materials and state EMS contacts. As

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understanding of EMS issues expands, periodic updates to this document are
planned and will be posted on the Internet.

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2 -  GETTING STARTED
   Federal facilities have a wide range of missions, activities, locations, resources,
   organizations, and environmental track records. Some have highly sophisticated
   environmental protection and compliance assurance programs, including most or
   all elements of a fully-functioning  EMS.  Others may have few  environmental
   capabilities, fewer resources, and little representation of environmental issues at
   senior levels within their agency. Between these two extremes are most Federal
   managers who may be considering use of an EMS.
   This chapter is  designed  to   	
   help Federal facility managers
   get started  in  planning and
   implementing an EMS.  This
   includes  gaining  access  to
   information,   as  well  as
   understanding the basic  EMS
   elements.
"Years ago, if you asked organizations,
especially large ones, if they had an
environmental management system, they
would usually respond 'of course.' Most of
these organizations in fact had systems for
compliance, for waste management, for
permitting, etc. So, naturally, we thought
we had systems. But, did we have a system
as defined, complete, coherent and
structured as ISO 14001? Now, I would say
no, we did nOot. I don't think we even knew
enough then to know that we didn't have
one."
- Joe Cascio, Chair,
  U.S. Technical Advisory Group to ISO
   GAINING ACCESS

   Learning  more  about  EMS
   approaches such as IS014001
   can  be  straightforward  for
   anyone with Internet access. A
   rapidly expanding set of World
   Wide  Web  sites  provide a
   wealth of information, contacts,
   tools,  services,  organizations,
   meetings,  and  conferences.
   Federal managers can also join
   Web site  discussions on  EMS
   topics and  rapidly learn  from
   the experience and opinions of
   others.     Once   you   feel
   grounded and comfortable with
   EMS  issues,  you can make
   informed choices about buying books, subscribing to newsletters, or engaging
   consultants.

   This Primer includes a substantial bibliography, emphasizing ease of access and
   applicability to Federal facilities. Web sites listed are generally accessible without
   cost and can  help narrow down your own range of interests. A selected list of
   books, reports, and newsletters is also included in the bibliography. While many
   of these materials are  business oriented, in addition to this Primer there are a
"(ISO) 14001 doesn't call for environmental
performance and certainly doesn't call for
environmental performance improvement.  It
calls for systems improvement. We think
the result is going to be a smarter way to
approach environmental management that
leads to environmental improvement."
-  Mary McKiel (EPA), Vice Chair,
   U.S. Technical Advisory Group

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number of government sites and sources of information. This Primer does not
endorse particular references; like any growing literature, the sources exhibit a
range of quality and applicability.
                                    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?


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   —   Is the EMS cost-effective?
   —   Does the EMS adequately respond to changing external conditions or
       requirements?
   —   Is the EMS contributing to achieving the mission of the organization?
There  are  no  set requirements regarding  the frequency and extent of the
management review.  These will vary according to the size and nature of your
organization and how stable or dynamic your external influences are.  Managers
should be encouraged to make public some form of the results of the management
review.  All decisions and  corrective  actions  should  be  documented and
communicated  to the appropriate employees, and progress in implementing the
action items should be tracked and evaluated. Management may wish to use the
management review as a vehicle to revise organizational goals, targets, policies
and plans.
SPECIAL TIPS
Even at complex installations, adopting
an EMS need not be complicated and
expensive.  Here are some tips to make
the process go smoothly:

>  Link the  EMS  to  Management
Priorities:  How do  you  obtain  the
          strong  upper-management
                     One way is to
necessary
support for an EMS?
show managers that an EMS can help
achieve agency priorities in addition to
improving  environmental performance.
For example, an EMS can demonstrate
world-class management  at a facility competing for new agency missions or
expedite the use of cost-saving cleanup technologies.
Summary of Special Tips:

   Link EMS implementation to
   management priorities
•   Fully use existing capabilities
•   Include stakeholders from the
   start
•   Focus on EMS as a framework
•   Defer decisions on third-party
   registration
                                             "Look for the choke-points... An
                                             EMS won't be able to fix them all
                                             but it may be able to knock corners
                                             off things that are driving everyone
                                             crazy..."
                                             - Department of Energy contractor
> Use a Gap Analysis and Maximize Use of
Existing Capabilities:   Adopting an  EMS
should not  require throwing out systems and
starting over. To get the greatest value out of
existing  capabilities and systems, conduct a
"gap analysis."  This involves determining where
there are gaps between current operating systems
and specifications of the EMS standard.  Of
course, a gap analysis conducted with boilerplate checklists or by people with little
direct knowledge of the facility will not help much.  The gap analysis can be made
more effective by gathering facility managers responsible for systems, and asking
them to decide which existing systems can be best adopted, extended, integrated
or adapted.  Worker input is especially valuable, and should also be solicited.
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> Include Stakeholders from the Start:  Federal facilities usually have multiple
regulators and stakeholders — often with different views and priorities.  Involving
stakeholders (including regulators) in implementing an EMS shows respect for their
views and can provide valuable input. The degree of stakeholder involvement will
vary with the mission, history of the facility, and current stakeholder relations.  Both
internal and  external  stakeholders will  appreciate  early  inclusion  in  the
implementation process, particularly in  areas  with  outcomes  they  consider
important.

> Focus on EMS as a Framework:  An EMS  should be seen as a  facility's
environmental management framework, rather than a set of activities. As missions,
budgets, priorities,  and staff continue to change, the structure of the EMS
framework will remain predictable while particular applications change. Thus new
activities, contractors, or suppliers can be "plugged into" (or unplugged from) this
commonly understood framework with minimal disruption, downtime, overlaps, and
errors.

> Defer Decisions on Third-Party Registration: Federal facilities implementing
the  ISO 14001  EMS  standard  can  "self-declare"  when  they  reach  full
implementation of the standard. Alternatively, they can be formally reviewed by an
independent  or "third-party" registrar.  The benefits  and costs  of third-party
registration for ISO 14001 are unclear at this time for both private and public sector
organizations (see Chapter 8 for more discussion). Federal managers can simplify
their choices by deferring consideration of third-party registration. Unless there is
a compelling  reason to register  your facility, you may want to focus instead on
implementing a fully-functioning  EMS.
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3 -  MEASURING PERFORMANCE
   Performance measurement is critical to the success of an EMS, and for this reason
   has a chapter devoted to itself.  This chapter describes some of the ways of
   measuring performance in the Federal  sector, and gives basic guidelines for
   managers  in developing performance measures.   Guidance on setting  up  a
   measurement process is available from IS014031 and a growing body of literature
   (see Appendix A for selected listings).

   Performance measures translate organizational goals and targets into operational
   terms. They can be pivotal in an organization's ability to define and demonstrate
   progress toward meeting its goals. When appropriately developed and effectively
   communicated, performance measures  can be understood  and  supported  by
   everyone in the organization, facilitating the feedback needed for continuous
   improvement.  Furthermore, involving the public in developing a facility's EMS can
   be an a valuable opportunity to build community support for facility missions and
   programs.

   With passage of the Government Performance and Results Act of 1993, measuring
   performance in the Federal government assumes an even greater importance.
   GPRA requires Federal agencies to prepare annual plans setting performance
   goals beginning in fiscal year 1999, and to report annually on actual performance
   compared  to performance goals.  Performance in environmental impacts and
   compliance, and in worker and public safety will need to be  reflected in GPRA
   reports.
   WHAT GETS MEASURED?

   "What  gets  measured  gets
   managed"  goes  the  saying.
   But defining  what should  be
   measured  -  and  at  what
   organizational level it will  be
   measured — is crucial to the
   success of  an   EMS.  EMS
   measures appropriate for one
   organizational level  may  be
   inappropriate at another.
Performance measures enable
organizations to:

•   Focus on progress toward goals
•   Benchmark with best-in-class
•   Identify what is and is not working
•   Aid internal & external communication
•   Demonstrate accountability
•   Evaluate program costs
•   Identify opportunities for improvement
   General  EMS  performance
   measures are often appropriate
   for higher levels within the organization or for an agency-wide effort. A research
   lab within a larger installation, on the other hand,  might need more specific
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measures, such as an  EMS performance measure for pollution prevention to
reduce the risks from storage and transfer of hazardous materials. It is important
to ensure that the more specific EMS performance measure remain tied to the
high-level measures.  This will help ensure an integrated approach to managing
environmental performance.

TYPES OF MEASURES

Identifying measures that
meaningful   in   improving
Identifying measures that are   Performance measures should be:
                                  Goal driven
management   a n d / o r   .   Appr0priate to the organizational level
                                  Able to measure results rather than
                                  activities
                                  Able to track trends
                                  Understandable to all
                                  Within the span of control
environmental  performance
can  be   a  daunting   task.
Potential   pitfalls   include
overreaching   (trying   to
measure   everything),   or
focusing on activities that are
easy to quantify rather than on
desired results directly keyed to organizational goals.  It is also important to avoid
measures outside the span of control of the managing organization.  This can lead
to frustration by individuals charged with achieving results outside their control and
can undermine overall effectiveness of efforts to measure performance.

In an EMS approach such as ISO 14001, performance can  be evaluated and
measured in several ways: by using environmental attributes, by gauging how well
the EMS itself is functioning, or by benchmarking against the performance of other
organizations.

>- Measuring Environmental Attributes: Traditionally, measuring environmental
attributes has focused on quantitative measures of regulated pollutants (e.g., tons
of emissions, gallons of effluent, or  volumes of  generated waste).    These
measures help identify when certain regulatory thresholds have been met or track
activities that can have  direct impacts on the environment.   As  an example,
factories may measure, control, and reduce emissions of sulfur dioxide consistent
with the provisions of the Clean Air Act. Traditional measures such as this continue
to be  important  because  they  can translate  directly  into environmental
performance.

>- Measuring EMS Performance:  Measuring the performance of an EMS and the
interaction of EMS components is very important and  it can be a challenge.  One
approach to selecting appropriate system measures is to consider how the system
responds to changing conditions.  For example,  in evaluating how elements of an
EMS respond to a regulatory change, possible  measures could include how the
system:

   —   Determined the regulation's applicability
   —   Incorporated it into training
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   —   Communicated it throughout the organization
   —   Incorporated it in operating procedures
   —   Incorporated it in self-assessment protocols
   —   Used it for pollution  prevention and  continuous  improvement and
        compliance
   —   Used it to adjust objectives and targets.

> Metrics and the Multi-State Working Group: A number of State environmental
regulators are participating in a Multi-State Working Group on EMS to explore the
utility of EMS, especially those based substantially on ISO 14001.  The effort is
becoming a partnership with  Federal regulators, with the  goal being to gather
credible and  compatible information of known  quality.  The idea is to have
adequate information to address key public policy issues such as the effect of EMS
environmental  performance,   environmental  conditions,  compliance  with
environmental requirements,  stakeholder  involvement,  pollution prevention
activities, and the costs and  benefits of environmental activities.  The primary
mechanism to generate this  information will be pilot projects wherein entities
implement an EMS.

In an effort to coordinate the work of the State and Federal-based groups, EPA has
issued  a Statement of Common Purpose with the Multi-State Working group  on
EMS to ensure that the data gathered through both the State and Federal pilot
projects can  be quantified, compared, and used to create a common data base.
A  guidance  document is  under development  which describes the general
categories of information and data that will be gathered through the pilot projects.
This guidance is a companion document to more specific data  protocols (also
under development) which will contain the specific questions and categories used
by the  individual facilities to  gather  data  and  information  regarding EMS
performance.

> "Benchmarking" is a term often used for the comparison of one organization
against others. Benchmarking allows the organization to see how it compares with
those whose performance it wishes to emulate,  and allows the  organization to
benefit from the experience of peak performers.  Measures might include trend
data, goals and targets, accepted norms,  professional standards, intra-program
comparisons, and external comparisons with entities doing similar work.  A baseline
to which progress can be compared must be established; as always, it is important
to  measure the baseline accurately because it will affect the interpretation and
findings of the performance  measures.   There is  a growing  literature  on
benchmarking environmental management systems (see Appendix A).

In the Federal facility  context, EPA engaged in a benchmarking exercise and found
that despite  a movement towards management system auditing by the  larger
Federal agencies, most of the  smaller Civilian Federal Agencies (CFAs) still were
focused on compliance audits  and had no system  in place to examine their
environmental management program. EPA's survey of these CFAs resulted in the
1994 report entitled  Environmental Management System Benchmark Report: A
Review of Federal Agencies and Selected Private Corporations (EPA Document

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Number  EPA-300R-94-009),  which  compared  environmental  management
programs at CFAs to those at the Department of Defense (DOD), the Department
of Energy (DOE), and three private corporations. What EPA generally discovered
was that there was weak management support for environmental compliance at
many Federal  agencies, as well  as  a lack of formality  to the environmental
compliance programs,  especially at CFAs.  EPA also discovered that training
programs were inadequate  at many  Federal agencies,  and that performance
measures and accountability were lacking.
                                                   Measures vs. Outcomes

                                                   Measures are elements an organization
                                                   will want to track as a trend over time,
                                                   such as:
                                                   volume of a key hazardous material
                                                   purchased, BTUs of energy consumed,
                                                   or concentration of a residual in
                                                   wastewater discharged.

                                                   Outcomes are levels the organization
                                                   wants to achieve, such as: a 5 percent
                                                   reduction in volume of hazardous
                                                   material purchased, installation of high-
                                                   efficiency lighting in 50 percent of office
                                                   space, or zero discharge of process
                                                   wastewater.
Performance measures should be both quantitative and
qualitative.    Measures  should evaluate the final
outcome and how long it took to reach it. For example,
it may take  only hours to inform  staff of a new
regulation   (say,  via  electronic  mail),   but  if the
information  simply consists of a reference to a Federal
Register notice, the effectiveness of the communication
aspect of the system will be diminished.

Effective  EMS  performance  measures  can  be  a
tremendous asset to Federal managers in navigating
ongoing change.  However, these same changes can
impact performance measures themselves. Thoughtful
interpretation  is required  and unexpectedly strong or
poor performance results should be carefully reviewed.
Poor results do not necessarily indicate poor execution.
Poor  results  can signal  unrealistic  expectations or
changed conditions  or inadequate definitions of the   ^^^^^~^^^^^~
performance measures. Conversely, apparently terrific
results can  result from both strong performance or a change of mission, budget,
or activity. The periodic management review that Federal managers will implement
as part of an EMS must include a review of the appropriateness of the performance
measures to help chart agency and facility progress toward meeting organizational
goals.

Because measurements  only approximate the actual program,  the old cliche,
"garbage  in,  garbage out" can be especially striking  when  tracking EMS
performance.  Most everyone has a favorite example of performance measures
gone  haywire, which actively  undermine the very  goals the measures were
designed  to  advance.    To  avoid this  scenario,   and  the turmoil  and
underperformance that can accompany it, Federal managers should  evaluate
performance measures in the full context of their operations.

> EPA Position Statement on EMS and Request for Comment on Data

EPA recently  published its Position Statement on EMS  and  ISO 14401 and a
Request for Comments on the Nature of the Data to be Collected  from EMS/ISO
14001 Pilots (63 FR 12,094, March 12, 1998). EPA supports and will help promote
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the development and use of EMSs,  including those based on the ISO 14001
standard, that help an organization achieve its  environmental obligations  and
broader environmental performance goals. EPA encourages the use of EMSs that
focus on improved environmental performance and compliance as well as source
reduction (pollution prevention) and system performance. EPA supports efforts to
develop quality data on the performance of any EMS to determine the extent to
which the system can help bring about improvements in these areas. The Federal
Register Notice also solicits comment on the categories of information and data
that  will  be  gathered  through  the pilot  projects  including  environmental
performance,   compliance,  pollution prevention,  environmental  conditions,
costs/benefits  to  implementing  facilities,  and  stakeholder  participation  and
confidence.
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4-  COMPLIANCE AND REGULATIONS
   What can an agency or facility expect from regulatory authorities in return for
   adopting an EMS?  What weight should an EMS be given by regulators and
   inspectors in evaluating compliance?  Will external stakeholders, especially those
   directly affected by a Federal facility's environmental performance, accept the use
   of an  EMS as a complement to more traditional approaches for achieving
   environmental protection?  How do  regulators view EMSs in  the context  of
   compliance? These are important questions with no simple answers. This chapter
   focuses on the relationship of EMSs to regulatory compliance.
   THE REGULATORY PERSPECTIVE
   Regulations and  enforcement
   have driven most improvements
   in  environmental  performance
   for the past 25 years. Until the
   last decade,  the  idea  that
   Federal facilities had sovereign
   immunity   from   penalties,
   enforcement,  and   certain
   governmental  regulations was
   widely held.   Since then, the
   Federal  Facilities Compliance
   Act of 1992 has changed the
   nature   of   Federal  facility
   compliance and enforcement by
   expressly  waiving  sovereign
   immunity in the RCRA context.
   Subsequent reauthorizations of
   statutes  like the Safe Drinking
   Water Act have continued this
   trend  of waiving  sovereign
   immunity.
"[ISO 14001 may] may foster improved
environmental compliance and sound
environmental management and
performance. ISO 14001 is not, however, a
performance standard.  Adoption of an EMS
pursuant to ISO 14001 does not constitute
or guarantee compliance with legal
requirements, and will not in any way
prevent governments from taking
enforcement action where appropriate."
- North American Commission for
Environmental Cooperation Resolution,
June 12,1997

"Be prepared for potential stiff resistance
from internal environmental advocates.
Some may incorrectly believe ISO is a
mechanism companies  will use to avoid
[compliance with] environmental laws."
- Department of Energy (DOE)
Management & Operations Contractor
   Federal  facilities  have made   ^^^^^^^^^^^^^^^^^^^^^^™
   substantial   strides  toward
   attaining and maintaining  compliance in recent years.  With improvements in
   compliance, dramatic environmental gains are less likely to be seen. Regulatory
   authorities are exploring new alternatives and innovative approaches to improve
   performance.

   An environmental compliance system focusses on compliance with Federal, State
   and local requirements. An EMS is not fundamentally a compliance system. An
   EMS focusses on management systems. However, an effective EMS can be an
   important part of a compliance system, and can reasonably be expected to ensure
   and improve environmental compliance.
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In this context, the question is often framed whether organizations adopting an
EMS (such as ISO 14001) have "earned" some form of decreased regulatory
oversight.  There are a number of reasons why regulatory authorities are cautious
about offering decreased oversight as an incentive for EMS implementation.
These reasons include:

> Limited Empirical Data: The international EMS movement has gained influence
over the past decade, but the number of organizations in the United States with a
comprehensive EMS is still relatively small. Some of the systems that have been
implemented  have suffered from a lack of common definitions regarding the
elements of a complete EMS. The rise of ISO 14001 is expected to change that,
but the track record of EMSs in improving performance is not yet well established.
Additionally,  Federal facilities often answer to multiple regulators  who  don't
necessarily speak with one voice.  More empirical data should become available
as more EMSs are implemented and as more lessons are learned and shared.

>  Compliance  Orientation:
The  basic  mission  of  any  I „,,           "   ~              ~~
    .  .        ..   ..   .    /     If you can systematize your approach to
regulatory  authority  is  to   environmental regulation, and beyond
                              regulation, you have a better chance of
                              having consistency when those of us in the
                              regulatory community knock on your door."
                              - Mary McKiel, EPA Standards Network
ensure  compliance.    The
compliance   approach   to
environmental  protection  has
paid great dividends.  Many in
the  regulatory   arena  are
understandably  reluctant  to
abandon such a successful approach, and may not have the discretion or authority
to do so.  Regulators do not want to be seen as abdicating their responsibilities or
risking their credibility. Therefore, innovations that encourage a softened approach
to compliance will generally be subject to a heavy  burden of proof,  and
implementing an  EMS should not  be thought of as  an  alternative  to  an
environmental compliance system.  An EMS can, however, provide the basis for
negotiating flexibility in certain areas where regulators have discretion.

> Accountability and Verification:  EMS certification under ISO is performed by
an independent third party, not by a regulator.  Some have voiced the concern that
it might be possible to "shop around" for an agent willing to certify a facility's EMS.
Although the certifying agent must be  trained and accredited, the process is
continually being improved and strengthened  as experience grows.  Regardless,
regulators need to have confidence in the  certification process.  Given  that
registration and  certification  do not guarantee performance or  compliance,
regulators feel  uncomfortable  with the  process  because  they will  be held
accountable by the public for  any resulting decline in performance at the facility.
But remember that an  EMS  can help  improve the accountability of people in
regulated entities, and should support a management framework for improving
performance and compliance.

Until EMSs build a track record of performance, the regulatory stance toward EMSs
will remain unclear. Certainly, adopting an EMS solely to secure 'regulatory relief
is a wrong reason to adopt an EMS and is guaranteed to be a disappointment.
Over time, however, it is possible that  EMSs may replace certain  elements of
regulatory oversight (such as  inspections or permits) where regulators have the
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discretion. A more cautious view holds that an EMS has the potential to harmonize
and complement regulatory oversight.

An EMS can, however, help improve ongoing relations with regulatory authorities
and stakeholders by making the management structure and procedure more visible
to regulators.   EMSs provide  the  opportunity  not  only for specific types of
improvements  —  reduced emissions, initiating self-reporting  and correction
programs, stakeholder participation in setting pollution prevention goals, or fewer
unplanned  releases — but also a framework  that gives outside  parties an
understanding of how environmental issues are being managed.

By the same token,  adopting an  EMS can also indirectly reduce regulatory
requirements.  This may sound surprising,  but it is actually quite simple.   The
structure of an  EMS, and the self-examination it  encourages, can help to reveal
hidden opportunities for the kinds of operational changes that will yield reductions
in the number of regulatory requirements that are applicable. The fewer the toxic
inputs  used, for example, the fewer regulatory  requirements apply.   Federal
facilities  may reduce permitting or reporting  requirements, as well as waste
management costs, through the substitution of regulated chemicals or process
changes  arrived at through the self-examination encouraged by an EMS.
Facilities can also use an EMS to reduce overlaps in existing compliance systems
as well as to seek cost-effective pollution prevention measures. (See Chapter 6.)
For example,  a facility may be  able  to  eliminate some  internal reporting
requirements   or   duplicate  	
permit  requirements  or
inspections.  Other incentives
for adopting   an   EMS  can
include lower support costs for
integrated  environmental,
safety,  and   health   (ESH)
programs.       Properly
implemented,   an  integrated
ESH  program  can  improve
internal  efficiency,  provide
better risk management (due to
identification and   closure of
gaps in assuring compliance),
and allow greater agility of ESH
operations during times of rapid
change. Each of these has the
potential to  directly  reduce
regulatory  obligations, without  speculating about responses from  regulators,
because fewer regulations will apply.
"At a meeting of the Management
Committee in mid-1992, a committee
member passed out a 'Special Report' from
a periodical, saying: 'These are new
sentencing guidelines.  There is a section
that allows for a reduction in  a monetary
fine if the company has a compliance
program to prevent and detect violations of
law. Show me that we have such a
formalized program or do what is necessary
to develop one.' This formed a catalyst in
the development of Ocean State Power's
environmental management system."
-  Ocean State Power, Burrillville, Rhode
   Island
If a facility's environmental programs are currently in compliance, its managers may
not realize that some form of an  EMS is already in  place, or may not see the
advantage of adopting  a more formal EMS.   Some managers may question
whether
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making any changes might risk falling out of compliance.  Hopefully, managers
can be educated to understand an EMS as managing applicable requirements
more cost- and mission-effectively.
EMS AS A COMPLEMENT TO COMPLIANCE

Ensuring that a facility is in compliance with environmental laws and regulations is
an essential component of an EMS.  Given that compliance with environmental
requirements is a baseline, an EMS can and should be viewed as a complement
to a "command and control" compliance approach. Although an EMS focusses on
management  systems and not  legal compliance per se, an EMS  can be an
important tool in an agency's compliance system by improving the management of
activities  and  programs  that  	
have significant environmental
impacts. As a practical matter,
an EMS should be integrated
with a compliance system. An
EMS  is consistent with,  and
should not diminish or interfere
with,  a facility's  compliance
management system.
Due Diligence

As a mitigating factor, due diligence
includes numerous elements consistent
with an EMS:
•  Developing standards and procedures
   to prevent noncompliant behavior that
   is not in conformity with the
   management program.
•  Allocating responsibility to oversee
   conformance to these management
   standards and procedures.
•  Training to communicate the standards,
   procedures and roles.
•  Using appropriate disciplinary
   mechanisms to encourage consistent
   enforcement of the standards.
•  Monitoring and auditing systems to
   implement the standards.
•  Correcting the nonconformance and
   prevent future nonconformance.

Source:  U.S. Sentencing Commission
Policies such as the 1991 U.S.
Sentencing   Commission
Sentencing Guidelines  have
had  an enormous impact in
encouraging development and
implementation of compliance
management  systems.   The
Guidelines cite the existence of
"an  effective  program  to
prevent and detect violations of
law" as the basis for substantial
reductions in criminal sentences
for those convicted.   Further,
they state that "the hallmark of
an effective program to prevent
and detect violations of law is
that the organization exercised due diligence in seeking to prevent and detect
criminal conduct by its employees and other agents."
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An EMS is also consistent with the 1995 EPA Self-Policing Policy which sets forth
conditions for reductions  in civil penalties and  limited  liability for criminal
prosecution.  Systematic discovery of violations through a compliance management
system (due diligence) or environmental audit is a condition for elimination of
gravity-based penalties.  EPA has  applied the Self-Policing Policy in many cases,
most of which resulted in substantial moderation or waiver of penalties.

EPA continues to emphasize the important role of a compliance management
system, and  recognizes that an effective EMS can complement the compliance
management system.  EPA's Code of Environmental  Management Principles
(CEMP) has a strong specific emphasis on compliance, and, since the late 1980s,
civil multimedia compliance investigations conducted by the National Enforcement
Investigations Center (NEIC) have made  a special effort to identify causes of
noncompliance. Noncompliance is most often caused by the lack of an EMS or an
EMS that doesn't work.  By participating in follow-up enforcement actions, NEIC
developed 12 detailed criteria (shown in the accompanying box) for a compliance-
focused  EMS.  The first five criteria are the most critical in assuring compliance.
The last seven serve to sustain  and improve the system. A complete description
of the NEIC EMS Criteria is provided in Appendix B.
                               NEIC EMS Criteria

                               1.   Management Policies and Procedures
                               2.   Organization, Personnel, and Oversight
                                   of EMS
                               3.   Accountability and Responsibility
                               4.   Environmental Requirements
                               5.   Assessment, Prevention, and Control
                               6.   Environmental Incident and
                                   Noncompliance  Investigations
                               7.   Environmental Training, Awareness,
                                   and Competence
                               8.   Planning for Environmental Matters
                               9.   Maintenance of Records and
                                   Documentation
                               10.  Pollution Prevention Program
                               11.  Continuing Program Evaluation
                               12.  Public Involvement/Community
                                   Outreach
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5 -  INNOVATIVE PROGRAMS
   EPA  is  exploring  several  innovative programs  to  encourage  improved
   environmental performance. This chapter describes these and other programs and
   explains how adopting an EMS can make your facility a better candidate for the
   innovative programs and flexible approaches that are being offered.
   THREE INNOVATIVE EPA PROGRAMS

   EPA has developed three  innovative programs to encourage environmental
   improvements.  They are: the Environmental Leadership Program (ELP), Project
   XL, and Environmental Management Reviews (EMRs).  Each of these programs
   can provide technical assistance and useful ideas to facilities chosen to participate.
   The ELP and Project XL also  require a substantial level of commitment by an
   agency or facility.
   >• Environmental Leadership  Program  (ELP):    The ELP  recognizes and
   encourages innovation and improved environmental performance. ELP facilities
   must still comply with the same regulations as non-ELP facilities. However, they are
   eligible for fewer inspections  	
   and a self-correcting period for
   violations. Other benefits can
   include  expedited  permitting,
   longer permitting cycles, and
   others deemed appropriate by
   EPA and States.
                             Puget Sound Naval Shipyard
                             ELP demonstrated that disposal of certain
                             waste materials at the shipyard should not
                             be restricted under the Toxic Substances
                             Control Act (TSCA). Benefits to the shipyard
                             include:
                                   Annual recycling of 2,500 tons of steel
                                   currently covered by TSCA
                                   Eliminating up to seven tons of solvent
                                   emissions resulting from TSCA analysis
                                   Establishing a process to evaluate
                                   innovative pollution prevention
                                   measures.
Under the ELP, a facility must
have a fully-implemented EMS
and conduct periodic EMS and
compliance  audits.   Audits
encourage facilities to look for
ways   to   go   "beyond
compliance."   Two  Federal
facilities, McClellan Air Force
Base   in   Sacramento,
California,   and  the  Puget
Sound Naval Shipyard in Bremerton, Washington, participated in ELP's pilot phase.

In addition to the EMS requirement, an ELP facility must participate in community
outreach and employee involvement programs to foster a more collaborative
atmosphere. Facilities are also expected to participate in a mentoring program
designed to transfer knowledge and innovation to  smaller or  less advanced
facilities. ELP has been adopted as the "Model Installation Program" described in
Executive Order 12856, and parent Federal agencies must endorse EPA's Code
of Environmental Management Principles (CEMP).
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> Project XL: Project XL (excellence & Leadership) is a national pilot program of
50 projects selected by EPA for testing innovative ways of achieving more effective
health and environmental protection.  Several of the projects selected include use
of an EMS as an important element of their approach.

Project XL is similar to the ELP in encouraging innovation.  However, Project XL
differs in one important respect:  a facility accepted for Project XL may receive
permission to go outside the current regulatory structure in order  to achieve a
superior result at a lower cost than  could be achieved  by strict adherence to
regulation.  In addition to superior results and lower cost,  Project XL projects
involve:

    — Less reliance on paperwork
    — Stakeholder support
    — Innovative approaches and preference for multi-media pollution prevention
    — Capability of transfer to other facilities/sites
    — Technical and administrative feasibility
    — Clear performance objectives  and data requirements
    — No shifting of risk/pollution to other population/media.

XL  Projects are undertaken  through a negotiated agreement among the facility,
state, EPA  region,  EPA program office (e.g.,  Air,  Water,  etc.), and  other
stakeholders.
> ENVVEST:  The Department of Defense (DOD) and EPA have jointly sponsored
the ENVVEST  initiative,  which  is DOD's  program to implement regulatory
reinvention activities such as Project XL.  ENVVEST allows regulators to grant
relief  from requirements  that  provide  little  additional  health  protection  or
environmental improvement. In return, the installation commander, in coordination
with the regulator, funds high payback pollution prevention projects with the money
originally programmed to satisfy the "waived" requirements.
*• Environmental Management Reviews:   An
Environmental Management Review (EMR) is an
evaluation  of  a  Federal  facility's program  and
management systems to determine how well the
facility has developed and implemented specific
environmental protection  programs  to  ensure
compliance.   EMRs are consultative technical
assistance visits intended to identify root causes of
environmental performance problems. EMRs are
voluntary and are usually initiated by the recipient
agency or facility. They generally focus on one or
two components of a fully developed  EMS, such
as:
"Very positive experience. The
EMR helped tremendously.  It was
a great learning experience. EPA
identified the positives and the
areas needing improvement. The
EMR energized our Environ-
mental Program."
- Federal Facility Environmental
Manager, EPA Region 1
    — Organizational structure
    — Environmental commitment
    — Formality of environmental programs (e.g., P2, auditing, compliance)
    — Internal and external communication
    — Staff resources, training, and development
    — Program evaluation, reporting, and corrective action
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— Environmental planning and risk management.
                             29

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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.
                                  30

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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.
                                      32

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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.
                                   34

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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:
                                   35

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   P2 in the Federal Government

   - Pollution Prevention Act of 1990: Establishes P2 as national environmental
   policy. Codifies the pollution prevention hierarchy of approaches to waste
   management: source reduction is the preferred approach, followed by recycling,
   treatment, and disposal as the last resort.

   - Executive Order 12856: Federal Compliance with Right-to-Know Laws and
   Pollution Prevention Requirements:  Directs Federal agencies to develop
   pollution prevention strategies that commit each agency to incorporate  P2
   through source reduction in facility management and use P2 as the primary
   means of achieving and maintaining compliance.  Requires preparation  of facility-
   specific P2 plans for reducing releases and transport of toxic chemicals by 50% by
   2000. Establishes the Federal Government Environmental Challenge Program,
   under which EPA developed the Code of Environmental Management Principles
   for Federal Agencies (CEMP).

   - Other Executive Orders on ozone-depleting substances, energy efficient
   computers, energy and water conservation, and recycling and waste reduction
   (see Executive Orders 12843,12844, 12845,12873, and 12902) promote Federal
   leadership in pollution prevention and environmental stewardship.
> Regulatory and Other Commitments Including CEMP: Sixteen Federal agencies
have committed to using pollution prevention as the primary means of achieving
regulatory compliance.  Many of these agencies and their individual facilities have set
specific pollution prevention, energy efficiency, or water conservation goals in addition
to regulatory requirements with which they must comply. An  EMS that integrates
regulatory requirements with additional pollution prevention goals helps the facility
identify or create opportunities for improvement, make their evaluation more systematic
and predictable, and sustain improvements once they are implemented. The facility
will meet both sets of goals more  swiftly and effectively.  For agencies that  have
endorsed the CEMP, which stresses pollution prevention as a core principle,  tying
P2 into an EMS can help show that the agency is meeting its voluntary obligation under
the CEMP.

> Health and Risk: Federal managers do not knowingly put their workers in danger,
but too often it takes an accident or injury to uncover the risks associated with the use
of hazardous materials. P2 meshes with risk reduction because the  most dangerous
materials are often the most difficult to dispose of. The EMS framework requires that
a facility examine all of its environmental activities, products, and services (not just
those that are  regulated) to identify the ways in which those activities affect the
environment, including workers, the public, and ecosystems. Incorporating this review
in an EMS can help a facility lower its risk profile and manage liabilities before  crisis
situations arise.
                                     36

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                                  One way to highlight pollution prevention is
                                  to "map" each process, identifying the
                                  factors that control the work and assigning
                                  costs to each contributing activity, even if it
                                  is just for paperwork.  An adhesive
                                  manufacturer found that losses from
                                  production shutdowns during certain
                                  training activities were many times the
                                  amount of the small training budget.
                                  Experimenting with  material handling
                                  processes allowed the facility to eliminate
                                  its storage tanks and associated training
                                  courses entirely.
>   Cost-Effectiven ess:     The
prospect of not having to pay direct
and indirect costs associated with
waste  disposal,  permitting, and
environmental  reporting   has
always offered a strong incentive
for  pollution   prevention.    Still,
facility-specific pollution prevention
efforts are often  localized, small-
scale,   reactive,   and   not
coordinated   with   other
organizational  activities.  In  many
cases  the   costs   of   waste
management  are  charged  to
general overhead costs, so their
impact is not fully appreciated  by
managers of individual activities. Combining pollution prevention with an EMS can help
to ensure that pollution prevention  considerations  are  identified and considered
throughout a facility's waste management process. Through integration and improved
efficiency, a well-designed EMS  can  enhance  savings,  as  well  as remove
environmental  management costs from overhead.
> Public  Confidence: Federal facilities operate  on the basis of public  trust.
Unfortunately, in the past, that stewardship was sometimes forgotten, resulting in a
legacy of contamination at Federal sites and shaken public confidence.  A pollution
prevention   ethic   shows   a
commitment to responsible waste
management   and   limiting
additional environmental damage.
An  EMS  further  builds  public
confidence by demonstrating that a
facility understands the connection
between its management practices
and   activities  that   affect the
environment. It helps demonstrate
that an agency's primary mission
can   be  fully  compatible  with
environmental   stewardship
responsibilities.  An effective EMS
also contains elements of public outreach, encouraging facilities to be more open in
communicating with the public.
                                  With an EMS, DOE can "provide
                                  stakeholders and customers with real
                                  evidence of performance in the
                                  environmental management arena that won't
                                  be subject to second-guessing or
                                  gainsaying. We're going to be very effective
                                  stewards of the environment under our
                                  control and our stakeholders will see that."
                                  - Dr. Tara O'Toole, DOE Assistant Secretary
> Sustainable Development: Although it may be difficult for any agency or facility to
precisely measure its contribution to sustainable development,  robust pollution
prevention programs can improve management of natural environmental resources.
Judicious use of resources is also in keeping with the public policies which encourage
husbanding of resources to ensure their continued availability to future generations.
An EMS can help facilities maintain focus on these long-term considerations.
                                    37

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USING EMS TO EXTEND POLLUTION PREVENTION

How can an EMS be used to integrate pollution prevention more thoroughly with other
environmental activities? Several  EMS elements  can be  particularly  useful  in
strengthening pollution prevention
programs.  In addition, it can be
easier  to   transfer  successful
                                  "We view pollution prevention as our best
  ..  ..          ..           .       approach to compliance."
pollution  prevention  approaches    _PMPcC|e||an Ajr FPrce B    Sacramento
from  one  site to another  if a
unifying management framework is
established.  The  EMS provides
just such a framework.  With an EMS, facilities will be able to identify more quickly
those approaches that could be adapted to their unique conditions.  This benefit can
also apply to private-sector innovations, which agencies will be  able to evaluate for
applicability to their own sites. The potential for incorporating pollution prevention into
each EMS element is described in more detail below.  Federal managers should keep
in mind that adopting an EMS approach does not — and should not — require building
programs from scratch.  It should encourage adapting existing programs to work within
the EMS framework to the fullest extent possible.

> Environmental Policy: Adopting an EMS can make an agency's commitment more
powerful by institutionalizing pollution prevention as a priority concern. All too often,
pollution prevention gets "lost  in the shuffle" when circumstances demand  more
attention  for items deemed mission-  or time-critical.   By emphasizing  pollution
prevention as a basic foundation, an EMS can raise the profile of pollution prevention
and help ensure that a P2 approach is adopted throughout an agency's activities.

> Identifying Environmental Activities and Impacts: Agencies can take advantage
of the process of identifying environmental interactions and impacts to seek out and
conduct pollution prevention opportunity assessments in areas that may not have been
targeted previously for  such assessments.  Similarly, opportunities  for advancing
sustainable development and reducing use of energy and natural resources can be
pursued.

> Identifying Legal and Other Requirements: By tracking environmental legislation
and  other  requirements,  agencies can better integrate pollution  prevention with
environmental  program  activities.   Early consideration  of forthcoming  regulatory
changes allows facilities and agencies to respond with pollution prevention solutions
and perhaps avoid  regulatory thresholds and reporting requirements. Because many
agencies already have internal networks that provide for review and comment on both
internal and external (e.g.,  regulatory) requirements, pollution prevention issues can
be incorporated into agency protocols.
                                    38

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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.
                                    39

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Federal agencies and facilities should be aware of this distinction, as adherence to the
ISO version of P2 may not be considered effective enough to be the "primary means
of  achieving  and   maintaining
compliance," as  required  under
Executive Order 12856.
Another potential  discrepancy is
that ISO requires organizations to
consider  "significant" impacts in
setting goals, but does not define
what  "significant"  impacts  are.
Federal agencies should be aware
that   what  an   organization
considers as a "significant" impact
for ISO purposes may not be the
same as  a facility's activities and
impacts  that  are   subject  to
regulatory requirements. In light of
this, a Federal agency EMS should
assume compliance as a baseline,
and consider compliance with legal
and regulatory requirements  to be
a "significant" impact when setting
goals.
An Example of Linking EMS and
Pollution Prevention: The Washington
State Department of Ecology (DEQ) is
implementing an Environmental
Management System Alternative to
Pollution Prevention Planning (EMS
Alternative). Facilities required to
prepare a State-required Pollution
Prevention Plan or Five Year Plan
Update can meet these requirements by
submitting documentation that they have
an operating EMS in place that meets a
set of pre-defined pollution prevention
criteria. A facility in conformance with
ISO 14001 qualifies for the EMS
Alternative, but must address pollution
prevention as defined by DEQ/Pollution
Prevention Act.
Despite these distinctions, ISO and other EMS approaches can be powerful tools in
augmenting pollution prevention programs.  ISO 14001 reaches beyond the single
facility level by highlighting environmental stewardship -- concern for the goods and
services that it both uses and produces. An organization is expected to communicate
with  its suppliers and  contractors regarding  the environmental standards and
requirements that accompany the purchase of those products. ISO is also developing
standards for life-cycle assessments (ISO 14040,14041,14042,14043) that can help
in the procurement of environmentally-friendly products.
                                    40

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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?
                                  41

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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.
                                    42

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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


                                   45

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Training records for hazardous site operators
Use of hazardous materials in daily operations
Status of enforcement actions or consent orders.
                              46

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An EMS audit looks at the facility from a different perspective, concentrating on the
management systems that support the activities examined during a compliance audit.
For example, the EMS auditor might look at:

  —   Procedures that address: updating of permits;
  —   monitoring of discharges and emissions;
  —   handling of hazardous waste and materials;
  —   handling of laboratory samples; and
  —   sampling  and other field
       activities
  —   Facility training program
  —   Environmental   aspects
       identified  by  the facility
       (should   include   a
       multimedia examination of
       all  emissions  and  waste
       streams  that  affect the
       environment)
  —   Procedures for addressing
       noncompliance,
       enforcement   actions,  or
       consent orders
  —   Assignment    of
       responsibility for each area
       examined.
"You don't get continuous improvement if
you don't have a way to check. The (ISO
14001) Standard requires that you have an
internal check.  You could call upon people
in your own organization, you could call
upon an external source for doing an
internal check.  You need to be able to see
where is the system working and, perhaps
more importantly, where at any given time is
the system not working.  Management, then,
has to have a review of the whole thing."
-  Mary McKiel, Vice Chair, U.S. Technical
   Advisor Committee
EMS and compliance audits can thus be thought of as complementary. The EMS
furnishes the blueprint. The EMS audit verifies the blueprint.  The compliance audit
examines  how  regulatory  requirements were addressed.   (It is  likely that the
procedures developed for conducting compliance audits will also be evaluated during
the EMS audit.)

Compliance audits, which focus more closely on regulatory requirements, can lead to
enforcement actions. This does not mean that agencies should view EMS breakdowns
as insignificant because they don't have major regulatory implications. First,  even
though implementation of an EMS is not required by law, discovery of noncompliance
requires prompt disclosure and  correction.  Second,  an EMS  can help to make
regulatory compliance more sustainable and predictable through program integration,
eliminating the  "crisis management"  approach to  compliance.  Therefore,  any
breakdown identified by an EMS audit may be seen as early warning of potential
compliance problems.
                                    47

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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
                                   48

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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.

                               52

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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.
                                53

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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)
                                   55

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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.
                                      59

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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)].
                                 61

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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.
                                 62

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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.
                                  63

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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.
                                 64

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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
                                   65

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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
                               66

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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.)?
1
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anned.
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X
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And About You:

Are you:

a Federal employee? Y N
a Federal Contractor? Y N
an ES&H Specialist? Y N
a Facilities Manager? Y N
HQ Program staff/manager? Y N
Other	
Responsible for:

regulatory compliance?   Y N
pollution prevention?    Y N
implementing an EMS?   Y N
implementing the CEMP?Y N
NEPA?               Y N
                                            67

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If you would like a copy of the updated Primer and other EMS material, please include your name and address
below.

Name	Agency/Org.	

Address
Telephone	    Fax	      Email_
Send to:      Environmental Protection Agency
             Federal Facilities Enforcement Office
             401 M St. S.W.
             Washington, DC 20460

             Attn: Priscilla Harrington
             Fax- 202-501-0069
                   or
             Department of Energy
             Office of Environmental Policy & Assistance (EH-41)
             1000 Independence Ave. S.W.
             Washington, DC  20585-0119

             Attn: Carolyn Douglas
             Fax - 202-586-0955
                                               68

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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

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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)

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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

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                                                            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

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                                                              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
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                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.
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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.
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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
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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.
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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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                                                            CEMP Evaluation of the National Park Service
        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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CEMP Evaluation of the National Park Service
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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CEMP Evaluation of the National Park Service
                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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                                                            CEMP Evaluation of the National Park Service
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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                                                             CEMP Evaluation of the National Park Service
                             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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CEMP Evaluation of the National Park Service
                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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                                                             CEMP Evaluation of the National Park Service
        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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                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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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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                   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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                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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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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                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.
                                                  5-4

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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.
                                                  5-5

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                              CEMP Evaluation of the National Park Service
MATRIX OF CEMP FINDINGS AND RECOMMENDATIONS
                      A-l

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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.	
                                                            Page A - 3

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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).
                                                             Page A - 4

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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.
                                                          Page A - 6

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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.
                                                            Page A - 7

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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.
                                                         Page A - 8

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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
                                                           Page A - 9

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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.
                                                      Page A - 10

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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.
                                                           Page A - 13

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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

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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

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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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